Cases - 2003 term

Illinois v. Lidster

Wed, 05 Nov 2003 13:00:00 +0000

Case Basics

Docket No.

02-1060

Petitioner

Illinois

Petitioner Type

Petitioner

Respondent

Robert S. Lidster

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

540 U.S. 419 (2004)

Granted

Monday, May 5, 2003

Argued

Wednesday, November 5, 2003

Decided

Tuesday, January 13, 2004

Advocates

Patricia A. Millett (argued the cause for Petitioner, on behalf of the United States, as amicus curiae)

Donald J. Ramsell (argued the cause for Respondent)

Gary Feinerman (argued the cause for Petitioner)

Facts of the Case

Police stopped Robert Lidster at a checkpoint set up to find information about a recent hit-and-run accident. Lidster was arrested, and later convicted, for drunk driving. Lidster successfully appealed his conviction to the Illinois Appellate Court. It relied on the U.S. Supreme Court's decision in Indianapolis v. Edmond (2000) holding that a checkpoint is unconstitutional if its only purpose is to uncover "ordinary criminal wrongdoing." The Illinois Supreme Court affirmed.

Question

Does Indianapolis v. Edmond, which dealt with the Fourth and 14th Amendment prohibitions of unreasonable searches and seizures, prohibit checkpoints organized to question motorists about a previous offense and arrest motorists for drunk driving?

Conclusion

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

No. In an opinion delivered by Justice Breyer, the Court held 6-3 that the Illinois checkpoint did not violate the Fourth Amendment's prohibition of unreasonable searches and seizures and was constitutional. It ruled that the checkpoint was reasonable because it advanced a "grave" public interest - "investigating a crime that had resulted in a human death" - and interfered minimally with Fourth Amendment liberty. The Court distinguished Illinois's "information-seeking" checkpoint from the "crime control" checkpoint struck down in Edmond. Justices Stevens, Souter, and Ginsburg - while agreeing that Edmond does not invalidate the Illinois checkpoint - dissented from the majority's decision granting constitutional approval to the checkpoint. They argued that the case should have been remanded to the Illinois courts.

Yates v. Hendon

Tue, 13 Jan 2004 13:00:00 +0000

Case Basics

Docket No.

02-458

Petitioner

Raymond B. Yates, M.D., P.C. Profit Sharing Plan, and Raymond B. Yates, Trustee

Petitioner Type

Petitioner

Respondent

William T. Hendon, Trustee

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

541 U.S. 1 (2004)

Granted

Friday, June 27, 2003

Argued

Tuesday, January 13, 2004

Decided

Tuesday, March 2, 2004

Advocates

Matthew D. Roberts (argued the cause for Petitioners, on behalf of the United States, as amicus curiae)

Conrad M. Troutman (argued the cause for Respondent)

James Al Holifield, Jr. (argued the cause for Petitioners)

Facts of the Case

Raymond Yates owned a corporation with a profit sharing/pension plan. Yates borrowed money from the plan at a set interest. After he had repaid the loan to his profit sharing/pension plan, Yates' creditors filed an involuntary bankruptcy petition against him. They asked the bankruptcy court to set aside the repayment (interest included) and give it to the creditors.

Yates argued that under the Employee Retirement Income Security Act (ERISA), the interest from the profit sharing/pension plan could not be seized (except for loans to participants). The bankruptcy court disagreed and granted Yates' creditors' requests. The court reasoned that as the sole owner of the business, Yates was an employer under ERISA, not a "participant." The plan's prohibition on interest seizure therefore did not apply. A federal district court and a Sixth Circuit Court of Appeals panel both affirmed.

Question

Is the owner of a business a "participant" in a profit sharing/pension plan established under the Employee Retirement Income Security Act (ERISA)?

Conclusion

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

Yes. Justice Ruth Bader Ginsburg delivered the Court's unanimous opinion holding that a business owner, such as Yates, qualifies as a "participant" in an ERISA pension plan. The Court reasoned that this was the intent of Congress and that the act's text verifies this. In a business in which an ERISA plan covers employees, the employer can essentially qualify as an employee and receive the plan's protections. In light of this, the Court sent Yates' bankruptcy issues to a lower court for resolution.

Arizona v. Gant

Sat, 27 Apr 2013 20:11:37 +0000

Case Basics

Docket No.

02-1019

Petitioner

Arizona

Respondent

Rodney J. Gant

Decided By

Rehnquist Court (1994-2005)

Granted

Monday, April 21, 2003

Decided

Monday, October 20, 2003

Advocates

Thomas F. Jacobs (Attorneys for Respondent)

Eric J. Olsson (Attorneys for Petitioner, Counsel of Record)

Facts of the Case

Arizona police went to the home of Rodney Gant in search of drugs and to arrest him for failing to appear in court. When they arrived at the house, Gant was not there (though two other people were in his home, one of whom was in possession of a crack pipe) but while the police were still at the house Gant pulled into the driveway. While Gant was still in his car, an officer shined a flashlight into the vehicle, but the police made no other contact with him until he stepped out of the car. After he was out of the car, the police searched it and found drugs and a handgun. Gant was arrested and charged with possession of drugs and drug paraphernalia.

Before trial, Gant asked the judge to rule the evidence found in the car unconstitutional because the search had been conducted without a warrant in violation of the Fourth Amendment's prohibition of unreasonable searches and seizures. The trial judge denied the motion, ruling that the search was a direct result of Gant's lawful arrest and therefore an exception to the general Fourth Amendment warrant requirement under New York v. Belton (1981). Gant was convicted and sentenced to three years in prison.

Gant appealed, and the Arizona Court of Appeals reversed the conviction, ruling the search unconstitutional. The court found that exceptions to the Fourth Amendment warrant requirement must be justified by concerns for officer safety or evidence preservation. The court ruled that these justifications did not apply in Gant's case because he had left the vehicle voluntarily without being stopped by police or asked to get out of the car. The search of the vehicle was therefore not directly connected to the arrest and, without that justification, clearly violated the Fourth Amendment.

Question

When police arrest the recent occupant of a vehicle who got out voluntarily, can they search the vehicle without a warrant?

Conclusion

On October 20, 2003, without issuing a decision in the case, the Court sent it back to Arizona state court for further consideration in light of the Arizona case State v. Dean. The issue raised in this case, however, was decided by the U.S. Supreme Court later in the same term. On May 24, 2004, the Court issued a decision in the case of Thornton v. U.S., finding that police could constitutionally search a vehicle even after its occupant has left it voluntarily.

Johnson v. California

Tue, 30 Mar 2004 13:00:00 +0000

Case Basics

Docket No.

03-6539

Petitioner

Jay Shawn Johnson

Petitioner Type

Petitioner

Respondent

California

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

541 U.S. 428 (2004)

Granted

Monday, December 1, 2003

Argued

Tuesday, March 30, 2004

Decided

Monday, May 3, 2004

Advocates

Stephen B. Bedrick (argued the cause for Petitioner)

Seth K. Schalit (argued the cause for Respondent)

Facts of the Case

Jay Shawn Johnson, on trial in California for murder, objected to the district attorney's use of peremptory challenges to eliminate all three black prospective jurors. Johnson argued the eliminations were based on race. The judge denied Johnson's motions and held that Johnson had failed to show a "strong likelihood" that the dismissals were race-based. The judge relied on People v. Wheeler, the 1978 case in which the California Supreme Court ruled that to establish a prima facie case of racial bias in peremptory challenges, the objector had to show "strong likelihood" that the challenges were race- based. The jury found Johnson guilty of second-degree murder.

Johnson appealed and argued that the "strong likelihood" standard in Wheeler was at odds with the 'reasonable inference" standard the U.S. Supreme Court set in Batson v. Kentucky (1986). The appeals court agreed and reversed Johnson's conviction. The California Supreme Court reversed and ruled that the two standards were the same.

Question

In order to establish a prima facie case under Batson v. Kentucky, 476 U.S. 79 (1986), must the objector show that it is more likely than not that the other party's peremptory challenges were based on impermissible group bias?

Conclusion

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

In a per curiam opinion, the Court ruled it lacked jurisdiction and dismissed the case.

Rumsfeld v. Padilla

Wed, 28 Apr 2004 13:00:00 +0000

Case Basics

Docket No.

03-1027

Petitioner

Donald H. Rumsfeld, Secretary of Defense

Petitioner Type

Petitioner

Respondent

Jose Padilla and Donna R. Newman, as Next Friend of Jose Padilla

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

542 U.S. 426 (2004)

Granted

Friday, February 20, 2004

Argued

Wednesday, April 28, 2004

Decided

Monday, June 28, 2004

Advocates

Paul D. Clement (argued the cause for Petitioner)

Jennifer Martinez (argued the cause for Respondents)

Facts of the Case

Jose Padilla, an American citizen, was arrested in Chicago's O'Hare International Airport after returning from Pakistan in 2002. He was initially detained as a material witness in the government's investigation of the al Qaeda terrorist network, but was later declared an "enemy combatant" by the Department of Defense, meaning that he could be held in prison indefinitely without access to an attorney or to the courts. The FBI claimed that he was returning to the United States to carry out acts of terrorism.

Donna Newman, who had represented him while he was being held as a material witness, filed a petition for habeas corpus on his behalf. The U.S. District Court for the Southern District of New York ruled that Newman had standing to file the petition despite the fact that Padilla had been moved to a military brig in South Carolina. However, the court also found that the Department of Defense, under the President's constitutional powers as Commander in Chief and the statutory authorization provided by Congress's Authorization for Use of Military Force, had the power to detain Padilla as an enemy combatant. The district judge rejected Newman's argument that the detention was prohibited by the federal Non-Detention Act, which states that no "citizen shall be imprisoned or otherwise detained by the United States except pursuant to an Act of Congress."

On appeal, a divided Second Circuit Court of Appeals panel reversed the district court's "enemy combatant" ruling. The panel found that the Authorization for Use of Military force did not meet the requirement of the Non-Detention Act and that the President could not, therefore, declare American citizens captured outside a combat zone as enemy combatants.

Question

Does Congress's "Authorization for use of Military Force" authorize the President to detain a United States citizen based on a determination that he is an enemy combatant, or is that power precluded by the Non-Detention Act?

Conclusion

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

The Court did not reach a decision on the merits in this case. Instead, in 5-to-4 opinion written by Chief Justice William H. Rehnquist, the Court found that the case had been improperly filed. Under federal law, a petition for a writ of habeas corpus can only be filed against the person directly responsible for a prisoner's confinement or, put another way, the person with the power to bring the prisoner to court. In most cases this person is the warden of the petitioner's prison; in this case, it was the commander of the military brig in which Padilla was held. Because Padilla's attorney had listed Secretary of Defense Donald Rumsfeld as the defendent, instead of the brig commander, and because the suit was filed in New York instead of in South Carolina, where the commander lived and worked, the Court found that the case would have to be re-filed in a federal district court in South Carolina.

Justices Stevens, Souter, Ginsberg and Breyer dissented, finding that an exception should be made to the jurisdictional rule because the government had moved Padilla to South Carolina without giving his attorney notice to file the habeas writ.

Lamie v. United States Trustee

Mon, 10 Nov 2003 13:00:00 +0000

Case Basics

Docket No.

02-693

Petitioner

John M. Lamie

Petitioner Type

Petitioner

Respondent

United States Trustee

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

540 U.S. 526 (2004)

Granted

Monday, March 10, 2003

Argued

Monday, November 10, 2003

Decided

Monday, January 26, 2004

Advocates

Lisa S. Blatt (argued the cause for Respondent)

Thomas C. Goldstein (argued the cause for Petitioner)

Facts of the Case

In the Bankruptcy Reform Act of 1994 Congress created a list of people that corporations could pay while going through Chapter 7 bankruptcy proceedings. The bankruptcy attorney for the corporation was not included in that list. John Lamie, a bankruptcy attorney, challenged the law, arguing that the omission of bankruptcy attorneys from the list was accidental. The bankruptcy court that heard the case ruled that the omission was not inadvertent. Nevertheless, it awarded Lamie the fees in question because money intended to pay them had been set aside in a retainer before the corporation entered Chapter 7 proceedings. A Fourth Circuit Court of Appeals panel reversed the decision to pay Lamie, holding that the retainer was not separate from the corporation's other funds. On the issue of whether the omission of the bankruptcy attorney from the list of acceptable payees, the panel affirmed the lower court's decision.

Question

Did Congress intend to omit bankruptcy attorneys from the list of people a corporation could pay during Chapter 7 bankruptcy proceedings?

Conclusion

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

Yes. In a unanimous decision, the Court upheld the Fourth Circuit, ruling that the Bankruptcy Reform Act of 1994 did not authorize the payment of bankruptcy attorneys by corporations going through Chapter 7 bankruptcy. According to Justice Anthony Kennedy's opinion for the Court: "The statute is awkward, and even ungrammatical; but that does not make it ambiguous on the point at issue." The Court ruled that though the Act's deletion of the words "or to the debtor's attorney" from the Bankruptcy Code had rendered a sentence grammatically incorrect, the Act should still be interpreted according to the plain meaning of its text, however awkward. The Court found the legislative history of the Act inconclusive, and concluded that "we must determine intent from the statute before us." The text of the statute, erroneously or not, omitted bankruptcy attorneys from the list of people bankrupt corporations could pay. r

USPS v. Flamingo Industries

Mon, 01 Dec 2003 13:00:00 +0000

Case Basics

Docket No.

02-1290

Petitioner

United States Postal Service

Petitioner Type

Petitioner

Respondent

Flamingo Industries (USA) Ltd., et al.

