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.

Sat, 19 May 2012 11:09:51 +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

Sat, 19 May 2012 11:09:54 +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

Sat, 19 May 2012 11:09:55 +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.