Cases - 1937 term

Erie Railroad Co. v. Tompkins

Mon, 31 Jan 1938 13:00:00 +0000

Case Basics

Docket No.

367

Petitioner

Erie Railroad Co.

Petitioner Type

Petitioner

Respondent

Tompkins

Respondent Type

Respondent

Decided By

Hughes Court (1938)

Opinion

304 U.S. 64 (1938)

Argued

Monday, January 31, 1938

Decided

Monday, April 25, 1938

Facts of the Case

Tompkins brought a lawsuit in federal court in New York against the Erie Railroad for personal injuries. Tompkins had been walking along the railroad tracks in Pennsylvania when he was hit by an open railcar door. Under Pennsylvania law, where the accident occurred, the railroad owed no duty to Tompkins. But this was the "law" according to the Pennsylvania courts. There was no statute of the state legislature declaring the law. In the federal courts, the railroad had a duty to take care. A federal court jury awarded Tompkins damages. The verdict was upheld on appeal.

Question

Does the law of the several states applied by the federal courts as rules of decision in civil cases include all the decisional or common law of the states?

Conclusion

In 1842, the Supreme Court held that the laws of the several states embraces only the statutes authored by the state legislatures. Federal judges were free to ignore the states' common (judge-made) law and substitute their own rules. Brandeis rejected this long-standing precedent on several grounds including the view that the 1842 decision represented "an unconstitutional assumption of power by the Courts of the United States." This case was a grand victory for states to express public policy through the decisions of state courts without interference from federal judges.

United States v. Carolene Products Co.

Wed, 06 Apr 1938 13:00:00 +0000

Location

Carolene Products

2nd block of West Sargent Street Litchfield IL 62056

Litchfield, IL 62056

United States

39° 10' 25.7772" N, 89° 39' 42.1884" W

See map: Google Maps

Case Basics

Docket No.

640

Petitioner

United States

Petitioner Type

Petitioner

Respondent

Carolene Products Co.

Respondent Type

Respondent

Heard By

Hughes Court (1938)

Decided By

Hughes Court (1938)

Opinion

304 U.S. 144 (1938)

Argued

Wednesday, April 6, 1938

Decided

Monday, April 25, 1938

Facts of the Case

A 1923 act of Congress banned the interstate shipment of "filled milk" (milk with skimmed milk and vegetable oil added). A manufacturer, indicted for shipping filled milk, challenged the law.

Question

Does the law violate the Commerce Power granted to Congress in Article Section 8 and the Due Process Clause of the Fifth Amendment?

Conclusion

The Court upheld the act. In this otherwise unremarkable case, the Court planted the seeds for a new jurisprudence in a footnote to Stone's opinion for the Court. Here Stone gives a presumption of constitutionality to economic regulation. The Court would no longer substitute its views on economic policy for the views of Congress. Stone went further in footnote four by cautiously asserting that certain types of legislation might not merit deference toward constitutional validity. The most controversial element in the footnote was the suggestion that prejudice directed against discrete and insular minorities may call for "more searching judicial inquiry."

Palko v. Connecticut

Fri, 12 Nov 1937 13:00:00 +0000

Location

Fairfield County Trial Court

1061 Main St Brdigeport CT 06604

Brdigeport, CT 06604

United States

41° 10' 44.382" N, 73° 11' 21.8256" W

See map: Google Maps

Case Basics

Docket No.

135

Petitioner

Palko

Respondent

Connecticut

Heard By

Hughes Court (1937-1938)

Decided By

Hughes Court (1937-1938)

Opinion

302 U.S. 319 (1937)

Argued

Friday, November 12, 1937

Decided

Monday, December 6, 1937

Facts of the Case

Frank Palko had been charged with first-degree murder. He was convicted instead of second-degree murder and sentenced to life imprisonment. The state of Connecticut appealed and won a new trial; this time the court found Palko guilty of first-degree murder and sentenced him to death.

Question

Does Palko's second conviction violate the protection against double jeopardy guaranteed by the Fifth Amendment because this protection applies to the states by virtue of the Fourteenth Amendment's due process clause?

Conclusion

Decision: 8 votes for Connecticut, 1 vote(s) against
Legal provision: US Const. Amend 5 (double jeopardy); US Const. Amend 14

The Supreme Court upheld Palko's second conviction. In his majority opinion, Cardozo formulated principles that were to direct the Court's actions for the next three decades. He noted that some Bill of Rights guarantees--such as freedom of thought and speech--are fundamental, and that the Fourteenth Amendment's due process clause absorbed these fundamental rights and applied them to the states. Protection against double jeopardy was not a fundamental right. Palko died in Connecticut's electric chair on April 12, 1938.

South Carolina State Highway Dept. v. Barnwell

Tue, 04 Jan 1938 13:00:00 +0000

Location

Barnwell Brothers Inc. Burlington, NC

United States

36° 5' 44.4912" N, 79° 26' 16.0764" W

See map: Google Maps

Case Basics

Docket No.

161

Petitioner

South Carolina State Highway Dept.

Petitioner Type

Petitioner

Respondent

Barnwell

Respondent Type

Respondent

Heard By

Hughes Court (1937-1938)

Decided By

Hughes Court (1938)

Opinion

303 U.S. 177 (1938)

Argued

Tuesday, January 4, 1938

Decided

Monday, February 14, 1938

Advocates

Frank Coleman (Argued the cause for the appellees)

S. King Funkhouser (Argued the cause for the appellees)

Thomas W. Davis (Argued the cause for the appellants)

Steve C. Griffith (Argued the cause for the appellants)

Facts of the Case

A South Carolina law banned from its state highways trucks which were more than 90 inches wide and weighed over 20,000 pounds.

Question

Did the law impose an unconstitutional burden on interstate commerce?

Conclusion

The Court upheld the law. The Court acknowledged that the law posed a burden on interstate commerce. However, regulating state highways is "so peculiarly of local concern." Moreover, Congress had not previously invoked the commerce power to implement national standards on this issue. Hence, South Carolina had the right to act. The law was carefully drawn and applied equally to intrastate and interstate travelers.