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

540 U.S. 736 (2004)

Granted

Tuesday, May 27, 2003

Argued

Monday, December 1, 2003

Decided

Wednesday, February 25, 2004

Advocates

Edwin S. Kneedler (argued the cause for Petitioner)

Harold J. Krent (argued the cause for Respondents)

Facts of the Case

When the U.S. Postal Service ended its mail-sack contract with Flamingo Industries, Flamingo sued in U.S. district court. Flamingo claimed the Postal Service declared a "fake emergency in the supply of mail sacks" so it could give no-bid contracts to cheaper foreign manufacturers without allowing U.S. companies to compete for them. Flamingo claimed this violated federal antitrust laws (among other charges). The district court dismissed the antitrust claim reasoning that the federal government is protected by sovereign immunity. The Ninth Circuit Court of Appeals reversed on the antitrust immunity count. It ruled that the 1970 Postal Reorganization Act waived the Postal Service's sovereign immunity and that it could be sued under federal antitrust laws as a "person."

Question

Can the U.S. Postal Service be sued under federal antitrust laws?

Conclusion

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

No. In a unanimous opinion delivered by Justice Anthony Kennedy, the Court held that the U.S. Postal Service cannot be sued under antitrust laws. The Court acknowledged the Postal Reorganization Act may waive the Postal Service's immunity from suit. However, federal antitrust laws (the Sherman Act, for example) do not allow the federal government - of which the Postal Service is a part - to be sued.

Bedroc Limited v. United States

Tue, 20 Jan 2004 13:00:00 +0000

Case Basics

Docket No.

02-1593

Petitioner

BedRoc Limited, LLC, and Western Elite, Inc.

Petitioner Type

Petitioner

Respondent

United States, et al.

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

541 U.S. 176 (2004)

Granted

Tuesday, September 30, 2003

Argued

Tuesday, January 20, 2004

Decided

Wednesday, March 31, 2004

Advocates

R. Timothy McCrum (argued the cause for Petitioners)

Thomas L. Sansonetti (argued the cause for Respondents)

Facts of the Case

BedRoc Ltd. and Western Elite, Inc., own property in Nevada patented under the federal Pittman Act (1919). (The act was repealed in 1964.) The act authorized the issuance of patents to desert lands in Nevada to individuals who successfully developed underground water resources. However, the act specified that patents reserve to the United States "all the coal and other valuable minerals" in the patented lands. When the previous owner of BedRoc and Western Elite's land extracted and sold commercially valuable sand and gravel from the lands without a federal mineral contract, the Bureau of Land Management (BLM) gave notification that the mining was illegal under federal law. The owner lost an appeal to the Interior Board of Land Appeals (IBLA). Once BedRoc and Western Elite owned the land, they filed suit in U.S. district court, arguing that the Pittman Act's "valuable minerals" provision did not include valuable sand and gravel. The district court rejected the companies' argument and sided with the United States. The Ninth Circuit Court of Appeals affirmed.

Question

Does the reservation to the United States of all "coal and other valuable minerals" in patents issued under the Pittman Act (1919) include commercially valuable sand and gravel?

Conclusion

Decision: 6 votes for Bedroc Limited, 3 vote(s) against
Legal provision: 43 U.S.C. 351

No. In an plurality opinion written by Chief Justice William Rehnquist and joined by three other Justices, the Court ruled that because sand and gravel were not commercially valuable in 1919 when the Pittman Act was passed, they were not "valuable minerals" covered under the Act. Although the Court had interpreted "minerals" expansively in the past, the Court held that the adjective "valuable" limited the term sufficiently to exclude sand and gravel. The Court emphasized that since the plain text of the statute was clear, there was no need to delve into the legislative history of the Act. Justice Thomas, joined by Justice Breyer, wrote a separate concurring opinion in which he agreed that sand and gravel were not "valuable minerals" under the Act, but disputed the plurality's reliance on the word "valuable." Justice Stevens, joined by Justices Souter and Ginsburg, dissented. The dissent argued that the legislative history of the Pittman Act indicated that "valuable minerals" should be interpreted broadly to include sand and gravel.

United States v. Banks

Wed, 15 Oct 2003 13:00:00 +0000

Case Basics

Docket No.

02-473

Petitioner

United States

Petitioner Type

Petitioner

Respondent

Lashawn Lowell Banks

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

540 U.S. 31 (2003)

Granted

Monday, February 24, 2003

Argued

Wednesday, October 15, 2003

Decided

Tuesday, December 2, 2003

Advocates

Randall J. Roske (argued the cause for Respondent)

David B. Salmons (argued the cause for Petitioner)

Facts of the Case

On July 15, 1998 police officers, with a warrant, knocked on the door of suspected drug dealer Lashawn Banks. They waited between 15 and 20 seconds, and when Banks did not come to the door they smashed it open with a battering ram. Banks was arrested but, before his trial, he filed a motion to suppress the evidence found in his apartment because, he claimed, the forced entry had been unlawful. When the request was denied, he pled guilty, but eventually attempted to retract his guilty plea on the advice of a new attorney. The new attorney, Randall Roske, argued that the search was unconstitutional because officers did not wait long enough before breaking down the door, and had no evidence that waiting longer would have had negative consequences. A Ninth Circuit Court of Appeals agreed, ruling the search unconstitutional and suppressing the evidence found during it.

Question

How long must officers wait after knocking on a door before they can use force to break it down in order to execute a warrant?

Conclusion

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

The Court unanimously held that 15 to 20 seconds was a reasonable period for police to wait before entering by force when they were investigating drug charges because waiting any longer was likely to result in the destruction of evidence. Justice David Souter, writing for the court, stated that "while we agree... that this call is a close one, we think that after 15 to 20 seconds without a response, police could fairly suspect that cocaine would be gone if they were reticent any longer."

Yarborough v. Alvarado

Mon, 01 Mar 2004 13:00:00 +0000

Case Basics

Docket No.

02-1684

Petitioner

Michael Yarborough, Warden

Petitioner Type

Petitioner

Respondent

Michael Alvarado

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

541 U.S. 652 (2004)

Granted

Tuesday, September 30, 2003

Argued

Monday, March 1, 2004

Decided

Tuesday, June 1, 2004

Advocates

John P. Elwood (argued the cause for Petitioner, on behalf of the United States, as amicus curiae)

Deborah Jane Chuang (argued the cause for Petitioner)

Tara K. Allen (argued the cause for Respondent)

Facts of the Case

Police interviewed Michael Alvarado, 17, without his parents at a police station about his involvement in a crime. Police neither arrested nor Mirandized Alvarado. During the interview, Alvarado confessed involvement. Based, in part, on these statements, Alvarado was convicted of second-degree murder and attempted robbery. After failed appeals in the California courts, Alvarado unsuccessfully sought a writ of habeas corpus in federal district court in California. The Ninth Circuit Court of Appeals reversed. Recognizing the "in custody" standard to be whether a reasonable person would feel free to end interrogation, the appeals court held that a juvenile is more likely to feel he is in custody. Because Alvarado was "in custody," the Fifth Amendment required that his rights under Miranda v. Arizona (1966) be read to him.

Question

When deciding whether a suspect is "in custody" and therefore entitled to his Miranda warnings, must an officer consider the suspect's age and previous history with law enforcement?

Conclusion

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

No. In a 5-to-4 decision written by Justice Anthony Kennedy, the Court ruled that the purpose of the Court's Miranda decision was to provide an objective rule readily understandable by police officers: when interrogating a suspect who is "in custody," an officer must first read the suspect his Miranda rights. Determining whether a suspect is actually in custody has always been based on objective criterion like whether he had been brought to the police station by police or had come of his own accord. Requiring officers to consider individual characteristics of a suspect when determining whether he is "in custody," such as the suspect's age or previous history with law enforcement, would make the test a subjective one that would be more difficult for officers to understand and abide by. Justice Kennedy wrote that the Miranda decision "states an objective rule designed to give clear guidance to the police, while consideration of a suspect's individual characteristics - including his age - could be viewed as creating a subjective inquiry."

Illinois v. Fisher

Sat, 27 Apr 2013 20:11:38 +0000

Case Basics

Docket No.

03-374

Petitioner

Illinois

Petitioner Type

Petitioner

Respondent

Fisher

Respondent Type

Respondent

Decided By

Rehnquist Court (1994-2005)

Opinion

540 U.S. 544 (2004)

Decided

Monday, February 23, 2004

Facts of the Case

Gregory Fisher was arrested and charged with possession of cocaine in 1988. He filed a motion for discovery, asking that the white powdery substance he had had in his possession be made available as evidence at trial so that he could have it independently tested in an attempt to disprove the four tests conducted by police showing that it was cocaine. The state agreed to make the substance available at a future date.

The defendant was released on bond, but in July of 1989 he failed to appear in court. He remained a fugitive for 10 years, during which time the police destroyed the substance in keeping with the standard practice of destroying old evidence. When Fisher was captured and brought to trial again in 1999, he claimed that the state had violated his Fourteenth Amendment Due Process Rights by destroying evidence that could possibly have proved his innocence after he had filed a motion for discovery. The trial court denied his motion, holding that the police had acted in "good faith" in accordance with Arizona v. Youngblood. Fisher was subsequently convicted. The Illinois Appellate Court overturned the conviction, however, holding that the case was different from Youngblood because Fisher had filed a discovery motion. The state Supreme Court declined to hear the case.

Question

Did Illinois police (acting in good faith) violate Fisher's Fourteenth Amendment Due Process rights by destroying evidence after he filed a motion for discovery?

Conclusion

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

No. In a per curiam opinion, the Court held that the simple fact that Fisher had filed a motion for discovery did not distinguish the case from Youngblood. The Court also rejected Fisher's contention that the substance was "material exculpatory evidence," which would have made the good faith/bad faith distinction irrelevant (whenever the state destroys or refuses to disclose "material exculpatory evidence" it violates Due Process, regardless of its intent). Instead, the Court held that the evidence was at the most "potentially useful evidence" (as it was in Youngblood) because the police had already determined, in good faith, that the material was cocaine. Justice John Paul Stevens concurred in this case.

Pliler v. Ford

Mon, 26 Apr 2004 13:00:00 +0000

Case Basics

Docket No.

03-221

Petitioner

Cheryl K. Pliler, Warden

Petitioner Type

Petitioner

Respondent

Richard Herman Ford

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

542 U.S. 225 (2004)

Granted

Friday, January 9, 2004

Argued

Monday, April 26, 2004

Decided

Monday, June 21, 2004

Advocates

Lisa M. Bassis (argued the cause for Respondent)

Facts of the Case

Richard Ford filed a habeas corpus petition in federal district court five days before the one-year statute of limitations for his appeal ended under the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA). He represented himself, and his petition contained some claims that had been decided on by state courts and others that had not. The judge informed him that he could not hear the claims that had not been heard by state courts, and that Ford had several options: the judge could dismiss all the claims, allowing Ford to re- file them after he had presented the unheard claims to a state court, or he could dismiss the unheard claims, but delay proceedings on the other ones so that Ford could re-add the unheard ones after they had been heard. Ford chose the first option, but when he tried to re-file the claims after they were rejected by a state court, the judge refused to let him file them because the one-year AEDPA statute of limitations had ended. Ford appealed the decision to the Circuit Court of Appeals for the Ninth Circuit, which reversed the district court's decision, finding that the judge could have heard the claims if Ford had chosen the second option and that he should have warned Ford that the statute of limitations would likely end before he could re-file the claims under the first option.

Question

Is a judge required to warn a habeas corpus petitioner who is representing himself that his claims may be barred by a statute of limitations if he chooses to drop the claims and re-file them at a later date?

Conclusion

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

No. In an opinion by Justice Clarence Thomas, the Court ruled that a judge is not required to warn a habeas corpus petitioner who is representing himself of the consequences of his legal decision. Justice Thomas wrote, "District judges have no obligation to act as counsel or paralegal to pro se litigants." Five justices joined Thomas' opinion, while two others concurred in his judgment.

Maryland v. Pringle

Mon, 03 Nov 2003 13:00:00 +0000

Case Basics

Docket No.

02-809

Petitioner

Maryland

Petitioner Type

Petitioner

Respondent

Joseph Jermaine Pringle

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

540 U.S. 366 (2003)

Granted

Monday, March 24, 2003

Argued

Monday, November 3, 2003

Decided

Monday, December 15, 2003

Advocates

Gary E. Bair (argued the cause for Petitioner)

Sri Srinivasan (argued the cause for Petitioner, on behalf of the United States, as amicus curiae)

Nancy S. Forster (argued the cause for Respondent)

Facts of the Case

A police officer stopped a car for speeding, searched the car, and seized money from the glove compartment and cocaine from behind the back-seat armrest. The officer arrested the car's three occupants after they denied ownership of the drugs and money. A state court sentenced Pringle, the front- seat passenger, for possessing and intending to distribute cocaine after he signed a written confession. The state appellate court reversed the conviction, holding that the mere finding of cocaine in the back armrest when Pringle was in the front-seat of a car being driven by its owner was insufficient to establish probable cause for arrest for possession.

Question

Does an arrest of a front-seat passenger in a car driven by its owner, after police find cocaine in the car's back armrest, lack probable cause and violate the Fourth Amendment's prohibition of unreasonable searches and seizures?

Conclusion

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

No. In a unanimous opinion delivered by Chief Justice William Rehnquist, the Court ruled that because the officer had probable cause to arrest Pringle, the arrest did not violate the Fourth Amendment. The Court reasoned that "a reasonable officer could conclude that there was probable cause to believe that Pringle committed the crime of possession of cocaine."

Kontrick v. Ryan

Mon, 03 Nov 2003 13:00:00 +0000

Case Basics

Docket No.

