Cases - 2000 term

Glover v. United States

Mon, 27 Nov 2000 13:00:00 +0000

Case Basics

Docket No.

99-8576

Petitioner

Glover

Petitioner Type

Petitioner

Respondent

United States

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

531 U.S. 198 (2001)

Argued

Monday, November 27, 2000

Decided

Tuesday, January 9, 2001

Advocates

Michael R. Dreeben (Department of Justice, argued the cause for the respondent)

Michael L. Waldman (Argued the cause for the petitioner)

Facts of the Case

In the 1980's and early 1990's, Paul Glover was the Vice President and General Counsel of the Chicago Truck Drivers, Helpers, and Warehouse Workers Union. Ultimately, Glover was convicted of federal labor racketeering, money laundering, and tax evasion, among other things, after using his control over the union's investments to enrich himself through kickbacks. Glover's probation officer, in his pre-sentence investigation report, recommended that Glover's federal labor racketeering, money laundering, and tax evasion convictions be grouped under the United States Sentencing Commission's Guidelines Manual section 3D1.2, which allows the grouping of counts involving substantially the same harm. The Federal Government objected to the grouping and the District Court agreed. Glover's offense level was thus increased by two levels, resulting in an increased sentence of between 6 and 21 months. Glover's counsel did not pursue the grouping issue on appeal. Glover then filed a pro se motion to correct his sentence, arguing that his counsel's failure to pursue the issue was ineffective assistance, without which his offense level would have been lower. The District Court denied Glover's motion, concluding that a 6 to 21 month sentencing increase was not significant enough to establish prejudice under the test for ineffective assistance of counsel articulated in Strickland v. Washington. Thus, the court denied his ineffective-assistance claim. The Court of Appeals affirmed.

Question

Is a significant increase on a prison sentence required in order to show prejudice in a claim for ineffective assistance of counsel?

Conclusion

Decision: 9 votes for Glover, 0 vote(s) against
Legal provision: Right to Counsel

No. In a unanimous opinion delivered by Justice Anthony M. Kennedy, the Court held that Court of appeals erred in engrafting onto the prejudice branch of the Strickland test the requirement that any increase in sentence must meet a standard of significance. Thus, the denial of Glover's motion to correct his sentence was reversed and remanded. Justice Kennedy wrote for the Court that the Court of Appeals erred "because there is no obvious dividing line by which to measure how much longer a sentence must be for the increase to constitute substantial prejudice. ... Although the amount by which a defendant's sentence is increased by a particular decision may be a factor to consider in determining whether counsel's performance in failing to argue the point constitutes ineffective assistance, ...it cannot serve as a bar to a showing of prejudice."

FEC v. Colorado Republican Federal Campaign Cmte.

Wed, 28 Feb 2001 13:00:00 +0000

Location

White House

1600 Pennsylvania Avenue Washington D.C. 20500

Washington 20500

United States

38° 53' 55.4928" N, 77° 2' 11.8536" W

See map: Google Maps

Case Basics

Docket No.

00-191

Petitioner

FEC

Petitioner Type

Petitioner

Respondent

Colorado Republican Federal Campaign Cmte.

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

533 U.S. 431 (2001)

Argued

Wednesday, February 28, 2001

Decided

Monday, June 25, 2001

Advocates

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

Barbara D. Underwood (Department of Justice, argued the cause for the petitioner)

Facts of the Case

The Federal Election Campaign Act of 1971's definition of "contribution" includes "expenditures made by any person in cooperation, consultation, or concert, with, or at the request or suggestion of, a candidate, his authorized political committees, or their agents." The U.S. Supreme Court, in Buckley v. Valeo, held that the limitations on political campaign contributions in the Act were generally constitutional, but that the Act's limitations on election expenditures infringed political expression in violation of the First Amendment. In Colorado Republican Federal Campaign Committee v. FEC, the Court held that the First Amendment prohibits the application of the Party Expenditure Provision of the Act to "an expenditure that the political party has made independently, without coordination with any candidate." In the wake of this decision, the Committee's broader claim remained, that the congressional campaign expenditure limitations on parties themselves are facially unconstitutional and thus unenforceable even as to spending coordinated with a candidate. The District Court ruled in favor of the committee and the Court of Appeals affirmed.

Question

Are congressional campaign expenditure limitations on parties facially unconstitutional and thus unenforceable even as to spending coordinated with a candidate?

Conclusion

Decision: 5 votes for FEC, 4 vote(s) against
Legal provision: Federal Election Campaign

No. In a 5-4 opinion delivered by Justice David H. Souter, the Court held that "a party's coordinated expenditures, unlike expenditures truly independent, may be restricted to minimize circumvention of contribution limits." Justice Souter noted that "'there is little evidence to suggest that coordinated party spending limits adopted by Congress have frustrated the ability of political parties to exercise their First Amendment rights to support their candidates.'" Justice Clarence Thomas filed a dissenting opinion, which was joined by Chief Justice William H. Rehnquist and Justices Antonin Scalia and Anthony M. Kennedy. Justice Thomas argued that the spending limit "sweeps too broadly, interferes with the party-candidate relationship, and has not been proved necessary to combat corruption."

INS v. St. Cyr

Tue, 24 Apr 2001 13:00:00 +0000

Case Basics

Docket No.

00-767

Petitioner

INS

Petitioner Type

Petitioner

Respondent

St. Cyr

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

533 U.S. 289 (2001)

Argued

Tuesday, April 24, 2001

Decided

Monday, June 25, 2001

Advocates

Edwin S. Kneedler (Department of Justice, Washington, D.C., argued the cause for the petitioner)

Lucas Guttentag (Argued the cause for the respondent)

Facts of the Case

On March 8, 1996, Enrico St. Cyr, a lawful permanent resident, pled guilty in a Connecticut court to a charge of selling a controlled substance. That conviction made him deportable. Before the effective dates of the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA) and the Illegal Immigration Reform and Immigrant Responsibility Act of 1996 (IIRIRA) section 212(c) of the Immigration and Nationality Act of 1952 was interpreted to give the Attorney General broad discretion to waive deportation of resident aliens. The AEDPA and IIRIRA restricted the class of aliens depending on section 212(c) for relief. St. Cyr's removal proceedings commenced after AEDPA's and IIRIRA's effective dates. Subsequently, the Attorney General claimed that the AEDPA and IIRIRA withdrew his authority to grant St. Cyr a waiver. The District Court accepted St. Cyr's habeas corpus application and agreed that the new restrictions do not apply to removal proceedings brought against an alien who pleaded guilty to a deportable crime before their enactment. The Court of Appeals affirmed.

Question

Do the Antiterrorism and Effective Death Penalty Act of 1996 and the Illegal Immigration Reform and Immigrant Responsibility Act of 1996 strip district courts of their jurisdiction under the general habeas corpus statute to entertain St. Cyr's challenge? Do the AEDPA and IIRIRA deny relief under section 212(c) of the Immigration and Nationality Act of 1952 to aliens who would have been eligible for such relief at the time of their convictions?

Conclusion

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

No and no. In a 5-4 opinion delivered by Justice John Paul Stevens, the Court held that habeas jurisdiction was not repealed by AEDPA and IIRIRA. Additionally, the Court held that "[section 212(c)] relief remains available for aliens, like [Enrico St. Cyr], whose convictions were obtained through plea agreements and who, notwithstanding those convictions, would have been eligible for [section 212(c)] relief at the time of their plea under the law then in effect." Justice Stevens wrote that "[w]e find nothing in IIRIRA unmistakably indicating that Congress considered the question whether to apply its repeal of [section 212(c)] retroactively to such aliens."

Buckhannon Board & Care Home v. West Virginia

Tue, 27 Feb 2001 13:00:00 +0000

Case Basics

Docket No.

99-1848

Petitioner

Buckhannon Board & Care Home

Petitioner Type

Petitioner

Respondent

West Virginia

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

532 U.S. 598 (2001)

Argued

Tuesday, February 27, 2001

Decided

Tuesday, May 29, 2001

Advocates

David P. Cleek (Charleston, West Virginia, argued the cause for the respondents)

Beth S. Brinkmann (Department of Justice, on behalf of the United States, as amicus curiae, supporting the petitioners)

Webster J. Arceneaux, III (Argued the cause for the petitioners)

Facts of the Case

Buckhannon Board and Care Home, Inc. operates care homes that provide assisted living to their residents. Buckhannon filed an inspection by the West Virginia fire marshal's office because some residents were incapable of "self- preservation." Buckhannon brought suit against the State and others arguing that the "self-preservation" requirement violated the Fair Housing Amendments Act of 1988 (FHAA) and the Americans with Disabilities Act of 1990 (ADA). Afterwards the state legislature eliminated the requirement and the District Court dismissed the case as moot. Buckhannon then requested attorney's fees as the "prevailing party" under the FHAA and ADA. Buckhannon based its claim on the "catalyst theory," which posits that a plaintiff is a "prevailing party" if it achieves the desired result because the lawsuit brought about a voluntary change in the defendant's conduct. The District Court denied the motion. The Court of Appeals affirmed.

Question

Does the term "prevailing party" include a party that has failed to secure a judgment on the merits or a court-ordered consent decree, but has nonetheless achieved the desired result because the lawsuit brought about a voluntary change in the defendant's conduct?

Conclusion

Decision: 5 votes for West Virginia, 4 vote(s) against
Legal provision: Americans with Disabilities Act (ADA)

No. In a 5-4 opinion delivered by Chief Justice William H. Rehnquist, the Court held that the "catalyst theory" is not a permissible basis for the award of attorney's fees under the FHAA and ADA. "In the United States, parties are ordinarily required to bear their own attorney's fees -- the prevailing party is not entitled to collect from the loser," wrote Chief Justice Rehnquist, "[u]nder this 'American Rule,' we follow 'a general practice of not awarding fees to a prevailing party absent explicit statutory authority.'" Dissenting, Justice Ruth Bader Ginsburg argued that "Congress prescribed fee-shifting provisions like those included in the FHAA and ADA to encourage private enforcement of laws designed to advance civil rights. Fidelity to that purpose calls for court-awarded fees when a private party's lawsuit, whether or not its settlement is registered in court, vindicates rights Congress sought to secure."

Ferguson v. City of Charleston

Wed, 04 Oct 2000 13:00:00 +0000

Location

Medical University of South Carolina

171 Ashley Avenue Charleston SC 29425

Charleston, SC 29425

United States

32° 47' 7.944" N, 79° 56' 47.9508" W

See map: Google Maps

Case Basics

Docket No.

99-936

Petitioner

Ferguson

Petitioner Type

Petitioner

Respondent

City of Charleston

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

532 U.S. 67 (2001)

Argued

Wednesday, October 4, 2000

Decided

Wednesday, March 21, 2001

Advocates

Priscilla J. Smith (Argued the cause for the petitioners)

Robert H. Hood (Argued the cause for the respondents)

Facts of the Case

After an increase in the use of cocaine by patients receiving prenatal care, the Medical University of South Carolina (MUSC) started to cooperate with Charleston to formulate a policy to prosecute mothers whose children tested positive for drugs at birth. MUSC obstetrical patients were arrested after testing positive for cocaine. They filed suit challenging the policy's validity on the theory that warrantless and nonconsensual drug tests conducted for criminal investigatory purposes were unconstitutional searches. Among the District Court's actions was an instruction to the jury to find for the patients unless they had consented to such searches. The jury found in favor of the city. In affirming, the Court of Appeals held that the searches were reasonable, reasoning that special needs may, in certain exceptional circumstances, justify a search policy designed to serve non-law-enforcement ends.

Question

Is a state hospital's performance of a diagnostic test to obtain evidence of a patient's criminal conduct for law enforcement purposes an unreasonable search in violation of the Fourth Amendment if the patient has not consented to the procedure?

Conclusion

Decision: 6 votes for Ferguson, 3 vote(s) against
Legal provision: Amendment 4: Fourth Amendment

Yes. In a 6-3 opinion delivered by Justice John Paul Stevens, the Court held that the diagnostic tests constituted an unreasonable search if the patient has not consented to the procedure. The interest in using the threat of criminal sanctions to deter pregnant women from using cocaine cannot justify a departure from the general rule that an official nonconsensual search is unconstitutional if not authorized by a valid warrant. Examining the "special needs" exception to the Fourth Amendment, Justice Stevens wrote that a special need is "divorced from the State's general interest in law enforcement," and that under the city's view "virtually any nonconsensual suspicionless search could be immunized under the special needs doctrine by defining the search solely in terms of its ultimate...purpose."

Calcano-Martinez v. INS

Tue, 24 Apr 2001 13:00:00 +0000

Case Basics

Docket No.

00-1011

Petitioner

Calcano-Martinez et al.

Petitioner Type

Petitioner

Respondent

INS

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

533 U.S. 348 (2001)

Argued

Tuesday, April 24, 2001

Decided

Monday, June 25, 2001

Advocates

Edwin S. Kneedler (Department of Justice, argued the cause for the respondent)

Lucas Guttentag (Argued the cause for the petitioners)

Facts of the Case

The Illegal Immigration Reform and Immigrant Responsibility Act of 1996 (IIRIRA) expressly precludes courts of appeals from exercising "jurisdiction to review any final order of removal against any alien who is removable by reason of "a conviction for certain criminal offenses, including any aggravated felony." Deboris Calcano-Martinez, Sergio Madrid, and Fazila Khan are all lawful permanent residents of the United States subject to administratively final orders of removal because they were convicted of aggravated felonies. Each filed a petition for review in the Court of Appeals and a habeas corpus petition in the District Court to challenge the Board of Immigration Appeals' determination that they were ineligible to apply for a discretionary waiver of deportation under former section 212(c) of the Immigration and Nationality Act. The Court of Appeals dismissed the petitions for lack of jurisdiction. The court also held that they could pursue their claims in a District Court habeas action.

Question

Does the Illegal Immigration Reform and Immigrant Responsibility Act of 1996 remove the jurisdiction of federal appellate courts to review direct appeals of final deportation orders, but preserve federal district courts' habeas jurisdiction over challenges to those orders?

Conclusion

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

Yes. In a 5-4 opinion delivered by Justice John Paul Stevens, the Court held that the Court of Appeals lacked jurisdiction to hear the petitions for direct but petitioners can proceed with their habeas petitions if they wish to obtain relief. "As petitioners in this case were convicted of 'aggravated felonies' within the meaning of the relevant statutes," wrote Justice Stevens, "the plain language of [IIRIRA] fairly explicitly strips the courts of appeals of jurisdiction to hear their claims on petitions for direct review." Justice Stevens continued that "Congress has not spoken with sufficient clarity to strip the district courts of jurisdiction to hear habeas petitions raising identical claims."

Atwater v. City of Lago Vista

Mon, 04 Dec 2000 13:00:00 +0000

Location

Travis County Jail

3614 Bill Price Road Del Valle TX 78617

Del Valle, TX 78617

United States

30° 11' 45.4992" N, 97° 38' 43.8936" W

See map: Google Maps

Case Basics

Docket No.

99-1408

Petitioner

Atwater

Petitioner Type

Petitioner

Respondent

City of Lago Vista

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

532 U.S. 318 (2001)

Argued

Monday, December 4, 2000

Decided

Tuesday, April 24, 2001

Advocates

Andy Taylor (Et al., as amici curiae, supporting the respondent)

Robert C. De Carli (Argued the cause for the petitioners)

Roger J. George, Jr. (Argued the cause for the respondents)

Facts of the Case

Under Texas law, it is a misdemeanor, punishable only by a fine, either for a front-seat passenger in a car equipped with safety belts not to wear one or for the driver to fail to secure any small child riding in front. In 1997, Gail Atwater was driving her truck in Lago Vista. Neither of Atwater's children, who were sitting in the front seat, was wearing seatbelts. Lago Vista policeman Bart Turek observed the violations and pulled Atwater over. Ultimately, Atwater was handcuffed, placed in jail, and released on bond. Atwater then filed suit alleging that Turek's actions had violated her Fourth Amendment right to be free from unreasonable seizure. In granting the city summary judgment, the District Court ruled the claim meritless. In affirming, the en banc Court of Appeals held that the arrest was not unreasonable for Fourth Amendment purposes because no one disputed that Turek had probable cause to arrest Atwater, and there was no evidence the arrest was conducted in an extraordinary manner, unusually harmful to Atwater's privacy interests.

Question

Does the Fourth Amendment, either by incorporating common-law restrictions on misdemeanor arrests or otherwise, limit a police officer's authority to arrest without warrant for minor criminal offenses?

Conclusion

Decision: 5 votes for City of Lago Vista, 4 vote(s) against
Legal provision: Amendment 4: Fourth Amendment

No. In a 5-4 opinion delivered by Justice David H. Souter, the Court held that the Fourth Amendment does not forbid a warrantless arrest for a minor criminal offense, such as a misdemeanor seatbelt violation punishable only by a fine. "If an officer has probable cause to believe that an individual has committed even a very minor criminal offense in his presence, he may, without violating the Fourth Amendment, arrest the offender," wrote Justice Souter for the Court. Justice Sandra Day O'Connor's dissenting opinion argued that the Court's decision "neglects the Fourth Amendment's express command in the name of administrative ease" and thus "cloaks the pointless indignity that Gail Atwater suffered with the mantle of reasonableness."

Nevada v. Hicks

Wed, 21 Mar 2001 13:00:00 +0000

Case Basics

Docket No.

99-1994

Petitioner

Nevada

Petitioner Type

Petitioner

Respondent

Hicks

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

533 U.S. 353 (2001)

Argued

Wednesday, March 21, 2001

Decided

Monday, June 25, 2001

Advocates

Barbara B. McDowell (On behalf of the United States, as amicus curiae, supporting affirmance)

C. Wayne Howle (Argued the cause for the petitioners)

S. James Anaya (Argued the cause for the respondents)

Facts of the Case

Floyd Hicks is a member of the Fallon Paiute-Shoshone Tribes of western Nevada. After tribal police observed that Hicks was in possession of two California bighorn sheep heads, state game wardens obtained search warrants from state court and from the tribal court. After the warrants were executed, Hicks filed suit in Tribal Court, alleging trespass to land and chattels, abuse of process, and violation of civil rights, specifically denial of equal protection, denial of due process, and unreasonable search and seizure. The Tribal Court held that it had jurisdiction over the claims and the Tribal Appeals Court affirmed. Agreeing, the District Court held that the wardens would have to exhaust their qualified immunity claims in Tribal Court. In affirming, the Court of Appeals concluded that the fact that Hicks's home is on tribe-owned reservation land is sufficient to support tribal jurisdiction over civil claims against nonmembers arising from their activities on that land.

Question

May a tribal court assert jurisdiction over civil claims against state officials who entered tribal land to execute a search warrant against a tribe member suspected of having violated state law outside the reservation?

Conclusion

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

No. In an opinion delivered by Justice Antonin Scalia, a unanimous Court held that "[b]ecause the Fallon Paiute-Shoshone Tribes lacked legislative authority to restrict, condition, or otherwise regulate the ability of state officials to investigate off-reservation violations of state law, they also lacked adjudicative authority to hear respondent's claim that those officials violated tribal law in the performance of their duties. "[S]ince the lack of authority is clear," continued Scalia, "there is no need to exhaust the jurisdictional dispute in tribal court. State officials operating on a reservation to investigate off-reservation violations of state law are properly held accountable for tortious conduct and civil rights violations in either state or federal court, but not in tribal court."

Dept of Interior v. Klamath Water Users Protect. Assoc.

Wed, 10 Jan 2001 13:00:00 +0000

Case Basics

Docket No.

99-1871

Petitioner

Dept of Interior

Petitioner Type

Petitioner

Respondent

Klamath Water Users Protect. Assoc.

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

532 U.S. 1 (2001)

Argued

Wednesday, January 10, 2001

Decided

Monday, March 5, 2001

Advocates

Malcolm L. Stewart (Department of Justice, argued the cause for the petitioners)

Andrew Hitchings (Argued the cause for the respondent)

Facts of the Case

The Department of the Interior's Bureau of Reclamation (Reclamation) administers the Klamath Irrigation Project (Project), which uses water from the Klamath River Basin to irrigate parts of Oregon and California. In order for the Department to provide water allocations among competing uses and users, it asked the Klamath and other Indian Tribes (Basin Tribes or Tribes) to consult with Reclamation. A memorandum of understanding solidified this relationship. When the Department's Bureau of Indian Affairs (Bureau) filed claims on behalf of the Klamath Tribe in Oregon to allocate water rights, the two exchanged written memorandums on the appropriate scope of the claims submitted by the Government for the benefit of the Tribe. Afterwards, the Klamath Water Users Protective Association (Association), a nonprofit group, whose members receive water from the Project and, generally, have interests adverse to the tribal interest because of the scarcity of water, filed requests with the Bureau under the Freedom of Information Act (FOIA) to gain access to communications between the Bureau and the Basin Tribes. Some documents were turned over, but the Bureau held other documents under the deliberative process privileges incorporated in FOIA Exemption 5, which exempts from disclosure "inter-agency or intra-agency memorandums or letters which would not be available by law to a party other than an agency in litigation with the agency." The Association sued to compel release of the documents. The District Court granted the government summary judgment. In reversing, the Court of Appeals ruled out any application of Exemption 5 on the ground that the Tribes with whom the Department has a consulting relationship have a direct interest in the subject matter of the consultations.

Question

Are documents shared between the Klamath and other Indian Tribes and the Department of the Interior, which address tribal interests subject to state and federal proceedings to determine water allocations, exempt from the disclosure requirements of the Freedom of Information Act, as " inter-agency or intra-agency memorandums or letters?"

Conclusion

Decision: 9 votes for Klamath Water Users Protect. Assoc., 0 vote(s) against
Legal provision: Freedom of Information, Sunshine, or Privacy Act

No. In a unanimous opinion delivered by Justice David H. Souter, the Court that there is no exemption under FOIA for the correspondence between the Tribes and the Bureau. Because the Klamath Tribe advocated its own positions in the water allocation proceedings, the communications between it and the Bureau did not equate to the role that personnel fulfils, in that personnel do not represent their own interests. Therefore, the documents were not exempt from public disclosure as inter-agency or intra-agency communications. "All of this boils down to requesting that we read an 'Indian trust' exemption into the statute, a reading that is out of the question," wrote Justice Souter for the Court.

Idaho v. United States

Mon, 23 Apr 2001 13:00:00 +0000

Case Basics

Docket No.

00-189

Petitioner

Idaho

Petitioner Type

Petitioner

Respondent

United States

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

533 U.S. 262 (2001)

Argued

Monday, April 23, 2001

Decided

Monday, June 18, 2001

Advocates

Steven W. Strack (Boise, Idaho, argued the cause for the petitioner)

David C. Frederick (Department of Justice, argued the cause for the respondent United States)

Raymond C. Givens (Argued the cause for the respondent Coeur d'Alene Tribe)

Facts of the Case

In 1873, the Coeur d'Alene Tribe agreed to relinquish all claims to its aboriginal lands outside the bounds of a more substantial reservation that U.S. negotiators agreed to set apart for the tribe's exclusive use. The reservation included part of the St. Joe River and virtually all of the Lake Coeur d'Alene. President Grant set the land aside in an 1873 Executive Order. In 1891, Congress ratified agreements in which the Tribe agreed to cede its rights to all land except that within the Executive Order reservation, and the Government promised to compensate the Tribe and agreed to hold the land forever as Indian land and the Tribe agreed to cede the reservation's northern portion, including two-thirds of the lake, for compensation. The United States initiated an action against Idaho to quiet title in the United States, in trust for the Tribe, to the submerged lands within the current reservation. The District Court quieted title in the United States as trustee, and the Tribe as beneficiary, to the bed and banks of the lake and the river within the reservation. The Court of Appeals affirmed.

Question

Does the National Government hold title, in trust for the Coeur d'Alene Tribe, to lands underlying portions of Lake Coeur d'Alene and the St. Joe River?

Conclusion

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

Yes. In a 5-4 opinion delivered by Justice David H. Souter, the Court held that the National Government holds title, in trust for the Tribe, to lands underlying portions of Lake Coeur d'Alene and the St. Joe River. Justice Souter wrote for the Court that "Congress recognized the full extent of the Executive Order reservation lying within the stated boundaries it ultimately confirmed, and intended to bar passage to Idaho of title to the submerged lands at issue here." Chief Justice William H. Rehnquist, with whom Justices Antonin Scalia, Anthony M. Kennedy, and Clarence Thomas joined, dissented. "Congress' desire to divest an entering State of its sovereign interest in submerged lands must be 'definitely declared or otherwise made very plain,'" argued Chief Justice Rehnquist, "That standard has not been met here."

Lewis v. Lewis & Clark Marine

Wed, 29 Nov 2000 13:00:00 +0000

Case Basics

Docket No.

