Cases - 1995 term

Melendez v. United States

Tue, 27 Feb 1996 13:00:00 +0000

Case Basics

Docket No.

95-5661

Petitioner

Melendez

Petitioner Type

Petitioner

Respondent

United States

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

518 U.S. 120 (1996)

Argued

Tuesday, February 27, 1996

Decided

Monday, June 17, 1996

Advocates

Patrick A. Mullin (Argued the cause for the petitioner)

Irving L. Gornstein (Argued the cause for the respondent)

Facts of the Case

After purchasing cocaine, Juan Melendez was charged with violating federal drug laws. The law carried a minimum sentence of ten years imprisonment. Melendez signed a plea agreement stating he would be cooperative. In turn the government agreed to give him a short sentence. The District Court thus sentenced Melendez to ten years in prison, the mandatory minimum. The Court of Appeals affirmed.

Question

Does a federal prosecutor's plea agreement that a cooperating defendant be given the minimum sentence authorize a judge to depart below a statutory minimum?

Conclusion

Decision: 7 votes for United States, 2 vote(s) against
Legal provision: 18 U.S.C. 3553

No. In a 7-2 decision authored by Justice Clarence Thomas, the Court held that, in the absence of a Government motion requesting or authorizing the district court to "impose a sentence below a level established by statute as minimum sentence," a prison sentence must not violate the statutory sentencing minimum.

Hercules Inc. v. United States

Mon, 30 Oct 1995 13:00:00 +0000

Case Basics

Docket No.

94-818

Petitioner

Hercules Inc.

Petitioner Type

Petitioner

Respondent

United States

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

516 U.S. 417 (1996)

Argued

Monday, October 30, 1995

Decided

Monday, March 4, 1996

Advocates

Carter G. Phillips (Argued the cause for the petitioners)

Edward C. DuMont (Department of Justice, argued the cause for the United States, supporting the respondent)

Facts of the Case

During the 1960s, the United States government contracted with several chemical manufacturers, including Hercules Incorporated and Wm. T. Thompson Company, to manufacture the herbicide known as Agent Orange. After health problems arose, Vietnam veterans and their families began filing lawsuits against the manufactures. The manufacturers incurred substantial costs defending, and then settling, the claims. The manufactures then filed suit under the Tucker Act to recover such costs from the Government on theories of contractual indemnification and warranty of specifications provided by the government. Ultimately, the Court of Appeals rejected the theory of implied warranty of specifications and the theory of implied promise to indemnify for liabilities incurred in performing the contracts. The appellate court also held that, by settling, the manufactures had voluntarily assumed liability for which the Government was not responsible.

Question

May the chemical manufacturers of Agent Orange recover costs incurred from defending and settling third-party tort claims arising out of their performance of Government contracts from the Government on alternative theories of contractual indemnification or warranty of specifications provided by the Government?

Conclusion

Decision: 6 votes for United States, 2 vote(s) against
Legal provision: Tucker

No. In a 6-2 opinion delivered by Chief Justice William H. Rehnquist, the Court held that the manufacturers may not recover on their warranty-of- specifications and contractual-indemnification claims. Chief Justice Rehnquist wrote for the Court that the manufactures could not recover from the government because the contracts did not contain warranties or indemnification provisions for costs in defending and settling third-party tort claims resulting from chemical manufacture and use. Moreover, Chief Justice Rehnquist wrote that the context in which the government compelled the manufacturer to manufacture Agent Orange did not give rise to an implied-in-fact indemnity agreement. Justice Stephen G. Breyer wrote a dissent that was joined by Justice Sandra Day O'Connor. Justice John Paul Stevens did not participate in the case.

Neal v. United States

Mon, 04 Dec 1995 13:00:00 +0000

Case Basics

Docket No.

94-9088

Petitioner

Neal

Petitioner Type

Petitioner

Respondent

United States

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

516 U.S. 284 (1996)

Argued

Monday, December 4, 1995

Decided

Monday, January 22, 1996

Advocates

Donald T. Bergerson (Argued the cause for the petitioner)

Paul R. Q. Wolfson (Department of Justice, argued the cause for the respondent)

Facts of the Case

A federal District Court sentenced Meirl Gilbert Neal on two plea-bargained convictions involving possession of LSD with intent to distribute. The amount of LSD was determined, under both the federal statute directing minimum sentences and the U. S. Sentencing Commission's Guidelines Manual, by the whole weight of the blotter paper, or carrier medium, containing the drug. The combined weight of the blotter paper and LSD actually sold by Neal was 109.51 grams. Thus, the court ruled that Neal was subject to 21 U.S.C. 841(b) (1)(A)(v), which imposes a 10-year mandatory minimum sentence on anyone convicted of trafficking in more than 10 grams of "a mixture or substance containing a detectable amount" of LSD. After the Commission revised the Guidelines' calculation method by instructing courts to give each dose of LSD on a carrier medium a constructive or presumed weight, Neal filed a motion to modify his sentence, contending that the weight of the LSD attributable to him under the amended Guidelines was only 4.58 grams, well short of 841(b)(1)(A)(v)'s 10-gram requirement, and that the Guidelines' presumptive- weight method controlled the mandatory minimum calculation. The District Court held that the actual weight of the blotter paper, with its absorbed LSD, was determinative of whether Neal crossed the 10-gram threshold and that the 10-year mandatory minimum sentence still applied to him notwithstanding the Guidelines. In affirming, an en banc Court of Appeals agreed with the District Court that a dual system now prevails in calculating LSD weights.

Question

Does U.S. Sentencing Commission's Guidelines Manual's revised system for determining LSD amounts take precedence over 21 U.S.C. 841 in determining sentencing?

Conclusion

Decision: 9 votes for United States, 0 vote(s) against
Legal provision: 21 U.S.C. 841

No. In a unanimous decision, authored by Justice Anthony Kennedy, the Court held that Section 841(b)(1) directs a sentencing court to take into account the actual weight of the blotter paper with its absorbed LSD, even though the U. S. Sentencing Commission's Guidelines Manual requires a different method of calculating the weight of an LSD mixture or substance.

United Food Workers v. Brown Group Inc.

Tue, 20 Feb 1996 13:00:00 +0000

Case Basics

Docket No.

95-340

Petitioner

United Food Workers

Petitioner Type

Petitioner

Respondent

Brown Group Inc.

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

517 U.S. 544 (1996)

Argued

Tuesday, February 20, 1996

Decided

Monday, May 13, 1996

Advocates

Lan Jenkins (On behalf of the United States, as amicus curiae, supporting the petitioner)

Alan Jenkins (on behalf of the United States, as amicus curiae, supporting the Petitioner)

Laurence E. Gold (Argued the cause for the petitioner)

Thomas C. Walsh (Argued the cause for the respondent)

Facts of the Case

The United Food and Commercial Workers Union Local 751 filed suit alleging that Brown Group, Inc. began to lay off workers in connection with the closing of one of its plants, Brown Shoe Company, before giving the union the closing notice required by the federal Worker Adjustment and Retraining Notification Act (the WARN Act). The union sought backpay for each of its affected members. Under modern associational standing doctrine, an organization may sue to redress its members' injuries when: 1) its members would otherwise have standing to sue in their own right; 2) the interests it seeks to protect are germane to the organization's purpose; and 3) neither the claim asserted nor the relief requested requires the participation of individual members in the lawsuit. The District Court dismissed the compliant. The Court of Appeals affirmed, holding that "[e]ach union member who wishes to recover WARN Act damages from Brown Shoe must participate in the suit so that his or her right to damages can be determined and the quantum of damages can be calculated by the court on the basis of particularized proof." Therefore, the court concluded that the suit was barred because the union failed to meet the third part of the test for asserting associational standing.

Question

May a labor union sue on behalf of its members over alleged violations of the federal Worker Adjustment and Retraining Notification Act?

Conclusion

Decision: 9 votes for United Food Workers, 0 vote(s) against
Legal provision: 29 U.S.C. 2101

Yes. In a unanimous decision, authored by Justice David H. Souter, the Court held that the federal Worker Adjustment and Retraining Notification Act grants unions authority to sue for damages on behalf of their members. Therefore, the union had standing to bring such an action. Justice Souter wrote that the court's ruling was based on previous decisions that state that "an organization may sue to redress its members' injuries even without a showing of injury to the association itself."

Lewis v. Casey

Wed, 29 Nov 1995 13:00:00 +0000

Case Basics

Docket No.

94-1511

Petitioner

Lewis

Petitioner Type

Petitioner

Respondent

Casey

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

518 U.S. 343 (1996)

Argued

Wednesday, November 29, 1995

Decided

Monday, June 24, 1996

Advocates

Grant Woods (Argued the cause for the petitioners)

Elizabeth Alexander (Argued the cause for the respondents)

Facts of the Case

Fletcher Casey, Jr. and other inmates of various prisons operated by the Arizona Department of Corrections (ADOC), brought a class action against ADOC officials, alleging that the ADOC officials were furnishing them with inadequate legal research facilities and thereby depriving them of their right of access to the courts, in violation of Bounds v. Smith. Bounds held that "the fundamental constitutional right of access to the courts requires prison authorities to assist inmates in the preparation and filing of meaningful legal papers by providing prisoners with adequate law libraries or adequate assistance from persons trained in the law." The District Court found the ADOC officials in violation of Bounds and issued an injunction mandating detailed, systemwide changes in ADOC's prison law libraries and in its legal assistance programs. The Court of Appeals affirmed both the finding of a Bounds violation and the injunction's major terms.

Question

Did a federal trial judge err when ruling that Arizona prison officials unconstitutionally failed to provide inmates with adequate legal research facilities?

Conclusion

Decision: 8 votes for Lewis, 1 vote(s) against
Legal provision:

No. In an opinion authored by Justice Antonin Scalia, the Court held that the success of Casey's systemic challenge was dependent on the ability to show widespread actual injury, and the District Court's failure to identify anything more than isolated instances of actual injury rendered its finding of a systemic Bounds violation invalid. Justice Scalia said the court's 1977 ruling in Bounds v. Smith "does not guarantee [inmates] the wherewithal to transform themselves into litigating engines capable of filing everything from shareholder derivative actions to slip-and-fall claims."

Leavitt v. Jane L.

Sun, 28 Apr 2013 09:19:14 +0000

Case Basics

Docket No.

95-1242

Petitioner

Leavitt, Governor of Utah

Petitioner Type

Petitioner

Respondent

Jane L.

Respondent Type

Respondent

Decided By

Rehnquist Court (1994-2005)

Opinion

518 U.S. 137 (1996)

Decided

Monday, June 17, 1996

Facts of the Case

A Utah district court held that a state statutory provision regulating early- term abortions was unconstitutional. The U.S. Court of Appeals for the Tenth Circuit ruled that a similar provision regulating later-term abortions should be invalidated along with the earlier-term provision. The Tenth Circuit held that the Utah Legislature would only have wanted to regulate later-term abortions if it could also regulate earlier-term abortions, and thus concluded that the provisions were not severable (i.e. separable). Utah governor Michael Leavitt appealed to the Supreme Court, arguing that the Utah Legislature intended the two provisions to be severable.

Question

Was the U.S. Court of Appeals for the Tenth Circuit correct to invalidate a Utah statutory provision regulating later-term abortions after a similar provision regulating earlier-term abortions was ruled unconstitutional?

Conclusion

Decision: 5 votes for Leavitt, 0 vote(s) against
Legal provision:

No. In a 5-4 decision, the Court reversed the Tenth Circuit's ruling. The anonymous Per Curiam opinion held that the Utah Legislature had explicitly stated that each of the two abortion provisions was meant to stand independent of the other. The Court called the Tenth Circuit's interpretation of the Utah legislature's intent "questionable when considered in isolation" and "plainly error" when considered in light of the statutory text. In dissent, Justice Stevens argued that the case should not have been granted, because it dealt with an issue of Utah state law that was better left to the lower courts.

Lonchar v. Thomas

Mon, 04 Dec 1995 13:00:00 +0000

Case Basics

Docket No.

95-5015

Petitioner

Lonchar

Petitioner Type

Petitioner

Respondent

Thomas

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

517 U.S. 314 (1996)

Argued

Monday, December 4, 1995

Decided

Monday, April 1, 1996

Advocates

Donald B. Verrilli, Jr. (Argued the cause for the petitioner)

Mary Beth Westmoreland (Argued the cause for the respondent)

Facts of the Case

Larry Grant Lonchar was sentenced to death for murder nine years ago. After the affirmance of Lonchar's conviction and sentence, his sister and brother filed "next friend" state habeas corpus petitions. Lonchar opposed both. Lonchar then filed a state habeas corpus petition, which was dismissed. Shortly before Lonchar's scheduled execution, he filed another state habeas corpus petition. When the petition was denied, Lonchar filed an "eleventh hour" federal petition, his first, on the day of his scheduled execution. The District Court held that Lonchar's conduct in waiting almost nine years to file his federal petition did not constitute an independent basis for rejecting the petition and granted a stay to permit time for consideration of other grounds for dismissal raised by the State. The court had reasoned that federal Habeas Corpus Rule 9, not some generalized equitable authority to dismiss, governed the case. The Court of Appeals vacated the stay. Setting aside the Rules and traditional habeas doctrine, the court held that equitable doctrines independent of Rule 9 applied and it concluded that Lonchar did not merit equitable relief.

Question

May a federal court dismiss a first federal habeas petition for general "equitable" reasons beyond those embodied in the federal Habeas Corpus Rules?

Conclusion

Decision: 5 votes for Lonchar, 4 vote(s) against
Legal provision: 28 USC 2241-2255 (habeas corpus)

No. In an opinion authored by Justice Stephen G. Breyer, the Court held that federal Habeas Corpus Rule 9, not some general "equitable" power to create exceptions to the Rule, should have determined whether or not a petition's dismissal was appropriate. Justice Breyer wrote for the court that a long delay does not generally constitute an abuse of the system, adding, "[d]ismissal of a first habeas petition is a particularly serious matter for that dismissal denies the petitioner the protections of the Great Writ entirely."

Medtronic Inc. v. Lohr

Tue, 23 Apr 1996 13:00:00 +0000

Case Basics

Docket No.

95-754

Petitioner

Medtronic Inc.

Petitioner Type

Petitioner

Respondent

Lohr

Respondent Type

Respondent

Consolidation

Lohr et vir v. Medtronic, Inc., No. 95-886

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

518 U.S. 470 (1996)

Argued

Tuesday, April 23, 1996

Decided

Wednesday, June 26, 1996

Advocates

Edwin S. Kneedler (Department of Justice, argued the cause on behalf of the United States, as amicus curiae, in support of Lora Lohr, et vir)

Arthur R. Miller (Argued the cause on behalf of Medtronic, Inc)

Brian Wolfman (Argued the cause on behalf of Lora Lohr, et vir)

Facts of the Case

The Medical Device Amendments of 1976 (MDA) provides for "the safety and effectiveness of medical devices intended for human use," and classifies such devices based on their level of risk. Class III devices pose the greatest risk and, thus, are subject to a rigorous premarket approval (PMA) process. However, two statutory exceptions to this process exist. Because Medtronic, Inc.'s pacemaker is a Class III device found substantially equivalent to a pre-existing device, it can avoid the PMA process. In 1990, Lora Lohr's Medtronic pacemaker failed, allegedly according to a defect. Lohr and her spouse filed a Florida state-court suit, alleging both negligence and strict- liability claims. Medtronic removed the case to federal district court. The court then dismissed the case as pre-empted by 21 USC section 360k(a), which provides that "no State...may establish or continue in effect with respect to a device intended for human use any requirement (1) which is different from, or in addition to, any requirement applicable under [the MDA] to the device, and (2) which relates to the safety or effectiveness of the device or to any other matter included in a requirement applicable to the device under [the Act]." Reversing and affirming in part, the Court of Appeals concluded that the Lohrs' negligent design claims were not pre-empted, but that their negligent manufacturing and failure to warn claims were. (This case was decided together with 95-886, Lohr et vir v. Medtronic, Inc.)

Question

Do the Medical Device Amendments of 1976 pre-empt a state common-law negligence action against the manufacturer of an allegedly defective medical device?

Conclusion

Decision: 5 votes for Lohr, 4 vote(s) against
Legal provision: Federal Food, Drug, and Cosmetic, and related statutes

No. In an opinion delivered by Justice John Paul Stevens, the Court held that the Court of Appeals decision was reversed insofar as it held that any of the claims were pre-empted and affirmed insofar as it rejected any pre-emption defense. In a 9-0 vote, the Court allowed the lawsuit based on alleged defects in the pacemaker's design to proceed. In a 5-4 vote, the Court allowed the lawsuit to proceed on its claims of alleged defects in its manufacturing and failure to warn. Justice Stevens reasoned that the MDA was not intended to pre-empt "traditional common-law remedies against manufacturers and distributors of defective devices," as long as they paralleled federal requirements.

Barnett Bank Of Marion County, N. A. v. Nelson, Florida Insurance Commissioner

Tue, 16 Jan 1996 13:00:00 +0000

Case Basics

Docket No.

94-1837

Petitioner

Barnett Bank Of Marion County, N. A.

Petitioner Type

Petitioner

Respondent

Nelson, Florida Insurance Commissioner, et al.

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

517 U.S. 25 (1996)

Argued

Tuesday, January 16, 1996

Decided

Tuesday, March 26, 1996

Advocates

Richard P. Bress (on behalf of the United States, as amicus curiae, supporting the Petitioner)

Ann Mary Kappler (on behalf of the Private Respondents)

Daniel Y. Sumner (on behalf of the State Respondents)

Nathan Lewin (on behalf of the Petitioner)

Facts of the Case

None

Question

None

Conclusion

Decision: 9 votes for Barnett Bank Of Marion County, N. A., 0 vote(s) against
Legal provision: 15 U.S.C. 1012

None

Auciello Iron Works Inc. v. National Labor Relations Board

Mon, 22 Apr 1996 13:00:00 +0000

Case Basics

Docket No.

95-668

Petitioner

Auciello Iron Works Inc.

Petitioner Type

Petitioner

Respondent

National Labor Relations Board

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

517 U.S. 781 (1996)

Argued

Monday, April 22, 1996

Decided

Monday, June 3, 1996

Advocates

Richard H. Seamon (Department of Justice, argued the cause for the respondent)

John D. O'Reilly, III (Argued the cause for the petitioner)

Facts of the Case

The day after Auciello Iron Works' contract offer was accepted by its union employees' collective-bargaining representative, Auciello disavowed the agreement because of a good-faith doubt, based on knowledge acquired before the offer's acceptance, that a majority of employees supported the Union. The National Labor Relations Board (NLRB) ruled that Auciello's withdrawal was an unfair labor practice in violation of the National Labor Relations Act and ordered that the agreement be reduced to a formal written instrument. The Court of Appeals enforced the order as reasonable after the NLRB issued a supplemental opinion to justify its refusal to consider Auciello's defense of good-faith doubt about the Union's majority status.

Question

May an employer disavow a collective-bargaining agreement because of a good- faith doubt about a union's majority status at the time the contract was made, when the doubt arises from facts known to the employer before its contract offer had been accepted by the union?

Conclusion

Decision: 9 votes for National Labor Relations Board, 0 vote(s) against
Legal provision: National Labor Relations, as amended

No. In a unanimous opinion delivered by Justice David H. Souter, the Court held that the NLRB reasonably concluded that an employer challenging an agreement under these circumstances commits an unfair labor practice in violation of the National Labor Relations Act. The Court agreed with the NLRB that an employer's precontractual, good-faith doubt is inadequate to support an exception to the conclusive presumption of a union's majority status, which arises at the moment when a collective-bargaining contract offer has been accepted.

Yamaha Motor Corp., U. S. A. v. Calhoun

Tue, 31 Oct 1995 13:00:00 +0000

Case Basics

Docket No.

94-1387

Petitioner

Yamaha Motor Corp., U. S. A.