02-819

Petitioner

Andrew J. Kontrick

Petitioner Type

Petitioner

Respondent

Robert A. Ryan

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

540 U.S. 443 (2004)

Granted

Monday, April 28, 2003

Argued

Monday, November 3, 2003

Decided

Wednesday, January 14, 2004

Advocates

E. King Poor (argued the cause for Petitioner)

Kent L. Jones (argued the cause for Respondent, on behalf of the United States, as amicus curiae)

James R. Figliulo (argued the cause for Respondent)

Facts of the Case

Andrew Kontrick filed for bankruptcy after he and his partner, Robert Ryan, dissolved their plastic surgery practice. Ryan notified the court that Kontrick owed him money before the 60-day filing deadline set by Bankruptcy Rule 4004. More than three months later (after the deadline for filing had passed) Ryan filed an amended complaint charging that Kontrick was diverting paychecks into his wife's account so that he wouldn't have to pay Ryan. Ryan's attorneys claimed that they were not making a new claim - the diversion had been alluded to in other court documents - but that they were merely refocusing the judge's attention. Furthermore, they argued that the deadline for filing could be - and had been - waived by the judge. Kontrick's attorneys, on the other hand, argued that the amended complaint was a new filing and that the deadlines for filing could not be waived. The bankruptcy court ruled for Ryan. The district court and a Seventh Circuit Court of Appeals panel both affirmed, holding that the deadline was subject to waiver.

Question

Are the deadlines established by Bankruptcy Rule 4004 "jurisdictional" - that is, do they trump other considerations no matter when they are raised?

Conclusion

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

No. In a unanimous opinion delivered by Justice Ruth Bader Ginsburg, the Court held that Kontrick lost the right to invoke Rule 4004's time limitation because he did so after the bankruptcy court reached the merits of Ryan's objection. The Court rejected Kontrick's claim that Rule 4004 is "jurisdictional" and that it trumps other considerations whenever raised in proceedings.

Hibbs v. Winn

Tue, 20 Jan 2004 13:00:00 +0000

Case Basics

Docket No.

02-1809

Petitioner

J. Elliott Hibbs, Director, Arizona Department of Revenue

Petitioner Type

Petitioner

Respondent

Kathleen M. Winn, et al.

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

542 U.S. 88 (2004)

Granted

Tuesday, September 30, 2003

Argued

Tuesday, January 20, 2004

Decided

Monday, June 14, 2004

Advocates

Marvin S. Cohen (argued the cause for Respondents)

Thomas G. Hungar (argued the cause for Petitioner, on behalf of the United States, as amicus curiae)

Samuel Goddard (argued the cause for Petitioner)

Facts of the Case

Several Arizona residents challenged in federal district court an Arizona statute that allows tax credits for money spent toward parochial schools. They alleged that the statute violates the religious establishment clause of the U.S. Constitution's First Amendment.

The district court dismissed the case and ruled that it lacked jurisdiction for two reasons: First, the federal Tax Injunction Act (TIA) prohibits federal district courts from ruling on the "assessment, levy or collection of any tax under state law where a plain, speedy and efficient remedy may be had in the courts of such state." And second, the court pointed to the comity doctrine - that is, the deference that federal courts should generally give to state tax laws. The Ninth Circuit Court of Appeals reversed, ruling that neither the TIA nor comity place the case outside federal jurisdiction. The court reasoned that the TIA was inapplicable because invalidating a tax credit would not harm Arizona's ability to raise revenue.

Question

Do the federal Tax Injunction Act and comity principles require federal district courts to dismiss (for lack of jurisdiction) constitutional challenges to state tax credits that directly affect a state's tax system?

Conclusion

Decision: 5 votes for Winn, 4 vote(s) against
Legal provision: 28 U.S.C. 1341

No. In a 5-to-4 decision written by Justice Ruth Bader Ginsburg, the Court held that the intention of the Tax Injunction Act (TIA) was to prevent taxpayers from trying to avoid their state taxes through federal litigation. TIA was not intended, however, to prevent all federal interference with state taxation. Justice Ginsburg wrote, "Third-party suits not seeking to stop the collection of a tax imposed on plaintiffs were outside Congress' purview. ... Nowhere does the [legislative] history announce a sweeping congressional direction to prevent federal-court interference with all aspects of state tax administration." (emphasis original) Establishment clause challenges to state tax exemptions for religious eduction could therefore be challenged without violating TIA.

General Dynamics Land Systems Inc. v. Cline

Wed, 12 Nov 2003 13:00:00 +0000

Case Basics

Docket No.

02-1080

Petitioner

General Dynamics Land Systems, Inc.

Petitioner Type

Petitioner

Respondent

Dennis Cline, et al.

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

540 U.S. 581 (2004)

Granted

Monday, April 21, 2003

Argued

Wednesday, November 12, 2003

Decided

Tuesday, February 24, 2004

Advocates

Paul D. Clement (argued the cause for Respondent, on behalf of the United States, as amicus curiae)

Mark W. Biggerman (argued the cause for Respondent)

Donald B. Verrilli, Jr. (argued the cause for Petitioner)

Facts of the Case

General Dynamics Land Systems renegotiated its union contract to provide full health care benefits only to retirees who were more than 50 years old by a July 1, 1997, deadline. Union member Dennis Cline fell two years short of 50 at the time of the deadline and was excluded permanently from receiving health benefits.

Cline - along with 196 other 40-to 49-year-old employees - filed suit against General Dynamics under the Age Discrimination in Employment Act of 1967 (ADEA). ADEA protects workers over 40 from age discrimination. Since the contract excluded workers between the ages of 40 and 49, Cline alleged that providing benefits only to retirees 50 and up was illegal age discrimination.

A U.S. district court in Ohio rejected Cline's claims. The court ruled that the ADEA does not recognize claims for "reverse discrimination" or preferential treatment for older people within the same over-40 class. Cline appealed and the U.S. Court of Appeals for the Sixth Circuit reversed. The court ruled that General Dynamics was guilty of plain age discrimination, since the ADEA protects all persons over 40 from age discrimination by their employers.

Question

Does the Age Discrimination in Employment Act (1967) prohibit "reverse discrimination" against workers over 40 (e.g., providing more favorable employer benefits to workers over 50 than to younger workers who are still over 40)?

Conclusion

Decision: 6 votes for General Dynamics Land Systems Inc., 3 vote(s) against
Legal provision: Age Discrimination in Employment (ADEA)

No. Justice David H. Souter delivered the Court's 6-3 opinion that the Age Discrimination in Employment Act's "text, structure, purpose, history, and relationship to other federal statutes show that the statute does not mean to stop an employer from favoring an older employee over a younger one." The Court cited a long-held understanding of the "ADEA as a remedy for unfair preference based on relative youth, leaving complaints of the relatively young outside the statutory concern." The Court also noted the findings section of the act included no evidence of younger workers being discriminated against in favor of older workers. Further "[i]f Congress had been worrying about protection the younger against the older, it would not likely have ignored everyone under 40."

Engine Mfrs. Assoc. v. South Coast Air Quality

Wed, 14 Jan 2004 13:00:00 +0000

Case Basics

Docket No.

02-1343

Petitioner

Engine Manufacturers Association and Western States Petroleum Association

Petitioner Type

Petitioner

Respondent

South Coast Air Quality Management District, et al.

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

541 U.S. 246 (2004)

Granted

Monday, June 9, 2003

Argued

Wednesday, January 14, 2004

Decided

Wednesday, April 28, 2004

Advocates

Carter G. Phillips (argued the cause for Petitioners)

Theodore B. Olson (argued the cause for Petitioners, on behalf of the United States, as amicus curiae)

Seth P. Waxman (argued the cause for Respondents)

Facts of the Case

The Engine Manufacturers Association (EMA) sued the South Coast Air Quality Management District (SCAQMD) - established under the California Health and Safety Code - in federal district court. The EMA alleged that the Clean Air Act (CAA) preempted SCAQMD's "fleet rules" - rules that required new commercial vehicles to meet specific emissions standards - and that the rules were therefore illegal. The EMA pointed to section 209 of the act, which prohibits states from enforcing "any standard relating to the control of emissions from new motor vehicles." Reasoning that the regulations affected the standards at which engines could be sold, not the standards to which they must be manufactured, and finding that Congress's purpose was to protect manufactures from "having to build engines in compliance with a multiplicity of standards," the district court ruled that the CAA did not preempt California's fleet rules. The Ninth Circuit Court of Appeals affirmed.

Question

Does the Clean Air Act preempt local government regulations prohibiting the purchase of new motor vehicles with specified emission characteristics?

Conclusion

Decision: 8 votes for Engine Mfrs. Assoc., 1 vote(s) against
Legal provision: Clean Air

Probably. In an 8-to-1 opinion written by Justice Antonin Scalia, the Court ruled that distinguishing between rules governing the standards to which engines must be made and the standards at which they may be sold was unreasonable. Justice Scalia wrote, "A command ... that certain purchasers may buy only vehicles with particular emission characteristics is as much an 'attempt to enforce' a 'standard' as a command ... that a certain percentage of a manufacturer's sales volume must consist of such vehicles." Justice Scalia reserved judgment on the specific regulations at issue in the case, however, sending the case back to the district court for further proceedings consistent with the holding that regulating the standards engines must meet to be sold is no different from regulating the standards at which they must be manufactured.

Nelson v. Campbell

Mon, 29 Mar 2004 13:00:00 +0000

Case Basics

Docket No.

03-6821

Petitioner

David L. Nelson

Petitioner Type

Petitioner

Respondent

Donal Campbell, Commissioner, Alabama Department of Corrections, et al.

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

541 U.S. 637 (2004)

Granted

Monday, December 1, 2003

Argued

Monday, March 29, 2004

Decided

Monday, May 24, 2004

Advocates

Kevin C. Newsom (argued the cause for Respondents)

Bryan A. Stevenson (argued the cause for Petitioner)

Facts of the Case

David Nelson was sentenced to death for murder and scheduled for execution in 1997. A series of appeals and habeas petitions in federal court delayed the execution until 2002, when an 11th Circuit Court of Appeals panel unanimously rejected a claim dealing with the alleged violation of his Sixth Amendment right to an attorney. After the final appeal was rejected, Nelson was rescheduled for execution on October 9, 2003.

Nelson filed petition in federal district court alleging that the method of execution proposed by Alabama violated his Eighth Amendment protection against cruel and unusual punishment. Alabama had notified Nelson that, because of damage done to his veins by previous intravenous drug abuse, the execution procedure might require corrections officers to cut through muscles and fat in his arm to get access to a vein that could carry the toxins. He claimed that this was an inhumane method of execution and should therefore be barred. Further, he argued that the petition was not an appeal of his conviction or sentence (appeals of both were prohibited by U.S. Code Title 28, Section 2254, a federal law designed to limit the number of habeas corpus appeals by death row inmates) but rather a freestanding lawsuit challenging the constitutionality of the proposed execution procedure. Alabama countered that Nelson's appeal was intended only to prolong his life through procedural delays, exactly what the federal law was designed to prevent, and should therefore be thrown out.

The federal district court agreed with Alabama, holding that Nelson's appeal dealt not just with the procedure but with the sentence itself. It was therefore functionally equivalent to a habeas corpus petition, which was barred by Section 2254. A divided 11th Circuit Court of Appeals panel affirmed the decision. After the 11th Circuit declined to rehear the case as a whole (en banc), the U.S. Supreme Court issued a stay of execution and then accepted the case for appeal.

Question

Is a prisoner's appeal of the proposed procedure for his execution functionally equivalent to a habeas corpus petition and therefore barred by Title 28, Section 2254 of U.S. Code?

Conclusion

Decision: 9 votes for Nelson, 0 vote(s) against
Legal provision: Reconstruction Civil Rights Acts (42 USC 1983)

No. In an opinion by Justice Sandra Day O'Connor, the Court ruled unanimously that Nelson's suit dealt only with the proposed method of execution, not with his conviction or sentence, and was therefore different from a habeas corpus appeal. Nelson had a right to challenge the necessity of the procedure for his execution using the same legal approach he would have used to challenge the conditions of his prison. However, the Court declined to rule on whether the execution would be constitutional if the district court found that cutting through was indeed necessary, leaving that question for a case in which necessity had already been determined.

Vieth v. Jubelirer

Wed, 10 Dec 2003 13:00:00 +0000

Location

Pennsylvania General Assembly

225 N Capitol Building Harrisburg PA 17101

Harrisburg, PA 17101

United States

40° 15' 52.8156" N, 76° 53' 6.1296" W

See map: Google Maps

Case Basics

Docket No.

02-1580

Appellee

Robert C. Jubelirer, President of the Pennsylvania Senate, et al.

Petitioner Type

Appellee

Appellant

Richard Vieth, Norma Jean Vieth, and Susan Furey

Respondent Type

Appellant

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

541 U.S. 267 (2004)

Granted

Friday, June 27, 2003

Argued

Wednesday, December 10, 2003

Decided

Wednesday, April 28, 2004

Advocates

John P. Krill, Jr. (argued the cause for Appellees Jubelirer and Perzel)

Paul M. Smith (argued the cause for Appellants)

J. Bart DeLone (argued the cause for Appellees Cortes and Accurti)

Facts of the Case

After the 2000 census reduced the size of the Pennsylvania Congressional delegation by two members, the Republican-controlled state legislature passed a redistricting plan that clearly benefitted Republican candidates. Several members of the Democratic party sued in federal court, claiming that the plan was unconstitutional because it violated the one-person, one-vote principle of Article I, Section 2 of Constitution, the Equal Protection clause, the Privileges and Immunities clause, and the freedom of association.

The district court dismissed all but the Article I, Section 2 claim. It held that the voters bringing the suit had not proved that they would be denied representation, only that they would be represented by Republican officials. Because the plaintiffs (those bringing the suit) were not denied the right to vote, to be placed on the ballot box, to associate as a party, or to express their political opinions, their political discrimination claims failed.

However, the court found the act unconstitutional because it created districts with different numbers of voters, thereby violating the one-person, one-vote principle. Because the plaintiffs had shown that it was possible to create districts with smaller differences, and because the defendants had failed to justify the disparities resulting under their plan, it was therefore unconstitutional.

