The Oyez Project: 1992 Term Decisions

Alexander v. United States (No. 91-1526)

1. Does property forfeiture under RICO as punishment for the distribution of obscene materials constitute 'prior restraint' on speech in violation of the First Amendment?

2. Does the forfeiture of a business as punishment for the sale of obscene media constitute an 'excessive fine'?

No and undecided. Chief Justice William Rehnquist wrote for a 5-4 majority that the application of RICO in Alexander's case was neither a 'prior restraint' on speech, nor a criminalization of speech typically protected under the Constitution. His sentence established no conditions on his behavior after its completion; once he paid the fine, surrendered his business and went to prison, he could theoretically distribute adult media without prejudice from the government. "To accept petitioner's argument," Rehnquist wrote, "would virtually obliterate the distinction [...] between prior restraints and subsequent punishments."

In a separate and unanimous vote, the Court ruled that the forfeiture did in fact merit Eighth Amendment review. The case was returned to the Eighth Circuit for an analysis under the Excessive Fines Clause.

Antoine v. Byers & Anderson, Inc. (No. 91-7604)

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Arave, Warden v. Creech (No. 91-1160)

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Austin v. United States (No. 92-6073)

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Bath Iron Works Corp. v. Director, Office Of Workers' Compensation Programs, United States Department Of Labor (No. 91-871)

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Brecht v. Abrahamson (No. 91-7358)

Is the "beyond a reasonable doubt" standard from Chapman v. California the appropriate standard for setting aside a conviction on the basis of constitutional error?

No. In a 5-4 decision, Chief Justice William H. Rehnquist wrote that the "substantial and injurious effect" test was preferable to the "beyond a reasonable doubt" test in requests for habeas corpus relief. Habeas proceedings are not to be the primary avenue for resolving disputes; Rehnquist called the writ "an extraordinary remedy", reserved for the victims of grave injustice. The Kotteakos standard, then, was sufficient to determine whether Brecht deserved habeas relief.

Brooke Group Ltd. v. Brown & Williamson Tobacco Corp. (No. 92-466)

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Buckley v. Fitzsimmons (No. 91-7849)

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Bufferd v. Commissioner Of Internal Revenue (No. 91-7804)

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Building & Construction Trades Council Of The Metropolitan District v. Associated Builders & Contractors Of Massachusetts/ Rhode Island, Inc. (No. 91-261)

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Cardinal Chemical v. Morton International (No. 92-114)

Can a federal court, with exclusive jurisdiction over all federal appeals concerning patent litigation, use its finding that a patent has not been infringed as a per se justification for upholding the validity of the disputed patents themselves?

No. In a unanimous decision, the Court held that two questions of law do not always necessarily cancel each other out when only one is resolved. The Court observed that in matters of patent law, noninfringement and invalidity are two separate questions. Therefore, the Court of Appeals for the Federal Circuit may find that a patent has not been infringed but it may not rely on such a determination as a per se basis for vacating a judgement holding the same patent invalid. Although the Court of Appeals' dogmatic practice existed since 1987, it was unsupported by the "case or controversy" requirement of Article III, and imposed undue burdens on those who remained convinced of the disputed patent's invalidity.

Church Of Scientology Of California v. United States (No. 91-946)

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Church of the Lukumi Babalu Aye v. Hialeah (No. 91-948)

Did the city of Hialeah's ordinance, prohibiting ritual animal sacrifices, violate the First Amendment's Free Exercise Clause?

Yes. The Court held that the ordinances were neither neutral nor generally applicable. The ordinances had to be justified by a compelling governmental interest and they had to be narrowly tailored to that interest. The core failure of the ordinances were that they applied exclusively to the church. The ordinances singled out the activities of the Santeria faith and suppressed more religious conduct than was necessary to achieve their stated ends. Only conduct tied to religious belief was burdened. The ordinances targeted religious behavior, therefore they failed to survive the rigors of strict strutiny.

