The Oyez Project: 1993 Term Decisions

ABF Freight System, Inc. v. National Labor Relations Board (No. 92-1550)

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Albright v. Oliver (No. 92-833)

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American Dredging v. Miller (No. 91-1950)

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Associated Industries of Missouri v. Lohman (No. 93-397)

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Barclays Bank Plc v. Franchise Tax Board Of California (No. 92-1384)

United States Code section 3565 says that if a person serving a sentence of probation possesses illegal drugs, "the court shall revoke the sentence of probation and sentence the defendant to not less than one third of the original sentence." Does "original sentence" refer to the original imprisonment sentence range set by U.S. Sentencing Guidelines, or to the term of probation?

In an opinion delivered by Justice Ruth Bader Ginsburg, the Court held 7-2 that the U.S. Code's section 3565 refers to the original sentence range set by U.S. Sentencing Guidelines. Therefore, the minimum revocation sentence for drug possession while on probation is one third the maximum of the Guidelines range of imprisonment; the maximum revocation sentence is the Guidelines maximum. The Court pointed out that the statute differentiates between "sentence of probation" and "original sentence." Moreover, the history of the language shows that Congress may not have given it careful attention and that it "may have been composed with an obsolete federal sentencing regime in the drafter's mind." In "circumstances, where the text, structure, and statutory history fail to establish that the Government's position is unambiguously correct, the rule of lenity... resolve[s] the statutory ambiguity in Granderson's favor."

Justices Antonin Scalia and Anthony Kennedy concurred separately. Dissenting, Chief Justice William H. Rehnquist, with whom Justice Clarence Thomas concurred, argued that "original sentence" should be interpreted as the term of probation.

Beecham v. United States (No. 93-445)

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BFP v. Resolution Trust Corporation, As Receiver Of Imperial Federal Savings Association (No. 92-1370)

Were the fines assessed against the United Mine Workers of America union, amounting to more than $64 million, criminal or civil in nature?

The fines were criminal in nature. The Supreme Court unanimously held that they had been intended to punish the union, not merely to maintain order or respect for the judiciary, and that the union was therefore entitled to the heightened protections of a criminal proceeding, such as a jury trial. Justice Harry Blackmun in the opinion of the Court, wrote, "The union's sanctionable conduct did not not occur in the court's presence or otherwise implicate the court's ability to maintain order and adjudicate the proceedings before it. ... Instead, the Virginia trial court levied contempt fines for widespread, ongoing, out-of-court violations of a complex injunction. In so doing, the court effectively policed petitioner's compliance with an entire code of conduct that the court itself had imposed. ... Under such circumstances, disinterested factfinding and evenhanded adjudication were essential, and petitioners were entitled to a criminal jury trial."

Board of Educ.Kiryas Joel Village School v. Grumet (No. 93-517)

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Boca Grande Club, Inc. v. Florida Power & Light Company, Inc. (No. 93-180)

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C & A Carbone, Inc. v. Town Of Clarkstown, New York (No. 92-1402)

Does federal statute 18 U.S.C. Section 3501(c), declaring separate charge-based confessions inadmissible if obtained after the first six hours of detention, apply to suspects that are held only on state or federal charges?

No. In a unanimous decision, the Court held that the provisions of the federal statute in question do not apply to suspects being held solely on state charges. The Court explained that no delay is said to occur until the suspect is arrested and detained for a federal crime. The six-hour period only begins to expire from the point of a suspect's federal arrest and charging. In this case, Alvarez-Sanchez was presented before a federal judge within six hours of his arrest on a federal counterfeit charge. The fact that he was held for some two and a half days prior has no bearing on his federal status under the statute since he was detained on state and local charges only during this time.