Question

Can voters affiliated with a political party sue to block implementation of a Congressional redistricting plan by claiming that it was manipulated for purely political reasons? Does a state violate the Equal Protection clause of the 14th Amendment when it disregards neutral redistricting principles (such as trying to avoid splitting municipalities into different Congressional districts) in order to achieve an advantage for one political party? Does a state exceed its power under Article I of the Constitution when it draws Congressional districts to ensure that a minority party will consistently win a super-majority of the state's Congressional seats?

Conclusion

Decision: 5 votes for Jubelirer, 4 vote(s) against
Legal provision: Article 1, Section 2, Paragraph 1: Composition of the House of Representatives

In a split decision that had no majority opinion, the Court decided not to intervene in this case because no appropriate judicial solution could be found. Justice Antonin Scalia, for a four-member plurality, wrote that the Court should declare all claims related to political (but not racial) gerrymandering nonjusticiable, meaning that courts could not hear them. Because no court had been able to find an appropriate remedy to political gerrymandering claims in the 18 years since the Court decided Davis v. Bandemer, 478 U.S. 109, which had held that such a remedy had not been found yet but might exist, Scalia wrote that it was time to recognize that the solution simply did not exist.

Justice Anthony Kennedy, however, wrote in his concurring opinion (which provided the deciding fifth vote for the judgment) that the Court should rule narrowly in this case that no appropriate judicial solution could be found, but not give up on finding one eventually.

Pennsylvania State Police v. Suders

Wed, 31 Mar 2004 13:00:00 +0000

Case Basics

Docket No.

03-95

Petitioner

Pennsylvania State Police

Petitioner Type

Petitioner

Respondent

Nancy Drew Suders

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

542 U.S. 129 (2004)

Granted

Monday, December 1, 2003

Argued

Wednesday, March 31, 2004

Decided

Monday, June 14, 2004

Advocates

Donald A. Bailey (argued the cause for Respondent)

John George Knorr, III (argued the cause for Petitioner)

Irving L. Gornstein (argued the cause for Petitioner, on behalf of the United States, as amicus curiae)

Facts of the Case

Nancy Drew Suders quit her job as a dispatcher for the Pennsylvania State Police in August 1998. She claimed that she had been sexually harassed by her supervisors since she got the job in March of that year, and that she had finally decided to quit after she was accused of theft, handcuffed, photographed and questioned. Two days before quitting, she had contacted the state police equal opportunity officer about the harassment, but did not file a report because, Suders claimed, the woman was unhelpful and unsympathetic.

Suders then filed suit in federal district court, charging that the harassment had forced her to quit. The district court judge, however, granted summary judgment to the state police before the case went to trial. He found that Suders had failed to use the internal procedures set up by the state police to deal with sexual harassment, and that she therefore could not bring suit unless the police had taken a "tangible employment action" that substantially changed her employment status. On appeal, a Third Circuit Court of Appeals panel overturned the district judge's decision, ruling that the harassment had been so bad that Suders had no choice but to quit. While the police had not fired Suders, they had been directly responsible for her resignation and therefore could not use her failure to file a report as a defense.

Question

When a supervisor makes a workplace environment so hostile (through sexual harassment) that an employee has no choice but to quit, may the employee bring suit even if she did not use the internal procedures established by the employer to report sexual harassment claims?

Conclusion

Decision: 8 votes for Pennsylvania State Police, 1 vote(s) against
Legal provision: Civil Rights Act of 1964, Title VII

Yes. In an 8-to-1 decision written by Justice Ruth Bader Ginsburg, the Court ruled that an employee faced with a situation in which a "reasonable person ... would have felt compelled to resign" could bring suit even if she had not filed a report with the employer before resigning. Her employer, however, could use her failure to file a report, along with evidence of the safeguards it had in place to prevent harassment, in its defense. If it could prove that she had not attempted to prevent the harassment, and that the safeguards in place would have prevented it if she had, the employer would not be liable.

Baldwin v. Reese

Mon, 08 Dec 2003 13:00:00 +0000

Case Basics

Docket No.

02-964

Petitioner

George H. Baldwin

Petitioner Type

Petitioner

Respondent

Michael Reese

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

541 U.S. 27 (2004)

Granted

Tuesday, May 27, 2003

Argued

Monday, December 8, 2003

Decided

Tuesday, March 2, 2004

Advocates

Dennis Balske (argued the cause for Respondent)

Hardy Myers (argued the cause for Petitioner)

Facts of the Case

A state trial court sentenced Reese to 33 years in prison. An appellate court lowered the sentence to 24 years. In another appeal to a state appellate court, Reese argued his federal Sixth Amendment right to effective counsel was violated at trial and on appeal. The appellate court refused to reverse Reese's sentence. Reese appealed to the state supreme court and failed.

Reese appealed to a U.S. District Court. Ruling against Reese, the Court held that Reese did clearly say to the state supreme court his claims were federal. Federal law requires state prisoners to "fairly present" federal constitutional claims in each state court before appealing to federal courts. A federal appellate court reversed, ruling that the state supreme court had had the opportunity to read the state appellate court decision - had the court done this, it would have understood Reese's claims were federal.

Question

Federal law requires state prisoners to "fairly present" their allegations of federal constitutional violations to state courts before turning to federal courts. To meet this requirement, do prisoners need to specifically say their claims are federal constitutional claims?

Conclusion

Decision: 8 votes for Baldwin, 1 vote(s) against
Legal provision: 28 USC 2241-2255 (habeas corpus)

Yes. In an 8-1 opinion delivered by Justice Stephen Breyer, the Court held that Reese did not "fairly present" his Sixth Amendment ineffective counsel claim to state courts. Federal law thus barred Reese from turning to federal courts. The state court could have understood Reese's claims were federal if the court had read the lower court opinion. However, a state prisoner does not "fairly present" a federal claim to a state court if that court must read beyond what the prisoner files. There is no federal requirement that courts read lower court opinions.

Tennessee Student Assistance Corporation v. Hood

Mon, 01 Mar 2004 13:00:00 +0000

Case Basics

Docket No.

02-1606

Petitioner

Tennessee Student Assistance Corporation

Petitioner Type

Petitioner

Respondent

Pamela L. Hood

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

541 U.S. 440 (2004)

Granted

Tuesday, September 30, 2003

Argued

Monday, March 1, 2004

Decided

Monday, May 17, 2004

Advocates

Daryl J. Brand (argued the cause for Petitioner)

Leonard H. Gerson (argued the cause for Respondent)

Facts of the Case

Pamela Hood had an outstanding debt to the Tennessee Student Assistance Corporation, a loan-granting institution established by the state, when she filed for bankruptcy. The state objected to her request that the debt be forgiven ("discharged" in the terms of bankruptcy law) by the federal bankruptcy court, arguing that to discharge the debt would violate the state's sovereign immunity (that is, its right not to be sued). Hood countered that the Federal Rules of Bankruptcy Procedure allow student loan debts to be discharged if the bankruptcy filer can demonstrate that they will suffer "undue hardship" if the debt is not forgiven, and that this congressional permission is a constitutional waiver of state sovereign immunity because it falls under the power granted to Congress by the Bankruptcy Clause (Article I, Section 8 of the U.S. Constitution).

The bankruptcy court sided with Hood, finding that Congress had acted constitutionally in waiving the states' sovereign immunity. The Sixth Circuit Bankruptcy Appellate Panel affirmed, as did a normal panel of the Sixth Circuit.

Question

Does the Bankruptcy Clause (Article I Section 8 of the U.S. Constitution) give Congress the power to waive a state's sovereign immunity in matters pertaining a federal bankruptcy court's forgiveness of debt owed to the state?

Conclusion

Decision: 7 votes for Hood, 2 vote(s) against
Legal provision: Amendment 11: Eleventh Amendment

In a per curiam (unsigned) opinion, the Court declined to reach the question of whether the Bankruptcy Clause gives Congress the power to waive a state's sovereign immunity. Instead, the Court ruled that discharging a debt owed to a state in a bankruptcy procedure is different from a suit and therefore not barred by sovereign immunity. "A bankruptcy court is able to provide the debtor a fresh start in this manner ... because the court's jurisdiction is premised on the debtor and his estate, and not on the creditors," wrote the Court. That is, the discharge of debt by a bankruptcy court is not a personal suit against a state (which would violate sovereign immunity) but instead merely a modification of a debtor's estate that incidentally affects a state. As such, it is permissible even without Congressional waiver of sovereign immunity.

Olympic Airways v. Husain

Wed, 12 Nov 2003 13:00:00 +0000

Case Basics

Docket No.

02-1348

Petitioner

Olympic Airways

Petitioner Type

Petitioner

Respondent

Rubina Husain, Individually, and as Personal Representative of the Estate of Abid M. Hanson, Deceased, et al.

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

540 U.S. 644 (2004)

Granted

Tuesday, May 27, 2003

Argued

Wednesday, November 12, 2003

Decided

Tuesday, February 24, 2004

Advocates

Barbara B. McDowell (argued the cause for Respondents)

Andrew J. Harakas (argued the cause for Petitioner)

H. Bartow Farr, III (argued the cause for Respondents)

Facts of the Case

Abid Hanson was allergic to second-hand smoke. On an Olympic Airways flight, he and his wife, Rubina Husain, sat in non-smoking seats. However, because the seats were close to the smoking section, Mrs. Husain requested she and her husband be moved. Her request was denied twice, even after the smoke began bothering Hanson. Hanson died during the flight. Husain filed suit in California federal district court. She sought damages under Article 17 of the Warsaw Convention, which allows damages recovery for international air travelers for accidents on airplanes. The district court agreed that Hanson's death was an ""accident"" as defined by the convention and awarded Husain $1.4 million. The 9th Circuit Court of Appeals affirmed.

Question

If a passenger's pre-existing medical condition is aggravated by exposure to normal airplane conditions, is this an "accident" under the Warsaw Convention's Article 17 (for which the airline is responsible)?

Conclusion

Decision: 6 votes for Husain, 2 vote(s) against
Legal provision: Treaty

Yes. Justice Clarence Thomas delivered the Court's 6-2 opinion that the events on the airplane were an "accident" under the Warsaw Convention's Article 17. The Court cited its 1985 decision in Air France v. Saks, in which it decided any "injury is the product of a chain of causes" and that an accident occurs when "some link in the chain was an unusual or unexpected event external to the passenger." The Court rejected Olympic Airways' argument that only the cigarette smoke was relevant and that no "accident" took place because the flight attended simply did not act. The flight attendant's refusal three times to reseat Husain was a "link in the chain" of causes leading to his death and the attendant's rejection of an explicit request for assistance was an "event."

Barnhart v. Thomas

Tue, 14 Oct 2003 13:00:00 +0000

Case Basics

Docket No.

02-763

Petitioner

Jo Anne B. Barnhart, Commissioner of Social Security

Petitioner Type

Petitioner

Respondent

Pauline Thomas

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

540 U.S. 20 (2003)

Granted

Monday, February 24, 2003

Argued

Tuesday, October 14, 2003

Decided

Wednesday, November 12, 2003

Advocates

Jeffrey A. Lamken (argued the cause for Petitioner)

Abraham S. Alter (argued the cause for Respondent)

Facts of the Case

After a heart attack left her unable to continue working as a housekeeper in the late 1980s, Pauline Thomas took a job as an elevator operator. By the mid- 1990s, however, Thomas's job and others like it were eliminated as elevators became automated. Thomas applied for Social Security disability benefits because she could not do other work. The Social Security Administration (SSA), however, rejected her claim because, it said, she was still able to perform the duties of her former position. The fact that it was nearly impossible to find such a position, the SSA held, did not entitle her to benefits under disability law. An administrative judge and a federal district court both upheld the SSA's position, but the Third Circuit Court of Appeals reversed, holding that "a claimant's previous work must be substantial gainful work which exists in the national economy."

Question

Are persons eligible for Social Security disability benefits if they are still able to perform their jobs, but the jobs no longer exists in meaningful numbers in the national economy?

Conclusion

Decision: 9 votes for Barnhart, 0 vote(s) against
Legal provision: Social Security, as amended, including Social Security Disability Benefits Reform Act, but excluding Medicare, Medicaid, Supplemental Security Income, and Aid to Families with Dependent Children

No. In a unanimous opinion authored by Justice Antonin Scalia, the Court held that the SSA's decision had been a reasonable interpretation of the statute and was therefore entitled to deference under Chevron U.S.A. Inc. v. Natural Resources Defense Council, Inc., 467 U.S. 837. Justice Scalia wrote, "The proper Chevron inquiry is not whether an agency construction can give rise to undesirable results... but whether... the agency construction is reasonable. Here, the SSA's authoritative decision satisfies that test."

Austria v. Altmann

Wed, 25 Feb 2004 13:00:00 +0000

Case Basics

Docket No.

03-13

Petitioner

Republic of Austria, et al.

Petitioner Type

Petitioner

Respondent

Maria V. Altmann

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

541 U.S. 677 (2004)

Granted

Tuesday, September 30, 2003

Argued

Wednesday, February 25, 2004

Decided

Monday, June 7, 2004

Advocates

Scott P. Cooper (argued the cause for Petitioners)

E. Randol Schoenberg (on behalf of the Respondent)

Thomas G. Hungar (argued the cause for Petitioners, on behalf of the United States, as amicus curiae)

Facts of the Case

Maria Altmann learned that the valuable artwork owned by her uncle had been either seized by the Nazi's or taken by Austria after World War II. She sued in American federal court to recover six paintings from the Austrian Gallery. She filed the suit under the Foreign Sovereign Immunities Act of 1976 (FSIA), which allows suits against foreign nations in cases involving "rights to property taken in violation of international law." Austria, however, claimed that the FSIA did not apply in this case because the paintings were taken in the 1940s, when the United States embraced a different - and more extensive - idea of immunity that would have barred the suit. Because the Act did not explicitly state that it applied retroactively (that is, to actions taken before it was passed) Austria claimed that it was entitled to this broader definition of immunity.