Petitioner Type

Petitioner

Respondent

Calhoun

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

516 U.S. 199 (1996)

Argued

Tuesday, October 31, 1995

Decided

Tuesday, January 9, 1996

Advocates

Paul A. Engelmayer (on behalf of the United States, as amicus curiae, supporting the Petitioners)

James W. Bartlett, III (Argued the cause for the petitioners)

Alan B. Morrison (Argued the cause for the respondents)

Facts of the Case

In 1989, 12-year-old Natalie Calhoun died in a collision in territorial waters off Puerto Rico while riding a Yamaha jet ski. Natalie's parents, invoking Pennsylvania's wrongful-death and survival statutes, filed a federal diversity and admiralty action for damages against Yamaha. Yamaha argued that, because Natalie died on navigable waters, state remedies could not be applied, and that federal, judge-declared maritime law controlled to the exclusion of state law. Under U.S. Supreme Court precedent, the District Court held that the federal maritime wrongful-death action excluded state law remedies, but that loss of society and loss of support and services were compensable. Both sides ask for an appeal. After granting the interlocutory review petition, the appellate panel held that state remedies remain applicable in accident cases of this type and have not been displaced by the federal maritime wrongful- death action.

Question

Do state remedies apply in maritime wrongful-death cases in which no federal statute specifies the appropriate relief and the decedent was not a seaman, longshore worker, or person otherwise engaged in a maritime trade?

Conclusion

Decision: 9 votes for Calhoun, 0 vote(s) against
Legal provision: 28 U.S.C. 1292

Yes. In a unanimous opinion delivered by Justice Ruth Bader Ginsburg, the Court held that state remedies remain applicable in such cases and have not been displaced by the federal maritime wrongful-death action recognized in Moragne v. States Marine Lines, Inc., 398 U.S. 375. The Court rejected Yamaha's argument that Moragne's wrongful-death action covers the waters, creating a uniform federal maritime remedy for all deaths occurring in state territorial waters, which replaces all state remedies previously available to supplement general maritime law.

United States v. International Business Machines Corp.

Mon, 18 Mar 1996 13:00:00 +0000

Case Basics

Docket No.

95-591

Petitioner

United States

Petitioner Type

Petitioner

Respondent

International Business Machines Corp.

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

517 U.S. 843 (1996)

Argued

Monday, March 18, 1996

Decided

Monday, June 10, 1996

Advocates

Jeffrey P. Minear (Argued the cause for the petitioner)

James R. Atwood (Argued the cause for the respondent)

Facts of the Case

Pursuant to the Internal Revenue Code, International Business Machines Corporation (IBM) paid a tax on insurance premiums it paid to foreign insurers to insure exports from the U.S. to foreign countries. IBM sought a refund on the tax and filed suit in the Court of Federal Claims when its refund claim was denied by the IRS. IBM contended the tax violated the Export Clause of the U.S. Constitution, which states that "[n]o Tax or Duty shall be laid on Articles exported from any State." The court agreed. The Court of Appeals affirmed.

Question

May the federal government impose a tax on premiums that U.S. businesses pay foreign insurers for risks that could arise in this country?

Conclusion

Decision: 6 votes for International Business Machines Corp., 2 vote(s) against
Legal provision: Article 1, Section 9, Paragraph 5: Export Clause

No. In a 6-2 decision, announced by Justice Clarence Thomas, the Court ruled the tax did violate the Export Clause and was therefore unconstitutional.

Montana v. Egelhoff

Wed, 20 Mar 1996 13:00:00 +0000

Case Basics

Docket No.

95-566

Petitioner

Montana

Petitioner Type

Petitioner

Respondent

Egelhoff

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

518 U.S. 37 (1996)

Argued

Wednesday, March 20, 1996

Decided

Thursday, June 13, 1996

Advocates

Miguel A. Estrada (Argued the cause for the United States, as amicus curiae, supporting the petitioner)

Joseph P. Mazurek (Argued the cause for the petitioner)

Ann Celestine German (Argued the cause for the respondent)

Facts of the Case

James Allen Egelhoff was tried in Montana courts for two counts of homicide. Egelhoff claimed that extreme intoxication rendered him physically incapable of committing or recalling the crimes. Montana law did not allow Egelhoff's intoxicated condition to be considered. Subsequently, Egelhoff was found guilty. The Supreme Court of Montana reversed the decision. It held Egelhoff had a due process right to present all relevant evidence. Moreover, it held that Montana law's denial of such a presentation relieved the state from part of its burden of proof needed to convict Egelhoff.

Question

May a state restrict the elements of a defense in criminal prosecution, consistent with the Fourteenth Amendment Due Process Clause?

Conclusion

Decision: 5 votes for Montana, 4 vote(s) against
Legal provision: Due Process

Yes. The Court could not reach a majority on the reasons for its decision. Justice Antonin Scalia, who announced the judgment of the Court, declared that defendants do not have an absolute constitutional right to present all relevant evidence in their defense.

United States v. Chesapeake & Potomac Telephone Company Of Virginia 516 U.S. 415

Wed, 06 Dec 1995 13:00:00 +0000

Case Basics

Docket No.

94-1893

Petitioner

United States et al.

Petitioner Type

Petitioner

Respondent

Chesapeake & Potomac Telephone Company Of Virginia et al. 516 U.S. 415

Respondent Type

Respondent

Consolidation

No. 94-1900

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

516 U.S. 415 (1996)

Argued

Wednesday, December 6, 1995

Decided

Wednesday, March 27, 1996

Advocates

Laurence H. Tribe (on behalf of the Respondents)

Lawrence G. Wallace (on behalf of the Petitioners)

Facts of the Case

To prevent "local media monopolies," Section 533(b) of the Cable Communications Policy Act of 1984 barred local phone service providers (local exchange carriers or LECs) from directly providing video programming to their local phone service subscribers. The government claimed that because LEC- controlled phone lines could also transmit video signals, allowing LECs to provide video programming would hurt competing cable companies. First, LECs could deny competitors access to their data lines. Second, LECs could offer lower cable prices than competitors by raising the costs of telephone service and using the extra profits to subsidize the costs of cable service.

Chesapeake and Potomac Telephone Company of Virginia (Chesapeake) challenged the constitutionality of the statute, pointing out that "video programming" is a form of speech protected by the First Amendment. The government argued that the statute's regulation of the cable market had a "content-neutral" objective. The District Court ruled that the statute's restrictions were not "narrowly tailored" to serve the statute's objective. The U.S. Court of Appeals for the Fourth Circuit affirmed, adding that the statute did not leave open "ample alternative channels for communication" between LECs and local residents. The Supreme Court consolidated the case with National Cable Television Assn., Inc. v. Bell Atlantic Corp.

Question

Does 47 U.S.C. 533(b), which bars local telephone companies from directly providing video programming to their local phone service subscribers, violate the First Amendment's protection of free speech?

Conclusion

Decision: 9 votes for United States, 0 vote(s) against
Legal provision:

Unanswered. After the Court heard oral arguments, the President signed the Telecommunications Act of 1996 into law. The Act repealed Section 533(b), allowing LECs to provide local cable service if they complied with a series of regulatory measures. The Court instructed the Fourth Circuit to reconsider the case and determine whether it had become moot.

Whren v. United States

Wed, 17 Apr 1996 13:00:00 +0000

Case Basics

Docket No.

95-5841

Petitioner

Whren

Petitioner Type

Petitioner

Respondent

United States

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

517 U.S. 806 (1996)

Argued

Wednesday, April 17, 1996

Decided

Monday, June 10, 1996

Advocates

James A. Feldman (on behalf of the Respondent)

Lisa Burget Wright (on behalf of the Petitioners)

Facts of the Case

Whren and Brown were driving in a 'high drug area.' Some plainclothes officers, while patrolling the neighborhood in an unmarked vehicle, noticed Whren and Brown sitting in a truck at an intersection stop-sign for an usually long time. Suddenly, without signaling, Whren turned his truck and sped away. Observing this traffic violation, the officers stopped the truck. When they approached the vehicle, the officers saw Whren holding plastic bags of crack cocaine. Whren and Brown were arrested on federal drug charges. Before trial, they moved to suppress the evidence contending that the officers used the traffic violation as a pretext for stopping the truck because they lacked either reasonable suspicion or probable cause to stop them on suspicion of drug dealing. The District Court denied the motion to suppress and convicted the petitioners. The Court of Appeals affirmed. The Supreme Court granted certiorari.

Question

Did the officers conduct an unreasonable search and seizure in violation of the Fourth Amendment?

Conclusion

Decision: 9 votes for United States, 0 vote(s) against
Legal provision: Amendment 4: Fourth Amendment

No. The unanimous Court held that as long as officers have a reasonable cause to believe that a traffic violation occurred, they may stop any vehicle. In the present case, the officers had reasonable cause to stop the petitioners for a traffic violation since they sped away from a stop sign at an 'unreasonable speed' and without using their turn signal. Thus, since an actual traffic violation occurred, the ensuing search and seizure of the offending vehicle was reasonable, regardless of what other personal motivations the officers might have had for stopping the vehicle. Furthermore, the Court rejected the claim that the anxiety, confusion, and haste which the petitioners experienced from the stop-and-search outweighed the government's interest in traffic safety. While the Fourth Amendment does require a balancing test between a search-and-seizure's benefits and the harm it might cause to the individual, such a test only applies to unusually harmful searches and seizures. There was nothing unusually harmful about this traffic stop.

Wisconsin v. New York

Wed, 10 Jan 1996 13:00:00 +0000

Case Basics

Docket No.

94-1614

Petitioner

Wisconsin

Respondent

New York

Consolidation

No. 94-1631

No. 94-1985

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

517 U.S. 1 (1996)

Argued

Wednesday, January 10, 1996

Decided

Wednesday, March 20, 1996

Advocates

Robert S. Rifkind (Argued the cause for the respondents)

James E. Doyle (Argued the cause for the state petitioners)

Drew S. Days, III (Argued the cause on behalf of the federal petitioners)

Facts of the Case

Under the Constitution's Census Clause, Congress is vested with the responsibility of conducting an "actual enumeration" of the American public every ten years, primarily for the purpose of aportioning congressional representation among the states. Congress delegated this responsibility to the Secretary of Commerce who, in the 1990 census, decided not to use a statistical correction, known as the post-enumeration survey (PES), to adjust an undercount in the initial population count. Acting on behalf of several citizens' groups, states, and cities, Wisconsin challenged the Secretary's decision not to use the PES; claiming that it resulted in an undercounting of certain identifiable minority groups.

Question

Did the decision of the Secretary of Commerce not to use the PES in the 1990 census violate the constitutional right of certain minorities to be counted?

Conclusion

Decision: 9 votes for Wisconsin, 0 vote(s) against
Legal provision: Article 1, Section 2, Paragraph 3: Apportionment of Representatives

No. The Court held that the decision not to use the PES-based statistical correction would not be reviewed under a strict scrutiny standard of "one person - one vote" because there was no showing of intentional discrimination by the Secretary of Commerce. The Secretary's decision was consistent with past census practices in which the promotion of distributive accuracy, rather than numerical accuracy, was the primary objective. This is because errors in numerical accuracy are less likely than errors in distributive accuracy to impact on the apportionment of representatives among the states. Moreover, the Court added that significant deference - regarding how best to conduct the census - must be accorded to the Secretary since he directly received such latitude from Congress which, in turn, received such latitude from the Constitution.

Ornelas v. United States

Tue, 26 Mar 1996 13:00:00 +0000

Case Basics

Docket No.

95-5257

Petitioner

Ornelas

Petitioner Type

Petitioner

Respondent

United States

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

517 U.S. 690 (1996)

Argued

Tuesday, March 26, 1996

Decided

Tuesday, May 28, 1996

Advocates

Peter D. Isakoff (By invitation of the Court as amicus curiae, argued the cause in support of the judgment below)

Cornelia T. L. Pillard (Argued the cause on behalf of the United States)

Robert G. LeBell (Argued the cause for the petitioners)

Facts of the Case

Saul Ornelas and Ismael Ornelas-Ledesma were arrested in Wisconsin after suspicious activity led to the discovery of cocaine in the defendants' car. In a motion to suppress the evidence, the defendants alleged that their Fourth and Fourteenth Amendment rights were violated in their detainment and in the police search of the car. The District Court denied the motion and the defendants pleaded guilty. The Court of Appeals ultimately affirmed the District Court but for different reasons.

Question

Should courts use a de novo standard in determining if a police search conducted without a warrant was based on reasonable suspicion and probable cause?

Conclusion

Decision: 8 votes for Ornelas, 1 vote(s) against
Legal provision: Amendment 4: Fourth Amendment

Yes. In an 8-1 decision, announced by Chief Justice William H. Rehnquist, the Court held "[t]he ultimate questions of reasonable suspicion and probable cause to make a warrantless search should be reviewed de novo." The principle details in such a review should be an analysis of events leading up to the search and the objective review of the search.

Commissioner v. Lundy

Mon, 06 Nov 1995 13:00:00 +0000

Case Basics

Docket No.

94-1785

Petitioner

Commissioner

Petitioner Type

Petitioner

Respondent

Lundy

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

516 U.S. 235 (1996)

Argued

Monday, November 6, 1995

Decided

Wednesday, January 17, 1996

Advocates

Glenn P. Schwartz (Argued the cause for the respondent)

Kent L. Jones (Department of Justice, argued the cause for the petitioner)

Facts of the Case

During 1987, Robert F. Lundy and his wife had $10,131 in federal income taxes withheld from their wages. This amount was substantially more than what the Lundys owed in taxes that year, but they did not file their 1987 tax return when it was due, nor did they file a return or claim a refund of the overpaid taxes in the following 2 1/2 years. In 1990, the Commissioner of Internal Revenue mailed Lundy a notice of deficiency for 1987. Subsequently, the Lundys filed their joint 1987 tax return, which claimed a refund of their overpaid taxes. Lundy also filed a petition in the Tax Court seeking a redetermination of the claimed deficiency and a refund. The Commissioner contended that the Tax Court lacked jurisdiction to award Lundy a refund, arguing that if a taxpayer does not file a tax return before the IRS mails the taxpayer a notice of deficiency, the Tax Court can only award the taxpayer a refund of taxes paid within two years prior to the date the notice of deficiency was mailed. The Tax Court agreed, finding also that 2-year "look-back" period applies. In reversing, the Court of Appeals found that the applicable look-back period in these circumstances is three years and that the Tax Court had jurisdiction to award a refund.

Question

Can the Tax Court award a refund of taxes paid more than two years prior to the date on which the Commissioner of Internal Revenue mailed the taxpayer a notice of deficiency, when, on the date the notice of deficiency was mailed, the taxpayer had not yet filed a return?

Conclusion

Decision: 7 votes for Commissioner, 2 vote(s) against
Legal provision: Internal Revenue Code

No. In a 7-2 opinion delivered by Justice Sandra Day O'Connor, the Court held that in these circumstances a 2-year look-back period applies and the Tax Court lacks jurisdiction to award a refund. Finding that the Tax Court properly applied the 2-year look-back period to Lundy's case, Justice O'Connor noted that Lundy's taxes were withheld from his wages such that they were deemed paid on the date his 1987 tax return was due, which is more than two years prior to the date the notice of deficiency was mailed. The Lundy was thus seeking a refund of taxes paid outside the applicable look-back period. Justices John Paul Stevens and Clarence Thomas filed dissents.

Shaw v. Hunt

Tue, 05 Dec 1995 13:00:00 +0000

Location

North Carolina General Assembly

16 West Jones Street Raleigh NC 27601

Raleigh, NC 27601

United States

35° 46' 59.5704" N, 78° 38' 20.202" W

See map: Google Maps

Case Basics

Docket No.

94-923

Appellee

Hunt

Petitioner Type

Appellee

Appellant

Shaw

Respondent Type

Appellant

Consolidation

Pope et al. v. Hunt, Governor of North Carolina, et al., No. 94-924

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

517 U.S. 899 (1996)

Argued

Tuesday, December 5, 1995

Decided

Thursday, June 13, 1996

Advocates

Robinson O. Everett (Argued the cause for the appellants in Shaw v. Hunt)

Julius LeVonne Chambers (on behalf of Appellees Gingles, et al)

Paul Bender (Argued the cause for the United States as amicus curiae urging affirmance)

Edwin M. Speas, Jr. (Argued the cause for appellees Hunt et al. in both cases)

Thomas A. Farr (Argued the cause for the appellants in Pope v. Hunt)

Facts of the Case

Residents of North Carolina challenged a plan to create two congressional districts on the ground that the proposed districts were racially gerrymandered. On initial review, a three-judge District Court panel dismissed the action only to have its decision reversed and remanded to it by the Supreme Court. However, the Court's standard for review left very little room for racial engineering of congressional voting districts. On remand, the District Court found the redistricting plans to be racially tailored and, therefore, unconstitutional. Again, the matter was appealed to the Supreme Court.

Question

Does North Carolina's redistricting plan constitute racial gerrymandering in violation of the Fourteenth Amendment's equal protection clause?

Conclusion

Decision: 5 votes for Shaw, 4 vote(s) against
Legal provision: Equal Protection

Yes. In a 5-to-4 opinion by Chief Justice Rehnquist, the Court first confronted the threshold question of "standing." It held that some of the appellants lacked proper standing to challenge the redistricting plan. Only those voters who resided in a congressional district alleged to have been created by racial gerrymandering had proper standing to challenge the constitutionality of that district's creation. Those voters who did not reside in one of the two allegedly racially gerrymandered districts, and who failed to provide evidence that they were assigned to their district of residence on the basis of race, lacked proper standing to participate in the racial gerrymandering claim. After noting the challenged district's unusually non- compact serpentine shape, and the appellants' admission that the districts' were primarily designed to create black voting majorities, the Court applied "strict scrutiny" to the facts at hand. Finding no narrowly tailored plans aimed at serving a compelling state interest that would justify the creation of racially gerrymandered districts, the Court concluded that the redistricting plans violated the Fourteenth Amendment's equal protection clause.

Quackenbush v. Allstate Insurance

Tue, 20 Feb 1996 13:00:00 +0000

Case Basics

Docket No.

95-244

Petitioner

Quackenbush

Petitioner Type

Petitioner

Respondent

Allstate Insurance

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

517 U.S. 706 (1996)

Argued

Tuesday, February 20, 1996

Decided

Monday, June 3, 1996

Advocates

Karl L. Rubinstein (Argued the cause for the petitioner)

Donald Francis Donovan (Argued the cause for the respondent)

Facts of the Case

The California Insurance Commissioner filed a state court action against Allstate Insurance Co. seeking damages for Allstate's alleged breach of reinsurance agreements in an effort to gather the assets of the defunct Mission Insurance companies. Allstate removed the action to federal court on diversity grounds and filed a motion to compel arbitration under the Federal Arbitration Act. The Commissioner sought to remand the case to state court, arguing that the court should abstain from hearing the case, under Burford v. Sun Oil Co., because its resolution might interfere with California's regulation of insurance insolvencies and liquidations. The District Court agreed, concluded that an abstention was appropriate, and remanded the case to state court without ruling on Allstate's arbitration motion. After determining the appealability of the District Court's remand order, the Court of Appeals vacated the decision and ordered the case sent to arbitration. The court held that abstention was inappropriate in this damages action because a Burford abstention is limited to equitable actions.

Question

Is an abstention-based remand order appealable as a final order? Can the abstention doctrine recognized in Burford v. Sun Oil Co. be applied in a suit for damages?

Conclusion

Decision: 9 votes for Allstate Insurance, 0 vote(s) against
Legal provision: 28 U.S.C. 1291

Yes and no. In a unanimous opinion delivered by Justice Sandra Day O'Connor, the Court held that an abstention-based remand order is appealable because the "remand order here falls within that narrow class of collateral orders that are immediately appealable." Further, the Court held that the "federal courts have the power to dismiss or remand cases based on abstention principles only where the relief sought is equitable or otherwise discretionary," and because "this was a damages action, the District Court's remand order was an unwarranted application of the Burford doctrine." Justices Antonin Scalia and Anthony M. Kennedy wrote concurring opinions.

Denver Area Consortium v. FCC

Wed, 21 Feb 1996 13:00:00 +0000

Location

Denver Area Consortium

4877 Knox Ct. Denver CO 80221

Denver, CO 80221

United States

39° 47' 6.7272" N, 105° 1' 57.1116" W

See map: Google Maps

Case Basics

Docket No.