99-1331

Petitioner

Lewis

Petitioner Type

Petitioner

Respondent

Lewis & Clark Marine

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

531 U.S. 438 (2001)

Argued

Wednesday, November 29, 2000

Decided

Wednesday, February 21, 2001

Advocates

James V. O'Brien (Argued the cause for the respondent)

Roy C. Dripps, III (Argued the cause for the petitioner)

Facts of the Case

In 1998, James F. Lewis, a deckhand aboard the M/V Karen Michelle owned by Lewis & Clark Marine, Inc., claimed that he was injured when he tripped over a wire on the boat. Lewis then sued Lewis & Clark in Illinois County Court, for personal injuries claiming negligence under the Jones Act. Lewis & Clark had already filed a complaint for exoneration from, or limitation of, liability in the District Court under the Limitation of Liability Act (Act). Subsequently, the court approved a surety bond of $450,000, representing Lewis & Clark's interest in the vessel, ordered that any claim related to the incident be filed with the court within a specified period, and enjoined the filing or prosecution of any suits related to the incident. The injunction prevented Lewis from litigating his personal injury claims in state court and he moved to dissolve it. The District Court noted that federal courts have the exclusive jurisdiction to determine whether a vessel owner is entitled to limited liability, but also recognized that the statute conferring exclusive jurisdiction over admiralty and maritime suits to federal courts saves to suitors "all other remedies to which they are other wise entitled." Ultimately, the court dissolved the injunction. The Court of Appeals reversed.

Question

Did a District Court abuse its discretion when it dissolved an injunction under the Limitation of Liability Act, which prevented a seaman from suing a vessel owner in state court for personal injuries sustained aboard the vessel?

Conclusion

Decision: 9 votes for Lewis, 0 vote(s) against
Legal provision: 46 U.S.C. 181

No. In a unanimous opinion delivered by Justice Sandra Day O'Connor, the Court held that because state courts may adjudicate claims like Lewis' against vessel owners so long as the owner's right to seek limitation of liability is protected, the Court of Appeals erred in reversing the District Court's decision to dissolve the injunction. Writing for the Court, Justice O'Conner rejected the respondent's proposal to make "run of the mill personal injury actions involving vessels a matter of exclusive federal jurisdiction except where the claimant happens to seek a jury trial."

Artuz v. Bennett

Tue, 10 Oct 2000 13:00:00 +0000

Case Basics

Docket No.

99-1238

Petitioner

Artuz

Petitioner Type

Petitioner

Respondent

Bennett

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

531 U.S. 4 (2000)

Argued

Tuesday, October 10, 2000

Decided

Tuesday, November 7, 2000

Advocates

John M. Castellano (Argued the cause for the petitioner)

Dan Schweitzer (As amicus curiae, by special leave of the Court, for petitioner)

Alan S. Futerfas (Argued the cause for the respondent)

Facts of the Case

In 1984, after firing two bullets at police during a car chase, Tony Bruce Bennett was convicted of attempted murder, among other crimes. Bennett moved pro se to vacate his judgment of conviction in 1995. A New York trial court orally denied Bennett's motion. Bennett claimed that he never received a copy of a written order reflecting the denial. In 1998, Bennett filed a federal habeas corpus petition alleging violations of his rights to present witnesses in his defense and to a fair trial, to be present at all material stages of the trial, and to the effective assistance of counsel. The Federal District Court dismissed Bennett's federal habeas corpus petition as untimely under the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA), which set a 1-year period of limitation on federal habeas corpus applications by state prisoners. In reversing, the Court of Appeals held that Bennett's habeas petition was not time-barred because his 1995 motion was still pending, under the AEDPA's tolling provision, since he had never received notification of the state's decision regarding it. Thus, the time for appealing the denial of that motion had not yet expired. Additionally, the court found that the 1995 motion was a "properly filed" application, even though the claims contained in the motion were procedurally barred under two New York statutory provisions.

Question

Is an application for state postconviction relief containing procedurally barred claims properly filed within the meaning of the Antiterrorism and Effective Death Penalty Act of 1996?

Conclusion

Decision: 9 votes for Bennett, 0 vote(s) against
Legal provision: 8 U.S.C. 2244

Yes. In a unanimous opinion delivered by Justice Antonin Scalia, the Court held that an application for state postconviction relief containing procedurally barred claims is properly filed within the meaning of the Antiterrorism and Effective Death Penalty Act of 1996. Writing for the unanimous court, Justice Antonin Scalia said that "[o]nly individual claims, and not the application containing those claims, can be procedurally defaulted under state law." "An application is 'filed,' as that term is commonly understood, when it is delivered to, and accepted by, the appropriate court officer for placement into the official record," noted Justice Scalia. "By construing 'properly filed application' to mean 'application raising claims that are not mandatorily procedurally barred,' [the Federal Government] elides the difference between an 'application' and a 'claim,'" argued Justice Scalia.

Cooper Industries v. Leatherman Tool Grp.

Mon, 26 Feb 2001 13:00:00 +0000

Case Basics

Docket No.

99-2035

Petitioner

Cooper Industries

Petitioner Type

Petitioner

Respondent

Leatherman Tool Grp.

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

532 U.S. 424 (2001)

Argued

Monday, February 26, 2001

Decided

Monday, May 14, 2001

Advocates

Jonathan S. Massey (Argued the cause for the respondent)

William Bradford Reynolds (Argued the cause for the petitioner)

Facts of the Case

Leatherman Tool Group, Inc., manufactures a multifunction pocket tool, the Pocket Survival Tool (PST). In 1996, Cooper Industries, Inc. used photographs of a modified PST to introduce a competing tool, the ToolZall. The photographs were used in posters, packaging, and advertising materials. Subsequently, Leatherman filed an action asserting claims of trade-dress infringement, unfair competition, and false advertising under the Trademark Act of 1946 (Lanham Act). Ultimately, a trial jury awarded Leatherman $50,000 in compensatory damages and $4.5 million in punitive damages. The District Court then entered judgment, rejecting Cooper's argument that the punitive damages were grossly excessive. In affirming, the Court of Appeals, using an "abuse of discretion" standard, concluded that the District Court did not abuse its discretion in declining to reduce the award.

Question

Did the Court of Appeals review the constitutionality of the punitive damages award against Cooper Industries, Inc. under the correct standard?

Conclusion

Decision: 8 votes for Cooper Industries, 1 vote(s) against
Legal provision: Due Process

No. In an 8-1 opinion delivered by Justice John Paul Stevens, the Court held that the Courts of Appeals should apply a de novo standard when reviewing district court determinations of the constitutionality of punitive damages awards. Because the Court of Appeals applied an "abuse of discretion" standard, a less demanding standard, the Court vacated the judgment and remanded the case for a determination on whether the award was grossly excessive under the correct standard.

United States v. Cleveland Indians Baseball Co.

Tue, 27 Feb 2001 13:00:00 +0000

Case Basics

Docket No.

00-203

Petitioner

United States

Petitioner Type

Petitioner

Respondent

Cleveland Indians Baseball Co.

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

532 U.S. 200 (2001)

Argued

Tuesday, February 27, 2001

Decided

Tuesday, April 17, 2001

Advocates

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

James A. Feldman (Department of Justice, argued the cause for the petitioner)

Facts of the Case

Under a grievance settlement agreement, the Cleveland Indians Baseball Company owed 8 players backpay for wages due in 1986 and 14 players backpay for wages due in 1987. The Company paid all of the back wages in 1994. No award recipient was a Company employee in that year. The Company also paid its share of employment taxes on the back wages according to 1994 tax rates and wage bases. The payments were subject to Social Security and Medicare taxes under the Federal Insurance Contributions Act (FICA) and taxes on wages to fund unemployment benefits under the Federal Unemployment Tax Act (FUTA). Both tax rates and the amount of the wages subject to tax have risen over time. After the Internal Revenue Service denied the Company's claims for a refund of the payments, the Company initiated suit in Federal District Court. The court, bound by precedent, ordered the Government to refund FICA and FUTA taxes. The Court of Appeals affirmed.

Question

Is backpay subject to federal taxes, under the Federal Insurance Contributions Act and the Federal Unemployment Tax Act, based on the year the money should have been paid out?

Conclusion

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

No. In a unanimous opinion delivered by Justice Ruth Bader Ginsburg, the Court held that back wages are subject to FICA and FUTA taxes by reference to the year the wages are in fact paid. "Although the regulations, like the statute, do not specifically address backpay, the Internal Revenue Service has consistently interpreted them to require taxation of back wages according to the year the wages are actually paid, regardless of when those wages were earned or should have been paid," wrote Justice Ginsburg for the Court. Justice Antonin Scalia filed an opinion concurring in the judgment.

Central Green Co. v. United States

Mon, 30 Oct 2000 13:00:00 +0000

Case Basics

Docket No.

99-859

Petitioner

Central Green Co.

Petitioner Type

Petitioner

Respondent

United States

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

531 U.S. 425 (2001)

Argued

Monday, October 30, 2000

Decided

Wednesday, February 21, 2001

Advocates

Timothy Jones (Argued the cause for the petitioner)

David C. Frederick (Department of Justice, argued the cause for the respondent)

Facts of the Case

The Madera Canal, a federal facility leased to the Madera Irrigation District (MID), flows through Central Green Co.'s 1,000 acres of pistachio orchards in California. Central Green filed suit under the Federal Tort Claims Act against the United States and the MID alleging that their negligence in the canal's design, construction, and maintenance caused subsurface flooding resulting in damage to the orchards and increased operating costs. The Federal Government moved for judgment on the pleadings based on immunity granted by the Flood Control Act of 1928, which states that "no liability of any kind shall attach to or rest upon the United States for any damage from or by floods or flood waters at any place." The complaint was then dismissed because the canal was a part of the Friant Division of the Central Valley Project, whose purpose was flood control. In affirming, the Court of Appeals held that although the canal serves no flood control purpose, immunity is attached solely because it is a branch of the larger project.

Question

Do the words "floods or flood waters" encompass all the water that flows through federal facilities, such that the Federal Government has immunity under the Flood Control Act of 1928 for damages such water may cause?

Conclusion

Decision: 9 votes for Central Green Co., 0 vote(s) against
Legal provision: 33 U.S.C. 702

No. In a unanimous opinion delivered by Justice John Paul Stevens, the Court held that in determining whether, under the Flood Control Act of 1928, immunity attaches, courts should consider the character of the waters that caused the relevant damage and the purposes behind their release rather than the relation between that damage and a flood control project. Thus, the Federal Government's immunity from liability for flood damage required a determination of whether actual flows through the Federal Government's canal constituted flood waters, regardless of the canal's flood control purpose.

Shaw v. Murphy

Tue, 16 Jan 2001 13:00:00 +0000

Case Basics

Docket No.

99-1613

Petitioner

Shaw

Petitioner Type

Petitioner

Respondent

Murphy

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

532 U.S. 223 (2001)

Argued

Tuesday, January 16, 2001

Decided

Wednesday, April 18, 2001

Advocates

Patricia A. Millett (Argued the cause for the United States, as amicus curiae, by special leave of court, supporting the petitioners)

Jeffrey T. Renz (Argued the cause for the respondent)

David L. Ohler (Helena, Montana, argued the cause for petitioners)

Facts of the Case

While incarcerated in Montana State Prison, Kevin Murphy sent a letter to an inmate to assist him with his defense after he assaulted a correctional officer. In accordance with prison policy, the letter was intercepted. Based on the letter's content, the prison sanctioned Murphy for violating prison rules prohibiting insolence and interfering with due process hearings. Murphy sought relief, alleging that the disciplinary action violated his First Amendment rights, including the right to provide legal assistance to other inmates. Ruling against Murphy, the District Court, based on precedent, found that reasonably related penological interests allowed the prison regulations to impinge on an inmate's constitutional rights. In reversing, the Court of Appeals found that an inmate's First Amendment right to give legal assistance to other inmates outweighed the government's interests.

Question

Do prison inmates have a constitutional right to provide legal assistance to fellow inmates?

Conclusion

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

No. In a unanimous opinion delivered by Justice Clarence Thomas, the Court held that inmates do not possess a special First Amendment right to provide legal assistance to fellow inmates that enhances the protections otherwise available. "Augmenting First Amendment protection for inmate legal advice would undermine prison officials' ability to address the 'complex and intractable' problems of prison administration," wrote Justice Thomas for the Court. Justice Thomas added that "[p]risoners have used legal correspondence as a means for passing contraband and communicating instructions on how to manufacture drugs or weapons." Justice Ruth Bader Ginsburg also wrote a concurring opinion.

Buford v. United States

Mon, 08 Jan 2001 13:00:00 +0000

Case Basics

Docket No.

99-9073

Petitioner

Buford

Petitioner Type

Petitioner

Respondent

United States

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

532 U.S. 59 (2001)

Argued

Monday, January 8, 2001

Decided

Tuesday, March 20, 2001

Advocates

Dean A. Strang (Milwaukee, Wisconsin, argued the cause for petitioner)

Paul R. Q. Wolfson (Argued the cause for respondent)

Facts of the Case

The United States Sentencing Guidelines define a career offender as one with at least two prior felony convictions for violent or drug-related crimes and provides that a sentencing judge must count as a single prior conviction all "related" convictions. Convictions may also be functionally related, if they were factually or logically related and sentencing was joint. After Paula Buford pleaded guilty to armed bank robbery, the sentencing judge had to determine whether her five prior state convictions were "related" or whether they should count as more than one. At sentencing, the government conceded that her four prior robbery convictions were related. The government did not concede that her prior drug conviction was related to the robberies. The District Court concluded that Buford's drug and robbery cases had not been either formally or functionally consolidated. In affirming, the Court of Appeals reviewed the decision deferentially rather than de novo, giving deference to the District Court.

Question

Does a de novo standard of review apply when a court of appeals reviews a trial court's sentencing guideline determination as to whether an offender's prior convictions were consolidated, and thus related, for sentencing purposes?

Conclusion

Decision: 9 votes for United States, 0 vote(s) against
Legal provision: 18 U.S.C. App.

No. In a unanimous opinion delivered by Justice Stephen G. Breyer, the Court held that the Court of Appeals properly reviewed the District Court's "''functional consolidation'" decision deferentially "[i]n light of the fact- bound nature of the legal decision, the comparatively greater expertise of the District Court, and the limited value of uniform court of appeals precedent." Rejecting Buford's arguments for de novo review, Justice Breyer wrote that "the district court is in a better position than the appellate court to decide whether a particular set of individual circumstances demonstrates 'functional consolidation.'"

Brentwood Acad. v. TN Sec. School Ath. Assn.

Wed, 11 Oct 2000 13:00:00 +0000

Case Basics

Docket No.

99-901

Petitioner

Brentwood Acad.

Petitioner Type

Petitioner

Respondent

TN Sec. School Ath. Assn.

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

531 U.S. 288 (2001)

Argued

Wednesday, October 11, 2000

Decided

Tuesday, February 20, 2001

Advocates

Richard L. Colbert (Argued the case for the respondents)

James F. Blumstein (Argued the cause for the petitioner)

Barbara D. Underwood (Argued the cause, on behalf of the United States, as amicus curiae, supporting the petitioner)

Facts of the Case

The Tennessee Secondary School Athletic Association (Association) is a not- for-profit membership corporation organized to regulate interscholastic sports among its members, a large portion of the public and private high schools in Tennessee. The Association's role in regulating interscholastic competition in public schools has been long acknowledged by the State Board of Education. Brentwood Academy sued the Association after it penalized the academy for placing "undue influence" on football recruits. At the time, all the voting members of the Association were public school administrators. Brentwood claimed that the rule's enforcement was state action that violated the First and Fourteenth Amendments. The District Court agreed and enjoined the rule's enforcement. In reversing, the Court of Appeals concluded that there was no state action.

Question

May a statewide association, incorporated to regulate interscholastic athletic competition among public and private secondary schools, be regarded as engaging in state action when it enforces a rule against a member school?

Conclusion

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

Yes. In a 5-4 opinion delivered by Justice David H. Souter, the Court held that the pervasive entwinement of state school officials in the ostensibly private organization, which regulated school sports, and the state education board's acknowledgment of the organization, indicated that the organization is a state actor for civil rights purposes. "The nominally private character of the Association is overborne by the pervasive entwinement of public institutions and public officials in its composition and workings, and there is no substantial reason to claim unfairness in applying constitutional standards to it," wrote Justice Souter for the majority. Chief Justice William H. Rehnquist and Justices Antonin Scalia and Anthony M. Kennedy joined Justice Clarence Thomas' dissent.

Zadvydas v. Davis

Wed, 21 Feb 2001 13:00:00 +0000

Location

Office of Attorney General

"950 Pennsylvania Avenue**** NW" Washington D.C. 20530

Washington 20530

United States

38° 53' 31.8084" N, 77° 1' 30.2196" W

See map: Google Maps

Case Basics

Docket No.

99-7791

Petitioner

Zadvydas

Petitioner Type

Petitioner

Respondent

Davis

Respondent Type

Respondent

Consolidation

No. 00-38

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

533 U.S. 678 (2001)

Argued

Wednesday, February 21, 2001

Decided

Thursday, June 28, 2001

Advocates

Robert F. Barnard (New Orleans, Louisiana, argued the cause for the petitioner Zadvydas)

Edwin S. Kneedler (Department of Justice, argued the cause for the respondents in 99-7791 and the petitioners in 00-38)

Jay W. Stansell (Seattle, Washington, argued the cause for the respondent Ma)

Facts of the Case

After a final removal order is entered, an alien ordered removed is held in custody during a 90-day removal period. If the alien is not removed in those 90 days, the post-removal-period detention statute authorizes further detention or supervised release. After being ordered deported based on is criminal record, efforts to deport Kestutis Zadvydas failed. When he remained in custody after the removal period expired, Zadvydas filed a habeas action. In granting the writ, the District Court reasoned that his confinement would be permanent and thus violate the Constitution. In reversing, the Court of Appeals concluded that Zadvydas' detention did not violate the Constitution because eventual deportation was not impossible. Conversely, in ordering Kim Ho Ma's release, the District Court held that the Constitution forbids post- removal-period detention unless there is a realistic chance that an alien will be removed, and that no such chance existed here because Cambodia has no repatriation treaty with the United States. In affirming, the Court of Appeals concluded that detention was not authorized for more than a reasonable time beyond the 90-day period.

Question

Does the post-removal-period statute authorize the Attorney General to detain a removable alien indefinitely beyond the 90-day removal period?

Conclusion

Decision: 5 votes for Zadvydas, 4 vote(s) against
Legal provision: Immigration and Naturalization, Immigration, Nationality, or Illegal Immigration Reform and Immigrant Responsibility Acts, as amended

No. In a 5-4 opinion delivered by Justice Stephen G. Breyer, the Court held that "the statute, read in light of the Constitution's demands, limits an alien's post-removal-period detention to a period reasonably necessary to bring about that alien's removal from the United States" and "does not permit indefinite detention." "Based on our conclusion that indefinite detention of aliens in the former category would raise serious constitutional concerns, we construe the statute to contain an implicit 'reasonable time' limitation, the application of which is subject to federal court review," wrote Justice Breyer.

Bush v. Gore

Mon, 11 Dec 2000 13:00:00 +0000

Location

Florida Supreme Court

500 South Duval Street Tallahassee FL 32399

Tallahassee, FL 32399

United States

30° 26' 17.214" N, 84° 16' 59.1672" W

See map: Google Maps

Case Basics

Docket No.

00-949

Petitioner

George W. Bush

Petitioner Type

Petitioner

Respondent

Albert Gore

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

531 U.S. 98 (2000)

Argued

Monday, December 11, 2000

Decided

Tuesday, December 12, 2000

Advocates

David Boies (Argued the cause for the respondent)

Joseph P. Klock (Argued the cause for petitioner Harris)

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

Facts of the Case

Following the U.S. Supreme Court's decision in Bush v. Palm Beach County Canvassing Board, and concurrent with Vice President Al Gore's contest of the certification of Florida presidential election results, on December 8, 2000 the Florida Supreme Court ordered that the Circuit Court in Leon County tabulate by hand 9000 contested ballots from Miami-Dade County. It also ordered that every county in Florida must immediately begin manually recounting all "under-votes" (ballots which did not indicate a vote for president) because there were enough contested ballots to place the outcome of the election in doubt. Governor George Bush and his running mate, Richard Cheney, filed a request for review in the U.S. Supreme Court and sought an emergency petition for a stay of the Florida Supreme Court's decision. The U.S. Supreme Court granted review and issued the stay on December 9. It heard oral argument two days later.

Question

Did the Florida Supreme Court violate Article II Section 1 Clause 2 of the U.S. Constitution by making new election law? Do standardless manual recounts violate the Equal Protection and Due Process Clauses of the Constitution?

Conclusion

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

Noting that the Equal Protection clause guarantees individuals that their ballots cannot be devalued by "later arbitrary and disparate treatment," the per curiam opinion held 7-2 that the Florida Supreme Court's scheme for recounting ballots was unconstitutional. Even if the recount was fair in theory, it was unfair in practice. The record suggested that different standards were applied from ballot to ballot, precinct to precinct, and county to county. Because of those and other procedural difficulties, the court held, 5 to 4, that no constitutional recount could be fashioned in the time remaining (which was short because the Florida legislature wanted to take advantage of the "safe harbor" provided by 3 USC Section 5).

Loathe to make broad precedents, the per curiam opinion limited its holding to the present case. Rehnquist (in a concurring opinion joined by Scalia and Thomas) argued that the recount scheme was also unconstitutional because the Florida Supreme Court's decision made new election law, which only the state legislature may do. Breyer and Souter (writing separately) agreed with the per curiam holding that the Florida Court's recount scheme violated the Equal Protection Clause, but they dissented with respect to the remedy, believing that a constitutional recount could be fashioned. Time is insubstantial when constitutional rights are at stake. Ginsburg and Stevens (writing separately) argued that for reasons of federalism, the Florida Supreme Court's decision ought to be respected. Moreover, the Florida decision was fundamentally right; the Constitution requires that every vote be counted.

Lorillard Tobacco v. Reilly

Wed, 25 Apr 2001 13:00:00 +0000

Location

Attorney General's Office of MA

1 Ashburton Pl. Boston MA 02114

Boston, MA 02114

United States

42° 21' 33.6996" N, 71° 3' 44.5428" W

See map: Google Maps

Case Basics

Docket No.

00-596

Petitioner

Lorillard Tobacco

Respondent

Thomas F. Reilly

Consolidation

No. 00-597

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

533 U.S. 525 (2001)

Argued

Wednesday, April 25, 2001

Decided

Thursday, June 28, 2001

Advocates

Barbara D. Underwood (Department of Justice, on behalf of the United States, as amicus curiae, supporting the respondents)

William W. Porter (Boston, Massachusetts, argued the cause for the respondents)

Jeffrey S. Sutton (Argued the cause for the petitioners)

Facts of the Case

The Attorney General of Massachusetts promulgated comprehensive regulations governing the advertising and sale of cigarettes, smokeless tobacco, and cigars. Members of the tobacco industry filed suit challenging the regulations. Lorillard Tobacco Company and others asserted that under the Supremacy Clause the cigarette advertising regulations were preempted by the Federal Cigarette Labeling and Advertising Act (FCLAA), which prescribes mandatory health warnings for cigarette packaging and advertising and that the regulations violated the First and Fourteenth Amendments. Ultimately, the Court of Appeals affirmed the District Court's rulings that the cigarette advertising regulations are not pre-empted by the FCLAA and that neither the regulations prohibiting outdoor advertising within 1,000 feet of a school or playground nor the sales practices regulations restricting the location and distribution of tobacco products violated the First Amendment. Reversing the lower court's finding, the appellate court found that the point-of-sale advertising regulations requiring that indoor advertising be placed no lower than five feet from the floor were valid.

Question

Does the Federal Cigarette Labeling and Advertising Act preempt portions of the Attorney General of Massachusetts' cigarette advertising regulations? Do portions of the Attorney General's regulations governing the advertising and sale of tobacco products violate the First Amendment?

Conclusion

Decision: 5 votes for Lorillard Tobacco, 4 vote(s) against
Legal provision: 15 U.S.C. 1334

Yes and yes. In an opinion delivered by Justice Sandra Day O'Connor, the highly fractured Court held that the FCLAA preempts Massachusetts' regulations governing outdoor and point-of-sale cigarette advertising and that Massachusetts' outdoor and point-of-sale advertising regulations related to smokeless tobacco and cigars violate the First Amendment, but that the sales practices regulations related to all three tobacco products are constitutional. "We conclude that the Attorney General has failed to show that the outdoor advertising regulations for smokeless tobacco and cigars are not more extensive than necessary to advance the State's substantial interest in preventing underage tobacco use," wrote Justice O'Connor.

Cook v. Gralike

Mon, 06 Nov 2000 13:00:00 +0000

Case Basics

Docket No.