Cisneros, Secretary Of Housing And Urban Development v. Alpine Ridge Group (No. 92-551)

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City Of Cincinnati v. Discovery Network, Inc. (No. 91-1200)

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Commissioner Of Internal Revenue v. Soliman (No. 91-998)

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Commissioner Of Internal Revenue v. Key Stone Consolidated Industries, Inc. (No. 91-1677)

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Concrete Pipe & Products Of California, Inc. v. Construction Laborers Pension Trust For Southern California (No. 91-904)

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Conroy v. Aniskoff (No. 91-1353)

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Crosby v. United States (No. 91-6194)

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Csx Transportation, Inc. v. Easterwood (No. 91-790)

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Darby v. Cisneros, Secretary Of Housing And Urban Development (No. 91-2045)

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Daubert Et Ux., Individually And As Guardians Ad Litem For Daubert v. Merrell Dow Pharmaceuticals, Inc. (No. 92-102)

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Deal v. United States (No. 91-8199)

Does a criminal's second through sixth convictions under section 924(c)(1) in a single proceeding arise "in the case of his second or subsequent conviction" within the meaning of section 924(c)(1)?

Yes. In a 6-3 opinion delivered by Justice Antonin Scalia, the Court held that Deal's second through sixth convictions in a single proceeding arose "in the case of his second or subsequent conviction" within the meaning of section 924(c)(1), finding that the statute was not ambiguous. The Court rejected that the rule of lenity applied because Deal's "105-year sentence 'is so glaringly unjust.'" Writing for the court, Justice Scalia said the 105 years sentence for the gun offenses was not unjust "simply because [Deal] managed to evade detection, prosecution and conviction for the first five offenses and was ultimately tried for all six in a single proceeding." Justice Stevens wrote a dissenting opinion, in which Justices Sandra Day O'Connor and Harry A. Blackmun joined.

Delaware v. New York (No. 111 ORIG)

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District Of Columbia v. Greater Washington Board Of Trade (No. 91-1326)

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Edenfield v. Fane (No. 91-1594)

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Farrar, Coadministrators Of Estate Of Farrar, Deceased v. Hobby (No. 91-990)

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FCC v. Beach Communications, Inc. (No. 92-603)

Is there a conceivable rational basis justifying the distinction between cable facilities that serve separately owned and managed buildings and those that serve one or more buildings under common ownership or management for purposes of the Due Process Clause of the Fifth Amendment?

Yes. In a unanimous opinion delivered by Justice Clarence Thomas, the Court held that section 602(7)(B)'s common-ownership distinction is constitutional because the statutory classification neither proceeded along suspect lines nor infringed fundamental constitutional rights. "As we have indicated," Justice Thomas concluded, "there are plausible rationales unrelated to the use of public rights-of-way for regulating cable facilities serving separately owned and managed buildings. The assumptions underlying these rationales may be erroneous, but the very fact that they are 'arguable' is sufficient, on rational-basis review, to 'immunize' the congressional choice from constitutional challenge." Justice John Paul Stevens wrote a concurring opinion.

Fex v. Michigan (No. 91-7873)

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Gilmore v. Taylor (No. 91-1738)

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Godinez, Warden v. Moran (No. 92-725)

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Good Samaritan Hospital v. Shalala, Secretary Of Health And Human Services (No. 91-2079)

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Graham v. Collins, Director, Texas Department Of Criminal Justice, Institutional Division (No. 91-7580)

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Granite State Insurance Company v. Tandy Corporation (No. 91-2086)

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Growe, Secretary Of State Of Minnesota v. Emison (No. 91-1420)

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Hadley v. United States (No. 91-6646)

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Harper v. Virginia Department Of Taxation (No. 91-794)

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Hartford Fire Insurance Co. v. California (No. 91-1111)

First, did the plaintiffs sufficiently allege "boycotts," as used in the McCarran-Ferguson Act, Section 3(b)? Second, did international comity counsel against exercising Sherman Act jurisdiction over the conduct of the London-based defendants?