95-124

Petitioner

Denver Area Consortium

Petitioner Type

Petitioner

Respondent

FCC

Respondent Type

Respondent

Consolidation

No. 95-227

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

518 U.S. 727 (1996)

Argued

Wednesday, February 21, 1996

Decided

Friday, June 28, 1996

Advocates

J. Michael Greenberger (Argued the cause for the petitioners)

Lawrence G. Wallace (Argued the cause for the respondents)

Facts of the Case

Sections 10(a) and 10(c) of the 1992 Cable Television Consumer Protection and Competition Act (the Act) empower leased access channel cable operators to control programming that they believe is indecent and obscene. Section 10(b) of the Act requires public access channel cable operators to restrict "patently offensive" programming to a single channel, access to which must be restricted to those subscribers who submit written requests. Petitioners, television access programmers and cable television viewers, filed suit alleging that the Act's empowerments and restrictions violated their First Amendment right to freedom of speech. This case was consolidated with Alliance for Community Media v. FCC.

Question

Do the Television Consumer Protection and Competition Act's empowerments and restrictions violate the petitioner's First Amendment right to freedom of speech?

Conclusion

Decision: 7 votes for FCC, 2 vote(s) against
Legal provision: 47 U.S.C. 532

Split Vote

No and yes. In a 6-to-3 decision, The Court held that the Act's grant of authority to leased channel cable operators under 10(a) - allowing them to restrict the transmission of "patently offensive" or indecent programming - is consistent with the First Amendment. The authority's discretionary nature and ultimate objective of protecting young viewers from offensive programming, is a constitutionally permissible method of restoring editorial authority to cable operators. By contrast, the Court found provision 10(c), permitting cable operators to ban offensive or indecent programming on public access channels, to be unconstitutional. Public access channels are already supervised by both private and public elements and have never been edited by cable operators in the past. Furthermore, a "cable operator's veto" is likely to ban many programs that should have been aired, and the volume of "patently offensive" programming on public access channels has never been so high as to warrant severe restrictions on its content. Finally, with respect to Section 10(b), the Court held that its "segregate and block" requirements for public access channels is also unconstitutional. Section 10(b), by enabling cable operators to take as many as 30 days to respond to a consumer's request to unlock their restricted channel, is overly restrictive. Also, by blocking out an entire channel, 10(b) does not permit viewers or operators to discern between offensive and "patently offensive" programming.

O'Connor v. Consolidated Coin Caterers Corp.

Tue, 27 Feb 1996 13:00:00 +0000

Location

Consolidated Coin Caterers Corp.

1828 S Main St Salisbury NC 28144

Salisbury, NC 28144

United States

35° 39' 17.4492" N, 80° 29' 35.2248" W

See map: Google Maps

Case Basics

Docket No.

95-354

Petitioner

O'Connor

Petitioner Type

Petitioner

Respondent

Consolidated Coin Caterers Corp.

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

517 U.S. 308 (1996)

Argued

Tuesday, February 27, 1996

Decided

Monday, April 1, 1996

Advocates

James B. Spears (Argued the cause for the respondent)

George Daly (Argued the cause for the petitioner)

Paul R. Q. Wolfson (On behalf of the United States, as amicus curiae, supporting the petitioner)

Facts of the Case

James O'Connor, 56, was fired by Consolidated Coin Caterers Corp. and replaced by a 40-year-old worker. O'Connor filed suit alleging that his discharge violated the Age Discrimination in Employment Act of 1967 (ADEA). The District Court granted Consolidated's summary judgment motion. In affirming, the Court of Appeals held that O'Connor failed to make out a prima facie case of age discrimination because he failed to show that he was replaced by someone outside the age group protected by the ADEA since his replacement was 40 years old.

Question

Can an employee file an age discrimination suit under the Age Discrimination in Employment Act of 1967 if his or her replacement is 40 or older?

Conclusion

Decision: 9 votes for O'Connor, 0 vote(s) against
Legal provision: Age Discrimination in Employment (ADEA)

Yes. In a unanimous decision, authored by Justice Antonin Scalia, the Court ruled that although the Age Discrimination in Employment Act of 1967 limits its protection to those who are 40 or older, it prohibits discrimination against those protected employees on the basis of age, not class membership. "That one member of the protected class lost out to another member is irrelevant, so long as he lost out because of his age. The latter is more reliably indicated by the fact that his replacement was substantially younger," wrote Justice Scalia.

Holly Farms Corp. v. National Labor Relations Board

Wed, 21 Feb 1996 13:00:00 +0000

Case Basics

Docket No.

95-210

Petitioner

Holly Farms Corp.

Petitioner Type

Petitioner

Respondent

National Labor Relations Board

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

517 U.S. 392 (1996)

Argued

Wednesday, February 21, 1996

Decided

Tuesday, April 23, 1996

Advocates

Charles P. Roberts, III (Argued the cause for the petitioners)

Richard H. Seamon (Department of Justice, argued the cause for the respondents)

Facts of the Case

Holly Farms Corporation, a wholly owned subsidiary of Tyson Foods, Inc., is a vertically integrated poultry producer. In 1989, the Chauffeurs, Teamsters and Helpers, Local 391, filed a representation petition with the National Labor Relations Board, seeking an election in a proposed unit that included live- haul employees working out of Holly Farms' Wilkesboro processing plant. The unit included workers described as "live-haul" crews, or teams of chicken catchers, forklift operators, and truckdrivers, who collect for slaughter chickens raised as broilers by independent contract growers, and transport the birds to the processing plant. Classifying the live-haul workers as employees protected by the National Labor Relations Act, rather than agricultural laborers excluded from the Act's coverage, the Board approved the bargaining unit. On petition for review, the Court of Appeals enforced the Board's order, holding that the Board's classification rested on a reasonable interpretation of the Act and was consistent with the Board's prior decisions.

Question

Did the National Labor Relations Board correctly classify chicken catchers as employees, and not as exempt agricultural workers, for purposes of the National Labor Relations Act?

Conclusion

Decision: 5 votes for National Labor Relations Board, 4 vote(s) against
Legal provision: National Labor Relations, as amended

Yes. In a 5-4 opinion delivered by Justice Ruth Bader Ginsburg, the Court held that the NLRB's determination that the producer's live-haul workers were covered employees rather than exempt agricultural laborers, was a reasonable interpretation to which a reviewing court properly deferred. The Court was also split 5-4 in upholding the Board's classification for forklift operators who work in the chicken industry. In a 9-0 vote, the Court upheld the Board's classification for the live-haul crew's truck drivers.

Brown v. Pro Football Inc.

Wed, 27 Mar 1996 13:00:00 +0000

Case Basics

Docket No.

95-388

Petitioner

Brown

Respondent

Pro Football Inc.

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

518 U.S. 231 (1996)

Argued

Wednesday, March 27, 1996

Decided

Thursday, June 20, 1996

Advocates

Kenneth W. Starr (Argued the cause for the petitioners)

Gregg H. Levy (Argued the cause for the respondents)

Lawrence G. Wallace (On behalf of the United States, as amicus curiae, supporting the petitioners)

Facts of the Case

After their collective-bargaining agreement expired, the National Football League (NFL) -- a group of football clubs -- and the NFL Players Association -- a labor union -- began to negotiate a new contract. The NFL presented a plan that would permit each club to establish a "developmental squad" of substitute players, each of whom would be paid the same $1,000 weekly salary. The union disagreed. When the negotiations reached an impasse, the NFL unilaterally implemented the plan. A number of squad players brought an antitrust suit, claiming that the employers' plan unfairly restrained trade. The District Court awarded damages to the players, but the Court of Appeals reversed that decision.

Question

Are several employers immune from a union anti-trust suit when these employers, bargaining together, unilaterally impose terms on the union if the collective bargaining process reaches an impasse?

Conclusion

Decision: 8 votes for Pro Football Inc., 1 vote(s) against
Legal provision:

Yes. In affirming the Court of Appeals decision, the Supreme Court held that federal labor laws protect professional football franchises from anti-trust actions brought by their players when those franchises unilaterally impose terms after the collective bargaining process breaks down. Labor laws stabilize, encourage, and protect the collective bargaining process. When that process breaks down, labor laws provide adequate remedies. Employee suits under the Sherman Anti-Trust Act, by contrast, might undermine the integrity of collective bargaining and preempt unnecessarily the labor laws.

Jaffee v. Redmond

Mon, 26 Feb 1996 13:00:00 +0000

Case Basics

Docket No.

95-266

Petitioner

Jaffee

Petitioner Type

Petitioner

Respondent

Redmond

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

518 U.S. 1 (1996)

Argued

Monday, February 26, 1996

Decided

Thursday, June 13, 1996

Advocates

Gregory E. Rogus (Argued the cause for the respondents)

Kenneth N. Flaxman (Argued the cause for the petitioner)

James A. Feldman (On behalf of the United States, as amicus curiae, support the respondents)

Facts of the Case

Mary Lu Redmond, a former police officer, received extensive counseling from a licensed clinical social worker after she shot and killed Ricky Allen. Carrie Jaffee, special administrator for Allen, filed suit in federal District Court alleging that Redmond had violated Allen's constitutional rights by using excessive force in the encounter. During the trial, Jaffee sought access to the notes from Redmond's counseling. Redmond's counsel resisted asserting the conversations were protected against involuntary disclosure by a psychotherapist-patient privilege. The District Court judge rejected the argument, but the notes were not released. The judge instructed the jury that they could presume that the contents could have been unfavorable to Redmond. The jury awarded monetary damages. The Court of Appeals reversed the decision. It found that Federal Rule of Evidence 501 prompted the recognition of a psychotherapist-patient privilege.

Question

Can psychotherapists be forced to provide evidence about their patients in federal court cases?

Conclusion

Decision: 7 votes for Redmond, 2 vote(s) against
Legal provision: Federal Rules of Evidence

No. In a 7-2 decision, announced by Justice John Paul Stevens, the Court ruled that Federal Rule of Evidence 501 protects the conversations between Redmond and her therapist from compelled disclosure. The Rule recognizes a "psychotherapist-patient privilege."

Morse v. Republican Party Of Virginia

Mon, 02 Oct 1995 13:00:00 +0000

Case Basics

Docket No.

94-203

Appellee

Republican Party Of Virginia

Petitioner Type

Appellee

Appellant

Morse

Respondent Type

Appellant

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

517 U.S. 186 (1996)

Argued

Monday, October 2, 1995

Decided

Wednesday, March 27, 1996

Advocates

Paul Bender (Department of Justice, argued the cause for the United States, as amicus curiae, supporting the appellants)

Pamela S. Karlan (Argued the cause for the appellants)

E. Duncan Getchell, Jr. (Argued the cause for the appellees)

Facts of the Case

In 1994, the Republican Party of Virginia held a state convention to nominate the Republican candidate for United States Senator. A local political committee could certify any voter as a delegate to the convention by paying a registration fee of $35 or $45. Fortis Morse, Kenneth Curtis Bartholomew, and Kimberly J. Enderson, registered voters in Virginia willing to declare their intent to support the Party's nominee, were eligible to participate. Bartholomew and Enderson refused to pay the fee and did not become delegates. Morse paid the fee with funds advanced by supporters of the eventual nominee. Moore and others then filed a complaint seeking an injunction preventing the Party from imposing the fee, alleging that that the imposition of the fee violated sections 5 and 10 of the Voting Rights Act of 1965. Ultimately, the District Court dismissed the claims.

Question

Does section 5 of the Voting Rights Act of 1965 require preclearance of the Republican Party of Virginia's decision to exact a fee to nominate the party's candidate for senator? Are voters permitted to challenge the fee as a poll tax prohibited by section 10?

Conclusion

Decision: 5 votes for Morse, 4 vote(s) against
Legal provision: Voting Rights Act of 1965

Yes and yes. In a 5-4 plurality opinion delivered by Justice John Paul Stevens, five Justices of the Court, although unable to agree on an opinion, agreed that the party's imposition of the registration fee was subject to the preclearance requirements of section 5 and that a private right of action existed to enforce section 10. "By limiting the opportunity for voters to participate in the Party's convention, the fee undercuts their influence on the field of candidates whose names will appear on the ballot, and thus weakens the 'effectiveness' of their votes cast in the general election itself," wrote Justice Stevens for the Court. Justice Stephen G. Breyer filed an opinion concurring in the opinion, in which Justice Sandra Day O'Connor and David H. Souter joined. Chief Justice William H. Rehnquist and Justices Antonin Scalia and Anthony M. Kennedy filed separate dissents. Each emphasized First Amendment concerns.

Bush v. Vera

Tue, 05 Dec 1995 13:00:00 +0000

Location

Texas General Assembly

1100 Congress Avenue Austin TX 78701

Austin, TX 78701

United States

30° 16' 21.882" N, 97° 44' 28.0752" W

See map: Google Maps

Case Basics

Docket No.

94-805

Petitioner

Vera

Respondent

Bush

Consolidation

Lawson et al. v. Vera et al., No. 94-806

United States v. Vera et al., No. 94-988

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

517 U.S. 952 (1996)

Argued

Tuesday, December 5, 1995

Decided

Thursday, June 13, 1996

Advocates

Paul Bender (Argued the cause for the United States in United States v. Vera)

Daniel E. Troy (Argued the cause for the appellees in all cases)

Penda D. Hair (Argued the cause for the appellants in Lawson v. Vera)

Javier Aguilar (Argued the cause for the appellants in Bush v. Vera)

Facts of the Case

Following the 1990 census, Texas planned the creation of three additional congressional districts. Following the redistricting, registered voters challenged the plans as racial gerrymandering. A three-judge federal district court found the plans unconstitutional. The case moved to the Supreme Court on appeal.

Question

Do the Texas redistricting plans violate the Equal Protection Clause of the Fourteenth Amendment?

Conclusion

Decision: 5 votes for Vera, 4 vote(s) against
Legal provision: Equal Protection

Yes. In a 5-to-4 decision, the Court held that the Texas redistricting plans were unconstitutional. Supporting its "strict scrutiny" approach, the Court noted that the proposed districts were highly irregular in shape, that their computerized design was significantly more sensitive to racial data, and that they lacked any semblance to pre-existing race-neutral districts. The Court also held that the totality of the circumstances surrounding the proposed districts would deprive minority groups of equal participation in the electoral political processes. Thus, the proposed districts violated the Voting Rights Act's "results" test prohibiting activity that "results in a denial or abridgment of the right of any citizen to vote on account of race or color." Finally, with respect to proposed district 18, the Court held that Texas deliberately designed it to hamper the local African-American minority's ability to elect representatives of their choice. This violated the Voting Rights Act's "nonretrogression" principle, prohibiting state action from obstructing a minority's ability to elect representatives of their choice.

Bank One Chicago, N. A. v. Midwest Bank & Trust Co.

Tue, 28 Nov 1995 13:00:00 +0000

Case Basics

Docket No.

94-1175

Petitioner

Bank One Chicago, N. A.

Petitioner Type

Petitioner

Respondent

Midwest Bank & Trust Co.

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

516 U.S. 264 (1996)

Argued

Tuesday, November 28, 1995

Decided

Wednesday, January 17, 1996

Advocates

Robert G. Epsteen (Argued the cause for the respondent)

Jeffrey P. Minear (Argued the cause for the United States as amicus curiae, supporting the petitioner, urging reversal)

Robert A. Long, Jr. (Argued the cause for the petitioner)

Facts of the Case

The Expedited Funds Availability Act requires banks to make deposited funds available for withdrawal within specified time periods. The act provides for administrative enforcement and civil liability. After a BankOne Chicago customer deposited a check drawn on a Midwest Bank and Trust account, the check was forwarded, but returned unpaid because BankOne's endorsement stamp was illegible. Subsequently, when the check was resubmitted, the account did not have sufficient funds to cover the withdrawal. Bank One then sued Midwest Bank for failing to meet its obligations prescribed by the Board of Governors of the Federal Reserve System (Board) pursuant to the act. The District Court entered summary judgment for BankOne. The Court of Appeals, vacating the lower court's decision, ordered the action dismissed for lack of subject-matter jurisdiction. The appellate court held that the act authorizes original federal-court jurisdiction only when a "person other than [a] depository institution" sues a "depository institution," or when a depositor sues a bank.

Question

Does the Expedited Funds Availability Act provide for federal-court jurisdiction only in suits between customers and banks?

Conclusion

Decision: 9 votes for Bank One Chicago, N. A., 0 vote(s) against
Legal provision: 12 U.S.C. 4010

No. In an opinion delivered by Justice Ruth Bader Ginsburg, the Court held that the act provides for federal-court jurisdiction not only in suits between customers and banks, but also in cases initiated by one bank against another bank. Justice Ginsburg wrote for the Court that section 4010 of the act authorizes claims for relief that are enforceable in federal court. Moreover, Justice Ginsburg continued, "it is implausible that Congress directed the Board to handle such disputes administratively, for [section 4010] does not explicitly confer adjudicatory authority on the Board, nor set forth the relevant procedures for resolution of private disputes." Justices John Paul Stevens and Antonin Scalia wrote concurring opinions.

Koon v. United States

Tue, 20 Feb 1996 13:00:00 +0000

Case Basics

Docket No.

94-1664

Petitioner

Koon

Petitioner Type

Petitioner

Respondent

United States

Respondent Type

Respondent

Consolidation

Powell v. United States, No. 94-8842

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

518 U.S. 81 (1996)

Argued

Tuesday, February 20, 1996

Decided

Thursday, June 13, 1996

Advocates

William J. Kopeny (Argued the cause for petitioner Powell)

Theodore B. Olson (Argued the cause for petitioner Koon)

Michael R. Dreeben (Argued the cause for the respondent)

Facts of the Case

Petitioners Stacey C. Koon and Laurence M. Powell, Los Angeles police officers, were acquitted on state charges of assault and excessive use of force in the beating of Rodney King during an arrest. They were convicted under 18 U. S. C. Section 242 of violating the victim's constitutional rights under color of law. Although the applicable U.S. Sentencing Guideline, 1992 USSG Section 2H1.4, indicated that they should be imprisoned for 70 to 87 months, the District Court granted them two downward departures from that range. The first was based on the victim's misconduct, which significantly contributed to provoking the offense. The second was based on a combination of four factors: (1) that the petitioners were unusually susceptible to abuse in prison; (2) that the petitioners would lose their jobs and be precluded from employment in law enforcement; (3) that the petitioners had been subject to successive state and federal prosecutions; and (4) that the petitioners posed a low risk of recidivism. The sentencing range after the departures was 30 to 37 months, and the court sentenced each petitioner to 30 months. The Court of Appeals reviewed the departure decisions utilizing a de novo standard and rejected all of them.

Question

Did the Court of Appeals use the wrong standard in deciding whether a federal trial judge had erred in departing from the federal Sentencing Guidelines and giving lighter sentences to two ex-policemen convicted in the beating of Rodney King?

Conclusion

Decision: 5 votes for Koon, 4 vote(s) against
Legal provision: 18 U.S.C. App.

Yes. In an opinion delivered by Justice Anthony Kennedy, the Court held that the Court of Appeals should not review de novo a decision to depart from the Guideline sentencing range, but instead should ask whether the sentencing court abused its discretion. Furthermore, because the Court of Appeals erred in rejecting certain of the downward departure factors relied upon by the District Judge, wrote Justice Kennedy, significant parts of the appellate court's rulings require reversal.

BMW v. Gore

Wed, 11 Oct 1995 13:00:00 +0000

Location

10th Judicial Circuit Court - Jefferson

"716 Richard Arrington**** Jr.**** Boulevard North" Birmingham AL 35203

Birmingham, AL 35203

United States

33° 31' 16.8996" N, 86° 48' 32.2632" W

See map: Google Maps

Case Basics

Docket No.