99-929

Petitioner

Cook

Petitioner Type

Petitioner

Respondent

Gralike

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

531 U.S. 510 (2001)

Argued

Monday, November 6, 2000

Decided

Wednesday, February 28, 2001

Advocates

James R. McAdams (Office of the Attorney General, Jefferson City, Missouri argued the cause for the petitioner)

Barbara D. Underwood (Department of Justice, for the United States, as amicus curiae, supporting the respondent)

Jonathan S. Franklin (Argued the cause for the respondent)

Facts of the Case

In the wake of U.S Term Limits v. Thornton, Missouri voters adopted an amendment to Article VIII of their State Constitution, which "instructs" each Member of Missouri's congressional delegation "to use all of his or her delegated powers to pass the Congressional Term Limits Amendment" set forth in section 16 of the Article. The Article also directs the Missouri Secretary of State to determine whether a statement reflecting a candidate's position on term limits should be placed by his or her name on the general election ballot. Don Gralike, a non-incumbent House of Representatives candidate, brought suit to enjoin the Secretary from implementing the Article. The District Court, granting Gralike summary judgment, found that Article VIII infringed upon the Qualifications Clauses of Article I of the Federal Constitution by creating additional qualifications for Congress and that the Article burdened a candidate's First Amendment right to speak freely on the issue of term limits. The Court of Appeals affirmed.

Question

Is Article VIII of the Missouri Constitution, as amended in 1996 to prompt the adoption of a "Congressional Term Limits Amendment" to the Federal Constitution, consistent with the Elections Clause of the U.S. Constitution (Art. I, Section 4, Clause 1)?

Conclusion

Decision: 9 votes for Gralike, 0 vote(s) against
Legal provision: Amendment 10: Tenth Amendment

No. In an opinion delivered by Justice John Paul Stevens, the Court held that Article VIII of the Missouri Constitution, which required the placement of negative labels next to state candidates for federal office, who failed to comply with voter-mandated support of federal term limits, was an unconstitutional attempt to regulate electoral outcomes, rather than a permissible regulation of state elections. Justice Stevens explained for the Court that Article VIII is designed to favor candidates who are willing to support a term-limits amendment and, "[t]hus, far from regulating the procedural mechanisms of elections, Article VIII attempts to 'dictate electoral outcomes.' Such 'regulation' of congressional elections simply is not authorized by the Elections Clause."

PGA Tour v. Martin

Wed, 17 Jan 2001 13:00:00 +0000

Case Basics

Docket No.

00-24

Petitioner

PGA Tour

Petitioner Type

Petitioner

Respondent

Martin

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

532 U.S. 661 (2001)

Argued

Wednesday, January 17, 2001

Decided

Tuesday, May 29, 2001

Advocates

Roy L. Reardon (Argued the cause for the respondent)

Barbara D. Underwood (On behalf of the United States, as amicus curiae, supporting the respondent)

H. Bartow Farr, III (Argued the cause for the petitioner)

Facts of the Case

Casey Martin is afflicted with a degenerative circulatory disorder that prevents him from walking golf courses. His disorder constitutes a disability under the Americans with Disabilities Act of 1990 (ADA). When Casey made a request to use a golf cart for the duration of the qualification tournament onto the professional tours sponsored by PGA Tour, Inc., PGA refused. Martin then filed suit under Title III of the ADA, which requires an entity operating "public accommodations" to make "reasonable modifications" in its policies "when... necessary to afford such...accommodations to individuals with disabilities, unless the entity can demonstrate that making such modifications would fundamentally alter the nature of such...accommodations." Ultimately, the District Court entered a permanent injunction against PGA, requiring it to allow Martin to use a cart. The court found that the purpose of the PGA's walking rule was to insert fatigue into the skill of shot-making, and that Martin suffered significant fatigue due to his disability, even with the use of a cart. In affirming, the Court of Appeals concluded that golf courses are places of public accommodation during professional tournaments and that permitting Martin to use a cart would not fundamentally alter the nature of those tournaments.

Question

Does the Americans with Disabilities Act of 1990 provide access to professional golf tournaments by a qualified entrant with a disability? May a disabled contestant be denied the use of a golf cart because it would "fundamentally alter the nature" of the tournaments to allow him to ride when all other contestants must walk?

Conclusion

Decision: 7 votes for Martin, 2 vote(s) against
Legal provision: Americans with Disabilities Act (ADA)

Yes and no. In a 7-2 opinion delivered by Justice John Paul Stevens, the Court held that Title III of the ADA, by its plain terms, prohibits the PGA from denying Martin equal access to its tours on the basis of his disability and that allowing Martin to use a cart, despite the walking rule, is not a modification that would "fundamentally alter the nature" of the game. "The purpose of the walking rule is... not compromised in the slightest by allowing Martin to use a cart," wrote Justice Stevens, noting Martin's fatiguing disability. Justice Antonin Scalia, joined by Justice Clarence Thomas, dissented.

Sinkfield v. Kelley

Sat, 27 Apr 2013 09:50:45 +0000

Case Basics

Docket No.

00-132

Appellee

Kelley

Petitioner Type

Appellee

Appellant

Sinkfield

Respondent Type

Appellant

Consolidation

No. 00-133

Decided By

Rehnquist Court (1994-2005)

Opinion

531 U.S. 28 (2000)

Decided

Monday, November 27, 2000

Facts of the Case

With the acknowledged purpose of maximizing the number of majority-minority districts -- i.e., districts in which a majority of voters belong to a minority group -- Alabama implemented a redistricting plan for its state legislative districts. White Alabama voters, who are residents of various majority-white districts (the appellees), brought suit in District Court challenging their own districts as the products of racial gerrymandering in violation of the equal protection clause of the Fourteenth Amendment. Ultimately, a three-judge court held that seven of the challenged majority- white districts were the product of unconstitutional racial gerrymandering and enjoined their use in any election. The judicial panel found that the group had standing on the ground that injury-in-fact could be conclusively presumed from the mere fact of residence in a gerrymandered district, independent of the plaintiff's subjective assessment of harm, because of the bizarre shapes of their districts. On direct appeal, Alabama state officials and a group of African-American voters argued that the appellees lacked standing to maintain the suit.

Question

Do white Alabama voters, who are residents of various majority-white districts, have standing to challenge Alabama's re-districting plan, which had an acknowledged purpose of maximizing the number of majority-minority districts?

Conclusion

Decision: 9 votes for Sinkfield, 0 vote(s) against
Legal provision: Article 3, Section 2, Paragraph 1: Case or Controversy Requirement

No. In a unanimous per curiam opinion, the Court held that the appellees lacked standing to maintain their challenge. The opinion stated that the appellees "have neither alleged nor produced any evidence that any of them was assigned to his or her district as a direct result of having 'personally been subjected to a racial classification.'" Consequently, the appellees lacked standing.

City of Indianapolis v. Edmond

Tue, 03 Oct 2000 13:00:00 +0000

Location

Roadblock Indianapolis, IN

United States

39° 46' 1.2576" N, 86° 9' 22.518" W

See map: Google Maps

Case Basics

Docket No.

99-1030

Petitioner

City of Indianapolis

Petitioner Type

Petitioner

Respondent

Edmond

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

531 U.S. 32 (2000)

Argued

Tuesday, October 3, 2000

Decided

Tuesday, November 28, 2000

Advocates

A. Scott Chinn (Argued the cause for petitioners)

Patricia A. Millett (Argued the cause for petitioners)

Kenneth Falk (Argued the cause for respondents)

Facts of the Case

In 1998, the City of Indianapolis began to operate vehicle checkpoints in an effort to interdict unlawful drugs. At each roadblock, one office would conduct an open-view examination of the vehicle. At the same time, another office would walk a narcotics-detection dog around the vehicle. Each stop was to last five minutes or less, without reasonable suspicion or probable cause. Both James Edmond and Joell Palmer were stopped at one of the narcotics checkpoints. They then filed a lawsuit, on their behalf and the class of motorists who had been stopped or were subject to being stopped, alleging that the roadblocks violated the Fourth Amendment and the search and seizure provision of the Indiana Constitution. The District Court denied a request for a preliminary injunction, holding that the checkpoint program did not violate the Fourth Amendment. The Court of Appeals reversed.

Question

Are highway checkpoint programs, whose primary purpose is the discovery and interdiction of illegal narcotics, consistent with the Fourth Amendment?

Conclusion

Decision: 6 votes for Edmond, 3 vote(s) against
Legal provision: Amendment 4: Fourth Amendment

No. In a 6-3 opinion delivered by Justice Sandra Day O'Connor, the Court held that because the checkpoint program's primary purpose was indistinguishable from the general interest in crime control, the checkpoints violated the Fourth Amendment. "We cannot sanction stops justified only by the generalized and ever-present possibility that interrogation and inspection may reveal that any given motorist has committed some crime," wrote Justice O'Connor. Chief Justice William H. Rehnquist and Justices Antonin Scalia and Clarence Thomas dissented, arguing that the reasonableness of the city's roadblocks depended on whether they served a "significant state interest with minimal intrusion on motorists."

Missouri Director of Revenue v. CoBank ACB

Tue, 28 Nov 2000 13:00:00 +0000

Case Basics

Docket No.

99-1792

Petitioner

Missouri Director of Revenue

Petitioner Type

Petitioner

Respondent

CoBank ACB

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

531 U.S. 316 (2001)

Argued

Tuesday, November 28, 2000

Decided

Tuesday, February 20, 2001

Advocates

Richard A. Hanson (Argued the cause for the respondent)

David C. Frederick (Department of Justice, on behalf of the United States, as amicus curiae, supporting the petitioner)

James R. Layton (Jefferson City, Missouri, argued the cause for the petitioner)

Facts of the Case

The Farm Credit Act of 1933 created various lending institutions, including banks for cooperatives, which are designated as federally chartered instrumentalities of the United States. CoBank ACB is the successor to all rights and obligations of the National Bank for Cooperatives. In 1996, CoBank filed amended returns on behalf of that bank, requesting an exemption from all Missouri corporate income taxes and refunds on the taxes it paid for 1991 through 1994. CoBank asserted that the Supremacy Clause accords federal instrumentalities immunity from state taxation unless Congress has expressly waived this immunity, which the Act did not expressly do. The state of Missouri denied the request, but the State Supreme Court reversed, stating that because the Act's current version is silent as to the banks' tax immunity, Congress cannot be said to have expressly consented to state income taxation and, thus, the banks are exempt.

Question

Is the National Bank for Cooperatives, which Congress has designated as a federally chartered instrumentality of the United States, exempt from state income taxation?

Conclusion

Decision: 9 votes for Missouri Director of Revenue, 0 vote(s) against
Legal provision: 12 U.S.C. 2134

No. In a unanimous opinion delivered by Justice Clarence Thomas, the Court held that banks for cooperatives are subject to taxation. Justice Thomas wrote for the Court that nothing in the 1985 amendments to the Farm Credit Act indicated a repeal of the previous express approval of state taxation and that the structure of the Act indicated by negative implication that banks for cooperatives were not entitled to immunity.

Egelhoff v. Egelhoff

Wed, 08 Nov 2000 13:00:00 +0000

Case Basics

Docket No.

99-1529

Petitioner

Egelhoff

Petitioner Type

Petitioner

Respondent

Egelhoff

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

532 U.S. 141 (2001)

Argued

Wednesday, November 8, 2000

Decided

Wednesday, March 21, 2001

Advocates

William J. Kilberg (Argued the cause for the petitioner)

Barbara B. McDowell (Argued the cause for the United States, as amicus curiae, by special leave of court, supporting the petitioner)

Thomas C. Goldstein (Argued the cause for the respondents)

Facts of the Case

David A. Egelhoff designated his wife, Donna Rae Egelhoff, as the beneficiary of a life insurance policy and a pension plan provided by his employer and governed by the Employee Retirement Income Security Act of 1974 (ERISA). Two months after the Egelhoffs divorced, Mr. Egelhoff died. His children then sued Donna Rae to recover the insurance proceeds and the pension plan benefits. The children relied on a Washington state statue that provides that the designation of a spouse as the beneficiary of a nonprobate asset - defined to include a life insurance policy or employee benefit plan - is revoked automatically upon divorce. Subsequently, the proceeds would pass to the children as Mr. Egelhoff's statutory heirs under state law. Under ERISA, the state trial courts granted Donna Rae summary judgment. In reversing, the Washington Court of Appeals found that the statute was not pre-empted by ERISA. In affirming, the Washington Supreme Court held that the statute does not "refer to" ERISA plans to an extent that would require pre-emption.

Question

Does the Employee Retirement Income Security Act of 1974 pre-empt a Washington statute provides that the designation of a spouse as the beneficiary of a nonprobate asset is revoked automatically upon divorce?

Conclusion

Decision: 7 votes for Egelhoff, 2 vote(s) against
Legal provision: Employee Retirement Income Security Act

Yes. In a 7-2 opinion delivered by Justice Clarence Thomas, the Court held that that the Washington statute has a "connection with" ERISA plans and is therefore pre-empted. "Differing state regulations affecting an ERISA plan's 'system for processing claims and paying benefits' impose 'precisely the burden that ERISA pre-emption was intended to avoid,'" wrote Justice Thomas. He continued: "The statute at issue here directly conflicts with ERISA's requirements that plans be administered, and benefits be paid, in accordance with plan documents." Justice Antonin Scalia filed a concurring opinion, in which Justice Ruth Bader Ginsburg joined. Justice Stephen G. Breyer filed a dissenting opinion, in which Justice John Paul Stevens joined.

Cedric Kushner Promotions v. King

Wed, 18 Apr 2001 13:00:00 +0000

Case Basics

Docket No.

00-549

Petitioner

Cedric Kushner Promotions

Petitioner Type

Petitioner

Respondent

King

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

533 U.S. 158 (2001)

Argued

Wednesday, April 18, 2001

Decided

Monday, June 11, 2001

Advocates

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

Austin C. Schlick (Department of Justice, for United States, as amicus curiae, supporting petitioner)

Peter Fleming, Jr. (Argued the cause for the respondents)

Facts of the Case

Cedric Kushner Promotions, Ltd., a corporate promoter of boxing matches, sued Don King, the president and sole shareholder of a rival corporation, alleging that King had conducted his corporation's affairs in violation of the Racketeer Influenced and Corrupt Organizations Act (RICO). RICO makes it "unlawful for any person employed by or associated with any enterprise...to conduct or participate...in the conduct of such enterprise's affairs through a pattern of racketeering activity." The District Court dismissed the complaint. In affirming, the Court of Appeals held that RICO applies only where a plaintiff shows the existence of two separate entities, a "person" and a distinct "enterprise," the affairs of which that "person" improperly conducts. The court concluded that King was part of the corporation, not a "person," distinct from the "enterprise," who allegedly improperly conducted the "enterprise's affairs."

Question

Are Don King and his corporation a distinct "person" and "enterprise," such that RICO applies?

Conclusion

Decision: 9 votes for King, 0 vote(s) against
Legal provision: Racketeer Influenced and Corrupt Organizations

Yes. In a unanimous opinion delivered by Justice Stephen G. Breyer, the Court held that "the need for two distinct entities is satisfied; hence, the RICO provision...applies when a corporate employee unlawfully conducts the affairs of the corporation of which he is the sole owner -- whether he conducts those affairs within the scope, or beyond the scope, of corporate authority." "The corporate owner/employee, a natural person, is distinct from the corporation itself, a legally different entity," wrote Justice Breyer. "A corporate employee who conducts the corporation's affairs through an unlawful RICO 'pattern...of activity,' uses that corporation as a 'vehicle' whether he is, or is not, its sole owner."

Whitman v. American Trucking Associations

Tue, 07 Nov 2000 13:00:00 +0000

Location

Environmental Protection Agency

"1200 Pennsylvania Avenue**** N.W." Washington DC 20460

Washington, DC 20460

United States

38° 53' 41.154" N, 77° 1' 43.9968" W

See map: Google Maps

Case Basics

Docket No.

99-1257

Petitioner

Whitman

Respondent

American Trucking Associations

Consolidation

No. 99-1426

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

531 U.S. 457 (2001)

Argued

Tuesday, November 7, 2000

Decided

Tuesday, February 27, 2001

Advocates

Judith L. French (Columbus, Ohio, argued the case for the respondents)

Edward W. Warren (Argued the cause for the respondents, on behalf of the Respondents)

Seth P. Waxman (on behalf of the Petitioners, on behalf of the Respondent)

Facts of the Case

Section 109(a) of the Clean Air Act (CAA) requires the Environmental Protection Agency (EPA) Administrator to promulgate national ambient air quality standards (NAAQS) for each air pollutant for which "air quality criteria" have been issued under section 108. In 1997, Carol Browner, the Administrator of the EPA, revised the ozone and particulate matter NAAQS. Afterwards, her revised NAAQS were challenged in court. The District of Columbia Circuit found that section 109(b)(1), which instructs the EPA to set standards, delegated legislative power to the Administrator in contravention of the Federal Constitution because the court found that the EPA had interpreted the statute to provide no "intelligible principle" to guide the agency's exercise of authority. The court remanded the NAAQS to the EPA. The courts also held to its rule that the EPA could not consider implementation costs in setting the NAAQS. Additionally, the court rejected the EPA's position that the implementation provisions for ozone found in Part D, Subpart 2, of Title I of the CAA, were so tied to the existing ozone standard that the EPA lacked the power to revise the standard.

Question

Does section 109(b)(1) of the Clean Air Act unconstitutionally delegate legislative power to the Administrator of the Environmental Protection Agency? May the Administrator of the EPA consider the costs of implementation in setting national ambient air quality standards under section 109(b)(1)? Does the Court of Appeals have the jurisdiction to review the EPA's interpretation of Part D of Title I of the CAA, with respect to implementing the revised ozone NAAQS?

Conclusion

Decision: 9 votes for Whitman, 0 vote(s) against
Legal provision: Clean Air

No, no, and yes. In an opinion delivered by Justice Antonin Scalia, the Court held that the CAA properly delegated legislative power to the EPA, but that the EPA could not consider implementation costs in setting primary and secondary NAAQS. Moreover, the Court held that the Court of Appeals has jurisdiction to review the EPA's interpretation of Part D of Title I of the CAA related to the implementation of the revised ozone NAAQS; however, the EPA's interpretation of Part D was unreasonable.

New York Times v. Tasini

Wed, 28 Mar 2001 13:00:00 +0000

Case Basics

Docket No.

00-201

Petitioner

New York Times

Petitioner Type

Petitioner

Respondent

Tasini

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

533 U.S. 483 (2001)

Argued

Wednesday, March 28, 2001

Decided

Monday, June 25, 2001

Advocates

Laurence H. Tribe (Argued the cause for the petitioners)

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

Facts of the Case

Various freelance authors wrote articles for various print publishers. The publishers treated the authors as independent contractors under contracts. The publishers each licensed rights to copy and sell articles to LEXIS/NEXIS, owner and operator of a computerized database containing articles in text-only format. NEXIS does not reproduce the print publication's formatting. The authors filed suit alleging that their copyrights were infringed when the print publishers placed their articles in the electronic publishers' databases, such as LEXIS/NEXIS. In response, the print and electronic publishers raised the privilege accorded collective work copyright owners by section 201(c) of the Copyright Act. In granting the publishers summary judgment, the District Court held that the electronic databases reproduced and distributed the authors' works, under section 201(c), "as part of...[a] revision of that collective work" to which the authors had first contributed. In reversing, the Court of Appeals found that the databases were not among the collective works covered by section 201(c), and specifically, were not "revisions" of the periodicals in which the Articles first appeared.

Question

Do print and electronic publishers violate the copyrights of freelance authors when they include the freelancers' already-published articles in computer databases without the author's permission?

Conclusion

Decision: 7 votes for Tasini, 2 vote(s) against
Legal provision: 17 U.S.C. 201

Yes. In a 7-2 opinion delivered by Justice Ruth Bader Ginsburg, the Court held that section 201(c) does not authorize the copying at issue. "The publishers are not sheltered by [section 201(c)], we conclude, because the databases reproduce and distribute articles standing alone and not in context, not 'as part of that particular collective work' to which the author contributed, 'as part of...any revision' thereof, or 'as part of...any later collective work in the same series.' Both the print publishers and the electronic publishers, we rule, have infringed the copyrights of the freelance authors," wrote Justice Ginsburg. Dissenting, Justice John Paul Stevens, joined by Justice Stephen G. Breyer, argued that "[e]ach individual file still reminds the reader that he is viewing 'part of' a particular collective work. And the entire editorial content of that work still exists at the reader's fingertips."

Solid Waste Agency v. Army Corps of Engineers

Tue, 31 Oct 2000 13:00:00 +0000

Case Basics

Docket No.

99-1178

Petitioner

Solid Waste Agency

Petitioner Type

Petitioner

Respondent

Army Corps of Engineers

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

531 U.S. 159 (2001)

Argued

Tuesday, October 31, 2000

Decided

Tuesday, January 9, 2001

Advocates

Timothy S. Bishop (Argued the cause for the petitioner)

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

Facts of the Case

The Solid Waste Agency of Northern Cook County (SWANCC) selected an abandoned sand and gravel pit as a solid waste disposal site. Excavation trenches on the site had previously become ponds for migrating birds. Because some trenches would have to be filled in, the SWANCC contacted the Army Corps of Engineers (Corps) to determine if a landfill permit was required under the Clean Water Act (CWA), which authorizes the Corps to issue permits allowing the discharge of dredged or fill material into "navigable waters." Under the CWA, "navigable waters" are defined as "the waters of the United States" and the Corps regulations define such waters to include intrastate waters, of which damage could affect interstate commerce. Subsequently, the Corps denied the SWANCC a permit. The District Court ruled in SWANCC's favor. In reversing, the Court of Appeals held that Congress has authority under the Commerce Clause to regulate intrastate waters.

Question

May the provisions of the Clean Water Act be extended to intrastate waters? Does Congress have the authority under the Commerce Clause to exercise such power?

Conclusion

Decision: 5 votes for Solid Waste Agency, 4 vote(s) against
Legal provision: 33 U.S.C. 1334

No and unanswered. In a 5-4 opinion delivered by Chief Justice William H. Rehnquist, the Court held that the provision of the CWA, which requires those discharging fill material into navigable waters to obtain a permit from the Corps, does not extend to isolated, abandoned sand and gravel pits with seasonal ponds, which provide migratory bird habitats. Writing for the majority, Chief Justice Rehnquist said that "[t]he term 'navigable' has...the import of showing us what Congress had in mind as its authority for enacting the CWA: its traditional jurisdiction over waters that were or had been navigable in fact or which could reasonably be so made." In answering the first question no, the Court did not reach the second question. Justice John Paul Stevens' dissent was joined by Justices David H. Souter, Ruth Bader Ginsburg and Stephen G. Breyer.

Board of Trustees v. Garrett

Wed, 11 Oct 2000 13:00:00 +0000

Location

University of Alabama Tuscaloosa, AL 35487

United States

33° 12' 33.84" N, 87° 34' 10.2" W

See map: Google Maps

Case Basics

Docket No.

99-1240

Petitioner

Board of Trustees

Petitioner Type

Petitioner

Respondent

Garrett

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

531 U.S. 356 (2001)

Argued

Wednesday, October 11, 2000

Decided

Thursday, February 1, 2001

Advocates

Jeffrey S. Sutton (Argued the cause for the petitioners)

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

Seth P. Waxman (Department of Justice, argued the cause for the United States)

Facts of the Case

After Patricia Garrett, Director of Nursing for the University of Alabama, was diagnosed with breast cancer, her treatment forced her to take a substantial leave from work. Upon her return, her supervisor informed her she would have to give up her position. Milton Ash, a security officer for the Alabama Department of Youth Services, who suffers from chronic asthma, requested that his employer modify his duties to accommodate him. Ultimately, none of Ash's requested relief was granted and his job performance evaluations fell. Both Garrett and Ash filed discrimination suits against their Alabama state employers, seeking money damages under Title I of the Americans with Disabilities Act of 1990 (ADA), which prohibits the States and other employers from "discriminating against a qualified individual with a disability because of that disability... in regard to... terms, conditions, and privileges of employment." The District Court disposed of both cases by ruling that the ADA exceeds Congress' authority to abrogate the State's Eleventh Amendment immunity. The Court of Appeals reversed.

Question

May an individual sue a state for damages in federal court under the Americans with Disabilities Act of 1990?

Conclusion

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

No. In a 5-4 opinion delivered by Chief Justice William H. Rehnquist, the Court held that suits in federal court by state employees to recover money damages by reason of the state's failure to comply with Title I of the ADA are barred by the Eleventh Amendment. The Chief Justice wrote for the majority that "in order to authorize private individuals to recover money damages against the States, there must be a pattern of discrimination by the States which violates the Fourteenth Amendment, and the remedy imposed by Congress must be congruent and proportional to the targeted violation." Rehnquist added that none of these requirements had been met. Justices John Paul Stevens, David H. Souter and Ruth Bader Ginsburg joined Justice Stephen G. Breyer's dissent.