The district court sided with Altmann, holding that the FSIA applied retroactively. A Ninth Circuit Court of Appeals panel affirmed.

Question

Does the Foreign Sovereign Immunities Act of 1976 apply to actions that took place before its passage?

Conclusion

Decision: 6 votes for Altmann, 3 vote(s) against
Legal provision: 28 U.S.C. 1605

Yes. In a 6-to-3 decision written by Justice John Paul Stevens, the Court ruled that, while the Foreign Sovereign Immunities Act of 1976 does not explicitly state that it should be applied to actions that took place before its passage, there are strong indications in the text of the statute that Congress intended it to apply retroactively. Justice Stevens wrote that, under the Act, immunity "claims are 'henceforth' to be decided by the courts. ... [T]his language suggests Congress intended courts to resolve all such claims 'in conformity with the principles set forth' in the Act, regardless of when the underlying conduct occurred."

Muhammad v. Close

Mon, 01 Dec 2003 13:00:00 +0000

Case Basics

Docket No.

02-9065

Petitioner

Shakur Muhammad, aka John E. Mease

Petitioner Type

Petitioner

Respondent

Mark Close

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

540 U.S. 749 (2004)

Granted

Monday, June 16, 2003

Argued

Monday, December 1, 2003

Decided

Wednesday, February 25, 2004

Advocates

Thomas L. Casey (argued the cause for Respondent)

Corinne A. Beckwith (argued the cause for Petitioner)

Facts of the Case

Prison officials sentenced Muhammad, a state prisoner, to seven days of special detention and 30 days of restricted privileges for insolence toward Close, a prison guard. Muhammad filed suit with a magistrate judge under section 1983 of the Civil Rights Act of 1871, seeking $10,000 in damages. Muhammad alleged Close had charged him with threatening behavior in retaliation for other proceedings against Close. Muhammad did not challenge his insolence conviction or punishment. The magistrate judge ruled that Muhammad lacked evidence proving Close acted in retaliation. The U.S. District Court agreed.

The U.S. Court of Appeals affirmed the ruling for a different reason, citing the U.S. Supreme Court decision Heck v. Humphrey (1994). In Heck the Court held that when a prisoner seeks damages in a case that questions his sentence, the prisoner must first have successfully challenged the sentence itself or the conviction itself. The Court of Appeals held that because Muhammad's damages case questioned his sentence, he must first successfully appeal the sentence itself. Going further the Court of Appeals held that Heck applies to all challenges to prison disciplinary proceedings.

Question

Does the U.S. Supreme Court's decision in Heck v. Humphrey (1994) require that prisoners who challenge prison disciplinary proceedings - but whose suits do not question their sentences' validity - first successfully challenge their sentences?

Conclusion

Decision: 9 votes for Close, 0 vote(s) against
Legal provision: Reconstruction Civil Rights Acts (42 USC 1983)

No. In a unanimous per curiam opinion, the Court ruled that prisoners - whose suits do not question their sentences - do not need to successfully challenge those sentences before challenging prison disciplinary proceedings. The Court rejected the argument that Heck necessarily requires successful sentence appeals before any challenges can be made to prison disciplinary proceedings. Muhammad's suit sought damages for prison disciplinary proceedings but in no way challenged his sentence.

Doe v. Chao

Wed, 03 Dec 2003 13:00:00 +0000

Case Basics

Docket No.

02-1377

Petitioner

Buck Doe

Petitioner Type

Petitioner

Respondent

Elaine L. Chao, Secretary of Labor

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

540 U.S. 614 (2004)

Granted

Friday, June 27, 2003

Argued

Wednesday, December 3, 2003

Decided

Tuesday, February 24, 2004

Advocates

Jack William Campbell IV (argued the cause for Petitioner)

Malcolm L. Stewart (argued the cause for Respondent)

Facts of the Case

Seven coal miners sued the Department of Labor, claiming that the department had violated the federal Privacy Act and the right to privacy found in the federal Constitution by releasing their social security numbers (SSNs). The Privacy Act stated that any "person entitled to recovery" in a suit against the government for a violation of privacy would be awarded "actual damages sustained by the individual... but in no case... [would the damages awarded be] less than the sum of $1000" and attorney fees.

The miners argued that all they needed to prove in order to receive the $1000 minimum award was that the government had violated their privacy by releasing their SSNs; they did not need to prove that they had suffered actual damages. They maintained that the inclusion of "actual damages" in the act was only intended to limit the size of judgments awarded against the government, not to require proof of actual damage. The government argued that the act required the miners to prove that they had been harmed by the government's violation of their privacy.

The district court ruled in favor of the government. A divided Fourth Circuit Court of Appeals panel affirmed.

Question

Does the federal Privacy Act require that people prove they suffered "actual damage" stemming from the government's violation of their privacy rights in order to win damages in a suit against the government?

Conclusion

Decision: 6 votes for Chao, 3 vote(s) against
Legal provision: 5 U.S.C. 552

Yes. Justice David Hackett Souter delivered the Court's 6-3 opinion that the Privacy Act requires plaintiffs prove actual damages to qualify for the minimum statutory award of $1000. The Court reasoned that "a straightforward textual analysis" of the Privacy Act shows that the statute guarantees the $1000 minimum for victims of willful Privacy Act violations only in relation to "actual damages sustained." Individuals subjected to an adverse effect - like the miners in this case - have "injury enough to open the courthouse door, but without more" have "no cause of action for damages under the Privacy Act."

Thornton v. United States

Wed, 31 Mar 2004 13:00:00 +0000

Case Basics

Docket No.

03-5165

Petitioner

Marcus Thornton

Petitioner Type

Petitioner

Respondent

United States

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

541 U.S. 615 (2004)

Granted

Monday, November 3, 2003

Argued

Wednesday, March 31, 2004

Decided

Monday, May 24, 2004

Advocates

Frank W. Dunham, Jr. (argued the cause for Petitioner)

Gregory G. Garre (argued the cause for Respondent)

Facts of the Case

Marcus Thornton was stopped after getting out of his vehicle by a police officer who had noticed that the license plate on Thornton's Lincoln Town Car belonged to a Chevy two-door car. During his conversation with Thornton, the officer asked if he could search him. During the search he found two bags of drugs. The officer arrested Thornton, then searched his vehicle (which Thornton had already exited by the time the police officer spoke with him, though the officer had seen him exit it). In the vehicle the officer found a gun.

Thornton was convicted of drug and firearms offenses. On appeal, he moved to have the gun dismissed as evidence because, he claimed, it had been found as the result of an unconstitutional search. He argued that the officer had contacted him after he had left the vehicle and that the search therefore did not fall within the "search incident to arrest" exception to the Fourth Amendment warrant requirement (the exception allows police to search the person being arrested and the area "within his immediate control").

A Fourth Circuit Court of Appeals panel rejected his argument, holding that requiring officers to signal their intent to arrest a person before he exited his vehicle would be dangerous because it would give him a chance to get any weapons in the vehicle or to use the vehicle to get away or run over the officers.

Question

Under the "search incident to arrest" exception to the Fourth Amendment, may police search the vehicle of a person they have arrested if they did not make contact with him until after he left the vehicle?

Conclusion

Decision: 7 votes for United States, 2 vote(s) against
Legal provision: Amendment 4: Fourth Amendment

Yes. In a 7-to-2 decision, the Court ruled that forcing officers to decide whether a suspect had noticed them before exiting the car (with the understanding that only if he had could the car be searched) would be too subjective and leave officers uncertain of whether they could perform searches. Further, it found that weapons or contraband inside a vehicle could still be easily accessed by someone who had just exited it, providing the same reason for searching the vehicle that was present in cases where suspects were arrested while still inside it (that is, the possibility that illegal material would be destroyed or officers attacked with concealed weapons). Chief Justice Rehnquist, in the majority opinion, wrote, "Once an officer determines there is probable cause to make an arrest, it is reasonable to allow officers to ensure their safety and to preserve evidence by searching the entire passenger compartment."

Blakely v. Washington

Tue, 23 Mar 2004 13:00:00 +0000

Case Basics

Docket No.

02-1632

Petitioner

Ralph Howard Blakely, Jr.

Petitioner Type

Petitioner

Respondent

Washington

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

542 U.S. 296 (2004)

Granted

Monday, October 20, 2003

Argued

Tuesday, March 23, 2004

Decided

Thursday, June 24, 2004

Advocates

John Knodell, III (argued the cause for Respondent)

Jeffrey L. Fisher (argued the cause for Petitioner)

Michael R. Dreeben (argued the cause for Respondent, on behalf of the United States, as amicus curiae)

Facts of the Case

Blakely pleaded guilty to the kidnapping of his estranged wife and the facts admitted in his plea supported a maximum sentence of 53 months. Washington state law allows a judge to impose a sentence above the standard range if he finds "substantial and compelling reasons" for doing so that were not computed into the standard range sentence. The judge in this case imposed an "exceptional" sentence of 90 months after determining Blakely had acted with "deliberate cruelty."

Blakely appealed, arguing that this sentencing procedure deprived him of his federal Sixth Amendment right to have a jury determine beyond a reasonable doubt all facts legally essential to his sentence. A state appellate court affirmed the sentence and the state supreme court denied review.

Question

Does a fact (other than a prior conviction) necessary to increase a sentence beyond the statutory standard range need to be proved by a jury and beyond a reasonable doubt?

Conclusion

Decision: 5 votes for Blakely, 4 vote(s) against
Legal provision: Right to Trial By Jury

In a 5-4 decision delivered by Justice Antonin Scalia, the Court held that an exceptional sentence increase based on the judge's determination that Blakely had acted with "deliberate cruelty" violated Blakely's Sixth Amendment right to trial by jury. Citing its decision in Apprendi v. New Jersey, the Court ruled that facts increasing the penalty for a crime beyond the prescribed statutory maximum must be submitted to a jury and and proved beyond a reasonable doubt. Dissents by Justice Sandra Day O'Connor, Anthony Kennedy and Justice Stephen Breyer argued the ruling will diminish legislatures' ability to set uniform sentencing guidelines.

Mitchell v. Esparza

Sat, 27 Apr 2013 20:11:40 +0000

Case Basics

Docket No.

02-1369

Petitioner

Mitchell

Petitioner Type

Petitioner

Respondent

Esparza

Respondent Type

Respondent

Decided By

Rehnquist Court (1994-2005)

Opinion

540 U.S. 12 (2003)

Decided

Monday, November 3, 2003

Facts of the Case

Gregory Esparza murdered a store clerk during a robbery in Ohio. He was convicted and sentenced to death for the murder. He appealed the death sentence, arguing that the prosecutors had failed to charge him as the "principle offender" in the murder and that he was therefore ineligible for the death penalty under Ohio law. The Ohio Court of Appeals rejected this argument, holding that, because Esparza had been the only person charged in the crime, it would have been redundant (and therefore unnecessary) to charge him as the "principle offender."

Esparza then filed a second appeal before the Court of Appeals, this time arguing that he had received ineffective assistance of counsel during his first appeal. He specifically cited his attorney's failure to argue that the state had violated the Eighth Amendment's prohibition on cruel and unusual punishment by not following the "letter of the law" in its sentencing. The court again rejected Esparza's argument, referring back to its first decision and holding that the prosecutor's error had been harmless and was therefore not grounds for overturning the sentence. The defense attorney's failure to raise Eighth Amendment objections to the prosecutor's error, therefore, was also harmless.

Esparza then filed a petition for a writ of habeas corpus in federal district court, raising the same ineffective assistance of counsel claim. In response, Ohio argued that the Ohio Appeals Court's decision had not violated "clearly established Federal law" and that the district court therefore could not overturn the sentence. The court sided with Esparza, however, holding that the state's failure to follow its sentencing laws violated the Eighth Amendment. The attorney's failure to raise the Eighth Amendment claim in the first appeal, therefore, was not harmless and could serve as grounds for overturning the sentence. A Sixth Circuit Court of Appeals panel affirmed the federal district court's opinion.

Question

Did the Ohio Appeals Court violate "clearly established Federal law" by deciding that the prosecution's failure to charge Esparza as the "principle offender" in a murder was harmless and therefore not grounds for overturning his death sentence?

Conclusion

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

No. In a per curiam decision, the Supreme Court held that the Ohio Appeals Court had not acted unreasonably or violated "clearly established Federal law" when it decided that the prosecutor's error was harmless. The federal courts, therefore, did not have authority to overturn the death sentence.

National Archives and Records Administration v. Favish

Wed, 03 Dec 2003 13:00:00 +0000

Case Basics

Docket No.

02-954

Petitioner

National Archives and Records Administration

Petitioner Type

Petitioner

Respondent

Allan J. Favish, et al.

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

541 U.S. 157 (2004)

Granted

Monday, May 5, 2003

Argued

Wednesday, December 3, 2003

Decided

Tuesday, March 30, 2004

Advocates

Patricia A. Millett (argued the cause for Petitioner)

James Hamilton (argued the cause for Respondents Anthony and Moody in support of petitioner)

Allan J. Favish (argued the cause for Respondents)

Facts of the Case

Vincent Foster, a high-ranking White House lawyer involved in the investigation of possible fraud by the Clinton family in the Whitewater real estate venture, was found dead in a Virginia park. Two government investigations subsequently found that the death had been a suicide. Allan Favish questioned the findings of the government investigations, claiming that they were part of a government cover-up of murder. Under the Freedom of Information Act, Favish requested access to 150 photos of Foster's body in the park and during the autopsy. He later reduced his request to 129 photos.

The government initially denied him access to all the photos, but eventually gave him access to 118 of them. It withheld the rest, arguing that the privacy interest of Foster's family members in relation to Foster's death trumped the public interest served by providing Favish access to the photos. The government stated that the photos were very graphic and that releasing them would upset the family. Favish countered by arguing that the family did not have a relevant privacy interest; the only person whose privacy interests would be violated by the release of the photos was Foster, Favish argued, and Foster's death had rendered him incapable of exercising that interest.