Yes to the first; no to the second. The Court, speaking through Justice Antonin Scalia, held that a boycott exists when, in order to coerce a target into certain terms on one transaction, parties refuse to engage in other, unrelated transactions with the target. On most counts, the plaintiffs' allegations, construed favorably, described boycotts. Justice David H. Souter wrote for the Court on jurisdiction over foreign conduct, holding that it was appropriate in this case because there is no true conflict between domestic and foreign law. That is, because the London reinsurers can comply with both British law and the Sherman Act, international comity does not counsel against exercising subject matter jurisdiction in this case.

Hazen Paper Co. v. Biggins (No. 91-1600)

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Heller, Secretary, Kentucky Cabinet For Human Resources v. Doe, By His Mother And Next Friend, Doe (No. 92-351)

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Helling v. McKinney (No. 91-1958)

May an inmate sue to prove that his Eighth Amendment right to be free from cruel and unusual punishment has been violated by prison officials who act with "deliberate indifference" to the future health risks associated with second-hand smoke?

Yes. In a 7-to-2 decision, the Supreme Court held that McKinney's suit stated a reasonable claim that, if proven, could be grounds for relief under the Eighth Amendment prohibition of cruel and unusual punishment. Justice Byron White, in the majority opinion, rejected the government's argument that the "deliberate indifference" test established by the Court in Wilson (which held that withholding medical care from prisoners only violated the Eighth Amendment if it was done with "deliberate indifference" to serious health risks) only applied to current medical conditions. If McKinney could prove that the second-hand smoke posed a serious threat to his future health and that the prison officials had deliberately ignored that threat, White wrote, McKinney would be entitled to relief.

Herrera v. Collins, Director, Texas Department Of Criminal Justice, Institutional Division (No. 91-7328)

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Itel Containers International Corp. v. Huddleston, Commissioner Of Revenue Of Tennessee (No. 91-321)

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Johnson v. Texas (No. 92-5653)

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Keene Corp. v. United States (No. 92-166)

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Lamb's Chapel v. Center Moriches School District (No. 91-2024)

Did the District violate the First Amendment's freedom of speech when it denied Lamb's Chapel the use of school premises to show religious-oriented films?

Yes, by a unaminous vote. The Supreme Court's holding consisted of two parts. First, the District violated freedom of speech by refusing the Chapel's request to show movies on school premises solely because such movies were religiously oriented. While non-public schools are permitted under New York law to restrict access to their premises based on subject matter or speaker identity, such restrictions must be reasonable and "viewpoint neutral." In this case, the District's restriction was neither reasonable nor viewpoint neutral, since it allowed the presentation of all other views about family values and child rearing - except those which were presented from a religious perspective. Second, a grant of permission to the Chapel to use the District's premises would not have amounted to an establishment of religion. This is because the showing of the films would neither be school-sponsored during school hours nor closed to the public.

Leatherman v. Tarrant County Narcotics Intelligence And Coordination Unit (No. 91-1657)

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Lincoln, Acting Director, Indian Health Service v. Vigil (No. 91-1833)

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Local 144 Nursing Home Pension Fund v. Demisay (No. 91-610)

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Lockhart, Director, Arkansas Department Of Correction v. Fretwell (No. 91-1393)

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Mcneil v. United States (No. 92-6033)

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Mertens v. Hewitt Associates (No. 91-1671)

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Minnesota v. Dickerson (No. 91-2019)

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Mississippi v. Louisiana (No. 91-1158)

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Montana v. Donald Glenn Imlay (No. 91-687)

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Moreau v. Klevenhagen, Sheriff, Harris County, Texas (No. 92-1)

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Musick, Peeler & Garrett v. Employers Insurance Of Wausau (No. 92-34)

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Nebraska v. Wyoming (No. 108 ORIG)

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Negonsott v. Samuels, Warden (No. 91-5397)

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Newark Morning Ledger Co., As Successor To The Herald Co. v. United States (No. 91-1135)

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Nixon v. United States (No. 91-740)

Is Nixon's claim -- that Senate Rule XI violates the Impeachment Trial Clause -- justiciable, i.e., appropriate for judicial resolution?