Illinois v. McArthur

Wed, 01 Nov 2000 13:00:00 +0000

Case Basics

Docket No.

99-1132

Petitioner

Illinois

Petitioner Type

Petitioner

Respondent

McArthur

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

531 U.S. 326 (2001)

Argued

Wednesday, November 1, 2000

Decided

Tuesday, February 20, 2001

Advocates

Joel D. Bertocchi (Chicago, Illinois, argued the cause for the petitioner)

Matthew D. Roberts (Department of Justice, on behalf of the United States, as amicus curiae, supporting the petitioner)

Deanne F. Jones (Argued the cause for the respondent)

Facts of the Case

In 1997, Tera McArthur asked two police officers to accompany her to her trailer, where she lived with her husband, Charles McArthur, so that they could keep the peace while she removed her belongings. While at the trailer, Tera alerted the officers, Assistant Chief John Love and Officer Richard Skidis, that her husband had marijuana hidden under the couch. Love then asked Charles for permission to search the trailer. Permission was denied and Love sent Officer Skidis with Tera to get a search warrant. Love told Charles he could not reenter his trailer, unless a police officer accompanied him. Afterwards, Love stood just inside the door to observe Charles when he went into the trailer. About two hours later, a search warrant was obtained. Subsequently, a search of the trailer transpired and officers found drug paraphernalia and marijuana. Charles McArthur was arrested. At trial, McArthur moved to suppress the drug paraphernalia and marijuana on the ground that they were the "fruit" of an unlawful police seizure, namely, the refusal to let him reenter the trailer unaccompanied, which would have permitted him, he said, to "have destroyed the marijuana." The trial court granted the motion. The Appellate Court of Illinois affirmed and the Illinois Supreme Court denied the state's petition for leave to appeal.

Question

Do officers, with probable cause to believe that a man had hidden marijuana in his home, who subsequently prevent that man from entering the home for about two hours while they obtain a search warrant, violate the Fourth Amendment?

Conclusion

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

No. In an 8-1 opinion delivered by Justice Stephen G. Breyer, the Court held that given the nature of the intrusion and the law enforcement interest at stake, the brief seizure of the premises was permissible under the Fourth Amendment. "We have found no case in which this Court has held unlawful a temporary seizure that was supported by probable cause and was designed to prevent the loss of evidence while the police diligently obtained a warrant in a reasonable period of time," wrote Justice Breyer for the Court. Dissenting, Justice John Paul Stevens noted he would have dismissed the writ of certiorari as improvidently granted.

Green Tree Fin. Corp. v. Randolph

Tue, 03 Oct 2000 13:00:00 +0000

Case Basics

Docket No.

99-1235

Petitioner

Green Tree Fin. Corp.

Petitioner Type

Petitioner

Respondent

Randolph

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

531 U.S. 79 (2000)

Argued

Tuesday, October 3, 2000

Decided

Monday, December 11, 2000

Advocates

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

Joseph M. Sellers (Argued the cause for the respondent)

Facts of the Case

Larketta Randolph financed the purchase of a mobile home through Green Tree Financial Corp.-Alabama. Randolph's financing agreement with Green Tree required that she buy insurance against default and provided that disputes under the contract would be resolved by binding arbitration. Randolph sued Green Tree, alleging that it violated the Truth in Lending Act (TILA) by failing to disclose the insurance requirement as a finance charge and that it violated the Equal Credit Opportunity Act by requiring her to arbitrate her statutory causes of action. The District Court granted Green Tree's motion to compel arbitration and denied her request for reconsideration, which stated that she lacked the resources to arbitrate and, therefore, would have to forgo her claims. The Court of Appeals, under the Federal Arbitration Act (FAA), which allows appeals from "a final decision with respect to an arbitration that is subject to this title," held that it had jurisdiction. Ultimately, the court concluded that because the agreement was silent with respect to payment of arbitration expenses, it was unenforceable.

Question

Is an order compelling arbitration a "final decision with respect to an arbitration" within the meaning of the Federal Arbitration Act? Is an arbitration agreement that does not mention arbitration costs and fees unenforceable because it fails to protect a party from potentially expensive arbitration costs?

Conclusion

Decision: 9 votes for Green Tree Fin. Corp., 0 vote(s) against
Legal provision: 9 U.S.C. 16

Yes and no. In a opinion delivered by Chief Justice William H. Rehnquist, the Court held that an order compelling arbitration pursuant to the parties' agreement is a "final decision with respect to an arbitration" within the meaning of the Federal Arbitration Act making it immediately appealable pursuant to the FAA. In a 5-4 split, the Court held that an arbitration agreement that is silent on arbitration costs and fees is not unenforceable. Writing for the majority, Chief Justice Rehnquist wrote that "[a]lthough the existence of large arbitration costs may well preclude a litigant...from effectively vindicating [her statutory rights], the record does not show that Randolph will bear such costs if she goes to arbitration." Justices Ruth Bader Ginsburg, John Paul Stevens, David H. Souter, and Stephen G. Breyer dissented.

United States v. Hatter

Tue, 20 Feb 2001 13:00:00 +0000

Case Basics

Docket No.

99-1978

Petitioner

United States

Petitioner Type

Petitioner

Respondent

Hatter

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

532 U.S. 557 (2001)

Argued

Tuesday, February 20, 2001

Decided

Monday, May 21, 2001

Advocates

Steven S. Rosenthal (Argued the cause for the respondents)

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

Facts of the Case

In 1982, when Congress extended Medicare to federal employees, then-sitting federal judges began to have Medicare taxes withheld from their salaries. In 1983, Congress then required federal judges to participate in Social Security, except for those who contributed to a "covered" retirement program. A "covered" program was defined to include any retirement system to which an employee had to contribute, which did not encompass the noncontributory pension system for federal judges, whose financial obligations and payroll deductions therefore had to increase. A group of federal judges, who were appointed before 1983, filed suit arguing that the 1983 law violated the Constitution's Compensation Clause, which guarantees federal judges a "Compensation, which shall not be diminished during their Continuance in Office." Ultimately, the Court of Federal Claims ruled that a 1984 judicial salary increase cured any violation. In reversing, the Federal Circuit held that the Compensation Clause prevented the government from collecting Medicare and Social Security taxes from the judges and that the violation was not cured by the 1984 pay increase.

Question

Did Congress violate the Compensation Clause when it extended the Medicare and Social Security taxes to the salaries of sitting federal judges? If so, was the violation cured when Congress increased the salaries of all federal judges by an amount greater than the new taxes?

Conclusion

Decision: 5 votes for United States, 2 vote(s) against
Legal provision: Article 3, Section 1, Paragraph 2: Good Behavior and Compensation Clause of Federal Judges

In a 6-1 opinion delivered by Justice Stephen G. Breyer, the Court held that the Compensation Clause prevents the government from collecting Social Security taxes from federal judges who held office before Congress extended those taxes to federal employees and that the Compensation Clause violation was not cured by the 1984 pay increase for federal judges. In a 5-2 split, the Court held that the Government could collect Medicare taxes from the same class of judges. On the Medicare question, Justice Breyer, wrote that "this Court has held that the Legislature cannot directly reduce judicial salaries even as part of an equitable effort to reduce all Government salaries. But a tax law, unlike a law mandating a salary reduction, affects compensation indirectly, not directly. And those prophylactic considerations that may justify an absolute rule forbidding direct salary reductions are absent here, where indirect taxation is at issue."

Lujan v. G&G Fire Sprinklers

Mon, 26 Feb 2001 13:00:00 +0000

Case Basics

Docket No.

00-152

Petitioner

Lujan

Petitioner Type

Petitioner

Respondent

G&G Fire Sprinklers

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

532 U.S. 189 (2001)

Argued

Monday, February 26, 2001

Decided

Tuesday, April 17, 2001

Advocates

Thomas S. Kerrigan (Argued the cause for the petitioners)

Stephen A. Seideman (Argued the cause for the respondent)

Jeffrey A. Lamken (Argued the cause for the United States, as amicus curiae, by special leave of court, supporting the petitioners)

Facts of the Case

The California Labor Code requires that contractors and subcontractors on public works project pay their workers a prevailing wage that is determined by the state. The Code authorizes the state to withhold payments from contractors who fail to pay the prevailing wage. The contractor can, in turn, withhold payments to subcontractors who fail to pay the wage. To recover the wages or penalties withheld, the Code permits the contractor to sue for breach of contract. After the State Division of Labor Standards Enforcement (DLSE) determined that G & G Fire Sprinklers, Inc., a public works subcontractor, had violated the Code, it withheld from the contractors an amount equal to the wages and penalties forfeited due to G & G's violations. After its payment was withheld, G & G filed suit against DLSE, claiming that the lacking of a hearing deprived it of property without due process in violation of the Fourteenth Amendment. Granting G & G summary judgment, the District Court declared the relevant Code sections unconstitutional. Ultimately, the Court of Appeals affirmed. The court reasoned that G & G's rights were violated not because it was deprived of immediate payment, but because the state statutory scheme afforded no hearing at all.

Question

Must states provide contractors and subcontractors a hearing to challenge a decision to withhold wage payments from contractors and subcontractors who fail to pay prevailing wages to satisfy due process?

Conclusion

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

No. In a unanimous opinion delivered by Chief Justice William H. Rehnquist, the Court held that because California state law affords G & G sufficient opportunity to pursue its claim for payment under its contracts in state court, the statutory scheme does not deprive it of due process. A contractor's claim for payment is "an interest...that can be fully protected by an ordinary breach-of-contract suit," wrote Chief Justice Rehnquist wrote for the Court. The Chief Justice continued that "if California makes ordinary judicial process available to [G & G] for resolving its contractual dispute, that process is due process."

Alexander v. Sandoval

Tue, 16 Jan 2001 13:00:00 +0000

Case Basics

Docket No.

99-1908

Petitioner

Alexander

Petitioner Type

Petitioner

Respondent

Sandoval

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

532 U.S. 275 (2001)

Argued

Tuesday, January 16, 2001

Decided

Tuesday, April 24, 2001

Advocates

Eric Schnapper (Argued the cause for the private respondents)

Jeffrey S. Sutton (Argued the cause for the petitioner)

Seth P. Waxman (Department of Justice, argued the cause for the respondent United States)

Facts of the Case

Because it is a recipient of federal financial assistance, the Alabama Department of Public Safety (Department) is subject to Title VI of the Civil Rights Act of 1964. Section 601 of Title VI prohibits discrimination based on race, color, or national origin. Under section 602, the Department of Justice issued a regulation forbidding funding recipients to utilize criteria or administrative methods having the effect of subjecting individuals to discrimination based on the prohibited grounds. Martha Sandoval brought a class action suit to enjoin the Department from administering state driver's license examinations only in English. Sandoval argued that the English-only policy violated the DOJ regulation because it had the effect of subjecting non-English speakers to discrimination based on their national origin. Ordering the Department to accommodate non-English speakers, the District Court enjoined the policy. The Court of Appeals affirmed. James Alexander, the Director of the Department, unsuccessfully argued before both courts that Title VI did not provide a cause of action to enforce the regulation.

Question

Does Title VI of the Civil Rights Act of 1964 provide a cause of action to enforce the Department of Justice's regulation forbidding federal financial assistance recipients to utilize criteria or administrative methods that have the effect of subjecting individuals to discrimination based on race, color, or national origin?

Conclusion

Decision: 5 votes for Alexander, 4 vote(s) against
Legal provision: Civil Rights Act of 1964, Title VI

No. In a 5-4 opinion delivered by Justice Antonin Scalia, the Court held that there is no private right of action to enforce disparate-impact regulations promulgated under Title VI. "Title VI itself directly reaches only instances of intentional discrimination," wrote Justice Scalia, "[n]either as originally enacted nor as later amended does Title VI display an intent to create a freestanding private right of action to enforce regulations promulgated under [section 602]." Justice John Paul Stevens filed a dissenting opinion, which was join by Justices David H. Souter, Ruth Bader Ginsburg, and Stephen G. Breyer.

Rogers v. Tennessee

Wed, 01 Nov 2000 13:00:00 +0000

Case Basics

Docket No.

99-6218

Petitioner

Rogers

Petitioner Type

Petitioner

Respondent

Tennessee

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

532 U.S. 451 (2001)

Argued

Wednesday, November 1, 2000

Decided

Monday, May 14, 2001

Advocates

Michael E. Moore (Nashville, Tennessee, argued the cause for the respondent)

W. Mark Ward (Memphis, Tennessee, argued the cause for the petitioner)

Facts of the Case

Wilbert K. Rogers was convicted in Tennessee of second degree murder. The victim, James Bowdery, died 15 months after Rogers stabbed him. On appeal, Rogers argued that the Tennessee common law "year and a day rule," under which no defendant could be convicted of murder unless his victim died by the defendant's act within a year and a day of the act, persisted and precluded his conviction. The Tennessee Court of Criminal Appeals affirmed the conviction. In affirming, the Tennessee Supreme Court ultimately abolished the rule and upheld Rogers' conviction. The court rejected Rogers' contention that abolishing the rule would violate the Ex Post Facto Clauses of the Tennessee and Federal Constitutions. The court reasoned that those provisions referred only to legislative acts. Additionally, the court concluded its decision would not offend due process.

Question

Did the Supreme Court of Tennessee deny a defendant due process of law in violation of the Fourteenth Amendment when it retroactively applied a decision to abolish the state's common law "year-and-a-day rule?"

Conclusion

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

No. In a 5-4 opinion delivered by Justice Sandra Day O'Connor, the Court held that the Tennessee Supreme Court's retroactive application to a defendant of its decision abolishing the year-and-a-day rule did not deny Rogers due process of law in violation of the Fourteenth Amendment. "The Tennessee court's abolition of the year and a day rule was not unexpected and indefensible," wrote Justice O'Connor. "Far from a marked and unpredictable departure from prior precedent, the court's decision was a routine exercise of common law decisionmaking in which the court brought the law into conformity with reason and common sense," continued O'Connor. Justices John Paul Stevens, Antonin Scalia and Stephen G. Breyer wrote separate dissents. Justices Clarence Thomas, Stevens and Breyer joined Justice Scalia's dissent.

Tyler v. Cain

Mon, 16 Apr 2001 13:00:00 +0000

Case Basics

Docket No.

00-5961

Petitioner

Tyler

Petitioner Type

Petitioner

Respondent

Cain

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

533 U.S. 656 (2001)

Argued

Monday, April 16, 2001

Decided

Thursday, June 28, 2001

Advocates

Charles E. F. Heuer (New Orleans, Louisiana, argued the cause for the respondent)

James A. Feldman (Department of Justice, argued the cause for the respondent)

Herbert V. Larson, Jr. (Argued the cause for the petitioner)

Facts of the Case

Melvin Tyler was convicted of second-degree murder. Ultimately, Tyler filed his sixth state habeas petition after the U.S. Supreme Court decided Cage v. Louisiana, which held that a jury instruction is unconstitutional if there is a reasonable likelihood that the jury understood it to allow conviction without proof beyond a reasonable doubt. Tyler claimed that that a jury instruction in his trial was similar to the one ruled unconstitutional in Cage. Ultimately, Tyler filed a second federal habeas petition pursuant to the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA). The District Court denied relief. In affirming, the Court of Appeals stated the District Court had failed to determine whether Tyler had satisfied the AEDPA's successive habeas standard, which requires a district court to dismiss a claim in a second or successive application unless the applicant "shows" that the "claim relies on a new rule of constitutional law, made retroactive to cases on collateral review by the Supreme Court, that was previously unavailable." The court concluded that Tyler did not meet this standard because he "could not show that any Supreme Court decision renders the Cage decision retroactively applicable to cases on collateral review."

Question

Was the ruled established under Cage v. Louisiana, that a jury instruction is unconstitutional if there is a reasonable likelihood that the jury understood the instruction to allow conviction without proof beyond a reasonable doubt, "made retroactive to cases on collateral review by the Supreme Court," such that an inmate is entitled to submit successive a habeas petition based on that new rule?

Conclusion

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

No. In a 5-4 opinion by Justice Clarence Thomas, the Court held that the Cage rule was not "made retroactive to cases on collateral review by the Supreme Court." Justice Thomas wrote for the Court that "[b]ecause 'made' means 'held'...it is clear that the Cage rule has not been 'made retroactive to cases on collateral review by the Supreme Court.' Cage itself does not hold that it is retroactive. The only holding in Cage is that the particular jury instruction violated the Due Process Clause." Justice Sandra Day O'Connor filed a concurring opinion. Justice Stephen G. Breyer filed a dissenting opinion, in which Justices John Paul Stevens, David H. Souter and Ruth Bader Ginsburg joined.

NLRB v. Ky. River Cmty. Care

Wed, 21 Feb 2001 13:00:00 +0000

Case Basics

Docket No.

99-1815

Petitioner

National Labor Relations Board

Petitioner Type

Petitioner

Respondent

Ky. River Cmty. Care

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

532 U.S. 706 (2001)

Argued

Wednesday, February 21, 2001

Decided

Tuesday, May 29, 2001

Advocates

Michael W. Hawkins (Argued the case for the respondents)

Lawrence G. Wallace (Department of Justice, argued the cause for the petitioner)

Facts of the Case

In 1997, a labor union petitioned the National Labor Relations Board (NLRB) to represent a unit of all the employees at the Caney Creek Developmental Complex, which is operated by Kentucky River Community Care, Inc. Kentucky River objected to the inclusion of its registered nurses in the unit because they were "supervisors" under National Labor Relations Act (NLRA). Under the NLRA, employees are deemed to be "supervisors" and thereby excluded from the NLRA if they exercise "independent judgment" in "responsibly...directing" other employees "in the interest of the employer." At the ensuing representation hearing, the NLRB placed the burden of proving supervisory status on Kentucky River and found that it had not carried its burden. The NLRB rejected Kentucky River's proof of supervisory status on the ground that employees do not use "independent judgment" under the NLRA when they exercise "ordinary professional or technical judgment in directing less-skilled employees to deliver services in accordance with employer-specified standards." Kentucky River then refused to bargain with the union. Ultimately, the Court of Appeals refused to enforce a bargaining order issued by the NLRB at an unfair labor practice proceeding. The court rejected the NLRB's interpretation of "independent judgment" under the NLRA's test for supervisory status and held that NLRB had erred in placing the burden of proving supervisory status on Kentucky River.

Question

Does the party claiming that an employee is a supervisor bear the burden of proving supervisor status in a representation hearing and unfair labor practice proceeding under the National Labor Relations Act? Under the National Labor Relations Act, is judgment "independent judgment" when it is informed by professional or technical training or experience?

Conclusion

Decision: 5 votes for Ky. River Cmty. Care, 4 vote(s) against
Legal provision: National Labor Relations, as amended

Yes and no. In a unanimous opinion delivered by Justice Antonin Scalia, the Court held that the burden of proving the applicability of the supervisory exception of the Act falls on the party asserting it. Justice Scalia wrote that the "Act does not...expressly allocate the burden of proving or disproving a challenged employee's supervisory status. The Board therefore has filled the statutory gap with the consistent rule that the burden is borne by the party claiming that the employee is a supervisor." Additionally, in a 5-4 split, the Court held that the NLRB's application of its interpretation of "independent judgment" to create categorical exclusion for nurses who exercised ordinary professional or technical judgment in directing less- skilled employees to deliver services was unlawful under the NLRA.

United States v. Oakland Cannabis Buyers' Coop

Wed, 28 Mar 2001 13:00:00 +0000

Case Basics

Docket No.

00-151

Petitioner

United States

Petitioner Type

Petitioner

Respondent

Oakland Cannabis Buyers' Coop

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

532 U.S. 483 (2001)

Argued

Wednesday, March 28, 2001

Decided

Monday, May 14, 2001

Advocates

Barbara D. Underwood (Department of Justice, argued the cause for the petitioner)

Gerald F. Uelmen (Argued the cause for the respondents)

Facts of the Case

Under California's Compassionate Use Act of 1996, the Oakland Cannabis Buyers' Cooperative was organized to distribute marijuana to qualified patients for medical purposes. In 1998, the United States sued to enjoin the Cooperative and its executive director. The government argued that the Cooperative's activities violated the Controlled Substances Act's prohibitions on distributing, manufacturing, and possessing with the intent to distribute or manufacture a controlled substance. Although the District Court enjoined it, the Cooperative continued to distribute marijuana. Rejecting the Cooperative's medical necessity defense, the court found the Cooperative in contempt. On appeal, the Court of Appeals concluded that the medical necessity defense was a legally cognizable defense. On remand from the Court of Appeals, the District Court modified its injunction to incorporate a medical necessity defense, under which medically necessary distributions were to be permitted.

Question

Does a medical necessity exception to the Controlled Substances Act's prohibition on the manufacture and distribution of various drugs, including marijuana, exist?

Conclusion

Decision: 8 votes for United States, 0 vote(s) against
Legal provision: 21 U.S.C. 801

No. In an 8-0 opinion delivered by Justice Clarence Thomas, the Court held that there is no medical necessity exception to the Controlled Substances Act's prohibitions on manufacturing and distributing marijuana. "The statute reflects a determination that marijuana has no medical benefits worthy of an exception, " wrote Justice Thomas, therefore, "medical necessity is not a defense to manufacturing and distributing marijuana." Justice John Paul Stevens' concurring opinion, which was joined by Justices David H. Souter and Ruth Bader Ginsburg, argued that "[b]ecause necessity was raised in this case as a defense to distribution, the Court need not venture an opinion on whether the defense is available to anyone other than distributors." Justice Stephen G. Breyer took no part in the consideration or decision of the case.

Ohio v. Reiner

Sat, 27 Apr 2013 09:50:47 +0000

Case Basics

Docket No.

00-1028

Petitioner

Ohio

Petitioner Type

Petitioner

Respondent

Reiner

Respondent Type

Respondent

Decided By

Rehnquist Court (1994-2005)

Opinion

532 U.S. 17 (2001)

Decided

Monday, March 19, 2001

Facts of the Case

Matthew Reiner was charged with involuntary manslaughter in connection with the death of his 2-month-old son Alex. The defense planned to argue that Susan Batt, the family's babysitter, was the culpable party. The trial court granted Batt transactional immunity from prosecution, at the state's request, after she informed the court she intended to assert her Fifth Amendment privilege against self-incrimination. Ultimately, Batt denied any involvement in the death. Reiner was convicted. The Court of Appeals of Ohio reversed. In affirming, the Supreme Court of Ohio held that "Susan Batt's [trial] testimony did not incriminate her because she denied any involvement in the abuse. Thus, she did not have a valid Fifth Amendment privilege." The court noted that the defense's theory of Batt's guilt was not grounds for a grant of immunity, "when the witness continues to deny any self-incriminating conduct." The court also found that the wrongful grant of immunity prejudiced Reiner, because it effectively told the jury that Batt did not cause Alex's injuries.

Question

May a witness who claims no involvement in a crime assert a Fifth Amendment right against self-incrimination?

Conclusion

Decision: 9 votes for Ohio, 0 vote(s) against
Legal provision: Self-Incrimination

Yes. In a per curiam opinion, the Court held that, while the self- incrimination privilege's protection only extended to witnesses who had reasonable cause to apprehend danger from a direct answer, the babysitter's expression of innocence did not by itself eliminate the babysitter's privilege and that the grant of immunity was thus not an error. The opinion stated that the "defense's theory of the case was that Batt, not [Reiner], was responsible for Alex's death... . In this setting, it was reasonable for Batt to fear that answers to possible questions might tend to incriminate her. Batt therefore had a valid Fifth Amendment privilege against self-incrimination."

Atkinson Trading v. Shirley

Tue, 27 Mar 2001 13:00:00 +0000

Case Basics

Docket No.

00-454

Petitioner

Atkinson Trading

Petitioner Type

Petitioner

Respondent

Shirley

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

532 U.S. 645 (2001)

Argued

Tuesday, March 27, 2001

Decided

Tuesday, May 29, 2001

Advocates

Charles G. Cole (Argued the cause for the petitioner)

Beth S. Brinkmann (Department of Justice, as amicus curiae, supporting the respondents)

Marcelino R. Gomez (Navajo Nation, Department of Justice, Window Rock, Arizona; argued the cause for the respondents)

Facts of the Case

Atkinson Trading Company, Inc. owns the Cameron Trading Post, which is located on non-Indian fee land within the Navajo Nation Reservation. The Cameron Trading Post consists of a hotel, restaurant, cafeteria, gallery, curio shop, retail store, and recreational vehicle facility. In 1992, the Navajo Nation enacted a hotel occupancy tax, which imposed an 8 percent tax upon any hotel room located within the exterior boundaries of the reservation. Atkinson challenged the tax under Montana v. United States. Under Montana, with two limited exceptions, Indian tribes lack civil authority over the conduct of nonmembers on non-Indian land within a reservation. The District Court upheld that tax. In affirming, the Court of Appeals concluded that the tax fell under Montana's first exception because a "consensual relationship exists in that the nonmember guests could refrain from the privilege of lodging within the confines of the Navajo Reservation and therefore remain free from liability for the [tax]."