94-896

Petitioner

BMW

Petitioner Type

Petitioner

Respondent

Gore

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

517 U.S. 559 (1996)

Argued

Wednesday, October 11, 1995

Decided

Monday, May 20, 1996

Advocates

Andrew L. Frey (Argued the cause for the petitioner)

Michael H. Gottesman (Argued the cause for the respondent)

Facts of the Case

After purchasing a new vehicle from an authorized Alabama BMW dealership, Ira Gore, Jr. discovered that his new vehicle had been repainted. He sued BMW's American distributor (BMW), alleging that it committed fraud by failing to inform him that his car had been repainted. The Alabama Circuit Court entered judgment, following a jury verdict, awarding Gore $4,000 in compensatory damages and $4 million in punitive damages. On appeal from the trial judge's denial of BMW's post-trial petition to set aside the punitive damages as 'grossly excessive,' the Alabama Supreme Court ruled that the punitive damages were not so excessive as to violate BMW's Fourteenth Amendment right to due process. Due to a jury calculation error, however, the Alabama Supreme Court reduced Gore's punitive damage award to $2 million. BMW appealed to the Supreme Court.

Question

Assuming that Gore's punitive damage award was grossly excessive, does the Fourteenth Amendment's due process clause protect BMW from paying the award?

Conclusion

Decision: 5 votes for BMW, 4 vote(s) against
Legal provision: Due Process

Yes. In a 5-to-4 decision, the Court held that while a state may impose punitive damages to further its interest in deterring unlawful conduct, the Fourteenth Amendment's due process clause prohibits states from imposing grossly excessive punishments on tort-feasors. In the present case, the punitive damage's excessive nature is indicated by the 500 to 1 ratio between the jury's punitive and actual damage awards, the relatively insignificant amount of damage, and the lack of statutory fines that remotely parallel the present award's magnitude. BMW's due process rights were also violated because it could not have possibly anticipated, nor did it receive fair notice, that it might face such a severe punishment.

Richards v. Jefferson County

Tue, 26 Mar 1996 13:00:00 +0000

Case Basics

Docket No.

95-386

Petitioner

Richards

Petitioner Type

Petitioner

Respondent

Jefferson County

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

517 U.S. 793 (1996)

Argued

Tuesday, March 26, 1996

Decided

Monday, June 10, 1996

Advocates

William J. Baxley (Argued the cause for the petitioners)

William M. Slaughter (Argued the cause for the respondents)

Facts of the Case

Jason Richards and others, who are privately employed in Jefferson County, filed a state court class action suit claiming that the county's occupation tax violates the Federal and Alabama Constitutions. The Alabama trial court found that their state claims were barred by a prior adjudication, Bedingfield v. Jefferson County. The unsuccessful Bedingfield adjudication of the tax was brought by Birmingham's acting finance director and the city itself, consolidated with a suit by three county taxpayers. However, the court found that their federal claims had not been decided in that case. On appeal, the county argued that the federal claims were also barred. The State Supreme Court agreed, concluding that the doctrine of res judicata applied because Richard and others were adequately represented in the Bedingfield action.

Question

May the Alabama residents, who claim that the Jefferson County occupation tax violates the Federal and Alabama Constitutions, proceed with their class action suit in court in light of a prior, similar adjudication?

Conclusion

Decision: 9 votes for Richards, 0 vote(s) against
Legal provision: Due Process

Yes. In a unanimous decision, authored by Justice John Paul Stevens, the Court ruled that because Richards and others received neither notice of, nor sufficient representation in, the Bedingfield litigation, that adjudication, as a matter of federal due process, may not bind them and thus cannot bar them from challenging an allegedly unconstitutional deprivation of their property.

Colorado Rep Fed Campaign Comm v. FEC

Mon, 15 Apr 1996 13:00:00 +0000

Location

Colorado Republican Party

5950 S. Willow Drive Greenwood Village CO 80111

Greenwood Village, CO 80111

United States

39° 36' 30.942" N, 104° 53' 21.696" W

See map: Google Maps

Case Basics

Docket No.

95-489

Petitioner

Colorado Rep Fed Campaign Comm

Petitioner Type

Petitioner

Respondent

FEC

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

518 U.S. 604 (1996)

Argued

Monday, April 15, 1996

Decided

Wednesday, June 26, 1996

Advocates

Jan W. Baran (Argued the cause for the petitioners)

Drew S. Days, III (Argued the cause for the respondent)

Facts of the Case

Before the Colorado Republican Party selected its 1986 senatorial candidate, its Federal Campaign Committee bought radio advertisements attacking the Democratic Party's likely candidate. The Federal Election Commission (FEC) brought suit charging that the Colorado Republican Federal Campaign Committee had violated the "Party Expenditure Provision" of the Federal Election Campaign Act of 1971 (FECA), which imposes dollar limits upon political party "expenditure[s] in connection with the general election campaign of a [congressional] candidate." The Colorado Party defended itself by claiming that the FECA expenditure limitations violated the First Amendment as applied to its advertisements, and filed a counterclaim seeking to raise a challenge to the Provision as a whole. The District Court held that the Provision did not cover the expenditure at issue. Therefore, the court entered summary judgment for the Colorado Party and it dismissed the counterclaim as moot. The Court of Appeals ruled that the Provision covered this expenditure and satisfied the Constitution. Subsequently, the court ordered judgment for the FEC.

Question

Do the federal campaign-financing limits on the amount of money political parties may spend on congressional races, as established by the Federal Election Campaign Act of 1971, violate First Amendment rights when applied to expenditures a political party has made independently of any candidate's campaign?

Conclusion

Decision: 7 votes for Colorado Rep Fed Campaign Comm, 2 vote(s) against
Legal provision: Federal Election Campaign

Yes. In a plurality decision, Justice Stephen G. Breyer announced the judgment of the Court and authored an opinion, in which the Court ruled that the First Amendment prohibits the application of the Party Expenditure Provision of the Federal Election Campaign Act of 1971 (FECA) to the kind of expenditure at issue here-an expenditure that the political party has made independently, without coordination with any candidate. Justices O'Connor and Souter joined Justice Breyer. Justice Kennedy, joined by Chief Justice Rehnquist and Justice Scalia, concluded that, on its face, FECA violates the First Amendment when it restricts as a "contribution" a political party's spending "in cooperation, consultation, or concert, with_a candidate." Justice Thomas concluded that the Provision is unconstitutional not only as applied to the Colorado Republican Federal Campaign Committee, but also on its face. Dissenting, Justices Stevens and Ginsburg agreed with the judgment of the Court of Appeals.

Wood v. Bartholomew

Sun, 28 Apr 2013 09:19:18 +0000

Case Basics

Docket No.

94-1419

Petitioner

Wood

Petitioner Type

Petitioner

Respondent

Bartholomew

Respondent Type

Respondent

Decided By

Rehnquist Court (1994-2005)

Opinion

516 U.S. 1 (1995)

Decided

Tuesday, October 10, 1995

Facts of the Case

Dwayne Bartholomew was convicted in a Washington state court of murder during a robbery. Bartholomew admitted the robbery, but claimed the victim was killed accidentally. At trial, Bartholomew's brother Rodney testified that Bartholomew had told them of his robbery plans and his intent to leave no witnesses. The prosecution never disclosed that Rodney's responses to questions about the robbery and murder weapon, during a pretrial polygraph examination, indicated deception. Bartholomew filed for federal habeas, claiming that because the polygraph results were material under Brady v. Maryland, 373 U.S. 83, which provides that under the due process clause of the Fourteenth Amendment a state prosecutor is required to disclose material evidence favorable to an accused, the prosecution's failure to disclose them justified setting aside the conviction. The District Court denied the writ. In reversing, the Court of Appeals concluded that the polygraph results, although inadmissible under Washington law, were material under Brady because they may have given Bartholomew's counsel known of the results a stronger reason to investigate Rodney's story.

Question

Did a Court of Appeals err in concluding, in habeas corpus proceedings, that the prosecution's failure to disclose to the accused the inadmissible results of a polygraph test of a witness violated due process?

Conclusion

Decision: 5 votes for Wood, 0 vote(s) against
Legal provision:

Yes. In a per curiam opinion, the Court held that the Court of Appeals's decision was a misapplication of the Court's Brady jurisprudence. Because evidence is material under Brady and the failure to disclose it justifies setting aside a conviction, only where there exists a reasonable probability that had the evidence been disclosed the result at trial would have been different, the Court reasoned that the polygraph results were not evidence and their disclosure would have had no direct effect on the trial's outcome because Bartholomew could have made no mention of them. Justices John Paul Stevens, David H. Souter, Ruth Bader Ginsburg, and Stephen G. Breyer dissented from the summary disposition of the case.

United States v. Reorganized CF& I Fab. of UT

Mon, 25 Mar 1996 13:00:00 +0000

Case Basics

Docket No.

95-325

Petitioner

United States

Petitioner Type

Petitioner

Respondent

Reorganized CF& I Fab. of UT

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

518 U.S. 213 (1996)

Argued

Monday, March 25, 1996

Decided

Thursday, June 20, 1996

Advocates

Steven Jack McCardell (Argued the cause for the respondents)

Kent L. Jones (Argued the cause for the petitioner)

Facts of the Case

The Employee Retirement Income Security Act of 1974 obligated CF&I; Steel Corporation (CF&I;) to make annual funding contributions to pension plans they sponsored. The required contribution for the 1989 plan totaled $12.4 million. CF&I; failed to make the payment and petitioned the Bankruptcy Court for Chapter 11 reorganization. The Government filed a proof of claim for tax liability arising under the Internal Revenue Code, 26 U.S.C. Section 4971(a), which imposes a 10 percent "tax" on any "accumulated funding deficiency" of plans such as CF&I;'s. The court allowed the claim, but rejected the Government's argument that the claim was entitled to priority as an "excise tax" under the Bankruptcy Code. The Bankruptcy Court also subordinated the Section 4971 claim to those of all other general unsecured creditors under the Bankruptcy Code's provision for equitable subordination. The court later approved a reorganization plan for CF&I; giving lowest priority (and no money) to claims for non-compensatory penalties. The District Court and the Court of Appeals affirmed.

Question

Is the Internal Revenue Code's 10% tax liability claim on any "accumulated funding deficiency" in pension plans an "excise tax" under the Bankruptcy Code? May the Government's tax claims be given a lower priority than competing claims by other creditors in bankruptcy proceedings?

Conclusion

Decision: 9 votes for United States, 0 vote(s) against
Legal provision: Internal Revenue Code

No and no. In an opinion authored by Justice David H. Souter, the Court held that the Internal Revenue Code's 10% tax liability claim on any "accumulated funding deficiency" in pension plans, 26 U.S.C. Section 4971(a), does not create an excise tax under the Bankruptcy Code. Additionally, the Court held that the subordination of the Government's tax claim to those of other creditors was an error.

Lane v. Pena

Mon, 15 Apr 1996 13:00:00 +0000

Case Basics

Docket No.

95-365

Petitioner

Lane

Petitioner Type

Petitioner

Respondent

Pena

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

518 U.S. 187 (1996)

Argued

Monday, April 15, 1996

Decided

Thursday, June 20, 1996

Advocates

Beth S. Brinkmann (Argued the cause for the respondent)

Walter A. Smith, Jr. (Argued the cause for the petitioner)

Facts of the Case

The Department of Transportation expelled Lane, a student, from the U.S. Merchant Marine Academy because he was diagnosed with diabetes. Lane sued the Department of Transportation alleging that his termination violated section 504 of the 1973 Rehabilitation Act, which barred "any program or activity under any executive agency" from discriminating on the basis of disability. The district court reinstated Lane, but refused to award damages because the federal government's sovereign immunity had not been waived by Congress. The appeals court affirmed the district court decision.

Question

Did Congress waive the federal government's sovereign immunity against monetary damages with respect to section 504(a) of the 1973 Rehabilitation Act?

Conclusion

Decision: 7 votes for Pena, 2 vote(s) against
Legal provision: Rehabilitation

No. Although the related provisions of the 1973 Rehabilitation Act and the 1991 Civil Rights Act might in combination be read as waiving the federal government's sovereign immunity, absent an unambiguous waiver of sovereign immunity, the court cannot permit damages to be awarded.

Exxon Co. USA v. Sofec

Tue, 19 Mar 1996 13:00:00 +0000

Case Basics

Docket No.

95-129

Petitioner

Exxon Co. USA

Petitioner Type

Petitioner

Respondent

Sofec

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

517 U.S. 830 (1996)

Argued

Tuesday, March 19, 1996

Decided

Monday, June 10, 1996

Advocates

George W. Playdon (Argued the cause for the respondents)

Shirley M. Hufstedler (Argued the cause for the petitioners)

Facts of the Case

An Exxon oil tanker, the Houston, broke free from a mooring facility under control of the respondents, Sofec, Inc. Exxon filed a complaint alleging negligence and breach of warranty in federal district court. Sofec, Inc. filed a successful motion to bifurcate the trial. The trial court considered whether the conduct of the ship's captain, Coyne, was the "superceding and sole proximate cause of the loss of the ship" after the ship had broken free of the moorings in order to determine if the tanker would have been lost despite Coyne's actions. The cause of the ship's release from the moorings became a secondary issue. The court found Coyne negligent, which was the primary cause of the Houston's grounding and subsequent loss. The Court of Appeals affirmed the decision. Exxon petitioned the U.S. Supreme Court for certiorari.

Question

Does the "superseding cause" doctrine apply to admiralty cases in which the court previously has adopted a comparative fault principle?

Conclusion

Decision: 9 votes for Sofec, 0 vote(s) against
Legal provision:

Yes. In a unanimous opinion written by Justice Clarence Thomas, the Court held that a plaintiff in admiralty that is the superseding cause of its own injury, and thus the sole, proximate cause, cannot recover part of its damages from tort-feasors or contracting partners whose blameworthy actions were causes in fact of the injury.

Louisiana v. Mississippi

Tue, 03 Oct 1995 13:00:00 +0000

Case Basics

Docket No.

121 ORIG

Plaintiff

Louisiana

Petitioner Type

Plaintiff

Defendant

Mississippi et al.

Respondent Type

Defendant

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

516 U.S. 22 (1995)

Argued

Tuesday, October 3, 1995

Decided

Tuesday, October 31, 1995

Advocates

Robert R. Bailess (on behalf of the Defendant Mississippi)

Gary L. Keyser (on behalf of the Plaintiff)

James W. McCartney (on behalf of the Defendant Houston Group)

Facts of the Case

None

Question

None

Conclusion

Decision: 9 votes for Mississippi, 0 vote(s) against
Legal provision:

None

Lotus Development Corporation v. Borland International, Inc.

Mon, 08 Jan 1996 13:00:00 +0000

Case Basics

Docket No.

94-2003

Petitioner

Lotus Development Corporation

Petitioner Type

Petitioner

Respondent

Borland International, Inc.

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

516 U.S. 233 (1996)

Argued

Monday, January 8, 1996

Decided

Tuesday, January 16, 1996

Advocates

Gary L. Reback (on behalf of the Respondent)

Henry B. Gutman (on behalf of the Petitioner)

Facts of the Case

Lotus Development Corporation (Lotus) copyrighted a computer spreadsheet program called Lotus 1-2-3. The program's menu options were arranged in a specific menu command hierarchy. Lotus 1-2-3 also allowed users to write "macros," which designate a certain series of commands to be executed with a single keystroke. Competing software-company Borland International, Inc. (Borland) released a similar program called Quattro that contained a program called "Key Reader." Lotus claimed that Key Reader infringed on its copyright because it copied Lotus 1-2-3 macros and arranged them according to the Lotus 1-2-3 menu command hierarchy. Borland explained that it did this to allow users already familiar with Lotus 1-2-3 to also operate Quattro and argued that the Lotus menu command hierarchy did not constitute copyright-protected material.

After the District Court ruled in favor of Lotus, Borland appealed to the U.S. Court of Appeals for the First Circuit. The First Circuit reversed, holding that the command menu hierarchy was a "method of operation" - a category excluded from copyright protection under 17 U.S.C.102(b).

Question

Is a computer program's menu command hierarchy a "method of operation" under 17 U.S.C.102(b), and therefore uncopyrightable?

Conclusion

Decision: 4 votes for Borland International, Inc., 4 vote(s) against
Legal provision:

Yes. The Supreme Court affirmed the First Circuit without opinion in an equally divided, per curiam decision. Justice John Paul Stevens did not take part in the case.

Field v. Mans

Mon, 02 Oct 1995 13:00:00 +0000

Case Basics

Docket No.

94-967

Petitioner

Field et al.

Petitioner Type

Petitioner

Respondent

Mans

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

516 U.S. 59 (1995)

Argued

Monday, October 2, 1995

Decided

Tuesday, November 28, 1995

Advocates

Christopher J. Seufert (on behalf of the Petitioners)

Alan Jenkins (on behalf of the United States, as amicus curiae, supporting the Petitioners)

W. E. Whittington (on behalf of the Respondent)

Facts of the Case

None

Question

None

Conclusion

Decision: 7 votes for Field, 2 vote(s) against
Legal provision: Bankruptcy Code, Bankruptcy Act or Rules, or Bankruptcy Reform Act of 1978

None

Seminole Tribe v. Florida

Wed, 11 Oct 1995 13:00:00 +0000

Location

Seminole Tribe

6300 Stirling Road Hollywood FL 33024

Hollywood, FL 33024

United States

26° 2' 43.908" N, 80° 13' 47.7084" W

See map: Google Maps

Case Basics

Docket No.

94-12

Petitioner

Seminole Tribe

Petitioner Type

Petitioner

Respondent

Florida

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

517 U.S. 44 (1996)

Argued

Wednesday, October 11, 1995

Decided

Wednesday, March 27, 1996

Advocates

Bruce S. Rogow (on behalf of the Petitioner)

Drew S. Days, III (on behalf of the United States, as amicus curiae, supporting the Petitioner)

Jonathan A. Glogau (on behalf of the Respondents)

Facts of the Case

The Seminole Tribe brought suit against the State of Florida for violating the good faith negotiations requirement of the Indian Gaming Regulatory Act (IGRA). Under the IGRA, the Tribe may engage in gaming (i.e., casino gambling) activities subject to Florida's good faith regulations. Florida moved to dismiss the Tribe's action, alleging that the lawsuit violated Florida's sovereign immunity. On appeal from the District Court's denial of Florida's motion to dismiss the lawsuit, the Court of Appeals reversed, holding that the Eleventh Amendment shielded Florida from federal suit and that under Ex Parte Young, the Tribe may not enforce its right to good faith negotiations by naming Florida's governor as a party to the suit.

Question

Does the Eleventh Amendment provide Florida with immunity from the Tribe lawsuit?

Conclusion

Decision: 5 votes for Florida, 4 vote(s) against
Legal provision: Amendment 11: Eleventh Amendment

Yes. In a 5-to-4 decision, The Court held that Congress did intend to abrogate states' sovereign immunity under the IGRA but that the Indian Commerce Clause (and by implication the Commerce Clause) did not give Congress that power. Under the Eleventh Amendment, all states are regarded as sovereign entities. Such sovereignty inherently implies that states may not be sued by parties without their consent, even if they are given authority to regulate those parties' activities through receipt of federal funds. Finally, Ex Parte Young's ruling does not justify the Tribe's suit against Florida's governor in light of certain IGRA provisions which specifically prohibit such an action.

Thompson v. Keohane, Warden

Wed, 11 Oct 1995 13:00:00 +0000

Case Basics

Docket No.

94-6615

Petitioner

Thompson

Petitioner Type

Petitioner

Respondent

Keohane, Warden, et al.

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

516 U.S. 99 (1995)

Argued

Wednesday, October 11, 1995

Decided

Wednesday, November 29, 1995

Advocates

Cynthia M. Hora (on behalf of the Respondents)

Julie R. O'Sullivan (on behalf of the Petitioner)

Facts of the Case

None

Question

None

Conclusion

Decision: 7 votes for Thompson, 2 vote(s) against
Legal provision: 28 USC 2241-2255 (habeas corpus)

None

Smiley v. Citibank (South Dakota)

Wed, 24 Apr 1996 13:00:00 +0000

Case Basics

Docket No.