No. A unanimous Court held that the question of whether or not the Senate rule violated the U.S. Constitution was nonjusticiable since the Impeachment clause expressly granted that the "Senate shall have sole Power to try any impeachments." The clause laid out specific regulations that were to be followed and as long as those guidelines were observed the courts would not rule upon the validity of other Senate procedures regarding impeachments. Chief Justice William Rehnquist observed that while the Supreme Court was the "ultimate intrepreter of the Constitution," a matter would be deemed nonjusticiable when there was "a constitutional commitment of the issue to a coordinate political department."

Nobelman Et Ux. v. American Savings Bank (No. 92-641)

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Northeastern Florida Chapter Of The Associated General Contractors Of America v. City Of Jacksonville, Florida (No. 91-1721)

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Oklahoma Tax Commission v. Sac And Fox Nation (No. 92-259)

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Ortega-Rodriguez v. United States (No. 91-7749)

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Parke, Warden v. Raley (No. 91-719)

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Pioneer Investment Services Co. v. Brunswick Associates Limited Partnership (No. 91-1695)

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Professional Real Estate Investors, Inc. v. Columbia Pictures Industries, Inc. (No. 91-1043)

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Puerto Rico Aqueduct And Sewer Authority v. Metcalf & Eddy, Inc. (No. 91-1010)

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Rake v. Wade, Trustee (No. 92-621)

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Reiter v. Cooper, Trustee For Carolina Motor Express, Inc. (No. 91-1496)

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Reno, Attorney General v. Catholic Social Services, Inc. (No. 91-1826)

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Reno, Attorney General v. Flores (No. 91-905)

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Republic National Bank Of Miami v. United States (No. 91-767)

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Reves v. Ernst & Young (No. 91-886)

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Richmond v. Lewis, Director, Arizona Department Of Corrections (No. 91-7094)

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Rowland, Former Director, California Department Of Corrections v. California Men's Colony, Unit II Men's Advisory Council (No. 91-1188)

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Sale, Acting Commissioner, Immigration And Naturalization Service v. Haitian Centers Council, Inc. (No. 92-344)

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Saudi Arabia v. Nelson Et ux. (No. 91-522)

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Shalala, Secretary Of Health And Human Services v. Schaefer (No. 92-311)

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Shaw v. Reno (No. 92-357)

Did the North Carolina residents' claim, that the State created a racially gerrymandered district, raise a valid constitutional issue under the Fourteenth Amendment's Equal Protection Clause?

Yes. The Court held that although North Carolina's reapportionment plan was racially neutral on its face, the resulting district shape was bizarre enough to suggest that it constituted an effort to separate voters into different districts based on race. The unusual district, while perhaps created by noble intentions, seemed to exceed what was reasonably necessary to avoid racial imbalances. After concluding that the residents' claim did give rise to an equal protection challenge, the Court remanded - adding that in the absence of contradictory evidence, the District Court would have to decide whether or not some compelling governmental interest justified North Carolina's plan.

Smith v. United States (No. 91-8674)

Does trading a gun for drugs make a convicted defendant eligible for sentence enhancement under a federal law, which requires such treatment if the defendant "during and in relation to . . . [a] drug trafficking crime[,] uses . . . a firearm?"

Yes. In a 6-3 decision, authored by Justice Sandra Day O'Connor, the Court ruled that a criminal who trades his or her firearm for drugs "uses" it "during and in relation to . . . [a] drug trafficking crime," which is within the bounds of the sentence enhancement. Justice O'Connor wrote that Congress intended to make the word "use" as broad as possible when it wrote the law. The law does not require proof that a defendant used the gun as a weapon.