Question

Does the rule in Montana v. United States, that, with limited exceptions, Indian tribes lack civil authority over the conduct of nonmembers on non- Indian fee land within a reservation, apply to tribal attempts to tax nonmember activity occurring on non-Indian fee land?

Conclusion

Decision: 9 votes for Atkinson Trading, 0 vote(s) against
Legal provision: 25 U.S.C. 261

Yes. In a unanimous opinion delivered by Chief Justice William H. Rehnquist, the Court held that the Navajo Nation's imposition of a hotel occupancy tax upon nonmembers on non-Indian fee land within its reservation is invalid. Chief Justice Rehnquist wrote that "Indian tribes are 'unique aggregations possessing attributes of sovereignty over both their members and their territory,' but their dependent status generally precludes extension of tribal civil authority beyond these limits. The Navajo Nation's imposition of a tax upon nonmembers on non-Indian fee land within the reservation is, therefore, presumptively invalid. Because respondents have failed to establish that the hotel occupancy tax is commensurately related to any consensual relationship with [Atkinson] or is necessary to vindicate the Navajo Nation's political integrity, the presumption ripens into a holding."

Kansas v. Colorado

Mon, 19 Mar 2001 13:00:00 +0000

Case Basics

Docket No.

105 ORIG

Plaintiff

Kansas

Petitioner Type

Plaintiff

Defendant

Colorado

Respondent Type

Defendant

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

533 U.S. 1 (2001)

Argued

Monday, March 19, 2001

Decided

Monday, June 11, 2001

Advocates

Jeffrey P. Minear (on behalf of the United States, as Intervenor)

David W. Robbins (on behalf of the Defendant)

John B. Draper (on behalf of the Plaintiff)

Facts of the Case

In 1949, Congress approved the Arkansas River Compact. Article IV-D provided that future development of the river basin could not materially deplete the usable quantity or availability to other users of the river's waters. In 1986, Kansas filed suit alleging that Colorado had violated the Compact. Ultimately, the Special Master found that post-Compact increases in groundwater well pumping in Colorado had materially depleted the waters in violation of Article IV-D. The Special Master, in his second report, recommended that damages be awarded to Kansas. In his third report, the Special Master recommended that such damages be measured by Kansas' losses attributable to Compact violations since 1950, be paid in money not water, and include prejudgment interest from 1969 to the date of judgment. Colorado filed four objections to the third report, Kansas filed one, and the United States submitted that all objections should be overruled.

Question

Does the Eleventh Amendment preclude the recommended award of damages based on losses sustained by individual water users in Kansas? Should the damages include prejudgment interest? Is the amount of interest excessive? Should the prejudgment interest be paid from 1950 rather than 1969? Did the Special Master improperly calculate the value of the crop losses attributable to the Compact violations?

Conclusion

Decision: 6 votes for Kansas, 3 vote(s) against
Legal provision:

No, yes, no, no, and no. In a unanimous opinion delivered by Justice John Paul Stevens, the Court remanded the case to the Special Master for preparation of a final judgment consistent with its opinion. The Court unanimously concluded that the recommended damages award does not violate the Eleventh Amendment and that the Special Master properly determined the value of the crop losses attributable to Compact violations. In a 6-3 split, the Court ruled that the unliquidated nature of Kansas' money damages does not bar an award of prejudgment interest and that the Special Master determined the appropriate rate for the prejudgment interest award, which should begin running in 1969.

Circuit City v. Adams

Mon, 06 Nov 2000 13:00:00 +0000

Case Basics

Docket No.

99-1379

Petitioner

Circuit City

Petitioner Type

Petitioner

Respondent

Adams

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

532 U.S. 105 (2001)

Argued

Monday, November 6, 2000

Decided

Wednesday, March 21, 2001

Advocates

Michael Rubin (Argued the cause for the respondent)

David E. Nagle (Argued the cause for the petitioner)

Facts of the Case

In 1995, Saint Clair Adams, who was hired as a sales counselor, signed an employment application with Circuit City. A provision in Adams' application required all employment disputes to be settled by arbitration. In 1997, Adams filed an employment discrimination lawsuit against Circuit City in California state court. Circuit City then filed suit in Federal District Court, seeking to enjoin the state-court action and to compel arbitration of Adams' claims under the Federal Arbitration Act (FAA). The District Court entered the requested order. The court concluded that Adams was obligated by the arbitration agreement. In reversing, the Court of Appeals found that the arbitration agreement between Adams and Circuit City was contained in a "contract of employment," and thus not subject to the FAA under section 1 of the Act. Section 1 of the FAA excludes "contracts of employment of seamen, railroad employees, or any other class of workers engaged in foreign or interstate commerce" from the Act's coverage.

Question

Does the Federal Arbitration Act, which excludes "contracts of employment of seamen, railroad employees, or any other class of workers engaged in foreign or interstate commerce" from the Act's coverage, apply to employment contracts?

Conclusion

Decision: 5 votes for Circuit City, 4 vote(s) against
Legal provision: 9 U.S.C. 1

No. In a 5-4 opinion delivered by Justice Anthony M. Kennedy, the Court held that section 1 exemption is confined to transportation workers. "The wording of [section 1] calls for the application of the maxim ejusdem generis, the statutory canon that 'where general words follow specific words in a statutory enumeration, the general words are construed to embrace only objects similar in nature to those objects enumerated by the preceding specific words,'" wrote Justice Kennedy. Justice Kennedy continued that "[u]nder this rule of construction the residual clause should be read to give effect to the terms 'seamen' and 'railroad employees,' and should itself be controlled and defined by reference to the enumerated categories of workers which are recited just before it; the interpretation of the clause pressed by respondent fails to produce these results." Therefore, section 1 "exempts from the FAA only contracts of employment of transportation workers."

Bush v. Palm Beach County Canvassing Board

Fri, 01 Dec 2000 13:00:00 +0000

Case Basics

Docket No.

00-836

Petitioner

Bush

Petitioner Type

Petitioner

Respondent

Palm Beach County Canvassing Board

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

531 U.S. 70 (2000)

Argued

Friday, December 1, 2000

Decided

Monday, December 4, 2000

Advocates

Joseph P. Klock (Argued the cause for petitioner Harris)

Laurence H. Tribe (Argued the cause for the respondent)

Paul Hancock (Argued the cause for petitioner Florida Attorney General)

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

Facts of the Case

The 2000 presidential election remained in limbo with the outcome dependent on the winner of the popular vote in Florida. Republican presidential candidate George W. Bush held a slim lead in the tally. Democratic presidential candidate Al Gore challenged the decision of Florida's Secretary of State, Katherine Harris, to certify the results of the presidential election on November 14, the deadline provided by Florida's election law. Gore also challenged Harris's decision to ignore the outcome of manual recounts his campaign had requested in four Florida counties, recounts available under another provision of Florida's election code. The Florida Supreme Court heard Gore's challenges and held that Harris could not certify the outcome until November 26. The Florida Supreme Court also held that Harris must include the results of manual recounts in the certified results. Governor Bush intervened. Harris and Bush appealed the Florida Supreme Court's decision to the U.S. Supreme Court.

Question

Do post-election court decisions that limit legislators' or executive officials' discretion to certify election results violate the Due Process Clause of the U.S. Constitution or 3 USC Section 5? Did the Florida Supreme Court's decision change the manner in which Florida's electoral votes were chosen, thereby violating Article II Section 1 Clause 2 of the US Constitution, which confers plenary power in federal election matters on state legislatures?

Conclusion

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

In a per curiam opinion, a unanimous court held that there was "considerable uncertainty" as to the reasons for the Florida Supreme Court's decision. Accordingly the court did not review the federal questions presented by the case. Instead it vacated the Florida Supreme Court's decision and remanded the case for clarification of two questions. One, did the Florida Supreme Court think that the Florida Constitution circumscribed the plenary power of the Florida Legislature in election matters conferred by the US Constitution? And two, how much weight did the Florida Supreme Court give to 3 USC Section 5?

Texas v. Cobb

Tue, 16 Jan 2001 13:00:00 +0000

Case Basics

Docket No.

99-1702

Petitioner

Texas

Petitioner Type

Petitioner

Respondent

Cobb

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

532 U.S. 162 (2001)

Argued

Tuesday, January 16, 2001

Decided

Monday, April 2, 2001

Advocates

Gregory S. Coleman (Austin, Texas, argued the cause for the petitioner)

Lisa S. Blatt (Argued the cause for the United States, as amicus curiae, by special leave of the court, supporting the petitioner)

Roy E. Greenwood (Argued the cause for the respondent)

Facts of the Case

In 1994, while under arrest for an unrelated offense, Raymond Levi Cobb confessed to a home burglary. Cobb, however, denied knowledge of the disappearance of a woman and child from the home. In 1995, after counsel was appointed to represent him in the burglary case, Cobb confessed to killing the woman and child to his father, who contacted the police. Cobb, now in custody, waived his rights under Miranda and confessed to the murders. Cobb was then indicted, convicted, and sentenced to death. On appeal to the Texas Court of Criminal Appeals, Cobb argued that his confession should have been suppressed because it was obtained in violation of his Sixth Amendment right to counsel, which he claimed attached when counsel was appointed in the burglary case. In reversing, the court held that once the right to counsel attaches to the offense charged, it also attaches to any other offense that is very closely factually related to the offense charged.

Question

Does the Sixth Amendment right to counsel extend to crimes that are "factually related" to those that have actually been charged?

Conclusion

Decision: 5 votes for Texas, 4 vote(s) against
Legal provision: Amendment 6: Other Sixth Amendment Provisions

No. In a 5-4 opinion delivered by Chief Justice William H. Rehnquist, the Court held that because the Sixth Amendment right to counsel is "offense specific," it does not necessarily extend to offenses that are "factually related" to those that have actually been charged. Since the right to counsel was offense specific, and the offenses were separate, Chief Justice Rehnquist wrote that the "Sixth Amendment right to counsel did not bar police from interrogating [Cobb] regarding the murders, and [Cobb's] confession was therefore admissible." Justice Anthony M. Kennedy wrote a concurring opinion, which was joined by Justices Antonin Scalia and Clarence Thomas. Justice Stephen G. Breyer wrote a dissenting opinion, which was joined by Justices John Paul Stevens, David H. Souter, and Ruth Bader Ginsburg.

Wharf Holdings Ltd. v. United International Holdings

Wed, 21 Mar 2001 13:00:00 +0000

Case Basics

Docket No.

00-347

Petitioner

Wharf Holdings Ltd.

Petitioner Type

Petitioner

Respondent

United International Holdings

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

532 U.S. 588 (2001)

Argued

Wednesday, March 21, 2001

Decided

Monday, May 21, 2001

Advocates

Louis R. Cohen (Argued the cause for the respondent)

Matthew D. Roberts (As amicus curiae, supporting the respondent)

Paul M. Dodyk (Argued the cause for the petitioner)

Facts of the Case

In return for United International Holdings, Inc.'s assistance in preparing its application, contracts, system, and financing for a cable television system in Hong Kong, Wharf Holdings Ltd. orally granted United an option to buy 10% of stock in the system. The parties never reduced the agreement to writing. Ultimately, Wharf refused to allow United to exercise its option. United then sued Wharf in Federal District Court, claiming that Wharf violated the Securities Exchange Act of 1934, which prohibits using "any manipulative or deceptive device or contrivance...in connection with the purchase or sale of any security." Wharf's internal documents, which suggested that Wharf never intended to carry out its promise, supported United's claim. A jury found in United's favor. The Court of Appeals affirmed.

Question

Does an oral agreement to grant an option to buy stock, while secretly intending not to honor the option, violate the Securities Exchange Act of 1934?

Conclusion

Decision: 9 votes for United International Holdings, 0 vote(s) against
Legal provision: Securities Act of 1933, the Securities and Exchange Act of 1934, or the Williams Act

Yes. In a unanimous opinion delivered by Justice Stephen G. Breyer, the Court held that an oral agreement to give an option to buy stock while secretly intending never to honor that option violates the Securities Exchange Act of 1934's prohibition of deceptive devices. Justice Breyer wrote for the Court that there was no "convincing reason to interpret the Act to exclude oral contracts as a class. The Act itself says that it applies to 'any contract' for the purchase or sale of a security."

Good News Club v. Milford Central School

Wed, 28 Feb 2001 13:00:00 +0000

Location

Milford Central School

42 West Main Street Milford NY 13807

Milford, NY 13807

United States

42° 35' 27.3948" N, 74° 56' 54.816" W

See map: Google Maps

Case Basics

Docket No.

99-2036

Petitioner

Good News Club

Petitioner Type

Petitioner

Respondent

Milford Central School

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

533 U.S. 98 (2001)

Argued

Wednesday, February 28, 2001

Decided

Monday, June 11, 2001

Advocates

Thomas Marcelle (Argued the cause for the petitioners)

Frank W. Miller (Argued the cause for the respondent)

Facts of the Case

Under New York law, Milford Central School policy authorizes district residents to use its building after school for certain activities. Stephen and Darleen Fournier were district residents eligible to use the school's facilities. They sought approval of their proposed use and sponsorship of the Good News Club, a private Christian organization for children. The Fourniers submitted a request to hold the Club's weekly afterschool meetings at the school. Milford denied the request reasoning that the proposed use, including singing songs, hearing Bible lessons, memorizing scripture, and praying, was the equivalent of religious worship prohibited by the community use policy. The Club filed suit alleging that the denial violated its free speech rights under the First and Fourteenth Amendments. Ultimately, the District Court granted Milford summary judgment. In affirming, the Court of Appeals held that because the subject matter of the Club's was "quintessentially religious", and the activities "fall outside the bounds of pure 'moral and character development,'" Milford's policy of excluding the Club's meetings was constitutional subject discrimination, not unconstitutional viewpoint discrimination.

Question

Did Milford Central School violate the First Amendment free speech rights of the Good News Club when it excluded the Club from meeting after hours at the school? If a violation occurred, was it justified by Milford's concern that permitting the Club's activities would violate the Establishment Clause?

Conclusion

Decision: 6 votes for Good News Club, 3 vote(s) against
Legal provision: Amendment 1: Speech, Press, and Assembly

Yes and no. In a 6-3 opinion delivered by Justice Clarence Thomas, the Court held that "Milford's restriction violates the Club's free speech rights and that no Establishment Clause concern justifies that violation." "When Milford denied the Good News Club access to the school's limited public forum on the ground that the Club was religious in nature, it discriminated against the Club because of its religious viewpoint in violation of the Free Speech Clause of the First Amendment," wrote Justice Thomas.

Becker v. Montgomery

Mon, 16 Apr 2001 13:00:00 +0000

Case Basics

Docket No.

00-6374

Petitioner

Becker

Petitioner Type

Petitioner

Respondent

Montgomery

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

532 U.S. 757 (2001)

Argued

Monday, April 16, 2001

Decided

Tuesday, May 29, 2001

Advocates

Stewart A. Baker (Was invited to brief and argue as amicus curiae in support of judgment below)

Jeffrey S. Sutton (Argued the cause for the petitioner)

Facts of the Case

Dale G. Becker, an Ohio prisoner, instituted a pro se civil rights action to contest the conditions of his confinement. Ultimately, the District Court dismissed Becker's complaint. In appealing, Becker, still pro se, filed his notice of appeal using a government-printed form, on which he filled in all of the required information. On the line labeled "Counsel for Appellant" Becker typed, but did not sign, his name. The form contained no indication of a signature requirement. The District Court docketed the notice, sent a copy to the Court of Appeals, and granted Becker leave to proceed in forma pauperis on appeal. Ultimately, the Court of Appeals, after notifying Becker that the court would not hold him to the same standards it required of attorneys in stating his case, dismissed the appeal on its own motion. The court held that the notice of appeal was fatally defective because it was not signed.

Question

When a party files a timely notice of appeal in district court, does the failure to sign the notice of appeal require the court of appeals to dismiss the appeal?

Conclusion

Decision: 9 votes for Becker, 0 vote(s) against
Legal provision: Federal Rules of Civil Procedure, including Appellate Procedure (or relevant rules of a circuit court)

No. In a unanimous opinion delivered by Justice Ruth Bader Ginsburg, the Court held that when a party files a timely notice of appeal in district court, the failure to sign the notice does not require the court of appeals to dismiss the appeal. Justice Ginsburg wrote for the Court that "if the notice is timely filed and adequate in other respects, jurisdiction will vest in the court of appeals, where the case may proceed so long as the appellant promptly supplies the signature once the omission is called to his attention."

Eastern Associated Coal Corp. v. Mine Workers

Mon, 02 Oct 2000 13:00:00 +0000

Case Basics

Docket No.

99-1038

Petitioner

Eastern Associated Coal Corp.

Respondent

Mine Workers

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

531 U.S. 57 (2000)

Argued

Monday, October 2, 2000

Decided

Tuesday, November 28, 2000

Advocates

John G. Roberts, Jr. (Argued the cause for the petitioner)

John R. Mooney (Argued the cause for the respondents)

Malcolm L. Stewart (Department of Justice, on behalf of the United States, as amicus curiae, supporting the respondents)

Facts of the Case

Eastern Associated Coal Corp. and the United Mine Workers of America are parties to a collective-bargaining agreement with arbitration provisions. Under the agreement, in order for Eastern to discharge an employee, it must prove it has "just cause," or the arbitrator will order the employee reinstated. The arbitrator's decision is final. With this framework in place, James Smith worked for Eastern as a truck driver subject to Department of Transportation (DOT) regulations requiring random drug testing of workers engaged in "safety-sensitive" tasks. After Smith tested positive for marijuana use twice, Eastern sought to discharge him. Each time the union went to arbitration. The arbitrator concluded that Smith's positive drug test did not amount to "just cause" for discharge and reinstated him conditionally. After the second occurrence, Eastern filed suit to vacate the arbitrator's award. The District Court ordered the award's enforcement, holding that Smith's conditional reinstatement did not violate the strong regulation-based public policy against drug use by workers who perform safety-sensitive functions. The Court of Appeals affirmed.

Question

Do public policy considerations require federal courts to refuse to enforce arbitrator's awards, which reinstate employees fired for testing positive for marijuana?

Conclusion

Decision: 9 votes for Mine Workers, 0 vote(s) against
Legal provision: 105 Stat. 952

No. In a opinion delivered by Justice Stephen G. Breyer, the Court held that under Eastern and the United Mine Workers of America collective bargaining agreement, the arbitration award, which required Smith's reinstatement, was not contrary to explicit, well defined, dominant public policy. The public- policy exception to enforcing an arbitrator's award is narrow; thus, the public policy must be "explicit, well-defined, and dominant," explained Justice Breyer, and must be ascertained "by reference to positive law and not from general considerations of supposed public interests." Justice Antonin Scalia, joined by Justice Clarence Thomas, concurred in the judgment.

C&L Enterprises v. Citizen Band Potawatomi

Mon, 19 Mar 2001 13:00:00 +0000

Case Basics

Docket No.

00-292

Petitioner

C&L Enterprises

Petitioner Type

Petitioner

Respondent

Citizen Band Potawatomi

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

532 U.S. 411 (2001)

Argued

Monday, March 19, 2001

Decided

Monday, April 30, 2001

Advocates

Gregory S. Coleman (On behalf of Texas, as amicus curiae, supporting the petitioner)

Michael Minnis (Argued the cause for the respondent)

John D. Mashburn (Argued the cause for the petitioner)

Gregory G. Garre (On behalf of the United States, as amicus curiae, supporting the respondent)

Facts of the Case

The Citizen Band Potawatomi Indian Tribe of Oklahoma, a federally recognized Tribe, entered into a contract with C & L Enterprises, Inc., for the installation of a roof on a Tribe-owned building in Oklahoma. The property rests outside the Tribe's reservation and is not held in trust by the Federal Government for the Tribe. The contract contains clauses requiring disputes arising out of the contract to be decided by arbitration and a choice-of-law clause that reads: "The contract shall be governed by the law of the place where the Project is located." Thus, Oklahoma law governed the contract. After the contract was executed, but before performance commenced, the Tribe retained another company to install the roof. C & L then submitted an arbitration demand. The Tribe asserted sovereign immunity. The arbitrator awarded C & L a monetary award. Ultimately, the Oklahoma Court of Civil Appeals held that the Tribe was immune from suit. The court noted that the contract seemed to indicate the Tribe's willingness to expose itself to suit on the contract, but concluded that the Tribe had not waived its suit immunity with the requisite clarity.

Question

Does a federally recognized tribe waives its immunity from suit in state court when it expressly agrees to arbitrate disputes relating to a contract, to the governance of state law, and to the enforcement of arbitral awards in any court with proper jurisdiction?

Conclusion

Decision: 9 votes for C&L Enterprises, 0 vote(s) against
Legal provision:

Yes. In a unanimous opinion delivered by Justice Ruth Bader Ginsburg, the Court held that "under the agreement the Tribe proposed and signed, the Tribe clearly consented to arbitration and to the enforcement of arbitral awards in Oklahoma state court; the Tribe thereby waived its sovereign immunity from C & L's suit." Justice Ginsburg wrote for the Court that "the Tribe agreed, by express contract, to adhere to certain dispute resolution procedures."

Semtek v. Lockheed Martin

Tue, 05 Dec 2000 13:00:00 +0000

Case Basics

Docket No.

99-1551

Petitioner

Semtek

Petitioner Type

Petitioner

Respondent

Lockheed Martin

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

531 U.S. 497 (2001)

Argued

Tuesday, December 5, 2000

Decided

Tuesday, February 27, 2001

Advocates

Walter E. Dellinger, III (Argued the cause for the respondent)

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

Facts of the Case

Semtek International filed a complaint against Lockheed Martin Corporation in California state court, alleging breach of contract and various business torts. Based on diversity of citizenship, Lockheed Martin moved the case to the District Court. In the District Court, Lockheed Martin successfully moved to dismiss Semtek's claims, as they were barred by California's 2-year statute of limitations. The dismissal was upheld on appeal. Semtek then filed suit in the State Circuit Court for Baltimore City, Maryland, alleging the same causes of action. The suit was not time barred under Maryland's 3-year statute of limitations. The court dismissed the case under res judicata. In affirming, the Maryland Court of Special Appeals held that the California federal court's dismissal barred the Maryland complaint because the res judicata effect of federal diversity judgments is prescribed by federal law, under which the earlier dismissal was on the merits and claim-preclusive.

Question

Is the claim-preclusive effect of a federal judgment dismissing a diversity action on statute-of-limitations grounds determined by the law of the state in which the federal court sits?

Conclusion

Decision: 9 votes for Semtek, 0 vote(s) against
Legal provision: Federal Rules of Civil Procedure, including Appellate Procedure (or relevant rules of a circuit court)

No. In a unanimous opinion delivered by Justice Antonin Scalia, the Court held that "[b]ecause the claim-preclusive effect of a federal court's dismissal 'upon the merits' of a diversity action on state statute-of-limitations grounds is governed by a federal rule, which in turn (in diversity cases) incorporates the claim-preclusion law that would be applied by state courts in the State in which the federal court sits, the Maryland Court of Special Appeals erred in holding that the California federal court's dismissal 'upon the merits' necessarily precluded the Maryland state-court action." Thus, the District Court's dismissal on the merits of claims as untimely under California law did not preclude Semtek from asserting its claims in a different state court forum.

New Hampshire v. Maine

Mon, 16 Apr 2001 13:00:00 +0000

Case Basics

Docket No.

130 ORIG

Plaintiff

New Hampshire

Petitioner Type

Plaintiff

Defendant

Maine

Respondent Type

Defendant

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

532 U.S. 742 (2001)

Argued

Monday, April 16, 2001

Decided

Tuesday, May 29, 2001

Advocates

Jeffrey P. Minear (Department of Justice, as amicus curiae, supporting the defendant)

Paul Stern (Augusta, Maine, argued the cause for the defendant)

Leslie J. Ludtke (Concord, NH, argued the cause for the plaintiff)

Facts of the Case

In 1977, a dispute between New Hampshire and Maine over lobster fishing rights resulted in the U.S. Supreme Court entering a consent judgment setting the precise location of the States' "lateral marine boundary," or the boundary in the marine waters off the coast. Utilizing a 1740 decree of King George II, the States agreed that the decree's words "Middle of the River" referred to the middle of the Piscataqua River's main navigable channel. Ultimately, the 1997 consent judgment defined "Middle of the River" as "the middle of the main channel of navigation of the Piscataqua River." The consent judgment did not fix the inland Piscataqua River boundary. In 2000, New Hampshire brought an original action against Maine, claiming that the inland river boundary runs along the Maine shore and that the entire Piscataqua River and all of Portsmouth Harbor belong to New Hampshire. In response, Maine filed a motion to dismiss, arguing that the 1740 boundary determination by King George II and the 1977 consent judgment barred the complaint.