95-860

Petitioner

Smiley

Petitioner Type

Petitioner

Respondent

Citibank (South Dakota)

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

517 U.S. 735 (1996)

Argued

Wednesday, April 24, 1996

Decided

Monday, June 3, 1996

Advocates

Richard B. Kendall (Argued the cause for the respondent)

Michael D. Donovan (Argued the cause for the petitioner)

Irving L. Gornstein (Argued the cause for the United States as amicus curiae, supporting the respondent, urging affirmance)

Facts of the Case

Barbara Smiley, a resident of California, possessed credits cards issued by Citibank, a national bank located in South Dakota. Under certain circumstances, Citibank will issue late-payment fees. In 1992, Smiley brought a class action against Citibank on behalf of herself and other California holders of Citibank's credit cards, alleging that the late-payment fees charged by Citibank, although legal under South Dakota law, violated California law. In response, Citibank argued that a provision of the National Bank Act of 1864, which permits a national bank to charge its loan customers "interest at the rate allowed by the laws of the State... where the bank is located," pre-empted Smiley's state law claims. After accepting Citibank's argument that late-payment fees constituted "interest," the California Superior Court ruled in its favor. The California Superior Court Supreme Court affirmed.

Question

Does the National Bank Act of 1864 authorize a national bank to charge late- payment fees that are lawful in the bank's home State but prohibited in the States where the cardholders reside?

Conclusion

Decision: 9 votes for Citibank (South Dakota), 0 vote(s) against
Legal provision: 12 U.S.C. 85

Yes. In a unanimous opinion delivered by Justice Antonin Scalia, the Court held that the National Bank Act of 1864 authorizes such charges because a regulation adopted by the Comptroller of the Currency, which defined interest to include late-payment fees, was a reasonable interpretation of the act and entitled to deference. The Court rejected arguments that late-payment fees do not constitute interest because they do not vary based on the payment owed or the time period of delay and because they are penalties.

Things Remembered, Inc. v. Petrarca

Mon, 02 Oct 1995 13:00:00 +0000

Case Basics

Docket No.

94-1530

Petitioner

Things Remembered, Inc.

Petitioner Type

Petitioner

Respondent

Petrarca

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

516 U.S. 124 (1995)

Argued

Monday, October 2, 1995

Decided

Tuesday, December 5, 1995

Advocates

Steven D. Cundra (Argued the cause for the petitioner)

John C. Weisensell (Argued the cause for the respondent)

Facts of the Case

Anthony Petrarca commenced an action in Ohio state court to collect rent allegedly owed by Child World, Inc. under two commercial leases and to enforce Cole National Corporation's guarantee of Child World's performance under the leases. After Child World filed a Chapter 11 bankruptcy petition, Cole's successor in interest, Things Remembered, Inc., removed the action to federal court under the bankruptcy removal statute and the general federal removal statute. The Bankruptcy Court held that the removal was timely and proper and that it had jurisdiction. The District Court reversed and remanded the case to state court, holding that the removal was untimely and that the Bankruptcy Court lacked jurisdiction. The Court of Appeals dismissed Things Remembered's appeal for lack of jurisdiction.

Question

May a federal court of appeals review a district court order remanding a bankruptcy case to state court on grounds of untimely removal?

Conclusion

Decision: 9 votes for Petrarca, 0 vote(s) against
Legal provision: 28 U.S.C. 1447

No. In a unanimous opinion delivered by Justice Clarence Thomas, the Court held that if an order remands a removed bankruptcy case to state court because of a timely raised defect in removal procedure or lack of subject-matter jurisdiction, a court of appeals lacks jurisdiction to review the order under the provisions of the general federal removal statute. The Court reasoned that the general removal statute bars appellate review of any order remanding a case to the State court from which it was removed so that only remands based on the grounds recognized by the statute, such as a timely raised defect in removal procedure or lack of subject-matter jurisdiction, are immune from review under the statute.

United States v. Winstar

Wed, 24 Apr 1996 13:00:00 +0000

Case Basics

Docket No.

95-865

Petitioner

United States

Petitioner Type

Petitioner

Respondent

Winstar

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

518 U.S. 839 (1996)

Argued

Wednesday, April 24, 1996

Decided

Monday, July 1, 1996

Advocates

Charles J. Cooper (Argued the cause for the respondents Winstar Corp., et al)

Paul Bender (Department of Justice, argued the cause for the petitioner)

Joe G. Hollingsworth (Argued the cause for the respondent Glendale Federal Bank)

Facts of the Case

During the savings and loan crisis of the 1980s, the Federal Home Loan Bank Board encouraged thrifts in good standing and outside investors to take over ailing thrifts in supervisory mergers. The Board agreed to permit acquiring entities to designate the excess of the purchase price over the fair value of identifiable assets as an intangible asset referred to as supervisory goodwill and to count such goodwill and certain capital credits toward the capital reserve requirements imposed by federal regulations. Subsequently, Congress's passage of the Financial Institutions Reform, Recovery, and Enforcement Act of 1989 (FIRREA) forbade thrifts from counting goodwill and capital credits in computing the required reserves. Three thrifts, created through supervisory mergers who consequently ran into financial troubles, each filed suit against the United States for breach of contract. Agreeing with the thrifts, the District Court granted each summary judgment. The court rejected Government's arguments that surrenders of sovereign authority, such as the promise to refrain from regulatory changes, must appear in unmistakable terms in a contract in order to be enforceable and that a public and general sovereign act, such as FIRREA's alteration of capital reserve requirements, could not trigger contractual liability. The Court of Appeals affirmed.

Question

Can the federal government be sued by thrifts that were sent into financial trouble when Congress changed the computation of required reserves after the Federal Home Loan Bank Board encouraged actions based on premise that the rules would not change?

Conclusion

Decision: 7 votes for Winstar, 2 vote(s) against
Legal provision: 12 U.S.C. 1464

Yes. In a 7-2 plurality opinion delivered Justice David H. Souter, the Court held that the terms assigning the risk of regulatory change to the Government are enforceable and that the Government is therefore liable in damages for breach, although Congress changed the relevant law, and thereby barred the Government from specifically honoring its agreements. Justices John Paul Stevens and Stephen G. Breyer joined all of the plurality opinion, and Justice Sandra Day O'Connor joined in part. In a concurring opinion, Justice Stephen G. Breyer wrote that the unmistakability doctrine was not intended to displace the rules of contract interpretation applicable to the government. In a concurring opinion joined by Justices Anthony M. Kennedy and Clarence Thomas, Justice Antonin Scalia wrote that the contracts at issue gave rise to an obligation on the part of the government to afford the three thrifts favorable accounting treatment and the contracts were broken by the government's discontinuation of that favorable treatment. Chief Justice William H. Rehnquist dissented in an opinion joined in part by Justice Ruth Bader Ginsburg.

United States v. Noland

Mon, 25 Mar 1996 13:00:00 +0000

Case Basics

Docket No.

95-323

Petitioner

United States

Petitioner Type

Petitioner

Respondent

Noland

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

517 U.S. 535 (1996)

Argued

Monday, March 25, 1996

Decided

Monday, May 13, 1996

Advocates

Raymond J. Pikna (Argued the cause for the respondent)

Kent L. Jones (Argued the cause for the petitioner)

Facts of the Case

The IRS filed claims in Bankruptcy Court for taxes, interest, and penalties that accrued when Thomas R. Noland, the trustee of the in-debt First Truck Lines, Inc., sought relief under federal Bankruptcy Code. The Bankruptcy Court held that the claims for taxes and interest were the first priority in the case. Consequently, the court subordinated the penalties, to be adjudicated following the taxes and interest, because the penalties were not financial losses for the IRS. The Court of Appeals affirmed the decision.

Question

May a bankruptcy court subordinate government attempts to collect tax penalties?

Conclusion

Decision: 9 votes for United States, 0 vote(s) against
Legal provision: Bankruptcy Code, Bankruptcy Act or Rules, or Bankruptcy Reform Act of 1978

No. In a unanimous decision, announced by Justice David H. Souter, the Court ruled that giving tax-penalty claims a lower priority than other claims contradicts Congress_ scheme of priorities regarding federal bankruptcy law.

National Labor Relations Board v. Town & Country Electric, Inc.

Tue, 10 Oct 1995 13:00:00 +0000

Case Basics

Docket No.

94-947

Petitioner

National Labor Relations Board

Petitioner Type

Petitioner

Respondent

Town & Country Electric, Inc., et al.

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

516 U.S. 85 (1995)

Argued

Tuesday, October 10, 1995

Decided

Tuesday, November 28, 1995

Advocates

James K. Pease, Jr. (on behalf of the Respondent)

Lawrence G. Wallace (on behalf of the Petitioner)

Facts of the Case

Town & County Electric, Inc., a non-union company, sought to fill several positions for a construction job in Minnesota. Town & Country received applications from union staff, but refused to interview any of the applicants except one, who was eventually hired and fired soon thereafter. These individuals applied with the intention to organize Town & Country and were to remain on Union payroll during their time of employment. The union, the International Brotherhood of Electrical Workers, filed a complaint with the National Labor Relations Board claiming that Town & Country had refused to interview and retain the workers because of their union affiliation, a violation of the National Labor Relations Act. The Board held that the 11 individuals met the definition of employees under the Act and rejected Town & Country's claims that the individuals had been refused for other reasons.

The U.S. Court of Appeals for the Eighth Circuit reversed on the ground that the term "employee" does not include those individuals who remain on Union payroll during their time of employment with another company.

Question

Does a worker qualify as an "employee" under the National Labor Relations Act if, while he is working, he is simultaneously paid by a union to help the union organize a company?

Conclusion

Decision: 9 votes for National Labor Relations Board, 0 vote(s) against
Legal provision: National Labor Relations, as amended

Yes. In a unanimous decision written by Justice Stephen Breyer, the Supreme Court ruled for the Board and held that individuals can meet the definition of employee even if they are paid by a union to organize a non-union company while on company payroll. The Court found this result consistent with the language and purpose of the Act as well as the dictionary definition of "employee." The Court also reasoned that the language of the Act seemed to specifically take into account the possibility of workers who are paid union organizers.

Bailey v. United States

Mon, 30 Oct 1995 13:00:00 +0000

Case Basics

Docket No.

94-7448

Petitioner

Bailey

Petitioner Type

Petitioner

Respondent

United States

Respondent Type

Respondent

Consolidation

Robinson v. United States, No. 94-7492

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

516 U.S. 137 (1995)

Argued

Monday, October 30, 1995

Decided

Wednesday, December 6, 1995

Advocates

Alan Edward Untereiner (Argued the cause for the petitioners)

Michael R. Dreeben (Argued the cause for the respondent)

Facts of the Case

Roland Bailey and Candisha Robinson were each convicted of violating 18 U.S.C. Section 924(c)(1), which, in relevant part, imposes a mandatory minimum sentence upon a person who "uses or carries a firearm" both "during and in relation to" a predicate offense. Bailey's Section 924(c)(1) conviction was based on a loaded pistol which the police found inside a bag in the locked trunk of a car he was driving after they arrested him for possession of illegal drugs. Robinson's Section 924(c)(1) conviction was based on an unloaded, holstered firearm which the police, executing a search warrant, found locked in a trunk in her bedroom closet, along with drugs and money from an earlier controlled buy. The D.C. Circuit, sitting en banc, upheld the Section 924(c)(1) convictions, interpreting "use" of a gun in violation of Section 924(c)(1) in accordance with an "accessibility and proximity" test.

Question

Is evidence of the proximity and accessibility of a firearm to drugs or drug proceeds alone sufficient to support a conviction for "use" of a firearm during and in relation to a predicate narcotics offense under 18 U.S.C. Section 924(c)(1)?

Conclusion

Decision: 9 votes for Bailey, 0 vote(s) against
Legal provision: 18 U.S.C. 924

No. The proximity and accessibility test for "use" is so broad that no independent role remains for "carry." "Use" in Section 924(c)(1) requires more than proximity and accessibility that might embolden a defendant. It requires active employment of the firearm by the defendant, making the firearm an operative factor in relation to the predicate offense.

Lockheed Corp. v. Spink

Mon, 22 Apr 1996 13:00:00 +0000

Case Basics

Docket No.

95-809

Petitioner

Lockheed Corp.

Petitioner Type

Petitioner

Respondent

Spink

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

517 U.S. 882 (1996)

Argued

Monday, April 22, 1996

Decided

Monday, June 10, 1996

Advocates

Richard P. Bress (Argued the cause for the United States, as amicus curiae)

Gordon E. Krischer (Argued the cause for the petitioners)

Theresa M. Traber (Argued the cause for the respondent)

Facts of the Case

Lockheed Corporation hired Paul L. Spink when he was sixty-one. He was excluded from participation in Lockheed's retirement program. Later changes in federal law required Lockheed to add Spink to the retirement program. Lockheed added Spink, but refused accrued benefits for the years he had worked at Lockheed before federal law changed. Lockheed also offered an increased pension benefit to employees who would retire early in exchange for their waiver of any employment claims against the corporation. Spink refused to be added without earning the extra benefits for the previous years he had worked. Spink filed suit alleging he should receive full benefits. The District Court dismissed the case for failure to state a claim. The Court of Appeals ruled in favor of Spink. It held the law applied retroactively which would cover Spink.

Question

May a business offer early retirement benefits on the condition that an employee give up the right to sue over any job-related claim? Can the federal government retroactively apply retirement income benefit laws?

Conclusion

Decision: 9 votes for Lockheed Corp., 0 vote(s) against
Legal provision: Employee Retirement Income Security

Yes and no. In unanimous and 7-2 decisions, announced by Justice Clarence Thomas, the Court ruled that businesses may condition early retirement benefits on the forfeiture of the right to sue in a job-related claim. The Court also ruled that the government could not retroactively apply retirement income benefit laws.

Tuggle v. Netherland

Sun, 28 Apr 2013 09:19:19 +0000

Case Basics

Docket No.

95-6016

Petitioner

Tuggle

Petitioner Type

Petitioner

Respondent

Netherland

Respondent Type

Respondent

Decided By

Rehnquist Court (1994-2005)

Opinion

516 U.S. 10 (1995)

Decided

Monday, October 30, 1995

Facts of the Case

Lem Tuggle was convicted of murder. After the Commonwealth presented unrebutted psychiatric testimony of his future dangerousness, the jury found two statutory aggravating circumstances and sentenced Tuggle to death. Subsequently, the U.S. Supreme Court remanded the case under Ake v. Oklahoma, 470 U.S. 68, which held that when the prosecution presents psychiatric evidence of an indigent defendant's future dangerousness in a capital sentencing proceeding, due process requires the State to provide the defendant with the assistance of an independent psychiatrist. On remand, the State Supreme Court invalidated the future dangerousness aggravating factor, but upheld the death sentence based on the vileness aggravator under Zant v. Stephens, 462 U.S. 862. Agreeing, the Court of Appeals construed Zant as establishing a rule that in nonweighing States a death sentence may be upheld based on one valid aggravating circumstance, regardless of the reasons for finding another aggravating factor invalid.

Question

Did the Court of Appeals correctly interpret Zant v. Stephens, 462 U.S. 862, to establish a rule that, in States that do not weigh aggravating circumstances against mitigating circumstances, a death sentence may be upheld on the basis of one valid aggravating circumstance, regardless of the reasons for which another aggravating factor may have been found to be invalid?

Conclusion

Decision: 9 votes for Tuggle, 0 vote(s) against
Legal provision:

No. In a per curiam opinion, the Court held that the Court of Appeals' interpretation of Zant was incorrect. The Court reasoned that the record here does not provide comparable support for the death sentence because, even after elimination of the invalid aggravator, the death sentence in Zant rested on two remaining unimpeached aggravating factors. Moreover, the Court noted, the Ake error prevented Tuggle from developing his own evidence to rebut the Commonwealth and to enhance his defense in mitigation, allowing the Commonwealth's psychiatric evidence to go unchallenged, which may have unfairly increased its persuasiveness and affected the jury's decision to impose death rather than life imprisonment.

Peacock v. Thomas

Mon, 06 Nov 1995 13:00:00 +0000

Case Basics

Docket No.

94-1453

Petitioner

Peacock

Petitioner Type

Petitioner

Respondent

Thomas

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

516 U.S. 349 (1996)

Argued

Monday, November 6, 1995

Decided

Wednesday, February 21, 1996

Advocates

Richard P. Bress (Department of Justice, argued on behalf of the United States, as amicus curiae supporting the respondent)

J. Kendall Few (Argued the cause for the respondent)

David L. Freeman (Argued the cause for the petitioner)

Facts of the Case

In 1987, Jack L. Thomas filed an Employee Retirement Income Security Act of 1974 (ERISA) class action against his former employer Tru-Tech, Inc. and D. Grant Peacock, an officer and shareholder of Tru-Tech. Thomas alleged that they had breached their fiduciary duties to the class in administering Tru- Tech's pension benefits plan and sought the benefits due under the plan. The District Court ruled in Thomas's favor, but found that Peacock was not a fiduciary. After the Court of Appeals affirmed and attempts to collect from Tru-Tech failed, Thomas sued Peacock. The District Court, agreeing with Thomas to pierce the corporate veil, entered judgment against Peacock in the amount of the judgment against Tru-Tech. In affirming, the Court of Appeals held that the District Court properly exercised ancillary jurisdiction over Thomas' suit.

Question

Do federal courts possess ancillary jurisdiction over new actions in which a federal judgment creditor seeks to impose liability for a money judgment on a person not otherwise liable for the judgment?

Conclusion

Decision: 8 votes for Peacock, 1 vote(s) against
Legal provision: Employee Retirement Income Security

No. In an 8-1 opinion delivered by Justice Clarence Thomas, the Court held that the District Court lacked jurisdiction over Thomas's subsequent suit. The Court found that neither ERISA's jurisdictional nor the general federal question jurisdictional provision supplied the District Court with subject matter jurisdiction over the suit against the corporate officer. The Court noted that is was unaware of any provision under ERISA for imposing liability under the circumstances for an extant ERISA judgment against a third party. Justice John Paul Stevens, in a dissent, argued that a federal court's jurisdiction encompasses a claim by a judgment creditor that a party in control of the judgment debtor has fraudulently exercised that control to defeat a judgment.

Fulton Corporation v. Faulkner

Tue, 31 Oct 1995 13:00:00 +0000

Case Basics

Docket No.

94-1239

Petitioner

Fulton Corporation

Petitioner Type

Petitioner

Respondent

Faulkner

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

516 U.S. 325 (1996)

Argued

Tuesday, October 31, 1995

Decided

Wednesday, February 21, 1996

Advocates

Jasper L. Cummings, Jr. (Argued the cause for the petitioner)

Charles A. Rothfeld (Argued the cause for the respondent)

Facts of the Case

After North Carolina levied an "intangibles tax" on a fraction of the value of corporate stock owned by state residents inversely proportional to the corporation's exposure to the State's income tax, the Fulton Corporation, a North Carolina company, filed a state-court action against the State Secretary of Revenue, seeking judgment that the tax violated the Federal Commerce Clause by discriminating against interstate commerce. The trial court ruled for the Secretary, but North Carolina's Court of Appeals reversed, holding that the taxable percentage deduction violated the Commerce Clause. In reversing, the North Carolina Supreme Court found that the State's scheme imposed a valid compensatory tax and that the intangibles tax imposed less of a burden on interstate commerce than the corporate income tax placed on intrastate commerce.

Question

Does North Carolina's "intangibles tax" on a fraction of the value of corporate stock owned by North Carolina residents inversely proportional to the corporation's exposure to the State's income tax violate the Federal Commerce Clause?

Conclusion

Decision: 9 votes for Fulton Corporation, 0 vote(s) against
Legal provision: Article 1, Section 8, Paragraph 3: Interstate Commerce Clause

Yes. In a unanimous opinion delivered by Justice David H. Souter, the Court held that North Carolina's intangibles tax discriminates against interstate commerce in violation of the dormant Commerce Clause. Justice Souter reasoned that the tax discriminated on face against interstate commerce by taxing stock only to the extent that its issuing corporation participated in interstate commerce. "North Carolina's intangibles tax facially discriminates against interstate commerce, it fails justification as a valid compensatory tax, and, accordingly, it cannot stand," wrote Justice Souter. Chief Justice William H. Rehnquist wrote a concurring opinion.

Bennis v. Michigan

Wed, 29 Nov 1995 13:00:00 +0000

Case Basics

Docket No.

