Cases - 1941 term

Betts v. Brady

Mon, 13 Apr 1942 13:00:00 +0000

Location

Circuit Court for Carroll County

55 N. Court Street Westminster MD 21157

Westminster, MD 21157

United States

39° 34' 14.9016" N, 76° 59' 15.7308" W

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Case Basics

Docket No.

837

Petitioner

Betts

Petitioner Type

Petitioner

Respondent

Brady

Respondent Type

Respondent

Heard By

Stone Court (1941-1942)

Decided By

Stone Court (1941-1942)

Opinion

316 U.S. 455 (1942)

Granted

Monday, February 16, 1942

Argued

April 13-14, 1942

Decided

Monday, June 1, 1942

Advocates

Jesse Slingluff Jr. (argued the cause for the petitioner)

G. Van Velsor Wolf (argued the cause for the petitioner)

William C. Walsh (Attorney General of Maryland, argued the cause for the respondent)

Robert E. Clapp Jr. (argued the cause for the respondent)

Facts of the Case

Betts was indicted for robbery in Maryland. An indigent, he was unable to afford counsel and requested one be appointed for him. The judge in the case denied the request, and Betts subsequently pled not guilty while maintaining he had a right to counsel and arguing his own defense.

Question

Does denying a request for counsel for an indigent defendant violate the due process clause of the Fourteenth Amendment which embraces the defendant's right to counsel guaranteed by the Sixth Amendment?

Conclusion

No. The Court ruled that the previously discovered right to counsel provided by the fourteenth amendment does not compel states to provide counsel to any defendant. Justice Owen Roberts' opinion asserted that the right to counsel merely prevented the state from interfering in a defendant’s request for representation rather than requiring a state to offer counsel.

Parker v. Brown

Tue, 05 May 1942 13:00:00 +0000

Case Basics

Docket No.

Petitioner

Parker

Petitioner Type

Petitioner

Respondent

Brown

Respondent Type

Respondent

Heard By

Stone Court (1941-1942)

Decided By

Stone Court (1942-1943)

Opinion

317 U.S. 341 (1943)

Argued

Tuesday, May 5, 1942

Reargued:

Monday, October 12, 1942

Decided

Monday, January 4, 1943

Advocates

Walter L. Bowers (Argued the cause for the appellants)

Robert L. Stern (As amicus curiae, by special leave of the Court)

G. Levin Aynesworth (Argued the cause for the appellee)

Facts of the Case

In 1933, the state of California enacted the California Prorate Act. The Act restricted competition among producers in order to stabilize prices. Brown, a raisin producer, attempted to enjoin enforcement of the Act on the ground that he was sustaining irreparable economic injuries under the program because of its regulations on contracts.

Question

Did the California Act violate the Commerce Clause?

Conclusion

In a unanimous decision, the Court held that the program created by the California Prorate Act of 1933 was a regulation of state industry of local concern that did not impair national control over commerce. The Court noted that states had authority to regulate local matters so long as they did not materially obstruct commerce. The Court also found that the effects of the California Act paralleled the desired effects of congressional legislation. Since both California and the Congress were attempting to stabilize agricultural prices, no conflict between local and national interests was present.

Chaplinsky v. State of New Hampshire

Thu, 05 Feb 1942 13:00:00 +0000

Location

East side of Wakefield Street

Wakefield Street Rochester NH 03867

Rochester, NH 03867

United States

43° 18' 42.2208" N, 70° 58' 38.8596" W

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Case Basics

Docket No.

255

Petitioner

Chaplinsky

Respondent

State of New Hampshire

Heard By

Stone Court (1941-1942)

Decided By

Stone Court (1941-1942)

Opinion

315 U.S. 568 (1942)

Argued

Thursday, February 5, 1942

Decided

Monday, March 9, 1942

Facts of the Case

Chaplinsky, a Jehovah's Witness, called a city marshal a "God-damned racketeer" and "a damned fascist" in a public place. He was arrested and convicted under a state law for violating a breach of the peace.

Question

Does the application of the statute violate Chaplinsky's freedom of speech protected by the First Amendment?