After a series of appeals in which a Ninth Circuit panel held that the Foster family's right to privacy was relevant to the case but that the district court must look at the specific photos in order to weigh the privacy rights against Favish's right to access government information, the Ninth Circuit eventually decided that Favish should be given access to all but four of the photos. The government, joined by the Foster family, appealed the decision to the Supreme Court.

Question

Do family members of a man who apparently committed suicide have a privacy right that justifies the government's withholding autopsy photos from a request for information under the Freedom of Information Act?

Conclusion

Decision: 9 votes for National Archives and Records Administration, 0 vote(s) against
Legal provision: Freedom of Information, Sunshine, or Privacy Act

Yes. In a unanimous opinion delivered by Justice Anthony Kennedy, the Court held that the Foster family's interest in privacy outweighed the public interest in seeing pictures from Vincent Foster's death scene. The public interest could only trump privacy interests if Favish could present evidence that the government might have acted improperly. Favish failed to do so. The Court acknowledged that citizens seeking access to documents under the Freedom of Information Act normally need not explain why they seek the information. The act, however, exempts from disclosure records that would present an unwarranted invasion of privacy. In ruling that the act protected the privacy of the Foster family, the Court rejected Favish's argument that the act only protected Vincent Foster's privacy (an interest that Favish argued died with Foster).

McConnell v. Federal Election Commission

Mon, 08 Sep 2003 13:00:00 +0000

Case Basics

Docket No.

02-1674

Petitioner

Federal Election Commission

Respondent

Mitch McConnell, United States Senator, et al.

Consolidation

National Rifle Association (NRA), et al. v. Federal Election Commission (FEC), No. 02-1675

Federal Election Commission (FEC), et al. v. Mitch McConnell, United States Senator, et al., No. 02-1676

John McCain, United States Senator, et al. v. Mitch McConnell, United States Senator, et al., No. 02-1702

Republican National Committee, et al. v. Federal Election Commission (FEC), No. 02-1727

National Right to Life Committee, Inc., et al. v. Federal Election Commission (FEC), No. 02-1733

American Civil Liberties Union (ACLU) v. Federal Election Commission (FEC), No. 02-1734

Victoria Jackson Gray Adams, et al. v. Federal Election Commission (FEC), No. 02-1740

Ron Paul, United States Congressman, et al. v. Federal Election Commission (FEC), No. 02-1747

California Democratic Party, et al. v. Federal Election Commission (FEC), No. 02-1753

American Federation of Labor and Congress of Industrial Organizations (AFL-CIO), et al. v. Federal Election Commission (FEC), No. 02-1755

Chamber of Commerce of the United States v. Federal Election Commission (FEC), No. 02-1756

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

540 U.S. 93 (2003)

Granted

Thursday, June 5, 2003

Argued

Monday, September 8, 2003

Decided

Wednesday, December 10, 2003

Advocates

Paul D. Clement (argued the cause for Defendant FEC)

Bobby R. Burchfield (argued the cause for Plaintiffs Political Party)

Kenneth W. Starr (argued the cause for Plaintiffs McConnell, et al.)

Jay A. Sekulow (argued the cause for Plaintiffs Echols, et al.)

Theodore B. Olson (argued the cause for Defendant FEC)

Laurence E. Gold (argued the cause for Plaintiffs AFL-CIO)

Seth P. Waxman (argued the cause for Defendant Intervenor)

Floyd Abrams (argued the cause for Plaintiffs McConnell, et al.)

Facts of the Case

In early 2002, a many years-long effort by Senators John McCain and Russell Feingold to reform the way that money is raised for--and spent during-- political campaigns culminated in the passage of the Bipartisan Campaign Finance Reform Act of 2002 (the so-called McCain-Feingold bill). Its key provisions were a) a ban on unrestricted ("soft money") donations made directly to political parties (often by corporations, unions, or well-healed individuals) and on the solicitation of those donations by elected officials; b) limits on the advertising that unions, corporations, and non-profit organizations can engage in up to 60 days prior to an election; and c) restrictions on political parties' use of their funds for advertising on behalf of candidates (in the form of "issue ads" or "coordinated expenditures").

The campaign finance reform bill contained an unusual provision providing for an early federal trial and a direct appeal to the Supreme Court of the United States, by-passing the typical federal judicial process. In May a special three-judge panel struck down portions of the Campaign Finance Reform Act's ban on soft-money donations but upheld some of the Act's restrictions on the kind of advertising that parties can engage in. The ruling was stayed until the Supreme Court could hear and decide the resulting appeals.

Question

Does the "soft money" ban of the Campaign Finance Reform Act of 2002 exceed Congress's authority to regulate elections under Article 1, Section 4 of the United States Constitution and/or violate the First Amendment's protection of the freedom to speak?
Do regulations of the source, content, or timing of political advertising in the Campaign Finance Reform Act of 2002 violate the First Amendment's free speech clause?

Conclusion

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

Split Vote

With a few exceptions, the Court answered "no" to both questions in a 5-to-4 decision written by Justices Sandra Day O'Connor and John Paul Stevens. Because the regulations dealt mostly with soft-money contributions that were used to register voters and increase attendance at the polls, not with campaign expenditures (which are more explicitly a statement of political values and therefore deserve more protection), the Court held that the restriction on free speech was minimal. It then found that the restriction was justified by the government's legitimate interest in preventing "both the actual corruption threatened by large financial contributions and... the appearance of corruption" that might result from those contributions.

In response to challenges that the law was too broad and unnecessarily regulated conduct that had not been shown to cause corruption (such as advertisements paid for by corporations or unions), the Court found that such regulation was necessary to prevent the groups from circumventing the law. Justices O'Connor and Stevens wrote that "money, like water, will always find an outlet" and that the government was therefore justified in taking steps to prevent schemes developed to get around the contribution limits.

The Court also rejected the argument that Congress had exceeded its authority to regulate elections under Article I, Section 4 of the Constitution. The Court found that the law only affected state elections in which federal candidates were involved and also that it did not prevent states from creating separate election laws for state and local elections.

Banks v. Dretke

Mon, 08 Dec 2003 13:00:00 +0000

Case Basics

Docket No.

02-8286

Petitioner

Delma Banks, Jr.

Petitioner Type

Petitioner

Respondent

Doug Dretke, Director, Texas Department of Criminal Justice, Correctional Institutions Division

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

540 U.S. 668 (2004)

Granted

Monday, April 21, 2003

Argued

Monday, December 8, 2003

Decided

Tuesday, February 24, 2004

Advocates

Gena A. Bunn (argued the cause for Respondent)

George H. Kendall (argued the cause for Petitioner)

Facts of the Case

Delma Banks, Jr. was convicted of murder and sentenced to death in Texas state court in 1980. Sixteen years later Banks learned that one of the witnesses against him, Robert Farr, was a paid informant (a fact not stated during the trial). Charles Cook, another witness against Banks, claimed that he had made up much of his testimony in order to get other criminal charges against him dropped as part of a plea agreement.

In Brady v. Maryland the U.S. Supreme Court held that due process is violated if prosecutors suppress evidence favorable to a defendant that relates to guilt or punishment. Pointing to Brady and evidence the prosecution suppressed information on its ties to the two witnesses, Banks sought a writ of habeas corpus in federal court to overturn his conviction and get a new trial. The district court granted habeas relief with respect to Banks' death sentence based on the state's failure to disclose Farr's informant status. However the district court refused to reverse the guilt verdict, rejecting Banks' Brady claim relating to Cook's testimony and Banks' argument that Federal Rule of Civil Procedure 15(b) allowed the claim to be treated as if it were raised earlier.

The Fifth Circuit Court of Appeals reversed the district court's decision to grant Banks relief as to his death sentence based on his Brady claim relating to Farr's testimony. The Court held that Banks first had to press his claims in state court. The Court upheld the district court's rejection of Banks' claim relating to Cook's testimony, holding that Federal Rule of Civil Procedure 15(b) does not apply to habeas proceedings.

Question

Was the Fifth Circuit wrong to reject Banks' claim relating to Farr's testimony under Brady v. Maryland on the ground that such a claim must first be made in state court? Was the Fifth Circuit wrong to reject Banks' claim relating to Cook's testimony on the grounds that such a claim should have been raised earlier and that Federal Rule of Civil Procedure 15(b) does not apply?

Conclusion

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

Yes and yes. In an opinion delivered by Justice Ruth Bader Ginsburg, the Court held 7-2 that the Fifth Circuit was wrong to dismiss Banks' claim under Brady relating to Farr's testimony and 9-0 that the Fifth Circuit was wrong to deny Banks' appeal based on Cook's testimony. Banks could make his Brady claim relating to Farr's testimony in federal court without have made the claim in state court because he demonstrated both cause for failing to present evidence in state court and evidence that that failure prejudiced the proceedings against him. The Court held that both the district court and the Fifth Circuit wrongly denied Banks' appeal with regard to his Brady claim on Cook's testimony. Federal Rule of Civil Procedure 15(b) does apply in this case and requires courts to treat Banks' claim relating to Cook's testimony as if it were raised in earlier proceedings.

Frew v. Hawkins

Tue, 07 Oct 2003 13:00:00 +0000

Case Basics

Docket No.

02-628

Petitioner

Linda Frew, on Behalf of Her Daughter, Carla Frew, et al.

Respondent

Albert Hawkins, Commissioner, Texas Health and Human Services Commission, et al.

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

540 U.S. 431 (2004)

Granted

Monday, March 10, 2003

Argued

Tuesday, October 7, 2003

Decided

Wednesday, January 14, 2004

Advocates

R. Ted Cruz (argued the cause for Respondents)

Susan Finkelstein Zinn (argued the cause for Petitioners)

Facts of the Case

In 1996, Linda Frew and other citizens settled a class-action lawsuit in federal district court against the Texas Health and Human Services Commission. Settlement was reached through a consent agree, in which the parties make an agreement that is subject to court supervision. As part of this consent decree, Texas was supposed to improve health care for poor children to comply with a federally mandated program called Early and Periodic Screening, Diagnosis and Treatment. Two years later, Frew and others remained unsatisfied that Texas was complying with the federal requirements, and asked the court to force Texas to create a plan for how it would improve health care. Texas refused, however, claiming that it was immune from the court order under the 11th Amendment, which provides for state sovereignty. Texas argued that because no federal rights had been violated, suit could not be brought in federal court. The Fifth Circuit Court of Appeals agreed with Texas.

Question

Do states forfeit 11th Amendment protection when they enter into a consent decree under federal law in federal court? And must states violate federal law, not just the consent agreement, in order to be subject to suit in federal court?

Conclusion

Decision: 9 votes for Frew, 0 vote(s) against
Legal provision: Amendment 11: Eleventh Amendment

Yes and no. In a unanimous opinion delivered by Justice Anthony Kennedy, the Court held that enforcement of the consent decree does not violate the 11th Amendment. The Court rejected the argument that a federal court cannot enforce a consent decree unless it finds a violation of federal law. "The decree here is a federal court order that springs from a federal dispute and furthers the objectives of federal law," Justice Kennedy wrote.

Tennessee v. Lane

Tue, 13 Jan 2004 13:00:00 +0000

Case Basics

Docket No.

02-1667

Petitioner

Tennessee

Petitioner Type

Petitioner

Respondent

George Lane, et al.

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

541 U.S. 509 (2004)

Granted

Monday, June 23, 2003

Argued

Tuesday, January 13, 2004

Decided

Monday, May 17, 2004

Advocates

Paul D. Clement (argued the cause for Respondent United States)

William J. Brown (argued the cause for Respondents Lane and Jones)

Michael E. Moore (argued the cause for Petitioner)

Facts of the Case

George Lane and Beverly Jones were disabled and could not access upper floors in Tennessee state courthouses. Lane, Jones, and several others sued Tennessee in federal district court, alleging that by denying them public services based on their disabilities, Tennessee was in violation of Title II of the Americans with Disabilities Act (1990). According to Title II, no person may be denied access to "services, programs, or activities" on the basis of his disability. The act allows alleged victims of discrimination to sue states for damages.

Tennessee asked that the case be dismissed, claiming that it was barred by the 11th Amendment's prohibition of suits against states in federal courts (the sovereign immunity doctrine). The state cited Alabama v. Garrett (2001), in which the U.S. Supreme Court ruled that Congress had acted unconstitutionally in granting citizens the right to sue states for disability discrimination (such as the denial of employment) under the 14th Amendment's equal protection clause. In that case the Supreme Court reasoned that Congress did not have enough evidence of disability discrimination by states to justify the waiver of sovereign immunity.

The district court rejected the state's argument and denied the motion to dismiss. The Sixth Circuit Court of Appeals panel affirmed. The courts reasoned that because Title II of the ADA dealt with the Due process Clause of the 14th Amendment, not the equal protection clause, the ruling in Garrett did not apply. The court found that while Congress may not have had enough evidence of disability discrimination to waive sovereign immunity for equal protection claims, it did have enough evidence of Due Process violations (such as non-handicap-accessible courthouses) to waive the sovereign immunity doctrine for Due Process claims.

Question

Did the Americans with Disabilities Act violate the sovereign immunity doctrine of the 11th Amendment when, based on Congress's 14th Amendment enforcement powers of the Due Process clause, it allowed individuals to sue states for denying them services based on their disabilities?

Conclusion

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

No. In a 5-to-4 opinion written by Justice John Paul Stevens, the Court held that Congress had sufficiently demonstrated the problems faced by disabled persons who sought to exercise fundamental rights protected by the Due Process clause of the 14th Amendment (such as access to a court). The Court also emphasized that the remedies required from the states were not unreasonable - they just had to make reasonable accommodations to allow disabled persons to exercise their fundamental rights. Because Title II was a "reasonable prophylactic measure, reasonably targeted to a legitimate end," and because Congress had the authority under the 14th Amendment to regulate the actions of the states to accomplish that end, the law was constitutional.