94-8729

Petitioner

Bennis

Petitioner Type

Petitioner

Respondent

Michigan

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

516 U.S. 442 (1996)

Argued

Wednesday, November 29, 1995

Decided

Monday, March 4, 1996

Advocates

Larry L. Roberts (Argued the cause for the respondent)

Richard H. Seamon (Argued the cause for the United States as amicus curiae urging affirmance)

Stefan B. Herpel (Argued the cause for the petitioner)

Facts of the Case

Bennis's husband was convicted of gross indecency following his sexual activity with a prostitute in the couple's jointly-owned car. The local county prosecutor filed a complaint alleging the car was a public nuisance subject to abatement (i.e., to eliminate or confiscate the car). The Circuit Court entered the abatement order, but the Appeals Court reversed. After granting leave to appeal, the Supreme Court of Michigan reversed the appellate court's decision and re-entered the abatement order. Bennis appealed to the Supreme Court.

Question

Does the abatement order entered against Bennis's car constitute a taking of private property for public use in violation of the property clauses of the Fifth and Fourteenth Amendments?

Conclusion

Decision: 5 votes for Michigan, 4 vote(s) against
Legal provision: Due Process

Writing for a 5-to-4 majority, Chief Justice William H. Rehnquist held that the abatement order against Bennis's car did not violate the takings clause. Her innocence and lack of knowledge concerning her husband's illegal and indecent activity, in the couple's jointly owned car, could not serve as a defense against her vehicle's forfeiture. Furthermore, under the present circumstances, the vehicle's forfeiture did not violate Bennis's property rights without due process. Michigan's abatement policy, aimed at deterring criminal uses of property, lawfully transferred her's vehicle to the state. As such, Michigan is not required to compensate Bennis for the vehicle's forfeiture.

Cooper v. Oklahoma

Wed, 17 Jan 1996 13:00:00 +0000

Case Basics

Docket No.

95-5207

Petitioner

Cooper

Petitioner Type

Petitioner

Respondent

Oklahoma

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

517 U.S. 348 (1996)

Argued

Wednesday, January 17, 1996

Decided

Tuesday, April 16, 1996

Advocates

W. A. Edmondson (Argued the cause for the respondent)

Robert Alan Ravitz (Argued the cause for the petitioner)

Facts of the Case

Byron Keith Cooper was charged with the murder of an 86-year-old man in the course of a burglary. After an Oklahoma jury found him guilty of first-degree murder and recommended punishment by death, the trial court imposed the death penalty. Cooper's competence was considered on five separate occasions, whether he had the ability to understand the charges against him and to assist defense counsel. Oklahoma law presumes that a criminal defendant is competent to stand trial unless he proves his incompetence by clear and convincing evidence. Despite Cooper's bizarre behavior and conflicting expert testimony, he was found competent on separate occasions before and during his trial. In affirming the conviction and sentence, the Oklahoma Court of Criminal Appeals rejected Cooper's argument that the State's presumption of competence, combined with its clear and convincing evidence standard, placed such an onerous burden on him as to violate due process under the Fourteenth Amendment.

Question

May state law presume that defendants are competent to stand trial unless they prove their incompetence by clear and convincing evidence without violating the Due Process Clause of the Fourteenth Amendment?

Conclusion

Decision: 9 votes for Cooper, 0 vote(s) against
Legal provision: Due Process

No. In a unanimous opinion delivered by Justice John Paul Stevens, the Court held that because Oklahoma's procedural rule allows the State to try a defendant who is more likely than not incompetent, it violates due process. Justice Stevens wrote for the court that the stringent standard is "incompatible with the dictates of due process," and that criminal defendants must be allowed to avoid trial if they prove incompetence by a "preponderance of the evidence."

United States v. Virginia

Wed, 17 Jan 1996 13:00:00 +0000

Location

Virginia Military Institute

319 Letcher Avenue Lexington VA 24450

Lexington, VA 24450

United States

37° 47' 20.76" N, 79° 26' 21.3108" W

See map: Google Maps

Case Basics

Docket No.

94-1941

Petitioner

United States

Petitioner Type

Petitioner

Respondent

Virginia

Respondent Type

Respondent

Consolidation

No. 94-2107

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

518 U.S. 515 (1996)

Argued

Wednesday, January 17, 1996

Decided

Wednesday, June 26, 1996

Advocates

Paul Bender (Argued the cause for the United States)

Theodore B. Olson (Argued the cause on behalf of Virginia et al)

Facts of the Case

The Virginia Military Institute (VMI) boasted a long and proud tradition as Virginia's only exclusively male public undergraduate higher learning institution. The United States brought suit against Virginia and VMI alleging that the school's male-only admissions policy was unconstitutional insofar as it violated the Fourteenth Amendment's equal protection clause. On appeal from a District Court ruling favoring VMI, the Fourth Circuit reversed. It found VMI's admissions policy to be unconstitutional. Virginia, in response to the Fourth Circuit's reversal, proposed to create the Virginia Women's Institute for Leadership (VWIL) as a parallel program for women. On appeal from the District Court's affirmation of the plan, the Fourth Circuit ruled that despite the difference in prestige between the VMI and VWIL, the two programs would offer "substantively comparable" educational benefits. The United States appealed to the Supreme Court.

Question

Does Virginia's creation of a women's-only academy, as a comparable program to a male-only academy, satisfy the Fourteenth Amendment's Equal Protection Clause?

Conclusion

Decision: 7 votes for United States, 1 vote(s) against
Legal provision: Equal Protection

No. In a 7-to-1 decision, the Court held that VMI's male-only admissions policy was unconstitutional. Because it failed to show "exceedingly persuasive justification" for VMI's gender-biased admissions policy, Virginia violated the Fourteenth Amendment's equal protection clause. Virginia failed to support its claim that single-sex education contributes to educational diversity because it did not show that VMI's male-only admissions policy was created or maintained in order to further educational diversity. Furthermore, Virginia's VWIL could not offer women the same benefits as VMI offered men. The VWIL would not provide women with the same rigorous military training, faculty, courses, facilities, financial opportunities, or alumni reputation and connections that VMI affords its male cadets. Finally, the Fourth Circuit's "substantive comparability" between VMI and VWIL was misplaced. The Court held that the Fourth Circuit's "substantive comparability" standard was a displacement of the Court's more exacting standard, requiring that "all gender-based classifications today" be evaluated with "heightened scrutiny." When evaluated with such "heightened scrutiny," Virginia's plan to create the VWIL would not provide women with the same opportunities as VMI provides its men and so it failed to meet requirements of the equal protection clause. [NOTE: Justice Ginsberg's announcement of the Court's opinion (below) may be considered an address to the American public. It is a plain-spoken and forceful summary of the majority position.]

Behrens v. Pelletier

Tue, 07 Nov 1995 13:00:00 +0000

Case Basics

Docket No.

94-1244

Petitioner

Behrens

Petitioner Type

Petitioner

Respondent

Pelletier

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

516 U.S. 299 (1996)

Argued

Tuesday, November 7, 1995

Decided

Wednesday, February 21, 1996

Advocates

Samuel T. Rees (Argued the cause for the respondent)

Cornelia T. L. Pillard (Department of Justice, for the United States as amicus curiae, supporting the petitioner, urging reversal)

Lenard G. Weiss (Argued the cause for the petitioner)

Facts of the Case

After the Federal Home Loan Bank Board recommended that Robert Pelletier be replaced because of he was under investigation for potential misconduct relating to the collapse of another financial institution, he was fired as the provisional managing officer of Pioneer Savings and Loan Association. Pelletier then filed suit, seeking damages. John Behrens, the agent responsible for the Federal Home Loan Bank Board's recommendation, asserted a statute-of-limitations defense and claimed qualified immunity from suit on the ground that his actions were taken in a governmental capacity. The District Court rejected Behrens' defense of qualified immunity. On appeal, the Court of Appeals held that denial of qualified immunity is an immediately appealable "final" decision, that an official claiming qualified immunity is entitled to only one such pretrial appeal, and, ultimately, affirmed the District Court's rejection of Behrens' qualified immunity. On remand, the District Court denied Behrens' motion for summary judgment, which again claimed qualified immunity. On appeal from the latest denial, the Court of Appeals dismissed it for lack of jurisdiction.

Question

Does a defendant's immediate appeal of an unfavorable qualified-immunity ruling on his motion to dismiss deprive the court of appeals of jurisdiction over a second appeal, also based on qualified immunity, immediately following denial of summary judgment?

Conclusion

Decision: 7 votes for Behrens, 2 vote(s) against
Legal provision: 28 U.S.C. 1291

No. In a 7-2 opinion delivered by Justice Antonin Scalia, the Court held that the court of appeals was not deprived of jurisdiction. The Court reasoned that the agent was not limited in such circumstances to one interlocutory appeal from a denial of qualified immunity. Justice Scalia wrote that, "an order rejecting the defense of qualified immunity at either the dismissal stage or the summary judgment stage is a 'final' judgment subject to immediate appeal." In a dissent joined by Justice John Paul Stevens, Justice Stephen G. Breyer wrote, in such cases, "the law normally permits a single interlocutory appeal, and not more than one such appeal."

Matsushita Electric Industrial Co., Ltd. v. Epstein

Mon, 27 Nov 1995 13:00:00 +0000

Case Basics

Docket No.

94-1809

Petitioner

Matsushita Electric Industrial Co., Ltd.

Petitioner Type

Petitioner

Respondent

Epstein

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

516 U.S. 367 (1996)

Argued

Monday, November 27, 1995

Decided

Tuesday, February 27, 1996

Advocates

Henry P. Monaghan (Argued the cause for the respondents)

Barry R. Ostrager (Argued the cause for the petitioners)

Facts of the Case

In 1990, Matsushita Electric Industrial Co. made a tender offer for the common stock of MCA, Inc., a Delaware corporation, which resulted in Matsushita's acquisition of MCA. Subsequently, two lawsuits followed. First, a class action filed in Delaware, alleged that, among other things, Matsushita and MCA conspired violating Delaware law. The second suit, filed in federal court, alleged that Matsushita's tender offer violated certain Securities and Exchange Commission Rules promulgated under the Securities Exchange Act of 1934, which confers exclusive jurisdiction upon the federal courts in such suits. After Matsushita won the federal case, and while it was on appeal, the parties to the state action reached a settlement. The class-action settlement stated that class members who did not opt out of the class would waive all claims in connection with the tender offer, including those asserted in the federal action. As members of both state and federal plaintiff classes, who neither opted out of the settlement class nor appeared to contest the settlement or the representation of the class, pursued the federal appeal, Matsushita argued that the Delaware judgment was a bar to further prosecution under the Full Faith and Credit Act.

Question

May a federal court refuse to grant full faith and credit to a state-court judgment approving a class-action settlement simply because the settlement releases claims within the exclusive jurisdiction of the federal courts?

Conclusion

Decision: 6 votes for Matsushita Electric Industrial Co., Ltd., 3 vote(s) against
Legal provision: 28 U.S.C. 1738

No. In a 7-2 opinion delivered by Justice Clarence Thomas, the Court held that, absent a partial repeal of the Full Faith and Credit Act by another federal statute, a federal court must give the judgment the same effect that it would have in the courts of the State in which it was rendered. Writing for the court, Justice Thomas said the federal Full Faith and Credit Act "is generally applicable in cases in which the state-court judgment at issue incorporates a class-action settlement releasing claims solely within the jurisdiction of the federal courts." Justice John Paul Stevens penned an opinion concurring in part and dissenting in part. Justice Ruth Bader Ginsburg wrote a concurring and dissenting opinion, and was joined in part by Justice David H. Souter.

O'Hare Truck Service v. Northlake

Wed, 20 Mar 1996 13:00:00 +0000

Case Basics

Docket No.

95-191

Petitioner

O'Hare Truck Service

Petitioner Type

Petitioner

Respondent

Northlake

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

518 U.S. 712 (1996)

Argued

Wednesday, March 20, 1996

Decided

Friday, June 28, 1996

Advocates

Gary M. Feiereisel (Argued the cause for the respondents)

Harvey Grossman (Argued the cause for the petitioners)

Facts of the Case

O'Hare Truck Service was one among several towing companies employed by the city of Northlake. Northlake kept a list of available towing companies and would only remove a company from its list after a showing of cause. In the present case, however, Northlake removed O'Hare Truck Service from its list because O'Hare's owner did not support Northlake's mayoral candidate in his reelection campaign. Instead, O'Hare's owner supported the opposition candidate. Upon removal from Northlake's employment list, O'Hare Truck Service filed suit alleging that its dismissal was a retaliation for its lack of support for Northlake's mayoral candidate. The dismissal was the cause of substantial loss in income. On appeal from the District Court's dismissal for failure to state a First Amendment violation, the Seventh Circuit affirmed. The Supreme Court granted certiorari.

Question

Did O'Hare Truck Service's removal from Northlake's employment list, as a result of its support for an opposition mayoral candidate, violate O'Hare Truck Services freedom of speech?

Conclusion

Decision: 7 votes for O'Hare Truck Service, 2 vote(s) against
Legal provision: Association

Yes. The Court held, in an opinion by Justice Anthony Kennedy, that independent contractors, such as O'Hare Truck Service, are entitled to the same First Amendment protections as those afforded to government employees. Accordingly, Northlake could not condition the towing company's employment on its political affiliations or beliefs unless Northlake could demonstrate that O'Hare's political affiliations had a reasonable and appreciable effect on its job performance. The Court held that Northlake neither attempted nor would it have been able to make such a demonstration. Therefore, Northlake's removal of O'Hare Truck Service from its employment list was unconstitutional.

44 Liquormart Inc. v. Rhode Island

Wed, 01 Nov 1995 13:00:00 +0000

Location

Rhode Island General Assembly

82 Smith St Providence RI 02903

Providence, RI 02903

United States

41° 49' 53.6448" N, 71° 24' 53.3664" W

See map: Google Maps

Case Basics

Docket No.

94-1140

Petitioner

44 Liquormart Inc.

Petitioner Type

Petitioner

Respondent

Rhode Island

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

517 U.S. 484 (1996)

Argued

Wednesday, November 1, 1995

Decided

Monday, May 13, 1996

Advocates

Rebecca T. Partington (Argued the cause for the respondents)

Evan T. Lawson (Argued the cause for the petitioners)

Facts of the Case

Rhode Island passed a statute banning the advertisement of retail liquor prices in places where liquor is not sold. Petitioners filed suit claiming that the statute violated their First Amendment right to freedom of speech. The District Court found the ban unconstitutional, noting that it did not serve any interest Rhode Island might have had in promoting temperance. The Court of Appeals reversed, holding that open competition for liquor pricing would be harmful insofar at it would increase consumption. The Supreme Court granted certiorari.

Question

Is Rhode Island's statute an infringement on the First Amendment right to commercial freedom of speech? If it is, can Rhode Island still pass such legislation under the Twenty-first Amendment which limits the dormant Commerce Clause by empowering the states to regulate the sale of alcohol?

Conclusion

Decision: 9 votes for 44 Liquormart Inc., 0 vote(s) against
Legal provision: Amendment 1: Speech, Press, and Assembly

Yes and no. In a fractious opinon for a unanimous Court, Justice Stevens found Rhode Island's statutory ban on liquor price advertising to be an unconstitutional infringement of the liquor sellers' First Amendment right to freedom of speech. In response to Rhode Island's claim that it passed the statutory ban to protect consumers from "commercial harms," Justice Stevens held that governmental impediments to truthful and accurate commercial messages rarely protect consumers. On the contrary, courts must take "special care" when considering such "protective" measures since they often hinder public choice and obstruct necessary debate over public policy issues. Furthermore, Rhode Island failed to show that its statutory ban would lower market-wide liquor consumption, must less alter alcohol consumption among abusive drinkers who are most in need of assistance. Finally, Justice Stevens held that although the Twenty-first Amendment did empower Rhode Island to regulate the sale of liquor, such regulatory power is not to be exercised to the detriment of its constitutional obligation to protect and abide by the First Amendment's freedom of speech guarantee.

Meghrig v. KFC Western, Inc.

Wed, 10 Jan 1996 13:00:00 +0000

Case Basics

Docket No.

95-83

Petitioner

Meghrig

Petitioner Type

Petitioner

Respondent

KFC Western, Inc.

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

516 U.S. 479 (1996)

Argued

Wednesday, January 10, 1996

Decided

Tuesday, March 19, 1996

Advocates

John P. Zaimes (Argued the cause for the petitioners)

Jeffrey P. Minear (On behalf of the United States, as amicus curiae, supporting the petitioners)

Daniel Romano (Argued the cause for the respondent)

Facts of the Case

Three years after complying with a county order to clean up petroleum contamination discovered on its property, KFC Western, Inc. brought an action under the citizen suit provision -- Section 6972 -- of the Resource Conservation and Recovery Act of 1976 (RCRA) to recover its cleanup costs from the Meghrigs. KFC claimed that the contamination had previously posed an "imminent and substantial endangerment" to health or the environment and that the Meghrigs were responsible for "equitable restitution" under the Act because, as prior owners of the property, they had contributed to the contaminated site. The District Court dismissed the complaint, holding that 6972(a) does not permit recovery of past cleanup costs and that 6972 does not authorize a cause of action for the remediation of toxic waste that does not pose an "imminent and substantial endangerment" at the time suit is filed. In reversing, the Court of Appeals disagreed with the District Court on both issues.

Question

May plaintiffs use the federal Resource Conservation and Recovery Act of 1976 to sue and recover money they spent to clean up hazardous waste on their property?

Conclusion

Decision: 9 votes for Meghrig, 0 vote(s) against
Legal provision: 42 U.S.C. 6972

No. In a unanimous opinion delivered by Justice Sandra Day O'Connor the Court held that section 6972 does not authorize a private cause of action to recover the prior cost of cleaning up toxic waste that does not, at the time of suit, continue to pose an endangerment to health or the environment. Writing for the court, Justice O'Connor said the law only allows private citizens to sue to minimize the present and future threat to human health and the environment and is not directed at providing compensation for past cleanup efforts.

Degen v. United States

Mon, 22 Apr 1996 13:00:00 +0000

Case Basics

Docket No.

95-173

Petitioner

Degen

Petitioner Type

Petitioner

Respondent

United States

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

517 U.S. 820 (1996)

Argued

Monday, April 22, 1996

Decided

Monday, June 10, 1996

Advocates

Miguel A. Estrada (Argued the cause for the respondent)

Lawrence S. Robbins (Argued the cause for the petitioner)

Facts of the Case

Brian Degen was indicted in 1989 for distributing marijuana, laundering money, and related crimes. On the same day the district court unsealed the indictment, it also unsealed a civil forfeiture complaint for properties allegedly worth $5.5 million and purchased with proceeds of Degen's drug sales or used to facilitate the sales. Degen is a citizen of both the U.S. and Switzerland, and in 1988 he and his family moved to Switzerland. He has not returned to the U.S. to face criminal charges and by treaty the Swiss are not obliged to extradite their nationals to the U.S. While residing in Switzerland, Degen filed an answer in the civil case, claiming that the forfeiture was barred by the statute of limitations and was an unlawful retroactive application of forfeiture laws. The district court did not consider his arguments. Instead, it entered summary judgment against him, holding that he was not entitled to be heard in the civil action because he remained outside the country, unamenable to criminal prosecution. On appeal, the government argued that the district court's inherent powers authorized it to strike Degen's claims under the "fugitive disentitlement doctrine."

Question

Should the fugitive disentitlement doctrine be extended to allow a court in a civil forfeiture suit to enter judgment against a claimant, without any opportunity to be heard, because the claimant is a fugitive from, or otherwise is resisting, a related criminal prosecution?

Conclusion

Decision: 9 votes for Degen, 0 vote(s) against
Legal provision:

No. Principles of deference to the other branches of government require a court to invoke its inherent power only as a reasonable response to the problems and needs that provoke it. No sufficient reason justifies disentitlement here. Since the court's jurisdiction over the property is secure despite Degen's absence, there is no risk of delay or frustration in determining the merits of the government's forfeiture claims or in enforcing the resulting judgment. Also, the court has alternatives, other than disentitlement, to keep Degen from using liberal civil discovery rules to gain an improper advantage in the criminal prosecution, where discovery is more limited. Finally, disentitlement is an excessive response to the court's interests in redressing the indignity visited upon it by Degen's absence from the criminal proceeding, and in deterring flight from criminal prosecution in general; it is a response that erodes rather than enhances the dignity of the court.