Campbell v. Acuff-Rose Music (No. 92-1292)

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Caspari, Superintendent, Missouri Eastern Correctional Center v. Bohlen (No. 92-1500)

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Cavanaugh v. Roller (No. 92-1510)

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Central Bank Of Denver, N. A. v. First Interstate Bank Of Denver, N. A. (No. 92-854)

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City Of Chicago v. Environmental Defense Fund (No. 92-1639)

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Consolidated Rail Corporation v. Gottshall (No. 92-1956)

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Custis v. United States (No. 93-5209)

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Dalton, Secretary Of The Navy v. Specter (No. 93-289)

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Davis v. United States (No. 92-1949)

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Department Of Revenue Of Montana v. Kurth Ranch (No. 93-144)

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Department Of Revenue Of Oregon v. Acf Industries, Inc. (No. 92-74)

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Department Of Taxation And Finance Of New York v. Milhelm Attea & Bros., Inc. (No. 93-377)

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Digital Equipment Corp. v. Desktop Direct Inc. (No. 93-405)

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Director, Office Of Workers' Compensation Programs, Department Of Labor v. Greenwich Collieries (No. 93-744)

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Dolan v. City of Tigard (No. 93-518)

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Elder v. Holloway (No. 92-8579)

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Farmer v. Brennan, Warden (No. 92-7247)

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Federal Deposit Insurance Corporation v. Meyer (No. 92-741)

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Florence County School District Four v. Carter (No. 91-1523)

May a court order reimbursement for parents who withdrew their child from a public school providing an inappropriate education under the Individuals with Disabilities Education Act and put the child in a private school that is in substantial - but not complete - compliance with the act?

Yes. In an opinion written by Justice Sandra Day O'Connor, the Supreme Court unanimously held that parents have a right to withdraw their child from a public school providing an inappropriate education under the meaning of IDEA and enroll them in a private school, as long as the private school provides an "appropriate" education. The Court further held that the specific requirements of the Act need not be met when a student is placed in a private school by his or her parents, because the IDEA requirements were not intended to apply to parental placements.

Fogerty v. Fantasy, Inc. (No. 92-1750)

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Hagen v. Utah (No. 92-6281)

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Harris v. Forklift Sys. (No. 92-1168)

May 2 Live Crew's commercial parody of Roy Orbison's "Oh, Pretty Woman" be a fair use within the meaning of the Copyright Act of 1976?

Yes. In a unanimous opinion delivered by Justice David H. Souter, the Court held that a parody's commercial character is only one element to be weighed in a fair use enquiry and that insufficient consideration was given to the nature of parody in weighing the degree of copying. The Court found that the Court of Appeals erred in applying the presumption that the commercial nature of the parody rendered it presumptively unfair, as no such evidentiary presumption was available to address either the character and purpose of the use or the market harm. Justice Souter wrote that the appellate court "erred in holding that 2 Live Crew had necessarily copied excessively from the Orbison original, considering the parodic purpose of the use." Justice Anthony M. Kennedy filed a concurring opinion.

Hawaiian Airlines, Inc. v. Norris (No. 92-2058)

Is the denial of a "right not to sue" established by a settlement agreement immediately appealable under the Supreme Court's decision in Coopers & Lybrand v. Livesay, 437 U.S. 463?

No. In a unanimous decision, the Supreme Court ruled that the denial of immunity - while cause for concern - does not automatically create a right to immediate appeal. It is important to have final judgments before appeals are made, Justice David H. Souter wrote for the Court, and exceptions should only be made in particularly important cases. A "right not to go to trial," while significant, is rarely the key factor in a settlement agreement, and cannot compare in importance to the right to be free from "double jeopardy" in criminal court or the encroachment on public duties caused by a denial of immunity to public officials.