Alaska Dept. of Environmental Conserv. v. EPA

Wed, 08 Oct 2003 13:00:00 +0000

Case Basics

Docket No.

02-658

Petitioner

Alaska Department of Environmental Conservation

Petitioner Type

Petitioner

Respondent

Environmental Protection Agency, et al.

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

540 U.S. 461 (2004)

Granted

Monday, February 24, 2003

Argued

Wednesday, October 8, 2003

Decided

Wednesday, January 21, 2004

Advocates

Thomas G. Hungar (argued the cause for Respondent)

Jonathan S. Franklin (argued the cause for Petitioner)

Facts of the Case

Under the Clean Air Act, state agencies must determine the best way to prevent air pollution in areas that have met national clean air standards. In part, they must require that polluting companies use the "best available control technology" to limit pollution whenever they construct new facilities. In 1998, Teck Cominco Alaska, a mining company, requested a permit to build an additional generator at one of its mines. The Alaska Department of Environmental Conservation (ADEC) issued the permit, which called for Cominco to use "Low NOx" technology on all its generators, not just the new one. The Environmental Protection Agency (EPA), however, stepped in, arguing that a better technology was available. ADEC appealed the EPA's decision to the Ninth Circuit Court of Appeals, arguing that the EPA did not have the right to interfere with the state agency's decision. The Ninth Circuit sided with the EPA.

Question

Under the Clean Air Act, does the Environmental Protection Agency have the authority to overrule a state agency's decision that a company is using the "best available controlling technology" to prevent pollution?

Conclusion

Decision: 5 votes for EPA, 4 vote(s) against
Legal provision: Clean Air

Yes. In a 5-4 opinion delivered by Justice Ruth Bader Ginsburg, the Court held that the Clean Air Act authorized the EPA to bar the construction of the polluting facility in Alaska. Though Alaska determined the facility's use of "Low NOx" met the act's requirement that facilities use "best available control technology," the EPA was reasonable to reject this claim. Justice Anthony Kennedy delivered a dissent joined by Justices Clarence Thomas, Antonin Scalia and Chief Justice William Rehnquist.

SEC v. Edwards

Tue, 04 Nov 2003 13:00:00 +0000

Case Basics

Docket No.

02-1196

Petitioner

Securities and Exchange Commission

Petitioner Type

Petitioner

Respondent

Charles E. Edwards

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

540 U.S. 389 (2004)

Granted

Monday, April 21, 2003

Argued

Tuesday, November 4, 2003

Decided

Tuesday, January 13, 2004

Advocates

Theodore B. Olson (argued the cause for Petitioner)

Michael K. Wolensky (argued the cause for Respondent)

Facts of the Case

Charles Edwards founded a company that sold pay telephones and then leased them back from the purchasers for a fixed monthly fee. After Edwards filed for bankruptcy, the Securities and Exchange Commission (SEC) sued him for selling securities (considering the telephones to be investments on the part of the purchasers and therefore securities) in violation of the registration and anti-fraud provisions of the federal securities laws.

A federal district court froze Edwards' assets in a preliminary injunction. The 11th Circuit Court of Appeals overruled the district court's injunction for lack of jurisdiction. The SEC, the court reasoned, failed to show that Edwards' selling pay telephones was an "investment contract" under federal securities laws. In defining "investment contract," the court used the Supreme Court's ruling in SEC v. W.J. Howey Co. (1946), that a financial interest is an "investment contract" if it involves (1) an investment of money, (2) in a common enterprise, (3) with the expectation of profits to be derived solely from the efforts of others. The 11th Circuit ruled that the SEC could not meet the test's third part because the purchasers received a fixed fee that was guaranteed by contract and therefore not dependant on Edwards' success.

Question

Does the Securities Exchange Act's (1934) term "investment contract" include an investment scheme in which the promoter promises a fixed return or the investor is entitled to a particular rate of return?

Conclusion

Decision: 9 votes for SEC, 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 Sandra Day O'Connor, the Court held that an investment scheme promising a fixed rate of return can be an "investment contract" and thus a "security" subject to federal securities laws. The test the Court uses for determining whether a scheme is an "investment contract" is "whether the scheme involves an investment of money in a common enterprise with profits to come solely from the efforts of others." Because the test does not distinguish between promises of fixed returns and promises of variable returns, the scheme at issue here can be defined as an "investment contract."

Middleton v. McNeil

Sat, 27 Apr 2013 20:11:41 +0000

Case Basics

Docket No.

03-1028

Petitioner

Middleton

Petitioner Type

Petitioner

Respondent

McNeil

Respondent Type

Respondent

Decided By

Rehnquist Court (1994-2005)

Opinion

541 U.S. 433 (2004)

Decided

Monday, May 3, 2004

Facts of the Case

Sally Marie McNeil was convicted of the murder of her husband. She appealed her conviction, claiming that the trial judge had given the jury improper instructions when it was deciding whether to convict her of murder or voluntary manslaughter (the last four words of the instruction, not included in the model jury instruction provided with the criminal statute, might have led the jury to misunderstand the meaning of voluntary manslaughter). The California Court of Appeal acknowledged that the jury instruction had been wrong, but found that, taken as a whole, the instruction did not make it reasonably likely that the jury would misunderstood the meaning of voluntary manslaughter, especially given the closing statements of the prosecutor, which provided the correct definition of the law.

McNeil then petitioned for a writ of habeas corpus in federal court. The district court rejected her claim, but a Ninth Circuit Court of Appeals panel reversed.

Question

Were the instructions given to the jury in McNeil's trial sufficiently misleading to warrant the reversal of her sentence?

Conclusion

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

No. In a per curiam (unsigned) opinion, the Court ruled that the judge had provided correct instructions for three other parts of the instruction that were closely related to the error, and that, given the clarity of those instructions, the jury was unlikely to have been mislead by the four words erroneously inserted at the end. "Given three correct instructions and one contrary one, the state court did not unreasonably apply federal law when it found that there was no reasonable likelihood the jury was misled."

Jones v. R.R. Donnelley and Sons Co.

Tue, 24 Feb 2004 13:00:00 +0000

Case Basics

Docket No.

02-1205

Petitioner

Edith Jones, et al., on Behalf of Herself and a Class of Others Similarly Situated

Petitioner Type

Petitioner

Respondent

R. R. Donnelley & Sons Company

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

541 U.S. 369 (2004)

Granted

Monday, May 19, 2003

Argued

Tuesday, February 24, 2004

Decided

Monday, May 3, 2004

Advocates

Kevin C. Newsom (argued the cause for Respondent)

Carter G. Phillips (argued the cause for Respondent)

H. Candace Gorman (argued the cause for Petitioners)

Gregory G. Garre (argued the cause for Petitioners, on behalf of the United States, as amicus curiae)

Facts of the Case

In November of 1996, Edith Jones and several other African Americans filed a class action lawsuit in federal district court against R.R. Donnelley and Sons, a commercial printing company. They claimed they had suffered racial discrimination in violation of section 1981 of United States Code (U.S.C.), which had no specified statute of limitations. Donnelley and Sons, however, argued that the section was bound by a two-year statute of limitations established by Illinois for all personal injury claims. The suit fell outside that statute of limitations, and the company argued that it should therefore be dismissed.

Jones, however, argued that a separate section of U.S.C. extended the statute of limitations to four years for any civil suit brought under an act of Congress passed after 1990. Because the 1991 Civil Rights Act had broadened the definition of section 1981, she argued, the four-year statute of limitations should apply to that section and the suit should therefore not be thrown out. Donnelley and Sons countered that the 1991 Civil Rights Act had merely amended the section, not created a new law, and that the four-year statute of limitations therefore did not apply.

A federal district court sided with Jones. A Seventh Circuit Court of Appeals panel unanimously reversed.

Question

Does the United States Code's four-year statute of limitations for suits brought under acts of Congress passed after 1990 apply only to new laws, or does it also apply to amendments of previously existing laws?

Conclusion

Decision: 9 votes for Jones, 0 vote(s) against
Legal provision: 26 U.S.C. 1658

It also applies to amendments of previously existing laws. Writing for a unanimous Court, Justice John Paul Stevens stated "[a]n amendment to an existing statute is no less an 'Act of Congress' than a new, stand-alone statute." The four-year statute of limitations therefore applies to any act or amendment to an act passed by Congress after 1990.

United States v. Flores-Montano

Wed, 25 Feb 2004 13:00:00 +0000

Case Basics

Docket No.

02-1794

Petitioner

United States

Petitioner Type

Petitioner

Respondent

Manuel Flores-Montano

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

541 U.S. 149 (2004)

Granted

Tuesday, October 14, 2003

Argued

Wednesday, February 25, 2004

Decided

Tuesday, March 30, 2004

Advocates

Lisa S. Blatt (argued the cause for Petitioner)

Steven F. Hubachek (argued the cause for Respondent)

Facts of the Case

When Manuel Flores-Montano approached the U.S.-Mexico border, U.S. Customs inspectors noticed his hand shaking; an inspector tapped Flores-Montano's gas tank with a screwdriver and noticed that the tank sounded solid; a drug- sniffing dog alerted to the vehicle. After a mechanic began disassembling the car's fuel tank, inspectors found 37 kilograms of marijuana bricks in the tank.

Flores-Montano was charged in federal district court in California for importing and possessing marijuana with intent to distribute. Flores-Montano moved to suppress the marijuana finding on Fourth Amendment grounds. He argued that the search that yielded the marijuana finding was intrusive and non- routine and therefore required reasonable suspicion (which, he argued, was not present in his case).

Relying on U.S. v. Molina-Tarazon, a case decided by the U.S. Ninth Circuit Court of Appeals in 2002 (with similar circumstances), the district court agreed that the search was non-routine and thus required reasonable suspicion. The government, the court held, failed to prove that reasonable suspicion prompted its search. The Ninth Circuit Court of Appeals affirmed.

Question

Does the Fourth Amendment require customs officers at the international border to have reasonable suspicion in order to remove, disassemble, and search a vehicle's gas tank for illegal material?

Conclusion

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

No. In a unanimous opinion delivered by Chief Justice William Rehnquist, the Court held that the government had authority to inspect a vehicle's fuel tank at the border without suspicion. Though the Fourth Amendment "'protects property as well as privacy,'" interference with a vehicle owner's gas tank "is justified by the Government's paramount interest in protecting the border." The Court rejected the argument that the requirement of suspicion for highly intrusive searches of people be carried over to cars (especially at the border): "Complex balancing tests...have no place in border searches of vehicles."

Hiibel v. Sixth Judicial District Court of Nevada, Humboldt County

Mon, 22 Mar 2004 13:00:00 +0000

Case Basics

Docket No.

03-5554

Petitioner

Larry D. Hiibel

Petitioner Type

Petitioner

Respondent

Sixth Judicial District Court of Nevada, Humboldt County, et al.

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

542 U.S. 177 (2004)

Granted

Monday, October 20, 2003

Argued

Monday, March 22, 2004

Decided

Monday, June 21, 2004

Advocates

Sri Srinivasan (argued the cause for Respondents, on behalf of the United States, as amicus curiae)

Conrad Hafen (argued the cause for Respondents)

Robert E. Dolan (argued the cause for Petitioner)

Facts of the Case

Larry Hiibel was arrested and convicted in Nevada state court for failing to identify himself to a police officer who was investigating an assault. Nevada, and many other states, has a law that requires a person to tell an officer his name if asked. Hiibel challenged the conviction, claiming it violated his Fifth Amendment right not to incriminate himself and his Fourth Amendment right to be free from unreasonable searches. The state intermediate court and Supreme Court rejected his argument in affirming the conviction.

Question

Did Hiibel's arrest and conviction for not telling a police officer his name violate his Fifth Amendment right not to incriminate himself and his Fourth Amendment right to be free from an unreasonable search?

Conclusion

Decision: 5 votes for Sixth Judicial District Court of Nevada, Humboldt County, 4 vote(s) against
Legal provision: Amendment 4: Fourth Amendment

No. In a 5-to-4 opinion written by Justice Anthony Kennedy, the Court ruled that the search did not violate the Fourth Amendment because it was based on reasonable suspicion (the police officer was investigating the assault, and Hiibel was nearby) and involved only a minimally intrusive question (his name). It also did not violate the Fifth Amendment because Hiibel never argued that telling the officer his name would actually incriminate him of any crime. Justice Kennedy wrote, "While we recognize petitioner's strong belief that he should not have to disclose his identity, the Fifth Amendment does not override the Nevada Legislature's judgment to the contrary absent a reasonable belief that the disclosure would tend to incriminate him."

Castro v. United States

Wed, 15 Oct 2003 13:00:00 +0000

Case Basics

Docket No.

02-6683

Petitioner

Hernan O'Ryan Castro

Petitioner Type

Petitioner

Respondent

United States

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

540 U.S. 375 (2003)

Granted

Monday, January 27, 2003

Argued

Wednesday, October 15, 2003

Decided

Monday, December 15, 2003

Advocates

Dan Himmelfarb (argued the cause for Respondent)

Michael G. Frick (argued the cause for Petitioner)

Facts of the Case

Hernan O'Ryan Castro was sentenced to 20 years in prison for drug related offenses. After the 11th Circuit Court of Appeals affirmed his conviction, Castro alleged that he had discovered evidence that a government witness had testified falsely. Based on this evidence, he requested a new trial without legal representation. The district court, because Castro had no legal representation, attempted to help him by re-characterizing his request for a new trial as a petition for a writ of habeas corpus. The judge's re- characterization of Castro's appeal was intended to help him, but two years later, in the Antiterrorism and Effective Death Penalty Act of 1996, Congress limited the number of petitions for writ of habeas corpus that a prisoner could file to one. When Castro attempted to petition for what he thought was his first write of habeas corpus in 1998, he was denied because of the earlier reclassification of his request for a new trial. When he appealed, the 11th Circuit Court of appeals initially sided with Castro, ruling that the reclassification should not count against him. Four months later, however, the 11th Circuit reconsidered, siding with the government.