Lawrence v. Chater

Sun, 28 Apr 2013 09:19:20 +0000

Case Basics

Docket No.

94-9323

Petitioner

Lawrence

Petitioner Type

Petitioner

Respondent

Chater

Respondent Type

Respondent

Decided By

Rehnquist Court (1994-2005)

Opinion

516 U.S. 163 (1996)

Decided

Monday, January 8, 1996

Facts of the Case

Kemmerlyn Lawrence asserted entitlement to Social Security benefits as the dependant, unmarried minor child of a deceased insured individual. Under the Social Security Act, which requires paternity to be decided by state law, Lawrence acknowledged that her claim appeared defeated, but agued that the relevant North Carolina law's proof of paternity requirements are unconstitutional. After the Federal Government argued that a state paternity law's constitutionality need not be considered before applying it to determine entitlement to Social Security benefits, the Court of Appeals affirmed the denial of Lawrence's benefits. Subsequently, the Social Security Administration reexamined its position and concluded that the Act does require a determination whether a state intestacy statute is constitutional. The Solicitor General thus invited the Court to grant certiorari, vacate the judgment below, and remand the case (GVR) to the Court of Appeals to decide the case or remand it to the Social Security Commissioner for reconsideration.

Question

Does the U.S. Supreme Court have the authority to set aside a lower court's ruling and remand the case without finding that the lower court committed some error?

Conclusion

Decision: 7 votes for Lawrence, 2 vote(s) against
Legal provision: 42 U.S.C. 416

Yes. In a 7-2 per curiam opinion, the Court held that it had the power to issue a GVR order and that such an order is an appropriate exercise of its discretionary certiorari jurisdiction. "In an appropriate case, a GVR order conserves the scarce resources of this Court that might otherwise be expended on plenary consideration, assists the court below by flagging a particular issue that it does not appear to have fully considered, assists this Court by procuring the benefit of the lower court's insight before we rule on the merits, and alleviates the 'potential for unequal treatment' that is inherent in our inability to grant plenary review of all pending cases raising similar issues," stated the unsigned opinion.

Gasperini v. Center for Humanities Inc.

Tue, 16 Apr 1996 13:00:00 +0000

Case Basics

Docket No.

95-719

Petitioner

Gasperini

Petitioner Type

Petitioner

Respondent

Center for Humanities Inc.

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

518 U.S. 415 (1996)

Argued

Tuesday, April 16, 1996

Decided

Monday, June 24, 1996

Advocates

Theodore B. Olson (Argued the cause for the respondent)

Jonathan S. Abady (Argued the cause for the petitioner)

Facts of the Case

William Gasperini, a journalist and photographer, loaned 300 original slide transparencies to the Center for Humanities, Inc. When the Center lost the transparencies, Gasperini commenced suit in the District Court. The Center conceded liability. A jury awarded Gasperini $1,500 per transparency, the asserted "industry standard" of compensation for a lost transparency. The Center moved for a new trial contending that the verdict was excessive. The District Court denied the motion. The Court of Appeals observed that New York law governed the controversy in this diversity case. Under New York law appellate courts are empowered to review the size of jury verdicts and to order new trials when the jury's award "deviates materially from what would be reasonable compensation." Contrarily, under the Seventh Amendment, "the right of trial by jury shall be preserved, and no fact tried by a jury, shall be otherwise re-examined in any Court of the United States, than according to the rules of the common law." Guided by New York Appellate Division decisions reviewing damage awards for lost transparencies, the court held that the $450,000 verdict "materially deviates from what is reasonable compensation." The court vacated the judgment entered on the jury verdict and ordered a new trial, unless Gasperini agreed to an award of $100,000.

Question

Does New York's law that empowers appellate courts to review the size of jury's awards conflict with the Seventh Amendment's guarantee of jury trials in civil cases?

Conclusion

Decision: 6 votes for Gasperini, 3 vote(s) against
Legal provision: Amendment 7: Seventh Amendment

Split Vote

No. In a 5-4 plurality decision, authored by Justice Ruth Bader Ginsburg, the Court ruled that New York's law controlling compensation awards for excessiveness or inadequacy can be given effect, without detriment to the Seventh Amendment, if the review standard is applied by the federal trial court judge, with appellate control of the trial court's ruling confined to "abuse of discretion."

Libretti v. United States

Tue, 03 Oct 1995 13:00:00 +0000

Case Basics

Docket No.

94-7427

Petitioner

Libretti

Petitioner Type

Petitioner

Respondent

United States

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

516 U.S. 29 (1995)

Argued

Tuesday, October 3, 1995

Decided

Tuesday, November 7, 1995

Advocates

Sara Sun Beale (on behalf of the Petitioner)

Malcolm L. Stewart (on behalf of the Respondent)

Facts of the Case

None

Question

None

Conclusion

Decision: 8 votes for United States, 1 vote(s) against
Legal provision: Federal Rules of Criminal Procedure (or relevant rules of a circuit court)

None

Lewis v. United States

Tue, 23 Apr 1996 13:00:00 +0000

Case Basics

Docket No.

95-6465

Petitioner

Lewis

Petitioner Type

Petitioner

Respondent

United States

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

518 U.S. 322 (1996)

Argued

Tuesday, April 23, 1996

Decided

Monday, June 24, 1996

Advocates

Cornelia T. L. Pillard (Department of Justice, argued the cause for the respondent)

Steven M. Statsinger (Argued the cause for the petitioner)

Facts of the Case

Ray Lewis, a mail handler for the United States Postal Service, was observed opening several pieces of mail and pocketing the contents. Subsequently, Lewis was charged with two counts of obstructing the mail, where each charge carries a maximum authorized prison sentence of six months. Lewis requested a jury trial. Denying his request, the Magistrate Judge ordered a bench trial, explaining that because she would not sentence him to more than six months' imprisonment, he was not entitled to a jury trial. The District Court affirmed. In affirming, the Court of Appeals noted that the Sixth Amendment jury trial right pertains only to those offenses for which the legislature has authorized a maximum penalty of over six months' imprisonment. The Court continued that, because each offense charged was petty in character, the fact that Lewis was facing more than six months' imprisonment in the aggregate did not entitle him to a jury trial. The court also reasoned that because the offense's characterization as petty or serious determined the right to a jury trial, a trial judge's self-imposed limitation on sentencing could not deprive a defendant of that right.

Question

Does a defendant who is prosecuted in a single proceeding for multiple petty offenses have a constitutional right to a jury trial where the aggregate prison term authorized for the offenses exceeds six months? May a defendant who would otherwise have a constitutional right to a jury trial be denied that right because the presiding judge has made a pretrial commitment that the aggregate sentence imposed will not exceed six months?

Conclusion

Decision: 7 votes for United States, 2 vote(s) against
Legal provision: Right to Trial By Jury

No. In a 7-2 opinion delivered by Justice Sandra Day O'Connor, the Court held that no jury trial right exists where a defendant is prosecuted for multiple petty offenses. Justice O'Connor wrote for the Court that the Sixth Amendment's guarantee of the right to a jury trial does not extend to petty offenses, and its scope does not change where a defendant faces a potential aggregate prison term in excess of six months for the petty offenses charged. Because the Court ruled that no jury trial right exists where a defendant is charged with multiple petty offenses, it did not reach the second question. Justice John Paul Stevens authored a dissenting opinion, in which Justice Ruth Bader Ginsburg joined.

United States v. Armstrong

Mon, 26 Feb 1996 13:00:00 +0000

Case Basics

Docket No.

95-157

Petitioner

United States

Petitioner Type

Petitioner

Respondent

Armstrong

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

517 U.S. 456 (1996)

Argued

Monday, February 26, 1996

Decided

Monday, May 13, 1996

Advocates

Barbara E. O'Connor (Argued the cause for the respondents)

Drew S. Days, III (Argued the cause for the petitioner)

Facts of the Case

Christopher Lee Armstrong and others were indicted on federal charges of "conspiring to possess with intent to distribute more than 50 grams of cocaine base (crack) and conspiring to distribute the same." The Federal Bureau of Alcohol, Tobacco, and Firearms had monitored Armstrong and others prior to their indictment and arrest. Armstrong filed a motion for discovery or dismissal, alleging that he was selected for prosecution because he was black. The District Court granted the discovery order. It ordered the government to provide statistics on similar cases from the last three years. The government indicated it would not comply. Subsequently, the District Court dismissed the case. The government appealed. The Court of Appeals affirmed the dismissal. It held that the proof requirements for a selective-prosecution claim do not require a defendant to demonstrate that the government has failed to prosecute others who are similarly situated.

Question

Must criminal defendants who pursue selective-prosecution claims demonstrate people of other races were not prosecuted for similar crimes?

Conclusion

Decision: 8 votes for United States, 1 vote(s) against
Legal provision: Federal Rules of Criminal Procedure (or relevant rules of a circuit court)

Yes. In an 8-1 decision, announced by Chief Justice William H. Rehnquist, the Court held that in order to file selective-prosecution claims, defendants must show that the government failed to prosecute similarly situated suspects of other races. "If the claim . . . were well founded," wrote Rehnquist, "it should not have been an insuperable task to prove that persons of a different race were not prosecuted."

Citizens Bank Of Maryland v. Strumpf

Tue, 03 Oct 1995 13:00:00 +0000

Case Basics

Docket No.

94-1340

Petitioner

Citizens Bank Of Maryland

Petitioner Type

Petitioner

Respondent

Strumpf

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

516 U.S. 16 (1995)

Argued

Tuesday, October 3, 1995

Decided

Tuesday, October 31, 1995

Advocates

Miguel A. Estrada (on behalf of the United States, as amicus curiae, supporting the Petitioner)

Roger Schlossberg (on behalf of the Respondent)

Irving E. Walker (on behalf of the Petitioner)

Facts of the Case

None

Question

None

Conclusion

Decision: 9 votes for Citizens Bank Of Maryland, 0 vote(s) against
Legal provision: Bankruptcy Code, Bankruptcy Act or Rules, or Bankruptcy Reform Act of 1978

None

Norfolk & Western Railway Co. v. Hiles

Mon, 08 Jan 1996 13:00:00 +0000

Case Basics

Docket No.

95-6

Petitioner

Norfolk & Western Railway Co.

Petitioner Type

Petitioner

Respondent

Hiles

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

516 U.S. 400 (1996)

Argued

Monday, January 8, 1996

Decided

Tuesday, February 27, 1996

Advocates

Lawrence M. Mann (Argued the cause for the respondent)

Carter G. Phillips (Argued the cause for the petitioner)

Facts of the Case

Railroad cars are connected by couplers consisting of knuckles - clamps that lock with their mates - joined to the ends of drawbars, which are fastened to housing mechanisms on the cars. Cars automatically couple when they come together and one car's open knuckle engages the other car's closed knuckle. The drawbar pivots in its housing, allowing the knuckled end some lateral play to prevent moving cars from derailing on a curved track. As a consequence of this lateral movement, drawbars may remain off-center when cars are uncoupled and must be realigned manually to ensure proper coupling. William J. Hiles injured his back while attempting to realign an off-center drawbar on a car at one of Norfolk & Western Rail Company's yards. Hiles sued in Illinois state court, alleging that Norfolk & Western had violated Section 2 of the federal Safety Appliance Act (SAA), which requires that cars be equipped with "couplers coupling automatically by impact, and capable of being uncoupled, without the necessity of individuals going between the ends of the vehicles." The trial court granted Hiles a directed verdict on liability, and the state appellate court affirmed.

Question

Is a railroad liable, under the federal Safety Appliance Act, for injuries incurred by a railroad employee while trying to straighten a misaligned drawbar?

Conclusion

Decision: 9 votes for Norfolk & Western Railway Co., 0 vote(s) against
Legal provision: 49 U.S.C. 2030

No. In a unanimous decision, authored by Justice Clarence Thomas, the Court held that Section 2 of the Safety Appliance Act does not make a railroad liable as a matter of law for injuries incurred by a railroad employee while trying to straighten a misaligned drawbar. "We are understandably hesitant to adopt a reading...that would suggest that almost every railroad car in service for nearly a century has been in violation of the SAA," wrote Justice Thomas.

Markman v. Westview Instruments, Inc.

Mon, 08 Jan 1996 13:00:00 +0000

Case Basics

Docket No.

95-26

Petitioner

Markman

Petitioner Type

Petitioner

Respondent

Westview Instruments, Inc.

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

517 U.S. 370 (1996)

Argued

Monday, January 8, 1996

Decided

Tuesday, April 23, 1996

Advocates

William B. Mallin (Argued the cause for the petitioners)

Frank H. Griffin, III (Argued the cause for the respondents)

Facts of the Case

Herbert Markman owns the patent to a system that tracks clothing through the dry-cleaning process using a keyboard and data processor to generate transaction records, including a bar code readable by optical detectors. According to the patent's claim, the portion of the patent document that defines the patentee's rights, Markman's product can "maintain an inventory total" and "detect and localize spurious additions to inventory." Westview Instruments, Inc.'s product also uses a keyboard and processor and lists dry- cleaning charges on bar-coded tickets that can be read by optical detectors. In an infringement suit, after hearing an expert witness testify about the meaning of the claim's language, a jury found that Westview's product had infringed Markman's patent. However, the District Court directed a verdict for Westview on the ground that its device is unable to track "inventory" as that term is used in the claim. In affirming, the Court of Appeals held that the interpretation of claim terms is the exclusive province of the court and that the Seventh Amendment right to a jury trial is consistent with that conclusion.

Question

Is the interpretation of a patent's claim, the portion of the patent document that defines the scope of the patentee's rights, a matter of fact to be decided by jurors?

Conclusion

Decision: 9 votes for Westview Instruments, Inc., 0 vote(s) against
Legal provision: Amendment 7: Seventh Amendment

No. In a unanimous decision, authored by Justice David H. Souter, the Court held that the construction of a patent, including terms of art within its claim, is exclusively within the province of the court. Justice Souter wrote that "judges, not juries, are the better suited to find the acquired meaning of patent terms."

United States v. Ursery

Wed, 17 Apr 1996 13:00:00 +0000

Location

Eastern District Court of Michigan

231 W. Lafayette Blvd. Detroit MI 48226

Detroit, MI 48226

United States

42° 19' 49.3356" N, 83° 2' 58.2432" W

See map: Google Maps

Case Basics

Docket No.

95-345

Petitioner

United States

Petitioner Type

Petitioner

Respondent

Ursery

Respondent Type

Respondent

Consolidation

No. 95-346

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

518 U.S. 267 (1996)

Argued

Wednesday, April 17, 1996

Decided

Monday, June 24, 1996

Advocates

Lawrence S. Robbins (Argued the cause for respondent Ursery)

Jeffry K. Finer (Argued the cause for respondents $405,089.23 et al)

Michael R. Dreeben (Argued the cause for the petitioner)

Facts of the Case

Alleging that Ursery manufactured marijuana on his property, the United States government initiated criminal proceedings against Ursery and began civil forfeiture proceedings against his property. On appeal from his conviction in District Court, the Court of Appeals reversed on double-jeopardy grounds. The government then initiated a second set of proceedings against Ursery's property, which was reversed on new double-jeopardy grounds. The government appealed this decision to the Supreme Court.

Question

Do civil property forfeitures ("in rem" forfeiture) constitute a "punishment" in terms of the Fifth Amendment's double jeopardy clause which forbids successive prosecutions and punishment for the same crime?

Conclusion

Decision: 8 votes for United States, 1 vote(s) against
Legal provision: Double Jeopardy

No. Chief Justice William H. Rehnquist, in an 8-to-1 decision, held that civil property forfeitures did not constitute a "punishment" for purposes of the double jeopardy clause. While the double jeopardy clause protects a defendant from being punished twice for the same offense, criminal and civil sanctions for the same offense are distinguishable. The civil property forfeiture is a remedial civil sanction not a punitive criminal "punishment." Applying a two- part test to determine if a forfeiture constitutes a "punishment" in terms of the double jeopardy clause, the Court held that it was both Congress's intention that property forfeitures be civil in nature and that they be remedial rather than punitive. The mere resemblance between Ursery's property forfeiture and criminal drug and money-laundering punishments, did not constitute the "clearest proof" that Congress did not intend to levy both civil and criminal sanctions on Ursery's conduct. Furthermore, property forfeiture's non-punitive remedial nature is also evident in its goal of encouraging owners to care for their property by guarding against its illegal usage.

Zicherman v. Korean Air Lines Co.

Tue, 07 Nov 1995 13:00:00 +0000

Case Basics

Docket No.

94-1361

Petitioner

Zicherman

Petitioner Type

Petitioner

Respondent

Korean Air Lines Co.

Respondent Type

Respondent

Consolidation

Korean Air Lines Co., Ltd v. Zicherman, Individually and as Executrix of the Estate of Kole, No. 94-1477

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

516 U.S. 217 (1996)

Argued

Tuesday, November 7, 1995

Decided

Tuesday, January 16, 1996

Advocates

W. Paul Needham (Argued the cause for the petitioners in 94-1361 and the respondents in 94-1477)

Andrew J. Harakas (Argued the cause for Korean Air Lines Co., Ltd., in both cases)

Facts of the Case

In 1983, Korean Air Lines (KAL) Flight KE007, en route from Alaska to South Korea entered the airspace of the former Soviet Union and was shot down. All 269 people on board were killed, including Muriel Kole. Subsequently, Marjorie Zicherman and Muriel Mahalek, Kole's sister and mother sued KAL under Article 17 of the Warsaw Convention, which governs international air transportation. Zicherman and Mahalek were awarded loss-of-society damages. The Court of Appeals set aside the verdict, holding that general maritime law supplied the substantive compensatory damages law to be applied in an action under the Warsaw Convention and that, under such law, a plaintiff can recover for loss of society only if he was the decedent's dependent at the time of death. The appellate court found that Mahalek had not established dependent status and remanded the case for the District Court to determine whether Zicherman was a dependent of the decedent.

Question

May a plaintiff, in a suit brought under Article 17 of the Warsaw Convention governing international air transportation, recover damages for loss of society resulting from the death of a relative in a plane crash on the high seas?

Conclusion

Decision: 9 votes for Korean Air Lines Co., 0 vote(s) against
Legal provision: Treaty

No. In a unanimous opinion delivered by Justice Antonin Scalia, the Court held that the relatives could not recover loss-of-society damages under the Warsaw Convention because Article 17 left it to the adjudicating court to specify what harm was cognizable as determined by domestic law, which is supplied by the Death on the High Seas Act (DOHSA). Justice Scalia then reasoned that, because DOHSA permits only pecuniary damages, the plaintiffs were not entitled to recover loss-of-society damages. The Court, therefore, did not reach the question whether, under general maritime law, dependency is a prerequisite for loss-of-society damages. Thus, the Court reversed the Court of Appeal's judgement insofar as it permitted Zicherman to recover loss-of-society damages if she could establish her dependency on the decedent and affirmed its decision with regards to vacating the award of loss-of-society damages to Mahalek is affirmed.

Romer v. Evans

Tue, 10 Oct 1995 13:00:00 +0000

Location

Colorado General Assembly

200 E Colfax Ave Denver CO 80203

Denver, CO 80203

United States

39° 44' 24.1332" N, 104° 59' 3.9048" W

See map: Google Maps

Case Basics

Docket No.

94-1039

Petitioner

Romer

Petitioner Type

Petitioner

Respondent

Evans

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

517 U.S. 620 (1996)

Argued

Tuesday, October 10, 1995

Decided

Monday, May 20, 1996

Advocates

Timothy M. Tymkovich (on behalf of the Petitioners)

Jean E. Dubofsky (on behalf of the Respondents)

Facts of the Case

Colorado voters adopted Amendment 2 to their State Constitution precluding any judicial, legislative, or executive action designed to protect persons from discrimination based on their "homosexual, lesbian, or bisexual orientation, conduct, practices or relationships." Following a legal challenge by homosexual and other aggrieved parties, the state trial court entered a permanent injunction enjoining Amendment 2's enforcement. The Colorado Supreme Court affirmed on appeal.