Conclusion

No. Some forms of expression--among them obscenity and fighting words--do not convey ideas and thus are not subject to First Amendment protection. In this case, Chaplinsky uttered fighting words, i.e., words that "inflict injury or tend to incite an immediate breach of the peace."

Edwards v. California

Tue, 21 Oct 1941 13:00:00 +0000

Location

California border near Yuma, AZ CA

United States

32° 43' 42.15" N, 114° 37' 25.968" W

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Case Basics

Docket No.

Petitioner

Edwards

Petitioner Type

Petitioner

Respondent

California

Respondent Type

Respondent

Heard By

Stone Court (1941-1942)

Decided By

Stone Court (1941-1942)

Opinion

314 U.S. 160 (1941)

Argued

Tuesday, October 21, 1941

Decided

Monday, November 24, 1941

Advocates

Samuel Slaff (Argued the cause for the appellant )

W. T. Sweigert (Argued the cause for the appellee)

Facts of the Case

At the height of the Great Depression, anyone who knowingly assisted a pauper in entering the state of California was guilty of a misdemeanor. A Californian named Edwards drove to Texas and then returned to California with his indigent brother-in-law. Edwards was found guilty of violating the state's "Okie law;" he was given a six-month suspended jail sentence.

Question

Does the Calfornia law violate the Constitution's Commerce Clause?

Conclusion

Yes, the Commerce Clause forbids a state to exclude indigents. California's interest in the health of its citizens and the sufficiency of its welfare funds do not justify the burden on interstate commerce occasioned by the law. Byrnes's unanimous opinion observed that "the indigent non-residents who are the real victims of this statute are deprived of the opportunity to exert political pressure upon the California legislature in order to obtain a change in policy." (See Mayor of New York v. Miln.)

Skinner v. Oklahoma ex rel. Williamson

Wed, 06 May 1942 13:00:00 +0000

Location

Oklahoma General Assembly

2300 N Lincoln Blvd. Oklahoma City OK 73105

Oklahoma City, OK 73105

United States

35° 29' 27.492" N, 97° 30' 12.258" W

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Case Basics

Docket No.

782

Petitioner

Skinner

Petitioner Type

Petitioner

Respondent

Oklahoma ex rel. Williamson

Respondent Type

Respondent

Heard By

Stone Court (1941-1942)

Decided By

Stone Court (1941-1942)

Opinion

316 U.S. 535 (1942)

Argued

Wednesday, May 6, 1942

Decided

Monday, June 1, 1942

Facts of the Case

Oklahoma's Criminal Sterilization Act allowed the state to sterilize a person who had been convicted three or more times of crimes "amounting to felonies involving moral turpitude."

Question

Did the Act violate the Due Process and Equal Protection Clauses of the Fourteenth Amendment?

Conclusion

A unanimous Court held that the Act violated the Equal Protection Clause of the Fourteenth Amendment. Since some crimes such as embezzlement, punishable as felonies in Oklahoma, were excluded from the Act's jurisdiction, Justice Douglas reasoned that the law had laid "an unequal hand on those who have committed intrinsically the same quality of offense." Moreover, Douglas viewed procreation as one of the fundamental rights requiring the judiciary's strict scrutiny.

United States v. Pink

Mon, 15 Dec 1941 13:00:00 +0000

Location

New York State Insurance Department

25 Beaver Street New York NY 10004

New York, NY 10004

United States

40° 42' 18.0072" N, 74° 0' 44.2836" W

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Case Basics

Docket No.

Petitioner

United States

Petitioner Type

Petitioner

Respondent

Pink

Respondent Type

Respondent

Heard By

Stone Court (1941-1942)

Decided By

Stone Court (1941-1942)

Opinion

315 U.S. 203 (1942)

Argued

Monday, December 15, 1941

Decided

Monday, February 2, 1942

Facts of the Case

In a case similar to United States v. Belmont (1937), the United States attempted to assist the Soviet Union in recovering assets of the First Russian Insurance Company which the New York Superintendent of Insurance refused to release.

Question

Did U.S. agreements with the U.S.S.R. compel New York to release the assets?