Smith v. United States (No. 91-1538)

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Soldal Et Ux. v. Cook County, Illinois (No. 91-6516)

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South Dakota v. Bourland, Individually And As Chairman Of The Cheyenne River Sioux Tribe (No. 91-2051)

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Spectrum Sports, Inc. v. Mcquillan Et Vir, Dba Sorboturf Enterprises (No. 91-10)

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St. Mary's Honor Center v. Hicks (No. 92-602)

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Stinson v. United States (No. 91-8685)

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Sullivan v. Louisiana (No. 92-5129)

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Txo Production Corp. v. Alliance Resources Corp. (No. 92-479)

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United States By And Through Internal Revenue Service v. Mcdermott (No. 91-1229)

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United States Department Of Justice v. Landano (No. 91-2054)

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United States Department Of Treasury v. Fabe, Superintendent Of Insurance Of Ohio (No. 91-1513)

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United States National Bank Of Oregon v. Independent Insurance Agents Of America, Inc. (No. 92-484)

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United States v. A Parcel Of Land, Buildings, Appurtenances, And Improvements, Known As 92 Buena Vista Avenue, Rumson, New Jersey (No. 91-781)

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United States v. California (No. 91-2003)

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United States v. Dixon (No. 91-1231)

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United States v. Dunnigan (No. 91-1300)

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United States v. Edge Broadcasting Co., T/A Power 94 (No. 92-486)

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United States v. Green (No. 91-1521)

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United States v. Hill Et ux. (No. 91-1421)

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United States v. Idaho, Ex Rel. Director, Idaho Dept of Water Resources (No. 92-190)

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United States v. Olano (No. 91-1306)

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United States v. Padilla (No. 92-207)

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United States v. Texas (No. 91-1729)

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Voinovich, Governor Of Ohio v. Quilter, Speaker Pro Tempore Of Ohio House Of Representatives (No. 91-1618)

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Wisconsin v. Mitchell (No. 92-515)

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Withrow v. Williams (No. 91-1030)

Does the Supreme Court's ruling in Stone v. Powell that federal habeas corpus review does not cover Fourth Amendment unreasonable search and seizure claims when defendants have already been given a fair chance to argue those claims in state court also apply to Fifth Amendment claims stemming from the withholding of Miranda warnings?

No. In an opinion written by Justice David H. Souter, the Supreme Court held that the decision in Stone had been one of prudence rather than one of jurisdiction. In Stone, the Court had decided against using the "exclusionary rule" in federal habeas cases dealing with unreasonable searches and seizures (the exclusionary rule prevents evidence discovered as the result of an unconstitutional search from being introduced in Court). The Court's decision had been based on an expectation that, even in the unlikely case that a state court had erred in its consideration of the constitutionality of a given search, that procedural error was not likely to produce a wrongful conviction. In Fifth Amendment involuntary testimony cases, though, it was possible that a suspect would given false statements about his own guilt because of confusion or fear. The question was not merely a procedural one, therefore, and the prudential concerns of Stone did not apply.

Zafiro v. United States (No. 91-6824)

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Zobrest v. Catalina Foothills School District (No. 92-94)

May a school district decline to provide an interpreter to a deaf child based on the Establishment Clause of the First Amendment?

No. In a 5-4 opinion delivered by Chief Justice William H. Rehnquist, the Court held that the Establishment Clause did not bar the school district from providing the requested interpreter. Chief Justice Rehnquist reasoned that, because the IDEA creates no financial incentive for parents to choose a sectarian school, the presence of an interpreter is not linked to the state and is the result of the private decision of individual's parents. "The service at issue in this case is part of a general government program that distributes benefits neutrally to any child qualifying as 'handicapped' under the IDEA, without regard to the 'sectarian-nonsectarian, or public-nonpublic nature' of the school the child attends," wrote Chief Justice Rehnquist.