Question

Does Amendment 2 of Colorado's State Constitution, forbidding the extension of official protections to those who suffer discrimination due to their sexual orientation, violate the Fourteenth Amendment's Equal Protection Clause?

Conclusion

Decision: 6 votes for Evans, 3 vote(s) against
Legal provision: Equal Protection

Yes. In a 6-to-3 decision, the Court held that Amendment 2 of the Colorado State Constitution violated the equal protection clause. Amendment 2 singled out homosexual and bisexual persons, imposing on them a broad disability by denying them the right to seek and receive specific legal protection from discrimination. In his opinion for the Court, Justice Anthony Kennedy noted that oftentimes a law will be sustained under the equal protection clause, even if it seems to disadvantage a specific group, so long as it can be shown to "advance a legitimate government interest." Amendment 2, by depriving persons of equal protection under the law due to their sexual orientation failed to advance such a legitimate interest. Justice Kennedy concluded: "If the constitutional conception of 'equal protection of the laws' means anything, it must at the very least mean that a bare desire to harm a politically unpopular group cannot constitute a legitimate governmental interest."

Doctor's Associates Inc. v. Casarotto

Tue, 16 Apr 1996 13:00:00 +0000

Case Basics

Docket No.

95-559

Petitioner

Doctor's Associates Inc.

Petitioner Type

Petitioner

Respondent

Casarotto

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

517 U.S. 681 (1996)

Argued

Tuesday, April 16, 1996

Decided

Monday, May 20, 1996

Advocates

Mark R. Kravitz (Argued the cause for the petitioners)

Lucinda A. Sikes (Argued the cause for the respondents)

Facts of the Case

Paul Casarotto, a Subway sandwich shop franchisee, sued franchisor Doctor's Associates, Inc. (DAI) and its agent, Nick Lombardi, in a Montana state court when a dispute arose between the parties with regard to a standard form franchise agreement for the operation of the shop. The court stayed the lawsuit pending arbitration pursuant to the arbitration clause set out in ordinary type on page nine of the franchise agreement. In reversing, the Montana Supreme Court held that the arbitration clause was unenforceable because it did not meet the state-law requirement, 27-5-114(4), that "[n]otice that a contract is subject to arbitration" be "typed in underlined capital letters on the first page of the contract." DAI and Lombardi unsuccessfully argued that the state-law requirement was preempted by the Federal Arbitration Act (FAA), which declares written provisions for arbitration "valid, irrevocable, and enforceable, save upon such grounds as exist at law or in equity for the revocation of any contract." The Montana Supreme Court focused on the question of whether the application of 27-5-114(4)'s notice requirement would undermine the FAA's goals and policies. In the Montana court's judgment, the notice requirement did not undermine these goals and policies, for it did not preclude arbitration agreements altogether.

Question

Does the Federal Arbitration Act preempt Montana's first-page notice of arbitration requirement?

Conclusion

Decision: 8 votes for Doctor's Associates Inc., 1 vote(s) against
Legal provision: 9 U.S.C. 2

Yes. In a 8-1 decision, authored by Justice Ruth Bader Ginsburg, the Court ruled that Montana's first-page notice requirement, 27-5-114(4), which governs not "any contract," but specifically and solely contracts "subject to arbitration," conflicts with the Federal Arbitration Act (FAA) and is therefore displaced by the federal measure. Justice Ginsburg wrote that Congress "precluded states from singling out arbitration provisions for suspect status" when it passed the FAA.

Carlisle v. United States

Tue, 16 Jan 1996 13:00:00 +0000

Case Basics

Docket No.

94-9247

Petitioner

Carlisle

Petitioner Type

Petitioner

Respondent

United States

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

517 U.S. 416 (1996)

Argued

Tuesday, January 16, 1996

Decided

Monday, April 29, 1996

Advocates

Paul A. Engelmayer (on behalf of the Respondent)

James A. Christopherson (Argued the cause for the petitioner)

Facts of the Case

At his trial on a federal marijuana charge, Charles Carlisle filed a motion for a judgment of acquittal under Federal Rule of Criminal Procedure 29(c) after the jury returned a guilty verdict. The District Court granted the motion even though it was filed one day outside the time limit prescribed by Rule 29(c), which provides that "[i]f the jury returns a verdict of guilty..., a motion for judgment of acquittal may be made or renewed within 7 days after the jury is discharged or within such further time as the court may fix during the 7-day period." In reversing and remanding for reinstatement of the verdict and for sentencing, the Court of Appeals held that under Rule 29(c) a district court has no jurisdiction to grant an untimely motion for judgment of acquittal, or to enter such a judgment after submission of the case to the jury.

Question

Does a district court have the authority to grant a post-verdict motion for judgment of acquittal if the motion is filed beyond the seven-day deadline prescribed by Federal Rule of Criminal Procedure 29(c)?

Conclusion

Decision: 7 votes for United States, 2 vote(s) against
Legal provision: Federal Rules of Criminal Procedure (or relevant rules of a circuit court)

No. In an opinion authored by Justice Antonin Scalia, the Court held that the District Court had no authority to grant the petitioner's motion for judgment of acquittal filed one day outside the Rule 29(c) time limit. Judges may not stretch the deadline by even one day; Justice Scalia wrote for the court that, "[t]here is simply no room...for the granting of an untimely post-verdict motion for judgment of acquittal, regardless of whether the motion is accompanied by a claim of actual innocence...."

Felker v. Turpin

Mon, 03 Jun 1996 13:00:00 +0000

Case Basics

Docket No.

95-8836

Petitioner

Felker

Petitioner Type

Petitioner

Respondent

Turpin

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

518 U.S. 651 (1996)

Argued

Monday, June 3, 1996

Decided

Friday, June 28, 1996

Advocates

Susan V. Boleyn (Argued the cause for the respondent)

Henry P. Monaghan (Argued the cause for the petitioner)

Drew S. Days, III (On behalf of the United States, as amicus curiae, supporting the respondent)

Facts of the Case

Ellis Felker filed a petition for writ of habeas corpus, appellate or certiorari review, and stay of execution after having his convictions for capital murder, rape, aggravated sodomy, and false imprisonment affirmed on appeal. Felker's habeas petition challenged the constitutionality of Title I of the Antiterrorism and Effective Death Penalty Act of 1996 (the "Act"). Title I of the Act requires that all motions for filing a second or successive habeas appeal from a district court be reviewed by an appellate panel whose decision shall not be appealable by writ of certiorari to the Supreme Court.

Question

Do the Act's Title I provisions, preventing the Supreme Court from reviewing an appellate review panel's denial of leave to file a second habeas petition, unconstitutionally "suspend" the habeas writ and restrict the Court's authority to entertain original habeas petitions?

Conclusion

Decision: 9 votes for Turpin, 0 vote(s) against
Legal provision: 28 USC 2241-2255 (habeas corpus)

No. The unanimous Court held that the Act's creation of an appellate panel, charged with reviewing all second or successive habeas applications, is not unconstitutional. The Act simply transfers the duty of habeas review from the district courts to an appellate panel. While the Act prevents an appeal to the Court from an appellate panel's denial of leave to file a second habeas petition, it does not repeal the Court's authority to entertain original habeas petitions. Thus, the shift in habeas "gatekeeping" duties to an appellate panel is neither an unconstitutional "suspension" of the habeas writ which would violate the Exceptions Clause of Article III, nor a deprivation of the Court's appellate jurisdiction.

Rutledge v. United States

Mon, 27 Nov 1995 13:00:00 +0000

Case Basics

Docket No.

94-8769

Petitioner

Rutledge

Petitioner Type

Petitioner

Respondent

United States

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

517 U.S. 292 (1996)

Argued

Monday, November 27, 1995

Decided

Wednesday, March 27, 1996

Advocates

James A. Feldman (Argued the cause for the United States)

Barry Levenstam (Argued the cause for the petitioner)

Facts of the Case

Tommy L. Rutledge was found guilty of conspiracy to distribute controlled substances and of conducting a continuing criminal enterprise. The District Court convicted Rutledge on both counts. It sentenced him to life imprisonment without possible release on each count. The sentences were to be served concurrently. The Court of Appeals affirmed. It rejected Rutledge's argument that his convictions and concurrent life sentences punished him twice for the same offense.

Question

Can a criminal be given concurrent life sentences for conspiring to distribute drugs and operating a continuing criminal enterprise?

Conclusion

Decision: 9 votes for Rutledge, 0 vote(s) against
Legal provision: 21 U.S.C. 848

No. In a unanimous decision, announced by Justice John Paul Stevens, the Court ruled one of the two sentences must be dropped. Both of the offenses were based on the same criminal act. Justice Stevens wrote, "A guilty verdict on a (continuing criminal enterprise) charge necessarily includes a finding that the defendant also participated in a conspiracy."

Henderson v. United States

Tue, 19 Mar 1996 13:00:00 +0000

Case Basics

Docket No.

95-232

Petitioner

Henderson

Petitioner Type

Petitioner

Respondent

United States

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

517 U.S. 654 (1996)

Argued

Tuesday, March 19, 1996

Decided

Monday, May 20, 1996

Advocates

Malcolm L. Stewart (Argued the cause for the respondent)

Richard A. Sheehy (Argued the cause for the petitioner)

Facts of the Case

Lloyd Henderson, a merchant mariner, was injured while working aboard a United States vessel. After exhausting administrative remedies, Henderson filed a seaman's personal injury action against the United States under the Suits in Admiralty Act. Henderson's complaint was filed close to, but within, the two- year limit set on complaints by the Act. Henderson then followed the Federal Rules of Civil Procedure on the service of the summons and complaint, or service of process, to the proper authorities. The United States argued that Henderson failed to serve the complaint "forthwith," or without delay. This deprived the court of jurisdiction because "forthwith" service is a prerequisite for the government's waiver of sovereign immunity under the Act. The government's argument prevailed and the federal District Court dismissed Henderson's suit. Henderson lost on appeal. The U.S. Supreme Court granted certiorari.

Question

Is service of process under the Suits of Admiralty Act a matter of procedure governed by the uniform Federal Rules of Civil Procedure?

Conclusion

Decision: 6 votes for Henderson, 3 vote(s) against
Legal provision: Federal Rules of Civil Procedure, including Appellate Procedure (or relevant rules of a circuit court)

Yes. In a 6-to-3 opinion by Justice Ruth Bader Ginsburg contended that process of service was primarily a means to notify another of impending legal action in a way that provides the defendant adequate time to answer and present defenses. The Court held that "[t]he federal rules thus convey a clear message: Complaints are not to be dismissed if served within 120 days, or within such additional time as the court may allow."

Varity Corp. v. Howe

Wed, 01 Nov 1995 13:00:00 +0000

Case Basics

Docket No.

94-1471

Petitioner

Varity Corp.

Petitioner Type

Petitioner

Respondent

Howe

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

516 U.S. 489 (1996)

Argued

Wednesday, November 1, 1995

Decided

Tuesday, March 19, 1996

Advocates

Edwin S. Kneedler (Department of Justice, argued the cause for the United State, as amicus curiae, supporting the respondents)

H. Richard Smith (Argued the cause for the respondents)

Floyd Abrams (Argued the cause for the petitioner)

Facts of the Case

Charles Howe and others used to work for Massey-Ferguson, Inc., a farm equipment manufacturer, and a wholly owned subsidiary of the Varity Corporation. These employees all were participants in, and beneficiaries of, Massey-Ferguson's self-funded employee welfare benefit plan, an Employee Retirement Income Security Act of 1974 (ERISA protected plan that Massey- Ferguson administered itself. When certain divisions in Massey-Ferguson stared losing money, Varity decided to transfer them to a separately incorporated subsidiary, Massey Combines. Varity also persuaded the employees of the failing divisions to change employers and benefit plans, conveying the message that employees' benefits would remain secure when they transferred. Ultimately, the employees lost their nonpension benefits. The employees filed an action under ERISA, claim that Varity, through trickery, had led them to withdraw from their old plan and forfeit their benefits. The District Court found that Varity and Massey-Ferguson, acting as ERISA fiduciaries, had harmed plan beneficiaries through deliberate deception, which gave the employees to right to relief, including the reinstatement to the old plan. The Court of Appeals affirmed.

Question

Did the Varity Corporation and Massey-Ferguson, Inc. act their capacity as an Employee Retirement Income Security Act of 1974fiduciary when they significantly and deliberately misled the beneficiaries? By doing so, did Varity and Massey-Ferguson violate the fiduciary obligations that ERISA imposes upon plan administrators? Does ERISA authorize a lawsuit in such cases?

Conclusion

Decision: 6 votes for Howe, 3 vote(s) against
Legal provision: Employee Retirement Income Security

Yes, yes, and yes. In a 6-3 opinion delivered by Justice Stephen G. Breyer, the Court held that, under the specific factual circumstances, Varity and Massey-Ferguson acted in their capacity as an ERISA fiduciary when they significantly and deliberately misled the plan's beneficiaries, thereby violating their fiduciary obligations imposed by ERISA. Finding that ERISA's general purpose of protecting beneficiaries' interests also favors a reading that provides a remedy, Justice Breyer said that Varity and Massey-Ferguson violated the fiduciary obligations imposed upon the plan's administrator by ERISA, by knowingly and significantly deceiving the employees as to the financial viability of the new entity and the future of the new entity's benefits plan, in order to save the employer money at the expense of the beneficiaries and that they could thus be sued for equitable relief by the individual beneficiaries. Justice Clarence Thomas filed a dissenting opinion, in which Justices Sandra Day O'Connor and Antonin Scalia joined.

Gray v. Netherland, Warden

Mon, 15 Apr 1996 13:00:00 +0000

Case Basics

Docket No.

95-6510

Petitioner

Gray

Petitioner Type

Petitioner

Respondent

Netherland, Warden

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

518 U.S. 152 (1996)

Argued

Monday, April 15, 1996

Decided

Thursday, June 20, 1996

Advocates

John H. McLees (Argued the cause for the respondent)

Mark E. Olive (Argued the cause for the petitioner)

Facts of the Case

Coleman Wayne Gray was tried for the murder of Richard McClelland in Virginia. The prosecution acknowledged that if the trial reached the capital penalty phase they would introduce Gray's admissions to other inmates that he had previously murdered 2 other people. Gray's attorney moved to exclude the evidence because Gray had not been officially charged with such crimes. Gray also claimed such evidence was a surprise tactic and that he could not pose the proper defense immediately. The Virginia trial court denied the motion to exclude. Subsequently, Gray was sentenced to death. After exhausting state remedies, Gray sough federal habeas corpus relief. He claimed that inadequate notice of evidence prevented him from a fair defense in the penalty phase of his capital trial in violation of his right to Due Process under the Fourteenth Amendment. The District Court initially denied the petition because it found Gray had no constitutional right to notice of individual testimony. Later, the District Court amended its ruling, holding that Gray was denied due process when the state failed to provide notice of what murder evidence would be presented. The Court of Appeals reversed the District Court. It found that to grant the habeas corpus relief would be to recognize a new federal constitutional law regarding notice-of-evidence claims.

Question

Can a defendant sentenced to death argue in his habeas corpus petition that prosecutors deceived him, in violation of the Fourteenth Amendment Due Process Clause, by producing surprise evidence in the sentencing phase of the trial?

Conclusion

Decision: 5 votes for Gray, 4 vote(s) against
Legal provision:

No. In a 5-4 decision, announced by Chief Justice William H. Rehnquist, the Court ruled that the notice-of-evidence claim would require the adoption of a new constitutional rule and therefore could not be raised in a habeas petition. In her dissent, Justice Ruth Bader maintained that due process allows Gray the right to a "full, fair, potentially effective opportunity to defend against the State's charges." Gary was not given that right.

Brotherhood Of Locomotive Engineers v. Atchison, Topeka & Santa Fe Railroad Co.

Mon, 30 Oct 1995 13:00:00 +0000

Case Basics

Docket No.

94-1592

Petitioner

Brotherhood Of Locomotive Engineers et al.

Petitioner Type

Petitioner

Respondent

Atchison, Topeka & Santa Fe Railroad Co. et al.

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

516 U.S. 152 (1996)

Argued

Monday, October 30, 1995

Decided

Monday, January 8, 1996

Advocates

Lawrence M. Mann (on behalf of the Petitioners)

Malcolm L. Stewart (on behalf of the Federal Respondent)

Ronald M. Johnson (on behalf of the Railroad Respondents)

Facts of the Case

None

Question

None

Conclusion

Decision: 9 votes for Atchison, Topeka & Santa Fe Railroad Co., 0 vote(s) against
Legal provision: 49 U.S.C. 2110

None

Loving v. United States

Tue, 09 Jan 1996 13:00:00 +0000

Case Basics

Docket No.

94-1966

Petitioner

Loving

Petitioner Type

Petitioner

Respondent

United States

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

517 U.S. 748 (1996)

Argued

Tuesday, January 9, 1996

Decided

Monday, June 3, 1996

Advocates

John H. Blume (Argued the cause for the petitioner)

Edwin S. Kneedler (Argued the cause for the respondent)

Facts of the Case

A general court-martial found Dwight J. Loving, an Army private, guilty of both premeditated murder and felony murder under Article 118 of the Uniform Code of Military Justice. The court-martial sentenced Loving to death based on the aggravating factors that the premeditated murder was committed during a robbery and that he had committed a second murder. The commander who convened the court-martial approved the findings and sentence. In affirming, the U.S. Army Court of Military Review and the U.S. Court of Appeals for the Armed Forces rejected Loving's contention that the President lacked the authority to prescribe aggravating factors in capital murder cases that enabled the court- martial to sentence him to death. Loving claimed that the separation-of-powers principle prevented the President from promulgating the Executive Order.

Question

Does the President have the authority, consistent with the separation-of- powers principle, to prescribe aggravating factors that permit a court-martial to impose the death penalty upon a member of the armed forces convicted of murder?

Conclusion

Decision: 9 votes for United States, 0 vote(s) against
Legal provision:

Yes. In a unanimous opinion delivered by Justice Anthony Kennedy, the Court held that not only does the Constitution require the aggravating factors of the military's death penalty, but that the President's prescription of the challenged aggravating factors did not violate the separation-of-powers principle. Justice Kennedy wrote, "[a]lthough it may not delegate the power to make the law...Congress may delegate to others the authority or discretion to execute the law under and in pursuance of its terms."

Board of County Commissioners v. Umbehr

Tue, 28 Nov 1995 13:00:00 +0000

Case Basics

Docket No.

94-1654

Petitioner

Board of County Commissioners

Petitioner Type

Petitioner

Respondent

Umbehr

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

518 U.S. 668 (1996)

Argued

Tuesday, November 28, 1995

Decided

Friday, June 28, 1996

Advocates

Beth S. Brinkmann (On behalf of the United States, as amicus curiae, argued in support of the respondent)

Robert A. Van Kirk (Argued the cause for the respondent)

Donald R. Patterson (Argued the cause for the petitioner)

Facts of the Case

Umbehr was an independent trash-hauling contractor for Wabaunsee County, Kansas. He frequently criticized the County's Board of Commissioners (the Board). When the Board voted to terminate his contract, supposedly because the Board grew tired of his constant criticisms, Umbehr filed suit against two of the Board's members. Umbehr alleged that his termination resulted from his criticisms of the Board and, therefore, infringed on his First Amendment right to freedom of speech. On appeal from the District Court's grant of summary judgment to the Board, the Tenth Circuit reversed and the Supreme Court granted Umbehr's petition for certiorari.

Question

Did the Board's termination of Umbehr's contract, presumably as a result of his criticisms, constitute a violation of his First Amendment freedom of speech?

Conclusion

Decision: 7 votes for Umbehr, 2 vote(s) against
Legal provision: Amendment 1: Speech, Press, and Assembly

Yes. In an opinion by Justice Sandra Day O'Connor, the Court held that the First Amendment's guarantee of freedom of speech shielded Umbehr, as a government employee, from termination due to things he might have said about the Board. Umbehr successfully proved that his criticisms of the Board preceded his termination and were the primary motivating factor behind its retaliatory termination of his contract. The Court added that, in balancing an employee's interest in commenting on public concerns against an employer's interest in promoting efficient performance by its employees, it could not find any countervailing county interest justifying its infringement of Umbehr's freedom of speech.