Question

Is New Hampshire's original suit against Maine, which disputes the Piscataqua River boundary, barred by earlier proceedings?

Conclusion

Decision: 8 votes for Maine, 0 vote(s) against
Legal provision: Estoppel

Yes. In an opinion delivered by Justice Ruth Bader Ginsburg, the Court held that "judicial estoppel bars New Hampshire from asserting that the Piscataqua River boundary runs along the Maine shore." Under the judicial estoppel doctrine, "[w]here a party assumes a certain position in a legal proceeding, and succeeds in maintaining that position, he may not thereafter, simply because his interests have changed, assume a contrary position, especially if it be to the prejudice of the party who has acquiesced in the position formerly taken by him," wrote Justice Ginsburg. "New Hampshire's claim that the Piscataqua River boundary runs along the Maine shore is clearly inconsistent with its interpretation of the words 'Middle of the River' during the 1970's litigation," concluded Ginsburg.

Alabama v. Bozeman

Tue, 17 Apr 2001 13:00:00 +0000

Case Basics

Docket No.

00-492

Petitioner

Alabama

Petitioner Type

Petitioner

Respondent

Bozeman

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

533 U.S. 146 (2001)

Argued

Tuesday, April 17, 2001

Decided

Monday, June 11, 2001

Advocates

Mark John Christensen (Argued the cause for the respondent)

Sandra Jean Stewart (Montgomery, Alabama, argued the cause for the petitioner)

Jeffrey A. Lamken (Department of Justice, on behalf of the United States, as amicus curiae, supporting the petitioner)

Facts of the Case

The Interstate Agreement on Detainers creates uniform procedures for lodging and executing a detainer, a legal order that requires a state to hold a currently imprisoned individual when he has finished serving his sentence so that he may be tried by a different State for a different crime. In 1997, Michael Bozeman was serving a federal prison sentence at a federal prison in Florida. In January, the district attorney of Covington County, Alabama sought temporary custody of Bozeman to arraign him on state firearm charges for which an earlier detainer had been filed. The Agreement provides that a state that obtains a prisoner for purposes of trial must try him within 120 days of his arrival, and if it returns him to his "original place of imprisonment" prior to that trial, charges shall be dismissed. After appearing in Alabama court, Bozeman was returned to federal prison in Florida. When Bozeman returned to Alabama court, his local counsel filed a motion to dismiss the state charges on the ground that Bozeman had been "returned to the original place of imprisonment" (the federal prison) "prior to" "trial" on state charges being "had." Ultimately, Bozeman was convicted and an appellate court affirmed. In reversing, the Alabama State Supreme Court held that the literal language of the Agreement required dismissal of the state charges.

Question

Does the Interstate Agreement on Detainers require the dismissal of criminal charges when a prisoner serving a federal sentence is transferred for a day to be arraigned on state charges and then returned to the original place of imprisonment before trial?

Conclusion

Decision: 9 votes for Bozeman, 0 vote(s) against
Legal provision: 19 U.S.C. App.

Yes. In a unanimous opinion delivered by Justice Stephen G. Breyer, the Court held that the literal language of Article IV(e) of the Agreement bars any further criminal proceedings when a defendant is returned to the original place of imprisonment before trial. The Court rejected the argument that the one-day breach did not interrupt rehabilitation significantly for two reasons. First, "the language of the Agreement militates against an implicit exception, for it is absolute," wrote Justice Breyer. Second, continued Justice Breyer, "even were we to assume for argument's sake that the Agreement exempts violations that...are de minimis...we could not say that the violation at issue here qualifies as trivial."

City News & Novelty v. Waukesha

Tue, 28 Nov 2000 13:00:00 +0000

Case Basics

Docket No.

99-1680

Petitioner

City News & Novelty

Petitioner Type

Petitioner

Respondent

Waukesha

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

531 U.S. 278 (2001)

Argued

Tuesday, November 28, 2000

Decided

Wednesday, January 17, 2001

Advocates

Curt Meitz (Argued the cause for the respondent)

James A. Feldman (Department of Justice, on behalf of the United States, as amicus curiae, supporting the respondent)

Jeff S. Olson (Argued the cause for the petitioner)

Facts of the Case

The City of Waukesha, Wisconsin requires sellers of sexually explicit materials to obtain and annually renew adult business licenses. City News and Novelty, Inc. (City News), owned and operated an adult-oriented shop in Waukesha. City News had first obtained a license in 1989. In 1995, City News applied for a renewal of its license. Waukesha's Common Council denied the application. The Council found that City News had violated Waukesha ordinances by permitting minors to loiter on the premises, failing to maintain an unobstructed view of booths in the store, and allowing patrons to engage in sexual activity inside the booths. Waukesha's refusal to renew City News's license was upheld in administrative proceedings and on judicial review in the state courts. Among other questions raised in its petition for certiorari, City News asked the Court to "resolve...whether the guarantee of prompt judicial review that must accompany [an adult business] licensing scheme means a prompt judicial determination or simply the right to promptly file for judicial review."

Question

Does the guarantee of prompt judicial review that must accompany an adult business-licensing scheme mean a prompt judicial determination?

Conclusion

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

The Court did not answer the question. In a unanimous opinion deliver by Justice Ruth Bader Ginsburg, the Court dismissed the writ of certiorari because City News was not properly situated to raise the question on which the Court granted review. The city of Waukesha had argued the case was moot after City News decided to withdraw its renewal application and close its business upon the city's grant of a license to another business, with which the Court agreed. "We do not doubt that an ongoing adult enterprise facing loss of its license to do business may allege First Amendment injuries. Such an establishment's typical concern, however, is not the speed of court proceedings, but the availability of a stay of adverse action during the pendency of judicial review, however long that review takes," wrote Justice Ginsburg for the Court.

Gitlitz v. Commissioner

Mon, 02 Oct 2000 13:00:00 +0000

Case Basics

Docket No.

99-1295

Petitioner

Gitlitz

Petitioner Type

Petitioner

Respondent

Commissioner

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

531 U.S. 206 (2001)

Argued

Monday, October 2, 2000

Decided

Tuesday, January 9, 2001

Advocates

Darrell D. Hallett (Argued the cause for the petitioners)

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

Facts of the Case

In 1991, P. D. W. & A., Inc., an insolvent corporation taxed under Subchapter S, excluded its entire discharge of indebtedness amount from its gross income. David Gitlitz and other shareholders were assessed tax deficiencies because they used the untaxed discharge of indebtedness to increase their basis in S corporation stock and to deduct suspended losses. Ultimately, the Tax Court held that Gitlitz and others could not use an S corporation's untaxed discharge of indebtedness to increase their basis in corporate stock. In affirming, the Court of Appeals held that the discharge of indebtedness amount first had to be used to reduce certain tax attributes of the S corporation and that only the leftover amount could be used to increase their basis. In so holding, the court assumed that the excluded discharge of indebtedness is an item of income subject to passthrough to shareholders.

Question

Does the Internal Revenue Code permit taxpayers to increase bases in their S corporation stock by the amount of an S corporation's discharge of indebtedness excluded from gross income? If the Code permits such an increase, does the increase occur before taxpayers are required to reduce the S corporation's tax attributes?

Conclusion

Decision: 8 votes for Gitlitz, 1 vote(s) against
Legal provision: Internal Revenue Code

Yes and yes. In an 8-1 opinion delivered by Justice Clarence Thomas, the Court held that excluded discharged debt is an "item of income," which passes through to shareholders and increases their bases in an S corporation's stock and that pass-through is performed before the reduction of an S corporation's tax attributes. Justice Thomas wrote that the Code "simply does not say that discharge of indebtedness ceases to be an item of income when the S corporation is insolvent. Instead it provides only that discharge of indebtedness ceases to be included in gross income." "In order to determine the 'tax imposed,' an S corporation shareholder must adjust his basis in his corporate stock and pass through all items of income and loss. Consequently, the attribute reduction must be made after the basis adjustment and pass- through," continued Justice Thomas.

Palazzolo v. Rhode Island

Mon, 26 Feb 2001 13:00:00 +0000

Location

Rhode Island General Assembly

82 Smith St Providence RI 02903

Providence, RI 02903

United States

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

See map: Google Maps

Case Basics

Docket No.

99-2047

Petitioner

Palazzolo

Petitioner Type

Petitioner

Respondent

Rhode Island

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

533 U.S. 606 (2001)

Argued

Monday, February 26, 2001

Decided

Thursday, June 28, 2001

Advocates

James S. Burling (Argued the cause for the petitioner)

Malcolm L. Stewart (Department of Justice, as amicus curiae, supporting the respondents)

Sheldon Whitehouse (State of Rhode Island, argued the cause for the respondents)

Facts of the Case

Anthony Palazzolo owns a waterfront parcel of land in Rhode Island. Most of the property is salt marsh, subject to tidal flooding. The Rhode Island Resources Management Council's Coastal Resources Management Program regulations designate salt marshes as protected "coastal wetlands," on which development is greatly limited. After multiple development proposals of his were denied, Palazzolo filed an inverse condemnation action in Rhode Island Superior Court. Palazzolo asserted that the State's wetlands regulations had taken his property without compensation in violation of the Fifth and Fourteenth Amendments because the Council's action had deprived him of "all economically beneficial use" of his property. Ruling against Palazzolo, the court held that his takings claim was not ripe, that he had no right to challenge the regulations predating his acquisition of the property's title, and that he could not assert a takings claim based on the denial of all economic use of his property in light of undisputed evidence that he had $200,000 in development value remaining on an upland parcel of the property.

Question

May a property owner who acquired title to the property after is was subject to wetlands regulations still bring a takings claim under the Fifth Amendment?

Conclusion

Decision: 5 votes for Palazzolo, 4 vote(s) against
Legal provision: Takings Clause

Yes. In a 5-4 opinion delivered by Justice Anthony M. Kennedy, the Court held that "the State Supreme Court erred in finding [Palazzolo's] claims were unripe and in ruling that acquisition of title after the effective date of the regulations barred the takings claims. The court did not err in finding that [Palazzolo] failed to establish a deprivation of all economic value, for it is undisputed that the parcel retains significant worth for construction of a residence." Discussing the post-regulation acquisition of title, Justice Kennedy wrote, "[w]ere we to accept the State's rule, the postenactment transfer of title would absolve the State of its obligation to defend any action restricting land use, no matter how extreme or unreasonable. A State would be allowed, in effect, to put an expiration date on the Takings Clause. This ought not to be the rule. Future generations, too, have a right to challenge unreasonable limitations on the use and value of land."

Fiore v. White

Sat, 27 Apr 2013 09:50:48 +0000

Case Basics

Docket No.

98-942

Petitioner

William Fiore

Petitioner Type

Petitioner

Respondent

White, Warden, et al.

Respondent Type

Respondent

Decided By

Rehnquist Court (1994-2005)

Opinion

531 U.S. 225 (2001)

Decided

Tuesday, January 9, 2001

Facts of the Case

William Fiore, an operater of a hazardous waste facility, was convicted of operating without a permit. Fiore had a valid permit, but had deviated from its terms by making alterations to the facility. Later the Pennsylvania Supreme Court ruled that the statute in question applied only to operators who actually lacked permits. Fiore appealed, seeking to have his convicted overturned. The U.S. Court of Appeals for the Third Circuit rejected the appeal on the ground that it would require a retroactive application of a new rule of law. (See Fiore v. White (1999)) The U.S. Supreme Court asked the Pennsylvania Supreme Court whether its decision had been a new rule, and the state court replied that the decision "did not announce a new rule of law," but "merely clarified the plain language of the statute."

Question

Does the Due Process Clause of the Fourteenth Amendment permit a state to convict a facility operater of operating without a permit, when the operater actually had a permit but deviated from its terms?

Conclusion

No. In a unanimous per curiam opinion, the Court held that Fiore's conviction was unconstitutional. Since the Pennsylvania Supreme Court's decision was not a new rule, it governed Fiore's case even though the case was final before the decision was handed down. The Court found that since Fiore had a permit, his offense was not covered by the statute he was convicted under. The Court concluded that "Fiore's conviction fails to satisfy the Federal Constitution's demands."

Buckman Co. v. Plaintiffs' Legal Committee

Mon, 04 Dec 2000 13:00:00 +0000

Case Basics

Docket No.

98-1768

Petitioner

Buckman Co.

Petitioner Type

Petitioner

Respondent

Plaintiffs' Legal Committee

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

531 U.S. 341 (2001)

Argued

Monday, December 4, 2000

Decided

Wednesday, February 21, 2001

Advocates

Michael D. Fishbein (Argued the cause for the respondent)

Kenneth S. Geller (Argued the cause for the petitioner)

Irving L. Gornstein (Department of Justice, on behalf of the United States, as amicus curiae, supporting the petitioner)

Facts of the Case

The Federal Food, Drug, and Cosmetic Act (FDCA) and the Medical Device Amendments of 1976 (MDA) regulate medical devices. Under the MDA, Class III devices "present a potential unreasonable risk of illness or injury" and thus require the Food and Drug Administration's (FDA) strictest regulation. In 1985, after a previously failed attempt, the AcroMed Corporation sought approval for its orthopedic bone screw device, a Class III device, for use in spinal surgery with the assistance of Buckman Company, a regulatory consultant to medical device manufacturers. The FDA also denied the second application. On the third attempt, instead of trying to show the bone screw device was "substantially equivalent" to similar devices already on the market and thus as safe and effective, AcroMed and Buckman split the device into its component parts, renamed them, and altered the intended use of the parts. Thus, the FDA approved the component devices for long bone surgery. Subsequently, the Judicial Panel on Multidistrict Litigation has directed over 2,300 civil actions related to these medical devices to the Federal District Court. Many actions claim, under state tort law, that AcroMed and Buckman made fraudulent representations to the FDA as to the intended use of the bone screws and that, as a result, the devices were improperly given market clearance, which injured the plaintiffs. The District Court dismissed the fraud claims as pre-empted by the MDA. The Court of Appeals reversed.

Question

Does the Federal Food, Drug, and Cosmetic Act, as amended by the Medical Device Amendments of 1976, pre-empt civil actions related to the alleged fraudulent approval of orthopedic bone screw devices?

Conclusion

Decision: 9 votes for Buckman Co., 0 vote(s) against
Legal provision: Federal Food, Drug, and Cosmetic, and related statutes

Yes. In an opinion delivered by Chief Justice William H. Rehnquist, the Court held that the plaintiffs' state-law fraud-on-the-FDA claims conflicted with, and were therefore pre-empted by, the FDCA, as amended by the MDA. "The conflict," wrote Chief Justice Rehnquist for the Court, "stems from the fact that the federal statutory scheme amply empowers the FDA to punish and deter fraud against the Agency, and that this authority is used by the Agency to achieve a somewhat delicate balance of statutory objectives. The balance sought by the Agency can be skewed by allowing fraud-on-the-FDA claims under state tort law." Chief Justice Rehnquist concluded that the "FDA...has at its disposal a variety of enforcement options that allow it to make a measured response to suspected fraud upon the Agency." Justices John Paul Stevens and Clarence Thomas concurred.

Shafer v. S. Carolina

Tue, 09 Jan 2001 13:00:00 +0000

Case Basics

Docket No.

00-5250

Petitioner

Shafer

Petitioner Type

Petitioner

Respondent

S. Carolina

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

532 U.S. 36 (2001)

Argued

Tuesday, January 9, 2001

Decided

Tuesday, March 20, 2001

Advocates

Donald John Zelenka (Argued the case for the respondent)

David I. Bruck (Argued the cause for the petitioner)

Facts of the Case

Wesley Aaron Shafer, Jr., was found guilty of murder, among other things. During the sentencing phase, Shafer's counsel argued that Simmons v. South Carolina required the trial judge to instruct the jury that under South Carolina law a life sentence carries no possibility of parole. The U.S. Supreme Court held in Simmons that where a capital defendant's future dangerousness is at issue, and the only sentencing alternative to death available to the jury is life imprisonment without possibility of parole, due process requires that the jury be informed of the defendant's parole ineligibility. The prosecution responded that because the state did not plan to argue to the jury that Shafer would be a danger in the future that no Simmons instruction was required. During deliberations, the jury asked under what conditions someone convicted of murder could become available for parole. The trial judge stated that parole eligibility or ineligibility was not a matter for the jury's consideration. Ultimately, the jury recommended the death penalty and the judge imposed the sentence. In affirming, the South Carolina Supreme Court held that Simmons generally did not apply to the State's sentencing scheme because an alternative to death other than life without the possibility of parole exists.

Question

Did the South Carolina Supreme Court properly hold Simmons v. South Carolina inapplicable to the state's current sentencing regime?

Conclusion

Decision: 7 votes for Shafer, 2 vote(s) against
Legal provision: Due Process

No. In a 7-2 opinion delivered by Justice Ruth Bader Ginsburg, the Court held that "whenever future dangerousness is at issue in a capital sentencing proceeding under South Carolina's new scheme, due process requires that the jury be informed that a life sentence carries no possibility of parole." Justice Ginsburg wrote that "[i]t is only when the jury endeavors the moral judgment whether to impose the death penalty that parole eligibility may become critical. Correspondingly, it is only at that stage that Simmons comes into play, a stage at which South Carolina law provides no third choice, no 30-year mandatory minimum, just death or life without parole." Justices Antonin Scalia and Clarence Thomas filed dissenting opinions.

Hunt v. Cromartie

Mon, 27 Nov 2000 13:00:00 +0000

Case Basics

Docket No.

99-1864

Appellee

Cromartie

Petitioner Type

Appellee

Appellant

Hunt

Respondent Type

Appellant

Consolidation

No. 99-1865

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

532 U.S. 234 (2001)

Argued

Monday, November 27, 2000

Decided

Wednesday, April 18, 2001

Advocates

Robinson O. Everett (Argued the cause for the appellees)

Adam Stein (Argued the cause for the appellants in No. 99-1865)

Walter E. Dellinger, III (Argued the cause for the appellants in No. 99-1864)

Facts of the Case

In Shaw v. Hunt, the U.S Supreme Court found that North Carolina's legislature violated the Constitution by using race as the predominant factor in drawing its Twelfth Congressional District's 1992 boundaries. In 1997, after the State redrew those boundaries, the District Court found that the new boundaries had also been created with dominating racial considerations. In reversing, the Court found, in Hunt v. Cromartie, that the evidence was insufficient to show an unconstitutional race-based objective. On remand, the District Court again found that North Carolina's legislature had used race driven criteria in drawing the 1997 boundaries based on the district's shape, its splitting of towns and counties, and its heavily African-American voting population. The court newly found that the legislature had drawn the boundaries to collect precincts with a high racial, rather than political, identification. (Argued and decided with 99-1865, Smallwood v. Cromartie.)

Question

Did a district court err in finding that North Carolina violated the Equal Protection Clause in its 1997 redrawing of its Twelfth Congressional District's 1992 boundaries?

Conclusion

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

Yes. In a 5-4 opinion delivered by Justice Stephen G. Breyer, the Court held that the District Court's conclusion that the state violated the Equal Protection Clause in drawing the 1997 boundaries is based on clearly erroneous findings. Justice Breyer wore for the Court that "the primary evidence upon which the District Court relied for its 'race, not politics,' conclusion is evidence of voting registration, not voting behavior; and that is precisely the kind of evidence that we said was inadequate the last time this case was before us." Justice Clarence Thomas's dissented, joined by Chief Justice William H. Rehnquist and Justices Antonin Scalia and Anthony M. Kennedy.

Pollard v. DuPont

Mon, 23 Apr 2001 13:00:00 +0000

Case Basics

Docket No.

00-763

Petitioner

Pollard

Petitioner Type

Petitioner

Respondent

DuPont

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

532 U.S. 843 (2001)

Argued

Monday, April 23, 2001

Decided

Monday, June 4, 2001

Advocates

Kathleen L. Caldwell (Argued the cause for the petitioner)

Matthew D. Roberts (Department of Justice, for the United States, as amicus curiae, supporting petitioner)

Raymond M. Ripple (Argued the cause for the respondents)

Facts of the Case

Sharon Pollard sued her former employer, E. I. du Pont de Nemours and Company (DuPont), alleging that she had been subjected to a hostile work environment based on her sex, in violation of Title VII of the Civil Rights Act of 1964. Ultimately, the Federal District Court found that Pollard was subjected to co- worker sexual harassment of which her supervisors were aware. The court awarded her $300,000 in compensatory damages, the maximum permitted under the Civil Rights Act of 1991 for such damages. The court then noted that the award was insufficient to compensate Pollard. On appeal, Pollard argued that "front pay," the money awarded for lost compensation during the period between judgment and reinstatement or in lieu of reinstatement, was not an element of compensatory damages, but a replacement for the remedy of reinstatement in situations in which reinstatement would be inappropriate. Rejecting Pollard, the Court of Appeals affirmed.

Question

Does "front pay" constitute an element of compensatory damages under the Civil Rights Act of 1991, such that it is subject to the Act's statutory cap on such damages?

Conclusion

Decision: 8 votes for Pollard, 0 vote(s) against
Legal provision: Civil Rights Act of 1991

No. In a unanimous opinion delivered by Justice Clarence Thomas, the Court held that front pay is not an element of compensatory damages under the Civil Rights Act of 1991 and thus is not subject to the damages cap imposed by the Act. "Because front pay is a remedy authorized under [the Civil Rights Act of 1964], Congress did not limit the availability of such awards in [the Civil Rights Act of 1991]. Instead, Congress sought to expand the available remedies by permitting the recovery of compensatory and punitive damages in addition to previously available remedies, such as front pay," wrote Justice Thomas for the Court. All members of the Court joined Justice Thomas' opinion, except Justice Sandra Day O'Connor, who took no part in the consideration or decision of the case.

Legal Services Corp. v. Velazquez

Wed, 04 Oct 2000 13:00:00 +0000

Case Basics

Docket No.

99-603

Petitioner

Legal Services Corp.

Petitioner Type

Petitioner

Respondent

Velazquez

Respondent Type

Respondent

Consolidation

No. 99-960

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

531 U.S. 533 (2001)

Argued

Wednesday, October 4, 2000

Decided

Wednesday, February 28, 2001

Advocates

Edwin S. Kneedler (Department of Justice, argued the cause for the United States)

Burt Neuborne (Argued the cause for the respondents)

Alan H. Levine (Argued the cause for the petitioner)

Facts of the Case

The Legal Services Corporation Act authorizes the Legal Services Corporation (LSC) to distribute funds, appropriated by Congress, to local grantee organizations, which provide free legal assistance to indigent clients in welfare benefits claims. The Omnibus Consolidated Rescissions and Appropriations Act of 1996 prohibited the LSC from funding any organization that represented clients in an effort to amend or challenge existing welfare law, among other things. The prohibition was such that grantees could not continue representation in a welfare matter even where a constitutional or statutory validity challenge became apparent after representation was well under way. LSC grantee lawyers and others filed suit to have the restriction declared unconstitutional. The District Court denied a preliminary injunction. However, the Court of Appeals invalidated the restriction, concluding that it was impermissible viewpoint discrimination that violated the First Amendment.

Question

Does the funding restriction on the Legal Services Corporation, which prevents attorneys from representing clients in an attempt to amend or challenge existing welfare law, violate the First Amendment?

Conclusion

Decision: 5 votes for Velazquez, 4 vote(s) against
Legal provision: Amendment 1: Speech, Press, and Assembly

Yes. In a 5-4 opinion delivered by Justice Anthony M. Kennedy, the Court held that the funding provision that limited arguments legal services attorneys were allowed to make on behalf of indigent welfare claimants violated the First Amendment by regulating private speech and insulating federal law from legitimate judicial challenge. Justice Kennedy wrote for that Court that, "the LSC program was designed to facilitate private speech, not to promote a governmental message." Justice Antonin Scalia wrote a dissent, which was joined by Chief Justice William H. Rehnquist and Justices Sandra Day O'Connor and Clarence Thomas, arguing that the Appropriations Act "does not directly regulate speech, and it neither establishes a public forum nor discriminates on the basis of viewpoint."

United States v. Mead Corp.

Wed, 08 Nov 2000 13:00:00 +0000

Case Basics

Docket No.

99-1434

Petitioner

United States

Petitioner Type

Petitioner

Respondent

Mead Corp.