Heck v. Humphrey (No. 93-6188)

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Holder, Individually And In His Official Capacity As County Commissioner For Bleckley County, Georgia v. Hall (No. 91-2012)

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Honda v. Oberg (No. 93-644)

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Howlett v. Birkdale Shipping Co., S. A. (No. 93-670)

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Ibanez v. Florida Department Of Business And Professional Regulation, Board Of Accountancy (No. 93-639)

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Izumi Seimitsu Kogyo Kabushiki Kaisha v. U. S. Philips Corp. (No. 92-1123)

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J.E.B. v. Alabama ex rel T.B. (No. 92-1239)

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John Hancock Mutual Life Insurance Co. v. Harris Trust And Savings Bank, As Trustee Of The Sperry Master Retirement Trust No.2 (No. 92-1074)

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Johnson, Speaker Of The Florida House Of Representatives v. De Grandy (No. 92-519)

Under 18 U.S.C. 922(g), can state procedures for the restoration of the civil rights of felons restore the right of a federal felon to possess a firearm?

No. Justice Sandra Day O'Connor wrote the opinion for a unanimous Court. The Court applied the choice of law clause to the exemption clause and reasoned that no rights could be restored unless by the jurisdiction that first barred the rights. The Court ruled that though the federal government did not currently have any procedures in place to restore the civil rights of felons, only the federal government had jurisdiction over federal convictions. Therefore, Beecham's state-law restoration of civil rights was insufficient to restore his right to possess a firearm in light of 18 U.S.C. 922(g).

Key Tronic Corp. v. United States (No. 93-376)

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Kokkonen v. Guardian Life Insurance Company Of America (No. 93-263)

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Ladue v. Gilleo (No. 92-1856)

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Landgraf v. Usi Film Products (No. 92-757)

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Liteky v. United States (No. 92-6921)

Did the city's conditions for the permit violate the 5th Amendment's "takings" clause as absorbed by the 14th Amendment's due process clause?

Yes. The Court ruled that the city did not present conclusive evidence that the walkway/bicycle path would reduce traffic congestion, and so could not require Dolan to give up her property as a condition of the permit. In addition, the city did not explain why a public greenway was necessary, as opposed to a private one. There must be an "essential nexus" between a legitimate state interest and the permit requirements (Nollan v. California Coastal Commission), and the city failed to demonstrate that the benefits would justify the requirements.

Livadas v. Bradshaw, California Labor Commissioner (No. 92-1920)

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Madsen v. Women's Health Center, Inc. (No. 93-880)

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McDermott, Inc. v. Amclyde (No. 92-1479)

Under the Federal Employers' Liability Act (FELA), does "emotional stress" resulting from employer "negligence" constitute an "injury" for which an employee can hold his employer liable?

No. Justice Clarence Thomas authored the opinion for a 7-2 Court. The Court categorized FELA emotional stress claims closely with common law treatments of emotional stress claims. The Court rejected the Third Circuit's assertion that common law tests were arbitrary and could be disregarded. Instead, common law standards should be used to verify claims filed under FELA. The Court adopted the "zone of danger test" from common law, which limits relief to those employees who sustain physical injury resulting from emotional stress caused by employer negligence. The Court held that this test would best distinguish between genuine and fraudulent claims, and provide relief in the case of injury. The Court rejected the Third Circuit's holding that employers were liable for causing foreseeably stressful conditions, reasoning that this would extend to many types of everyday employment.

Mcfarland v. Scott, Director, Texas Department Of Criminal Justice, Institutional Division (No. 93-6497)

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MCI Telecommunications Corp. v. American Telephone & Telegraph Co. (No. 93-356)

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Morgan Stanley & Co. Inc. v. Pacific Mutual Life Insurance Co. (No. 93-609)

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National Labor Relations Board v. Health Care & Retirement Corporation Of America (No. 92-1964)

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National Organization for Women (NOW) v. Scheidler (No. 92-780)

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Nichols v. United States (No. 92-8556)

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Northwest Airlines, Inc. v. County Of Kent, Michigan (No. 92-97)

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O'Melveny & Myers v. Federal Deposit Insurance Corporation, As Receiver For American Diversified Savings Bank (No. 93-489)

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Oregon Waste Systems, Inc. v. Department Of Environmental Quality Of The State Of Oregon (No. 93-70)