Conclusion

The Court required New York to release the assets. Justice Douglas affirmed Justice Sutherland's reasoning in Belmont and argued that New York could not "rewrite our foreign policy to conform to its own domestic policies. Power over external affairs . . . is vested in the national government exclusively."

Ex parte Quirin

jgoldman — Wed, 29 Jul 1942 13:00:00 +0000

Location

Atlantic Avenue Beach East Hampton, NY 11937

United States

40° 58' 8.76" N, 72° 7' 22.8" W

See map: Google Maps

Case Basics

Docket No.

1_ORIG

Plaintiff

Richard Quirin

Petitioner Type

Plaintiff

Defendant

United States

Respondent Type

Defendant

Consolidation

Original, Ex parte Haupt

Original, Ex parte Kerling

Original, Ex parte Burger

Original, Ex parte Heinck

Original, Ex parte Thiel

Original, Ex parte Neubauer

No. 1, US ex rel. Quirin v. Cox

No. 2, US ex rel. Haupt v. Cox

No. 3, US ex rel. Kerling v. Cox

No. 4, US ex rel. Burger v. Cox

No. 5, US ex rel. Heinck v. Cox

No. 6, US ex rel. Thiel v. Cox

No. 7, US ex rel. Neubauer v. Cox

Heard By

Stone Court (1941-1942)

Decided By

Stone Court (1943-1945)

Opinion

317 U.S. 1 (1942)

Argued

July 29-30, 1942

Decided

Friday, July 31, 1942

Advocates

Kenneth C. Royall (argued the cause for the plaintiffs)

Francis Biddle (Attorney General, Department of Justice, argued the cause for the United States)

Facts of the Case

These cases concern Operation Pastorius, a failed attempt in June 1942 by Nazi agents to sabotage various U.S. targets. Following the declaration of war between the United States and Germany, eight German residents, Richard Quirin, Ernst Burger, George Dasch, Herbert Haupt, Heinrich Heinck, Edward Keiling, Herman Neubauer, and Werener Thiel, received training on sabotage at a school near Berlin. The men traveled to the United States via submarine. On the night of June 13, 1942, Burger, Heinrich, Quirin, and Dasch landed near Long Island, New York wearing German uniforms and carrying explosives. On the night of June 17, 1942, the remaining four came ashore in similar fashion at Ponte Vedra Beach, Florida. Shortly after the landings, Burger and Dasch backed out of the mission. Dasch turned himself in to the Federal Bureau of Investigations. All eight conspirators were subsequently arrested and, on the orders of President Franklin Roosevelt, tried by military commission. The commission found all eight men guilty and sentenced them to death. Because of their confessions and cooperation, President Roosevelt later commuted Burger and Dasch's sentences to life in prison. Arguing that the President exceeded his power in ordering the commission and that the Fifth and Sixth Amendments to the Constitution protect their rights to a regular trial, seven of the eight conspirators, not including Dasch, filed petitions for a writ of habeas corpus in Federal District Court. Their claims were denied, and they appealed to the U.S. Court of Appeals for the District of Columbia. Before the court ruled, however, they filed for hearing before the Supreme Court and, separately, filed petitions for habeas corpus directly with the Court. The Court, sitting in a special term, agreed to hear the cases.

Question

Did the President exceed his authority in ordering a trial by military commission for the German saboteurs, thereby violating their rights under the Fifth and Sixth Amendments?

Conclusion

No. In a unanimous opinion authored by Chief Justice Harlan Fisk Stone, the Court concluded that the conspirators, as spies without uniform whose purpose was sabotage, violated the law of war and were therefore unlawful enemy combatants. Noting that Congress had, under the Articles of War, authorized trial by military commission for unlawful enemy combatants, the Court therefore determined that the President had not exceeded his power. Furthermore, the Court asserted that the Fifth and Sixth Amendments "did not enlarge the right to jury trial" beyond those cases where it was understood by the framers to have been appropriate. Therefore, because the amendments cannot be read "as either abolishing all trials by military tribunals, save those of the personnel of our own armed forces, or, what in effect comes to the same thing, as imposing on all such tribunals the necessity of proceeding against unlawful enemy belligerents only on presentment and trial by jury," the rights of the conspirators were not violated.