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

533 U.S. 218 (2001)

Argued

Wednesday, November 8, 2000

Decided

Monday, June 18, 2001

Advocates

J. Peter Coll, Jr. (Argued the cause for the respondent)

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

Facts of the Case

Under the Harmonized Tariff Schedule of the United States, the United States Customs Service is authorized to classify and fix the rate of duty on imports under rules and regulations issued by the Secretary of the Treasury. Under the Secretary's regulations, any port-of-entry Customs office and the Customs Headquarters Office may issue "ruling letters" setting tariff classifications for particular imports. The Mead Corporation's imported "day planners," were classified as duty-free until the Customs Headquarters issued a ruling letter classifying them as bound diaries subject to tariff. Subsequently, Mead filed suit in the Court of International Trade. The court granted the Government summary judgment. In reversing, the Court of Appeals found that ruling letters should not be treated like Customs regulations, which receive the highest level of deference, because they are not preceded by notice and comment as under the Administrative Procedure Act, do not carry the force of law, and are not intended to clarify importers's rights and obligations beyond the specific case. The court gave no deference at all to the ruling letter at issue.

Question

Does a tariff classification ruling by the United States Customs Service deserve judicial deference?

Conclusion

Decision: 8 votes for Mead Corp., 1 vote(s) against
Legal provision: 19 U.S.C. 1202

No. In an 8-1 opinion delivered by Justice David H. Souter, the Court held that the "administrative implementation of a particular statutory provision qualifies for [the greatest level of deference accorded under Chevron U.S.A. Inc. v. Natural Resources Defense Council] when it appears that Congress delegated authority to the agency generally to make rules carrying the force of law, and that the agency interpretation claiming deference was promulgated in the exercise of that authority." Justice Souter wrote that "a tariff classification has no claim to judicial deference under Chevron, there being no indication that Congress intended such a ruling to carry the force of law, but we hold that under Skidmore v. Swift & Co., the ruling is eligible to claim respect according to its persuasiveness."

Arkansas v. Sullivan

Sat, 27 Apr 2013 09:50:49 +0000

Case Basics

Docket No.

00-262

Petitioner

Arkansas

Petitioner Type

Petitioner

Respondent

Sullivan

Respondent Type

Respondent

Decided By

Rehnquist Court (1994-2005)

Opinion

532 U.S. 769 (2001)

Decided

Tuesday, May 29, 2001

Facts of the Case

In 1998, Officer Joe Taylor of the Conway, Arkansas, Police Department stopped Kenneth Andrew Sullivan for traffic violations. When Officer Taylor saw Sullivan's license, he realized that he was aware of narcotics intelligence regarding him. Sullivan was then arrested. Afterwards Officer Taylor conducted an inventory search of Sullivan's vehicle and discovered methamphetamine as well as items of drug paraphernalia. Ultimately, Sullivan was charged with various state-law drug offenses, unlawful possession of a weapon, and speeding. Sullivan moved to suppress the evidence seized from his vehicle on the basis that his arrest was merely a "pretext and sham to search" him and, therefore, violated the Fourth and Fourteenth Amendments. The trial court granted the motion and the Arkansas Supreme Court affirmed. In petitioning for rehearing, the State argued that the court had erred by taking into account Office Taylor's subjective motivation using Whren v. United States, which makes "the ulterior motives of police officers...irrelevant so long as there is probable cause for the traffic stop." The court rejected the argument and denied the petition.

Question

Did the Arkansas Supreme Court err by taking into account an officer's subjective motivation in its probable-cause Fourth Amendment analysis contrary to the U.S. Supreme Court's controlling precedent, Whren v. United States?

Conclusion

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

Yes. In a per curiam opinion, the Court held that the Arkansas Supreme Court's decision was contrary to the U.S. Supreme Court's controlling precedent, which held that police officers' subjective intentions played no role in ordinary, probable-cause Fourth Amendment analysis, and reversed its decision. In addressing the Arkansas court's alternative holding, that it could interpret the U.S. Constitution to provide greater protection than the U.S. Supreme Court, the Court reiterated that while a State may impose greater restrictions, it "may not impose such greater restrictions as a matter of federal constitutional law when this Court specifically refrains from imposing them." Justice Ruth Bader Ginsburg wrote a concurring opinion, which was joined by Justices John Paul Stevens, Sandra Day O'Connor, and Stephen G. Breyer.

Florida v. Thomas

Wed, 25 Apr 2001 13:00:00 +0000

Case Basics

Docket No.

00-391

Petitioner

Florida

Petitioner Type

Petitioner

Respondent

Thomas

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

532 U.S. 774 (2001)

Argued

Wednesday, April 25, 2001

Decided

Monday, June 4, 2001

Advocates

Robert J. Krauss (Tampa, Florida, argued the cause for the petitioner)

Cynthia J. Dodge (Bartow, Florida, argued the cause for the respondent)

Gregory G. Garre (Department of Justice, on behalf of the United States, as amicus curiae, supporting the petitioner)

Facts of the Case

While officers were investigating marijuana sales at Florida home, Robert Thomas drove up to the house. An officer asked Thomas for his name and driver license. Thomas was arrested when a search on his license revealed an outstanding warrant. After taking Thomas inside the house, the officer searched Thomas' car and found methamphetamine. Subsequently, the trial court granted Thomas' motion to suppress. In reversing, the appellate found the search valid under New York v. Belton. In New York v. Belton, the U.S. Supreme Court established a "bright-line" rule permitting an officer who has made a lawful custodial arrest of a car's occupant to search the car's passenger compartment as a contemporaneous incident of the arrest. In reversing, the Florida Supreme Court held Belton did not apply because it is limited to situations where the officer initiates contact with a vehicle's occupant while that person remains in the vehicle.

Question

Is New York v. Belton's bright-line rule limited to situations where the officer initiates contact with a vehicle's occupant while that person remains in the vehicle?

Conclusion

Decision: 9 votes for Thomas, 0 vote(s) against
Legal provision: 28 U.S.C. 1257

In a unanimous opinion delivered by Chief Justice William H. Rehnquist, the Court dismissed the writ of certiorari for want of jurisdiction. Chief Justice Rehnquist wrote that the Florida Supreme Court's decision did not fit any of the categories where the Court "treated state-court judgments as final for jurisdictional purposes although there were further proceedings to take place in the state court." Thus, the Court concluded that the Florida Supreme Court's decision was not final.

Penry v. Johnson

Tue, 27 Mar 2001 13:00:00 +0000

Case Basics

Docket No.

00-6677

Petitioner

Penry

Petitioner Type

Petitioner

Respondent

Johnson

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

532 U.S. 782 (2001)

Argued

Tuesday, March 27, 2001

Decided

Monday, June 4, 2001

Advocates

Andy Taylor (Austin, Texas, argued the cause for the respondent)

Robert S. Smith (Argued the cause for the petitioner)

Gene C. Schaerr (As amicus curiae, supporting the respondent)

Facts of the Case

In 1989, the U.S. Supreme Court held that Johnny Paul Penry had been sentenced to death in violation of the Eighth Amendment after finding that Texas' special issues questions did not permit the jury to consider mitigating evidence involving his mental retardation. On retrial in 1990, Penry was again found guilty of capital murder. The defense again put on extensive evidence regarding Penry's mental impairments. Ultimately, a psychiatric evaluation, which stated that Penry would be dangerous to others if released, prepared at the request of Penry's former counsel, was cited. Upon submission to the jury, the trial judge instructed the jury to determine Penry's sentence by answering the same special issues in the original Penry case. Additionally, the trial judge gave a supplemental instruction on mitigating evidence. The court sentenced Penry to death in accordance with the jury's answers to the special issues. In affirming, the Texas Court of Criminal Appeals rejected Penry's claims that the admission of language from the psychiatric evaluation violated his Fifth Amendment privilege against self-incrimination, and that the jury instructions were constitutionally inadequate because they did not permit the jury to consider and give effect to his particular mitigating evidence. Penry's petitions for state and federal habeas corpus relief failed.

Question

Was a Texas trial court's supplemental instruction on mitigating evidence of mental retardation under the state's "special circumstances" for sentencing in capital murder cases to a jury constitutionally adequate? Does the admission into evidence of statements from a psychiatric report based on an uncounseled interview with the defendant violate the Fifth Amendment's privilege against self-incrimination?

Conclusion

Decision: 6 votes for Penry, 3 vote(s) against
Legal provision: Self-Incrimination

No and no. In a 6-3 opinion delivered by Justice Sandra Day O'Connor, the Court held that the supplemental instruction was constitutionally inadequate. "Any realistic assessment of the manner in which the supplemental instruction operated would therefore lead to the same conclusion we reached in Penry I," wrote Justice O'Connor "'A reasonable juror could well have believed that there was no vehicle for expressing the view that Penry did not deserve to be sentenced to death based upon his mitigating evidence.'" Unanimously, the Court held that "considerable doubt" that the psychiatric report "even if erroneous, had a 'substantial and injurious effect'" on the verdict, meant not overturning the Texas Court of Criminal Appeals' rejection of Penry's Fifth Amendment claim.

Lackawanna County District Attorney v. Coss

Tue, 20 Feb 2001 13:00:00 +0000

Case Basics

Docket No.

99-1884

Petitioner

Lackawanna County District Attorney

Petitioner Type

Petitioner

Respondent

Coss

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

532 U.S. 394 (2001)

Argued

Tuesday, February 20, 2001

Decided

Wednesday, April 25, 2001

Advocates

Robert M. Russel (Denver, Colorado, on behalf of Colorado, et al., as amici curiae, supporting the petitioners)

William P. O'Malley (Scranton, Pennsylvania, argued the cause for the petitioners)

James V. Wade (Harrisburg, Pennsylvania, argued the cause for the respondent)

Facts of the Case

In 1986, after being convicted for simple assault, institutional vandalism, and criminal mischief, Edward R. Coss, Jr., filed a petition for relief, but the Pennsylvania courts never ruled on the petition. In 1990, after he had served the full sentences for his 1986 convictions, Coss was convicted of aggravated assault. Ultimately, the sentencing court did not consider Coss' 1986 convictions in determining his eligible sentencing range. In choosing a sentence within the applicable range, the court considered several factors including Coss' extensive criminal record, making reference to his 1986 convictions. Coss then filed a petition for a writ of habeas corpus, claiming that his 1986 convictions were constitutionally invalid. The Federal District Court denied the petition reasoning that Coss had not been prejudiced by his 1986 counsel's ineffectiveness. The Court of Appeals found that Coss would not have been convicted in 1986 but for the ineffective assistance. The court remanded the case ordering a retrial or resentencing without consideration of the 1986 conviction.

Question

May a state prisoner use a federal habeas petition to challenge a current sentence on the ground that it was enhanced based on an unconstitutional prior conviction for which the sentence has fully expired?

Conclusion

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

No. In a 5-4 opinion delivered by Justice Sandra Day O'Connor, the Court held that "once a state conviction is no longer open to direct or collateral attack in its own right because the defendant failed to pursue those remedies while they were available (or because the defendant did so unsuccessfully), the conviction may be regarded as conclusively valid. If that conviction is later used to enhance a criminal sentence, the defendant generally may not challenge the enhanced sentence through a [federal habeas petition] on the ground that the prior conviction was unconstitutionally obtained." Justice David H. Souter filed a dissenting opinion, which was joined by Justices John Paul Stevens and Ruth Bader Ginsburg. Justice Stephen G. Breyer also filed a dissenting opinion.

Duncan v. Walker

Mon, 26 Mar 2001 13:00:00 +0000

Case Basics

Docket No.

00-121

Petitioner

Duncan

Petitioner Type

Petitioner

Respondent

Walker

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

533 U.S. 167 (2001)

Argued

Monday, March 26, 2001

Decided

Monday, June 18, 2001

Advocates

Preeta D. Bansal (Argued the cause for the petitioner)

Deborah W. Loewenberg (Argued the cause for the respondent)

Facts of the Case

28 USC section 2244(d)(2) provides that the "time during which a properly filed application for State post-conviction or other collateral review with respect to the pertinent judgment or claim is pending shall not be counted toward any period of limitation under this subsection." In 1996, Sherman Walker filed a federal habeas petition under section 2254. The District Court dismissed the petition because it concluded that Walker had not exhausted available state remedies. In 1997, without returning to state court, Walker filed another federal habeas petition. Th District Court dismissed the petition because it had not been filed within a reasonable time from the Antiterrorism and Effective Death Penalty Act of 1996's effective date. In reversing, the Court of Appeals found that Walker's first federal habeas petition was an application for "other collateral review" that tolled the limitation period under section 2244(d)(2) and made his current petition timely.

Question

Is a federal habeas corpus petition is an "application for State post- conviction or other collateral review" within the meaning of 28 USC section 2244(d)(2), such that the one-year statute-of-limitations period under the Antiterrorism and Effective Death Penalty Act is tolled?

Conclusion

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

No. In a 7-2 opinion delivered by Justice Sandra Day O'Connor, the Court held that an federal habeas corpus petition is not an "application for State post- conviction or other collateral review" within the meaning of 28 USC section 2244(d)(2). "Section 2244(d)(2) therefore did not toll the limitation period during the pendency of [Walker's] first federal habeas petition," wrote Justice O'Connor. "[I]f the statute were construed so as to give applications for federal review the same tolling effect as applications for state collateral review, then [section] 2244(d)(2) would furnish little incentive for individuals to seek relief from the state courts before filing federal habeas petitions," concluded Justice O'Connor.

Cleveland v. United States

Tue, 10 Oct 2000 13:00:00 +0000

Case Basics

Docket No.

99-804

Petitioner

Cleveland

Petitioner Type

Petitioner

Respondent

United States

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

531 U.S. 12 (2000)

Argued

Tuesday, October 10, 2000

Decided

Tuesday, November 7, 2000

Advocates

Paul Mogin (Argued the cause for the petitioner)

Michael R. Dreeben (Department of Justice, argued the cause for the respondent)

Facts of the Case

Louisiana law authorizes the State to award nontransferable, annually renewable licenses to operate video poker machines. In 1992, Fred Goodson and his family formed Truck Stop Gaming, Ltd. (TSG), a video poker business. Carl Cleveland, a lawyer, assisted Goodson in preparing TSG's video poker license applications, each of which identified Goodson's children as the sole beneficial owners of the partnership. From 1992 through 1995, TSG successfully renewed its license. In 1996, Cleveland and Goodson were charged with money laundering under federal law, along with racketeering and conspiracy in connection with a scheme to bribe state legislators to vote in a manner favorable to the video poker industry. Acts supporting these charges came from federal mail fraud charges, defined as "any scheme or artifice to defraud, or for obtaining...property by means of...fraudulent...representations." The indictment alleged that Cleveland and Goodson fraudulently concealed that they were the true owners of TSG in the license applications they had mailed to the State because they had tax and financial problems that could have undermined their ability to receive a video poker license. Before trial, Cleveland moved to dismiss the mail fraud counts on the ground that the alleged fraud did not deprive the State of "property." The District Court denied the motion, concluding that licenses constitute property even before they are issued. A jury found Cleveland guilty. The Court of Appeals affirmed.

Question

Do state video poker licenses qualify as property for purposes of the federal mail fraud statute?

Conclusion

Decision: 9 votes for Cleveland, 0 vote(s) against
Legal provision: 18 U.S.C. 1341

No. In a unanimous opinion delivered by Justice Ruth Bader Ginsburg, the Court held that State and municipal licenses in general, and Louisiana's video poker licenses in particular, do not rank as "property," for purposes of federal law, in the hands of the official licensor. Thus, Cleveland's conviction for making false statements to obtain state video poker license was vacated. "Equating issuance of licenses or permits with deprivation of property would subject to federal mail fraud prosecution a wide range of conduct traditionally regulated by state and local authorities," wrote Justice Ginsburg for the Court.

Saucier v. Katz

Tue, 20 Mar 2001 13:00:00 +0000

Case Basics

Docket No.

99-1977

Petitioner

Saucier

Petitioner Type

Petitioner

Respondent

Katz

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

533 U.S. 194 (2001)

Argued

Tuesday, March 20, 2001

Decided

Monday, June 18, 2001

Advocates

Paul D. Clement (Department of Justice, argued the cause for the petitioner)

John K. Boyd (Argued the cause for the respondents)

Facts of the Case

Donald Saucier, a military police officer, arrested Elliot Katz, who was protesting during a speech by Vice President Gore at the Presidio Army Base in San Francisco. Katz filed suit against Saucier alleging that Saucier had violated his Fourth Amendment rights by using excessive force in arresting him. Rejecting Saucier's motions for summary judgment on qualified immunity grounds, the District Court held that the immunity inquiry is the same as the inquiry made on the merits. In affirming, the Court of Appeals made a two-part qualified immunity inquiry. After finding that the law governing Saucier's conduct was clearly established when the incident occurred, the court moved to determined whether a reasonable officer could have believed, in light of the clearly established law, that his conduct was lawful. The court then reasoned that this step and the merits of a Fourth Amendment excessive force claim were identical because both concern the objective reasonableness of the officer's conduct in light of the circumstances the officer faced at the scene. Subsequently, the court found that summary judgment based on qualified immunity was inappropriate.

Question

Is the reasonableness inquiry into claims of qualified immunity by a police officer accused of using excessive force in an arrest the same as the reasonableness inquiry on the merits of the excessive-force claim?

Conclusion

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

No. In an opinion delivered by Justice Anthony M. Kennedy, the Court held that "the ruling on qualified immunity requires an analysis not susceptible of fusion with the question whether unreasonable force was used in making the arrest." "The approach the Court of Appeals adopted -- to deny summary judgment any time a material issue of fact remains on the excessive force claim -- could undermine the goal of qualified immunity to 'avoid excessive disruption of government and permit the resolution of many insubstantial claims on summary judgment,'" wrote Justice Kennedy. The majority then concluded that the military policeman was entitled to qualified immunity.

Clark County School District v. Breeden

Sat, 27 Apr 2013 09:50:50 +0000

Case Basics

Docket No.

00-866

Petitioner

Clark County School District

Petitioner Type

Petitioner

Respondent

Breeden

Respondent Type

Respondent

Decided By

Rehnquist Court (1994-2005)

Opinion

532 U.S. 268 (2001)

Decided

Monday, April 23, 2001

Facts of the Case

Under Title VII of the Civil Rights Act of 1964, it is unlawful "for an employer to discriminate against any of his employees...because [the employee] has opposed any practice made an unlawful employment practice by [Title VII], or because [the employee] has made a charge, testified, assisted, or participated in any manner in an investigation, proceeding, or hearing under [Title VII]." Shirley Breeden alleged that, during a review of job applicant files in 1994, a male co-worker's vocal reaction to an applicant's psychological evaluation report constituted sexual harassment. Moreover, Breeden alleged that she suffered from adverse employment actions for complaining about the about the alleged harassment. Breeden claimed she was transferred about a month later to a job with less supervisory authority. In 1997, Breeden filed a retaliation claim against Clark County School District. The District Court granted summary judgment for the school district. A panel of the Court of Appeals reversed.

Question

Does a single sexually explicit remark and a change in employment status less than a month after an employee files a complaint about the remark meet the threshold for an adverse employment action under Title VII of the Civil Rights of 1964?

Conclusion

Decision: 9 votes for Clark County School District, 0 vote(s) against
Legal provision: Civil Rights Act of 1964, Title VII

No. In a per curiam opinion, the Court held that a cause for retaliation was not shown. "No reasonable person could have believed that the single incident recounted above violated Title VII's standard," declared the Court. Continuing, the opinion noted that the occurrence was "at worst an 'isolated incident' that cannot remotely be considered 'extremely serious,' as our cases require."

Booth v. Churner

Tue, 20 Mar 2001 13:00:00 +0000

Case Basics

Docket No.

99-1964

Petitioner

Booth

Petitioner Type

Petitioner

Respondent

Churner

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

532 U.S. 731 (2001)

Argued

Tuesday, March 20, 2001

Decided

Tuesday, May 29, 2001

Advocates

Gerald J. Pappert (Harrisburg, Pennsylvania, argued the cause for the respondents)

Irving L. Gornstein (On behalf of the United States, as amicus curiae, supporting the respondents)

Nancy Winkelman (Argued the cause for the petitioner)

Facts of the Case

The Prison Litigation Reform Act of 1995 requires a prisoner to exhaust "such administrative remedies as are available" before suing over prison conditions. Timothy Booth, an inmate at the State Correctional Institution at Smithfield, Pennsylvania, initiated a suit in District Court, claiming that corrections officers violated his Eighth Amendment right to be free from cruel and unusual punishment in various ways. Booth sought both injunctive relief and monetary damages. At the time of Booth's suit, Pennsylvania provided an administrative grievance and appeals system, which addressed Booth's complaints but had no provision for recovery of money damages. After the prison authority denied his administrative grievance, Booth did not seek administrative review. Subsequently, the District Court dismissed the complaint for failure to exhaust administrative remedies. In affirming, the Court of Appeals rejected Booth's argument that the exhaustion requirement was inapplicable because the administrative process could not award him the monetary relief he sought (At this point, Booth was only seeking money).

Question

Must prisoners who seek only monetary damages in suits over prison conditions still exhaust all administrative remedies before going to court, even if monetary damages are not available under the particular administrative process?

Conclusion

Decision: 9 votes for Churner, 0 vote(s) against
Legal provision: 42 U.S.C. 1997

Yes. In a unanimous opinion delivered by Justice David H. Souter, the Court held that even though the prison grievance procedure did not provide for requested monetary relief, Booth was nonetheless required to exhaust administrative remedies before filing suit with respect to prison conditions. Justice Souter wrote for the Court, "we think that Congress has mandated exhaustion clearly enough, regardless of the relief offered through administrative procedures."

Lopez v. Davis

Mon, 30 Oct 2000 13:00:00 +0000

Case Basics

Docket No.

99-7504

Petitioner

Lopez

Petitioner Type

Petitioner

Respondent

Davis

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

531 U.S. 230 (2001)

Argued

Monday, October 30, 2000

Decided

Wednesday, January 10, 2001

Advocates

Beth S. Brinkmann (Department of Justice, argued the cause for the respondents)

Mark V. Meierhenry (Argued the cause for the petitioner)

Facts of the Case

Congress has provided the Bureau of Prisons (BOP) with the statutory authority to reduce the prison term of an inmate convicted of a nonviolent felony by up to one year, if the prisoner successfully completes a substance abuse program. The BOP's implementing regulation categorically denies early release to prisoners whose offense is a felony attended by "the carrying, possession, or use of a firearm." In 1997, Christopher A. Lopez was convicted of possession with intent to distribute methamphetamine. Additionally, the court found that Lopez possessed a firearm in connection with his offense. While incarcerated, Lopez requested substance abuse treatment. The BOP found Lopez qualified for its residential drug abuse program, but was found him categorically ineligible for early release. The District Court, in ordering the BOP to reconsider Lopez for early release, held that the BOP may not, based on weapons possession, categorically count out inmates, whose underlying conviction was for a nonviolent crime. The Court of Appeals reversed.

Question

Does the Bureau of Prisons have the authority to categorically deny consideration for eligibility for early release to inmates convicted of non- violent offenses after they have completed substance abuse programs?

Conclusion

Decision: 6 votes for Davis, 3 vote(s) against
Legal provision: 18 U.S.C. 3621

Yes. In a 6-3 opinion delivered by Justice Ruth Bader Ginsburg, the Court held that the categorically denial of early release to a prisoner who committed felony using firearm is a permissible exercise of the BOP's discretion, even if the prisoner has successfully completed a substance abuse program. "The Bureau reasonably concluded that an inmate's prior involvement with firearms, in connection with the commission of a felony, suggests his readiness to resort to life-endangering violence and therefore appropriately determines the early release decision," wrote Justice Ginsburg for the majority. Justice John Paul Stevens, joined by Chief Justice William H. Rehnquist and Justice Anthony M. Kennedy, dissented.

District of Columbia v. Tri County Industries

Wed, 10 Jan 2001 13:00:00 +0000

Case Basics

Docket No.

99-1953

Petitioner

District of Columbia

Petitioner Type

Petitioner

Respondent

Tri County Industries

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

531 U.S. 287 (2001)

Argued

Wednesday, January 10, 2001

Decided

Wednesday, January 17, 2001

Advocates

Frank J. Emig (on behalf of the Respondent)

Charles S. Reischel (on behalf of the Petitioner)

Facts of the Case

Using a 1993 building permit issued by the District of Columbia, Tri County Industries, Inc. spent nearly $600,000 readying a site for a "soil remediation" facility, which would decontaminate soil tainted by hazardous wastes. After protests and a dispute over whether the company was violating its permit by storing contaminated soil on the site, the city issued a stop- work order. Tri County filed suit against the District of Columbia for suspending its building permit on the facility claiming its due process rights had been violated. Ultimately, the U.S. Court of Appeals for the District of Columbia reinstated a 1998 jury's $5 million award. The appellate court rule that the District Court should have conducted a "more searching inquiry" than it had to preserve the Seventh Amendment right to jury trials in civil cases. The appellate court normally applies a "abuse of discretion" standard. Under the "more searching inquiry," the appellate court discounted the reasons the district judge had cited in ordering a new trial.

Question

Must federal appellate courts conduct a "more searching inquiry" than "abuse of discretion" when reviewing a federal trial court's decision to grant a new trial?