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Posters 'N' Things, Ltd. v. United States (No. 92-903)

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Powell v. Nevada (No. 92-8841)

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PUD No. 1 Of Jefferson County v. Washington Department Of Ecology (No. 92-1911)

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Ratzlaf Et Ux. v. United States (No. 92-1196)

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Reed v. Farley, Superintendent, Indiana State Prison (No. 93-5418)

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Rivers v. Roadway Express, Inc. (No. 92-938)

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Romano v. Oklahoma (No. 92-9093)

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Schiro v. Farley, Superintendent, Indiana State Prison (No. 92-7549)

Does the Oregon prohibition on judicial review of jury awards violate the Due Process Clause of the 14th Amendment?

Yes. The denial of judicial review creates the possibility that juries might make arbitrary and excessive awards without offering a way to adjust them. The common-law practice of allowing judicial review for jury awards is important in ensuring that juries do not ignore guidelines.

Security Services, Inc. v. Kmart Corp. (No. 93-284)

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Shannon v. United States (No. 92-8346)

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Simmons v. South Carolina (No. 92-9059)

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Stansbury v. California (No. 93-5770)

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Staples v. United States (No. 92-1441)

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Tennessee v. Middlebrooks (No. 92-989)

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Thomas Jefferson University, Dba Thomas Jefferson University Hospital v. Shalala, Secretary Of Health And Human Services (No. 93-120)

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Thunder Basin Coal Co. v. Reich, Secretary Of Labor (No. 92-896)

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Ticor Title Insurance Co. v. Brown (No. 92-1988)

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Tuilaepa v. California (No. 93-5131)

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Turner Broadcasting v. FCC (No. 93-44)

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United Mineworkers of America v. Bagwell (No. 92-1625)

Does RICO require that an organization, to be defined as a racketeering enterprise, must be acting in pursuit of an economic motive?

The unanimous Court held that organizations without an economic motive can detrimentally "affect interstate or foreign commerce," satisfying the RICO definition of a racketeering enterprise. An "enterprise" does not have to be an economic organization or a principally criminal organization to trigger the RICO act. Consequently, the Court reversed the appeals court decision which allowed the original case to proceed.

United States Department Of Defense v. Federal Labor Relations Authority (No. 92-1223)

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United States v. Alvarez-Sanchez (No. 92-1812)

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United States v. Carlton (No. 92-1941)

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United States v. Granderson (No. 92-1662)

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United States v. Irvine (No. 92-1546)

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United States v. James Daniel Good Real Property (No. 92-1180)

1) Does a state violate the Due Process Clause by accepting "reasonable approximations" of financial data?

2) By requiring multinational corporations to provide exhaustive financial information to calculate taxes, does a State impose a disproportionately large compliance burden upon the corporation and thereby violate the anti-discrimination requirement of the Commerce Clause?

Justice Ruth Ginsburg wrote the opinion for a 7-2 Court. (1) The Court dismissed the alleged Due Process violation because a corporation could take action against the Tax Board if it felt the approximated amount was inaccurate. (2) Reasoning that the use of "reasonable approximations" minimized a multinational's compliance burden, the Court also dismissed the alleged Commerce Clause violation. The Court recognized that the "worldwide combined reporting" method carried a risk of double taxation by both the state and the federal government, but reasoned that this did not violate the Commerce Clause because every other method employed by the state to tax foreign commerce carried the same risk. Also, the Court found no "specific indications of congressional intent" to enforce uniformity in taxation of foreign commerce by preempting the California tax laws.

Victor v. Nebraska (No. 92-8894)

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Waters v. Churchill (No. 92-1450)

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Weiss v. United States (No. 92-1482)

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West Lynn Creamery, Inc. v. Healy, Commissioner Of Massachusetts Depart Ment Of Food And Agriculture (No. 93-141)

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Williamson v. United States (No. 93-5256)

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