Conclusion

Decision: 9 votes for Tri County Industries, 0 vote(s) against
Legal provision:

In a per curiam opinion, the Court dismissed the writ of certiorari as improvidently granted. The dismissal had the effect of leaving in place the ruling by the U.S. Court of Appeals for the District of Columbia that new- trial grants demand a "more searching inquiry" than the usual abuse-of- discretion review and reinstating the appellate court's decision that upheld the first jury's verdict that awarded Tri County $5 million in damages.

Bartnicki v. Vopper

Tue, 05 Dec 2000 13:00:00 +0000

Location

WILK Radio

305 Route 315 Hwy Pittston PA 18640

Pittston, PA 18640

United States

41° 18' 22.5864" N, 75° 45' 49.3632" W

See map: Google Maps

Case Basics

Docket No.

99-1687

Petitioner

Bartnicki

Petitioner Type

Petitioner

Respondent

Vopper

Respondent Type

Respondent

Consolidation

No. 99-1728

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

532 U.S. 514 (2001)

Argued

Tuesday, December 5, 2000

Decided

Monday, May 21, 2001

Advocates

Jeremiah A. Collins (Argued the cause for the private petitioners)

Thomas C. Goldstein (Argued the cause for the respondent Yocum)

Lee Levine (Argued the cause for the respondents Vopper, et al)

Seth P. Waxman (Department of Justice, argued the cause for the petitioner United States)

Facts of the Case

An unidentified person intercepted and recorded a phone call between the chief union negotiator and the union president (the petitioners) during collective- bargaining negotiations involving a teachers' union and the local school board. After a teacher-favorable proposal was accepted, a radio commentator played a tape of the intercepted conversation. Petitioners filed suit under both federal and state wiretapping laws, alleging that an unknown person using an electronic device had surreptitiously intercepted their telephone conversation. Rejecting a First Amendment protection defense, the District Court concluded, in part, that the statutes were content-neutral laws of general applicability containing "no indicia of prior restraint or the chilling of free speech." Ultimately, the Court of Appeals found the statutes invalid because they deterred significantly more speech than necessary to protect the private interests at stake.

Question

Does the First Amendment provide protection to speech that discloses the contents of an illegally intercepted communication?

Conclusion

Decision: 6 votes for Vopper, 3 vote(s) against
Legal provision: Amendment 1: Speech, Press, and Assembly

Yes. In a 6-3 opinion delivered by Justice John Paul Stevens, the Court held that the First Amendment protects the disclosure of illegally intercepted communications by parties who did not participate in the illegal interception. "In this case, privacy concerns give way when balanced against the interest in publishing matters of public importance," wrote Justice Stevens. "[A] stranger's illegal conduct does not suffice to remove the First Amendment shield from speech about a matter of public concern." Noting that the negotiations were a matter of public interest, Justice Stevens wrote that the "debate may be more mundane than the Communist rhetoric that inspired Justice Brandeis' classic opinion in Whitney v. California, but it is no less worthy of constitutional protection."

Daniels v. United States

Mon, 08 Jan 2001 13:00:00 +0000

Case Basics

Docket No.

99-9136

Petitioner

Daniels

Petitioner Type

Petitioner

Respondent

United States

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

532 U.S. 374 (2001)

Argued

Monday, January 8, 2001

Decided

Wednesday, April 25, 2001

Advocates

G. Michael Tanaka (Los Angeles, California, argued the cause for the petitioner)

Michael R. Dreeben (Department of Justice, argued the cause for the respondent)

Facts of the Case

In 1994, Earthy D. Daniels, Jr., was convicted of being a felon in possession of a firearm. Under the Armed Career Criminal Act of 1984 (ACCA), which imposes a mandatory minimum 15-year sentence on anyone convicted of being a felon in possession of a firearm and who has three previous convictions for a violent felony, Daniels' sentence was enhanced. After an unsuccessful appeal, Daniels filed a motion to vacate, set aside, or correct his federal sentence. Daniels argued that his sentence violated the Constitution because it was based in part on two prior convictions that were themselves unconstitutional. The District Court denied the motion. The Court of Appeals affirmed.

Question

May a federal defendant, who has been sentenced under the Armed Career Criminal Act of 1984, challenge his federal sentence through a motion on the ground that his prior convictions were unconstitutionally obtained?

Conclusion

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

No. In a 5-4 opinion delivered by Justice Sandra Day O'Connor, the Court held that the nonexistent or unsuccessful pursuit of available challenges to the constitutionality of prior state convictions, which were used to enhance a federal sentence, precluded such challenge to collaterally attack a federal sentence. "[Daniels] could have pursued his claims while he was in custody on those convictions," wrote Justice O'Connor for the majority. "As his counsel conceded at oral argument, there is no indication that [Daniels] did so or that he was prevented from doing so by some external force."

United States v. United Foods

Tue, 17 Apr 2001 13:00:00 +0000

Case Basics

Docket No.

00-276

Petitioner

United States

Petitioner Type

Petitioner

Respondent

United Foods

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

533 U.S. 405 (2001)

Argued

Tuesday, April 17, 2001

Decided

Monday, June 25, 2001

Advocates

Barbara B. McDowell (Department of Justice, argued the cause for the petitioner)

Laurence H. Tribe (Argued the cause for the respondent)

Facts of the Case

The Mushroom Promotion, Research, and Consumer Information Act mandates that fresh mushroom handlers pay assessments used primarily to fund advertisements promoting mushroom sales. United Foods, Inc. refused to pay the assessment, claiming that it violated the First Amendment. Ultimately, United Foods sought review in the District Court. In granting the Government summary judgement, the court relied on Glickman v. Wileman Brothers & Elliott, Inc., which held that the First Amendment was not violated when agricultural marketing orders, as part of a larger regulatory marketing scheme, required producers of California tree fruit to pay assessments for product advertising. In reversing, the Court of Appeals held that Glickman did not control because the mandated payments in this case were not part of a comprehensive statutory agricultural marketing program.

Question

Do mandatory advertising assessments imposed on mushroom producers and handlers under the Mushroom Promotion, Research, and Consumer Information Act violate the First Amendment?

Conclusion

Decision: 6 votes for United Foods, 3 vote(s) against
Legal provision: 7 U.S.C. 6101

Yes. In a 6-3 opinion delivered by Justice Anthony M. Kennedy, the Court held that the assessment requirement violates the First Amendment. Justice Kennedy wore for the Court that "the mandated support is contrary to the First Amendment principles set forth in cases involving expression by groups which include persons who object to the speech, but who, nevertheless, must remain members of the group by law or necessity." "We have not upheld compelled subsidies for speech in the context of a program where the principal object is speech itself," continued Justice Kennedy.

TrafFix Devices Inc. v. Marketing Displays Inc.

Wed, 29 Nov 2000 13:00:00 +0000

Case Basics

Docket No.

99-1571

Petitioner

TrafFix Devices Inc.

Respondent

Marketing Displays Inc.

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

532 U.S. 23 (2001)

Argued

Wednesday, November 29, 2000

Decided

Tuesday, March 20, 2001

Advocates

John G. Roberts, Jr. (Argued the cause for the petitioner)

Lawrence G. Wallace (Argued the cause for the United States, as amicus curiae, by special leave of court, supporting the petitioner)

John A. Artz (Argued the cause for the respondent)

Facts of the Case

Marketing Displays, Inc. (MDI) held utility patents for a "dual-spring design" mechanism that keeps temporary road and other outdoor signs upright in wind. After the patents expired, TrafFix Devices, Inc. began marketing sign stands with a dual-spring mechanism copied from MDI's design. MDI brought suit under the Trademark Act of 1964 for, among other things, trade dress infringement. MDA claimed that its sign stands were recognizable to buyers and users because the patented design was visible. In granting summary judgement for TrafFix, the District Court concluded that MDI had not established a "secondary meaning," or that consumers did not associate the look of the dual-spring design with MDI. The court also found that there could be no trade dress protection for the design because it was functional. In reversing, the Court of Appeals suggested that the District Court committed legal error by looking only to the dual-spring design when evaluating MDI's trade dress because a competitor had to find some way to hide the design or otherwise set it apart from MDI's and noted the issue whether an expired utility patent forecloses the possibility of trade dress protection in the product's design.

Question

Is Marketing Displays, Inc.'s trade dress infringement claim precluded because its dual-spring design is a functional feature for which there is no trade dress protection?

Conclusion

Decision: 9 votes for TrafFix Devices Inc., 0 vote(s) against
Legal provision: 15 U.S.C. 1051

Yes. In a unanimous opinion delivered by Justice Anthony M. Kennedy, the Court held that because MDI's dual-spring design is a functional feature for which there is no trade dress protection, MDI's claim is barred. "A utility patent is strong evidence that the features therein claimed are functional, " wrote Justice Kennedy. Focusing on the dual-spring design, Justice Kennedy continued that "[w]here the expired patent claimed the features in question, one who seeks to establish trade dress protection must carry the heavy burden of showing that the feature is not functional, for instance by showing that it is merely an ornamental, incidental, or arbitrary aspect of the device." "MDI did not, and cannot, carry the burden," concluded the Court.

Kyllo v. United States

Tue, 20 Feb 2001 13:00:00 +0000

Location

Kyllo's Home

Rhododendron Drive Florence OR 97439

Florence, OR 97439

United States

43° 58' 15.4632" N, 124° 6' 40.3272" W

See map: Google Maps

Case Basics

Docket No.

99-8508

Petitioner

Kyllo

Petitioner Type

Petitioner

Respondent

United States

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

533 U.S. 27 (2001)

Argued

Tuesday, February 20, 2001

Decided

Monday, June 11, 2001

Advocates

Michael R. Dreeben (Department of Justice, argued the cause for the United States)

Kenneth Lerner (Argued the cause for the petitioner)

Facts of the Case

A Department of the Interior agent, suspicious that Danny Kyllo was growing marijuana, used a thermal-imaging device to scan his triplex. The imaging was to be used to determine if the amount of heat emanating from the home was consistent with the high-intensity lamps typically used for indoor marijuana growth. Subsequently, the imaging revealed that relatively hot areas existed, compared to the rest of the home. Based on informants, utility bills, and the thermal imaging, a federal magistrate judge issued a warrant to search Kyllo's home. The search unveiled growing marijuana. After Kyllo was indicted on a federal drug charge, he unsuccessfully moved to suppress the evidence seized from his home and then entered a conditional guilty plea. Ultimately affirming, the Court of Appeals held that Kyllo had shown no subjective expectation of privacy because he had made no attempt to conceal the heat escaping from his home, and even if he had, there was no objectively reasonable expectation of privacy because the imager "did not expose any intimate details of Kyllo's life," only "amorphous 'hot spots' on the roof and exterior wall."

Question

Does the use of a thermal-imaging device to detect relative amounts of heat emanating from a private home constitute an unconstitutional search in violation of the Fourth Amendment?

Conclusion

Decision: 5 votes for Kyllo, 4 vote(s) against
Legal provision: Amendment 4: Fourth Amendment

Yes. In a 5-4 opinion delivered by Justice Antonin Scalia, the Court held that "[w]here, as here, the Government uses a device that is not in general public use, to explore details of the home that would previously have been unknowable without physical intrusion, the surveillance is a 'search' and is presumptively unreasonable without a warrant." In dissent, Justice John Paul Stevens argued that the "observations were made with a fairly primitive thermal imager that gathered data exposed on the outside of [Kyllo's] home but did not invade any constitutionally protected interest in privacy," and were, thus, "information in the public domain."

Norfolk Shipbuilding v. Garris

Wed, 18 Apr 2001 13:00:00 +0000

Case Basics

Docket No.

00-346

Petitioner

Norfolk Shipbuilding

Petitioner Type

Petitioner

Respondent

Garris

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

532 U.S. 811 (2001)

Argued

Wednesday, April 18, 2001

Decided

Monday, June 4, 2001

Advocates

James T. Ferrini (Argued the cause for the petitioner)

Patrick H. O'Donnell (Argued the cause for the respondent)

Facts of the Case

Christopher Garris' mother filed a complaint in Federal District Court alleging that her son died as the result of injuries he sustained while sandblasting aboard the USNS Maj. Stephen W. Pless. Because the vessel was berthed in the navigable waters of the United States, Garris invoked federal admiralty jurisdiction and sought damages under general maritime law. Garris asserted that the injuries were caused by the negligence of Norfolk Shipbuilding & Drydock Corporation. The District Court dismissed the complaint for failure to state a federal claim. The court stated that no cause of action exists, under general maritime law, for death resulting from negligence. In reversing, the Court of Appeals noted that although the U.S. Supreme Court had not yet recognized a maritime cause of action for wrongful death resulting from negligence, the action was made appropriate by principles contained in precedent.

Question

Does a maritime cause of action for wrongful death resulting from negligence exist?

Conclusion

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

Yes. In an opinion delivered by Justice Antonin Scalia, the Court held that the general maritime cause of action for death caused by violation of maritime duties is available for the negligent breach of a maritime duty of care. "The general maritime law has recognized the tort of negligence for more than a century, and it has been clear since [Moragne v. States Marine Lines Inc.] that breaches of a maritime duty are actionable when they cause death, as when they cause injury," wrote Justice Scalia for the Court. Justice Ruth Bader Ginsburg wrote an opinion concurring in part, which was joined by Justices David H. Souter and Stephen G. Breyer.

United Dominion Industries v. United States

Mon, 26 Mar 2001 13:00:00 +0000

Case Basics

Docket No.

00-157

Petitioner

United Dominion Industries

Petitioner Type

Petitioner

Respondent

United States

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

532 U.S. 822 (2001)

Argued

Monday, March 26, 2001

Decided

Monday, June 4, 2001

Advocates

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

Eric R. Fox (Argued the cause for the petitioner)

Facts of the Case

Under the Internal Revenue Code of 1954, a taxpayer may carry back its "product liability loss" up to 10 years in order to offset prior years' income. United Dominion Industries, Inc. predecessor in interest, AMCA International Corporation, was the parent of an affiliated group filing consolidated returns for the years 1983 through 1986. AMCA calculated its product liability loss (PPL) on a consolidated basis, or a "single-entity" approach. The government's "separate-member" approach would have prohibited 5 of AMCA's 26 members from contributing to the group's total PPL. In 1986 and 1987, AMCA petitioned the Internal Revenue Service for a refund based on its PPL calculations. Ultimately, the District Court applied AMCA's single-entity approach, concluding that if the affiliated group's consolidated return reflects consolidated net operating losses in excess of the group's aggregate product liability expenses, the total of those expenses is a PLL that may be carried back. In reversing, the Court of Appeals applied the separate-member approach.

Question

Must an affiliated group of corporations' product liability loss be figured on a consolidated, single-entity basis?

Conclusion

Decision: 8 votes for United Dominion Industries, 1 vote(s) against
Legal provision: Internal Revenue Code

Yes. In an 8-1 opinion delivered by Justice David H. Souter, the Court held that an affiliated group's product liability loss must be figured on a consolidated, single-entity basis, and not by aggregating product liability losses separately determined company by company. Justice Souter wrote for the Court that "'the Internal Revenue Code vests ample authority in the Treasury to adopt consolidated return regulations to effect a binding resolution of the question presented in this in this case.' To the extent that the Government has exercised that authority, its actions point to the single-entity approach as the better answer. To the extent the Government disagrees, it may amend its regulations to provide for a different one."

Seling v. Young

Tue, 31 Oct 2000 13:00:00 +0000

Case Basics

Docket No.

99-1185

Petitioner

Seling

Petitioner Type

Petitioner

Respondent

Young

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

531 U.S. 250 (2001)

Argued

Tuesday, October 31, 2000

Decided

Wednesday, January 17, 2001

Advocates

Robert C. Boruchowitz (Argued the cause for the respondent)

Maureen A. Hart (Olympia, Washington, argued the cause for the petitioner)

Facts of the Case

Washington State's Community Protection Act of 1990 (Act) authorizes the civil commitment of "sexually violent predators," or persons who suffer from a mental abnormality or personality disorder that makes them likely to engage in predatory acts of sexual violence. After his imprisonment for committing six rapes, Andre Brigham Young was scheduled to be released from prison in 1990. Prior to his release, the state successfully filed a petition to commit Young as a sexually violent predator. Ultimately, Young instituted a federal habeas action. Initially, the District Court granted the writ, finding that the Act was criminal rather than civil, and that it violated the double jeopardy and ex post facto guarantees of the Constitution. On remand from the Court of Appeals, the District Court denied Young's petition. The court determined that the Act was civil and, therefore, it could not violate the double jeopardy and ex post facto guarantees. On appeal, the Court of Appeals reasoned that the case turned on whether the Act was punitive "as applied" to Young.

Question

May an act, found to be civil, be deemed punitive "as applied" to an individual in violation of the Double Jeopardy and Ex Post Facto Clauses, thereby providing a cause for release?

Conclusion

Decision: 8 votes for Seling, 1 vote(s) against
Legal provision: Article 1, Section 10: Ex Post Facto

No. In an 8-1 opinion delivered by Justice Sandra Day O'Connor, the Court held that because the Washington Community Protection Act of 1990 had been found to be civil, it could not be deemed punitive as applied to Young for the purposes of double jeopardy and ex post facto challenges. Justice O'Connor wrote for the majority that an "as-applied" analysis would be "unworkable" because it would "never conclusively resolve whether a particular scheme is punitive and would thereby prevent a final determination of the scheme's validity under the Double Jeopardy and Ex Post Facto Clauses." Justice John Paul Stevens dissented.

Tuan Anh Nguyen v. INS

Tue, 09 Jan 2001 13:00:00 +0000

Case Basics

Docket No.

99-2071

Petitioner

Tuan Anh Nguyen

Petitioner Type

Petitioner

Respondent

INS

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

533 U.S. 53 (2001)

Argued

Tuesday, January 9, 2001

Decided

Monday, June 11, 2001

Advocates

Edwin S. Kneedler (Department of Justice, argued the cause for the respondent)

Martha F. Davis (Argued the cause for the petitioner)

Facts of the Case

In 1969, Tuan Ahn Nguyen was born in Saigon, Vietnam to Joseph Boulais and a Vietnamese citizen. At age six, Nguyen became a lawful permanent United States resident. At age 22, Nguyen pleaded guilty in a Texas state court to two counts of sexual assault on a child. Subsequently, the Immigration and and Naturalization Service initiated deportation proceedings against Nguyen. After the Immigration Judge ordered Nguyen, Boulais obtained an order of parentage from a state court. Dismissing Nguyen's appeal, the Board of Immigration of Appeals rejected Nguyen's citizenship claim because he had not complied with 8 USC section 1409(a)'s requirements for one born out of wedlock and abroad to a citizen father and a noncitizen mother. On appeal, the Court of Appeals rejected Nguyen and Boulais argument that section 1409(a) violates equal protection by providing different rules for attainment of citizenship by children born abroad and out of wedlock depending upon whether the one parent with American citizenship is the mother or the father.

Question

Is 8 USC section 1409(a)'s statutory distinction, which imposes different requirements for a child's acquisition of citizenship depending upon whether the citizen parent is the mother or the father, consistent with the equal protection guarantee embedded in the Due Process Clause of the Fifth Amendment?

Conclusion

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

Yes. In a 5-4 opinion delivered by Justice Anthony M. Kennedy, the Court held that "[section 1409(a)] is consistent with the constitutional guarantee of equal protection." "For a gender-based classification to withstand equal protection scrutiny, it must be established 'at least that the [challenged] classification serves important governmental objectives and that the discriminatory means employed are substantially related to the achievement of those objectives,'" wrote Justice Kennedy, "[f]or reasons to follow, we conclude [section 1409(a)] satisfies this standard." Justice Sandra Day O'Connor, with whom Justices David H. Souter, Ruth Bader Ginsburg, and Stephen G. Breyer joined, dissented, noted that "[n]o one should mistake the majority's analysis for a careful application of this Court's equal protection jurisprudence concerning sex-based classifications."

MLB Players Assn v. Garvey

Sat, 27 Apr 2013 09:50:51 +0000

Case Basics

Docket No.

00-1210

Petitioner

MLB Players Assn

Petitioner Type

Petitioner

Respondent

Garvey

Respondent Type

Respondent

Decided By

Rehnquist Court (1994-2005)

Opinion

532 U.S. 504 (2001)

Decided

Monday, May 14, 2001

Facts of the Case

After the Major League Baseball Players Association filed grievances against the Major League Baseball Clubs, arbitrators found that the Clubs had colluded in the market for free-agent services in violation of the industry's collective bargaining agreement. To cover damages, the Association and Clubs entered into an agreement, which provided funds and framework to resolve individual player's claims. Steve Garvey, a first baseman, submitted a claim alleging that the San Diego Padres did not extend his contract to the 1988 and 1989 seasons due to collusion. Under the framework, the Association denied Garvey's claim. Agreeing, the arbitrator determined that Garvey did not receive a contract extension due to collusion and found that Garvey had not shown a specific offer of extension. Ultimately, the Court of Appeals reversed the District Court's denial of Garvey's motion to vacate the arbitrator's award. The appellate court, under the Labor Management Relations Act, directed the arbitration panel to enter an award for Garvey because it concluded from the arbitration proceedings that an offer was made to Garvey and that it was withdrawn due to collision.

Question

Did the Court of Appeals err in reversing the District Court's denial of a baseball player's motion to vacate an arbitration award and in directing the arbitrator to enter judgment in favor of the player, where the arbitrator denied the player's claim?

Conclusion

Decision: 8 votes for MLB Players Assn, 1 vote(s) against
Legal provision:

Yes. In a per curiam opinion, the Court reversed the Court of Appeals' determination because it conflicted with the Court's cases limiting review of an arbitrator's award entered pursuant to an agreement between an employer and a labor organization and prescribing the appropriate remedy where vacation of the award is warranted. The opinion stated that: "Judicial review of a labor- arbitration decision pursuant to such an agreement is very limited. Courts are not authorized to review the arbitrator's decision on the merits despite allegations that the decision rests on factual errors or misinterprets the parties' agreement." The opinion continued "even 'serious error' on the arbitrator's part does not justify overturning his decision, where, as here, he is construing a contract and acting within the scope of his authority."

Bilski v. Kappos

jgoldman — Mon, 09 Nov 2009 13:00:00 +0000

Location

United States

38° 48' 17.4096" N, 77° 2' 48.9156" W

See map: Google Maps

Case Basics

Docket No.

08-964

Petitioner

Bernard L. Bilski and Rand A. Warsaw

Petitioner Type

Petitioner

Respondent

David J. Kappos, Under Secretary of Commerce for Intellectual Property and Director, Patent and Trademark Office

Respondent Type

Respondent

Decided By

Roberts Court (2009-2010)

Opinion

561 U.S. ___ (2010)

Granted

Monday, June 1, 2009

Argued

Monday, November 9, 2009

Decided

Monday, June 28, 2010

Advocates

J. Michael Jakes (for the petitioners)

Malcolm L. Stewart (Deputy Solicitor General, Department of Justice, for the respondent)

Facts of the Case

Applicants were denied a patent by the Patent and Trademark Office (PTO) for claims pertaining to a process of managing risk in commodities trading. The PTO examiner deemed the invention not to be of patentable subject matter under 35 U.S.C. Section 101. The Board of Patent Appeals and Interferences affirmed the decision.

On appeal, the U.S. Court of Appeals for the Federal Circuit affirmed. The court relied on Supreme Court precedent stating that an invention is patentable if: "1) it is tied to a particular machine or apparatus, or 2) it transforms a particular article into a different state or thing." Reasoning from this, it held that the applicants' invention clearly failed this test (machine-or-transformation test) and therefore did not constitute patentable subject matter.

Question

1) Did the Federal Circuit err by using the machine-or-transformation test in determining patentable subject matter?

2) Does the machine-or-transformation test prevent patent protection for many business methods and thus contradict congressional intent that patents protect "methods of doing or conducting business."

Conclusion

Decision: 9 votes for Kappos, 0 vote(s) against
Legal provision: Patent Act

No. No. The Supreme Court affirmed the Federal Circuit, holding that the applicants' claimed invention is not patent eligible. With Justice Anthony M. Kennedy writing for the majority, the Court reasoned that the Federal Circuit did not err when it used the "machine-or-transformation test" to determine patentability. However, the Court noted, in contrast to the Federal Circuit, that the machine-or-transformation test is not the sole test for determining patent eligibility.

Justice John Paul Stevens, joined by Justices Ruth Bader Ginsburg, Stephen G. Breyer, and Sonia Sotomayor, concurred in the judgment. He disagreed with the majority to the extent it suggested that any series of steps that is not itself an abstract idea or law of nature may constitute a "process" within Section 101. Justice Stephen G. Breyer, joined by Justice Antonin Scalia, also concurred in the judgment. He noted his agreement with Justice Stevens' concurrence and also highlighted the extent to which the Court agreed on many fundamental issues of patent law raised by this case.