Question

When a district judge re-classifies a post-conviction motion by a defendant, turning it into a petition for a writ of habeas corpus, does that preclude future petitions for a writ of habeas corpus under the Antiterrorism and Effective Death Penalty Act of 1996?

Conclusion

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

In a unanimous opinion delivered by Justice Stephen Breyer, the Court held that a federal court can recharacterize a motion as a first habeas corpus petition only if the court: (1) informs the litigant of the court's intent to recharacterize; (2) warns the litigant that this recharacterization means that any subsequent habeas corpus petition will be treated as a second petition; (3) gives the litigant an opportunity to withdraw or amend the motion. The Court held that because the district court failed to give these prescribed warnings, Castro's 1994 motion could not be considered a first habeas corpus petition and his 1997 motion therefore could not be considered a second petition.

United States v. Galletti

Mon, 12 Jan 2004 13:00:00 +0000

Case Basics

Docket No.

02-1389

Petitioner

United States

Petitioner Type

Petitioner

Respondent

Abel C. Galletti, et al.

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

541 U.S. 114 (2004)

Granted

Monday, June 23, 2003

Argued

Monday, January 12, 2004

Decided

Tuesday, March 23, 2004

Advocates

David R. Haberbush (argued the cause for Respondents)

Kent L. Jones (argued the cause for Petitioner)

Facts of the Case

Abel Galletti and his wife, along with another couple, the Briguglios, formed a business partnership. The partnership underpaid its federal employment taxes, and the IRS assessed the unpaid taxes against the partnership (meaning the partnership would be forced to pay the taxes). According to the Internal Revenue Code, if a tax debt is assessed within three years after the return was filed, the government has 10 additional years to collected the money.

More than three years later, the Gallettis and the Briguglios separately filed for bankruptcy. The IRS made a claim in bankruptcy court against the two couples for the taxes assessed against the partnership. The couples objected, arguing that because the partners themselves had not been separately assessed, the statute of limitations had not been extended to the partners.

The bankruptcy court ruled against the IRS, holding that the IRS must assess tax claims against individual partners, not just the partnership, in order to later collect on those claims from the individuals. The district court and a Ninth Circuit Court of Appeals panel both affirmed the decision.

Question

To qualify for the 10-year extension in the statute of limitations, does the government need to assess - beyond just the partnership that owes money - each individual partner for the debt?

Conclusion

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

No. In a unanimous opinion delivered by Justice Clarence Thomas, the Court held that the IRS' assessment against the partnership was sufficient to extend the statute of limitations by 10 years to collect the money from the partners themselves. The Internal Revenue Code does not require the government to make separate assessments of a single debt against people or entities secondarily liable in order to extend the statute of limitations. The statute of limitations extension is attached to the debt - without reference to the entities who owe the debt.

Cheney v. U.S. District Court for the District of Columbia

Tue, 27 Apr 2004 13:00:00 +0000

Case Basics

Docket No.

03-475

Petitioner

Richard B. Cheney, Vice President of the United States, et al.

Petitioner Type

Petitioner

Respondent

United States District Court for the District of Columbia, et al.

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

542 U.S. 367 (2004)

Granted

Monday, December 15, 2003

Argued

Tuesday, April 27, 2004

Decided

Thursday, June 24, 2004

Advocates

Alan B. Morrison (argued the cause for Respondent Sierra Club)

Theodore B. Olson (argued the cause for Petitioners)

Paul J. Orfanedes (argued the cause for Respondent Judicial Watch, Inc.)

Facts of the Case

In January 2001, President Bush created an advisory committee on energy policy headed by Vice President Dick Cheney. After the group issued its recommendations five months later, Judicial Watch, a non-profit government watchdog group, filed suit in federal district court. The Sierra Club, an environmentalist organization, later filed a nearly identical suit that was joined with the Judicial Watch suit. The two organizations alleged that the advisory committee had violated the Federal Advisory Committee Act (FACA) by not making public all the documents that it had generated. While FACA exempts committees composed entirely of federal officials, Judicial Watch and the Sierra Club argued that the exemption did not apply because private lobbyists had participated in the energy committee's meetings.

Cheney and the advisory group asked the court to dismiss the case, claiming that it violated the Constitutional separation of powers by requiring judicial oversight of internal executive branch deliberations. The district court refused.

The government then sought summary judgment of the case (without the discovery process) based on a few administrative documents that it claimed showed that only federal officials had worked on the group. The district court denied this request as well, and the government appealed to the Court of Appeals for the District of Columbia. The appeals court refused to grant summary judgment, arguing that it could not yet rule on the separation of powers argument. The government then appealed the case to the U.S. Supreme Court.

Question

Does the Federal Advisory Committee Act authorize judicial review of executive branch deliberations through a broad discovery process that allows a private organization to review internal documents of high-level advisors to the President? If such review is authorized by FACA, does it violate the Constitutional doctrine of separation of powers?

Conclusion

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

In a 7-2 opinion delivered by Justice Anthony Kennedy, the Court sent the case back to the D.C. Court of Appeals, arguing that the appellate court should have considered separation-of-powers claims and was wrong to conclude it lacked authority to order District Court discovery to stop. Such an order (mandamus) to stop discovery proceedings should be considered because those proceedings, "by virtue of their overbreadth," could interfere with presidential activity. Further, the appellate court misinterpreted U.S. v. Nixon to mean that the government needed to assert executive privilege for separation-of-powers objections to be considered.

Dretke v. Haley

Tue, 02 Mar 2004 13:00:00 +0000

Case Basics

Docket No.

02-1824

Petitioner

Doug Dretke, Director, Texas Department of Criminal Justice, Correctional Institutions Division

Petitioner Type

Petitioner

Respondent

Michael Wayne Haley

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

541 U.S. 386 (2004)

Granted

Tuesday, October 14, 2003

Argued

Tuesday, March 2, 2004

Decided

Monday, May 3, 2004

Advocates

R. Ted Cruz (argued the cause for Petitioner)

Matthew D. Roberts (argued the cause for Petitioner, on behalf of the United States, as amicus curiae)

Eric M. Albritton (argued the cause for Respondent)

Facts of the Case

Haley was convicted in Texas state courts of a felony theft and sentenced as a habitual felony offender (extending his sentence). After a failed appeal to the Texas appellate court, Haley filed a state habeas application in the trial court, arguing that his past crimes did not qualify him as a habitual offender and that his attorney had provided ineffective counsel when he failed to object to the extended sentence. The court dismissed his claims on procedural grounds, because he had not raised the issue during his trial and therefore could not raise it in the habeas petition. The Texas Court of Criminal Appeals denied his habeas application based on the trial court's findings.

Haley then filed for habeas corpus relief in federal district court. Pointing to the procedural-default doctrine, Texas argued that Haley's claim was procedurally barred from federal habeas review. Under the procedural-default doctrine, federal courts cannot grant habeas relief if the last state court rejected the appeal for procedural violations of state law; the only exception is if the petitioner is actually innocent.

The district court held that Haley showed he was "actually innocent" of earlier violations on which his sentence enhancement was based. The court ruled that Haley's sentence was therefore improperly extended. It never reached his ineffective assistance of counsel claim, having already found grounds for overturning the extended sentence. The U.S. Fifth Circuit Court of Appeals affirmed, rejecting Texas's argument that the actual-innocence exception applies only to cases involving capital offenses.

Question

Does the actual-innocence exception to the procedural-default doctrine apply to both capital and non-capital cases?

Conclusion

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

The Court declined to answer the question presented, ruling instead that the district court should have first considered the ineffective assistance of counsel claim before reaching the question of whether the "actual innocence" exception applies to non-capital cases. Justice Sandra Day O'Connor, for a seven-member majority, wrote that the ineffective assistance of counsel claim would accomplish the same thing - the reduction of the sentence - without burdening the state with the need to prove the existence of all prior convictions beyond a reasonable doubt.

City of Littleton v. Z.J. Gifts D-4, L.L.C.

Wed, 24 Mar 2004 13:00:00 +0000

Case Basics

Docket No.

02-1609

Petitioner

City of Littleton, Colorado

Petitioner Type

Petitioner

Respondent

Z.J. Gifts D-4, L.L.C., a Limited Liability Company, dba Christal's

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

541 U.S. 774 (2004)

Granted

Tuesday, October 14, 2003

Argued

Wednesday, March 24, 2004

Decided

Monday, June 7, 2004

Advocates

Douglas R. Cole (argued the cause for Petitioner)

J. Andrew Nathan (argued the cause for Petitioner)

Michael W. Gross (argued the cause for Respondent)

Facts of the Case

Littleton required adult businesses to apply for a permit to operate from the city. If the city denied the license, the business could appeal to a state district court under the Colorado Rules of Civil Procedure. Z.J. Gifts, an adult bookstore, wanted to operate in a place not zoned for adult businesses. Rather than apply for a license, they challenged the licensing law itself as unconstitutional, claiming that the Colorado Rules of Civil Procedure provide merely for prompt judicial review of city denial, not for a prompt judicial decision. Because stores denied a license cannot operate until the court has made its decision, they could potentially be forced to wait indefinitely for a license based solely on the content of the material they intend to sell. This, Z.J. argued, violated the Supreme Court's holding in Freedman v. Maryland, 380 U.S. 51, that censorship laws must provide for "prompt judicial determination."

The federal district court sided with Littleton. A Tenth Circuit Court of Appeals panel reversed.

Question

Did Littleton's adult business licensing ordinance violate the First Amendment protection of Free Speech because it did not guarantee a prompt judicial decision when a business appeals the denial of a license?

Conclusion

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

No. In an opinion by Justice Stephen G. Breyer, the Court held that Colorado did not have to explicitly provide for a "prompt judicial determination" to make the law constitutional. As long as Colorado courts did not unnecessarily delay such claims, the normal judicial review process could be expected to provide a decision quickly enough to satisfy the constitutional demands. If the courts failed to make a prompt decision in a specific case, the business in that particular case could sue, but the absence of explicit "prompt judicial determination" language in the statute did not make it unconstitutional.

Central Laborers' Pension Fund v. Heinz

Mon, 19 Apr 2004 13:00:00 +0000

Case Basics

Docket No.

02-891

Petitioner

Central Laborers' Pension Fund

Petitioner Type

Petitioner

Respondent

Thomas E. Heinz, et al.

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

541 U.S. 739 (2004)

Granted

Monday, December 1, 2003

Argued

Monday, April 19, 2004

Decided

Monday, June 7, 2004

Advocates

John P. Elwood (argued the cause for Petitioner, on behalf of the United States, as amicus curiae)

Thomas C. Goldstein (argued the cause for Petitioner)

David M. Gossett (argued the cause for Respondents)

Facts of the Case

Thomas Heinz worked as a construction worker for 20 years, then retired. Upon retirement, he began to receive pension payments from the Central Laborers' Pension Plan. He continued to receive the pension after he took another job as a supervisor in the construction industry. The pension plan had a list of occupations that a recipient could not work in while receiving pension payments, but construction supervisors were not included. After two years, however, Central Laborers' Pension amended the list of prohibited professions to include construction supervisors. As a result, Heinz stopped receiving his pension payment. He and Richard Schmitt, a friend who was in the same situation, filed suit in federal district court. They claimed that the amendment, because it was passed after they had already started receiving the benefits, violated the "anti-cutback" provision of the Employee Retirement Income Security Act (ERISA) of 1974. ERISA states that amendments to a pension plan may not decrease the "accrued benefit of a participant." Because the amendment barred them from receiving payments that they were otherwise eligible for, Heinz and Schmitt claimed that it had reduced their "accrued benefit." Central Laborers' Pension, however, argued that the men were still eligible to receive the same pension, they just could not receive it while working as construction supervisors. Because the value of the plan itself had not been changed, only the stipulations for receiving it, the pension plan managers argued that the amendment did not violate ERISA.

The federal district court sided with the pension plan. A divided Seventh Circuit Court of Appeals panel, however, reversed the decision, writing that "an amendment placing materially greater restrictions on the receipt of the benefit 'reduces' the benefit just as surely as a decrease in the size of the monthly benefit payment."

Question

Did Central Laborers' Pension violate the "anti-cutback" provision of the Employee Retirement Income Security Act of 1974 when it added to a list of positions that temporarily disqualified pension holders from receiving their benefits?

Conclusion

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

Yes. The Court unanimously held that the amendment to the plan had narrowed Heinz's rights to the benefits promised him at the time he retired, and that such a narrowing violated ERISA. Justice David H. Souter, in the Opinion of the Court, wrote, "'[A] participant's benefits cannot be understood without reference to the conditions imposed on receiving those benefits.' ... We simply do not see how, in any practical sense, this change of terms could not be viewed as shrinking the value of Heinz's pension rights and reducing his promised benefits."

Norton v. Southern Utah Wilderness Alliance

Mon, 29 Mar 2004 13:00:00 +0000

Case Basics

Docket No.

03-101

Petitioner

Gale Norton, Secretary of the Interior, et al.

Petitioner Type

Petitioner

Respondent

Southern Utah Wilderness Alliance, et al.

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

542 U.S. 55 (2004)

Granted

Monday, November 3, 2003

Argued

Monday, March 29, 2004

Decided

Monday, June 14, 2004

Advocates

Edwin S. Kneedler (argued the cause for Petitioners)

Paul M. Smith (argued the cause for Respondents)

Facts of the Case

The federal Bureau of Land Management (BLM) designated 2.5 million acres of land in Utah as "Wilderness Study Areas" under the Federal Land Policy and Management Act of 1976 (FLPMA). Under the Act, the BLM is required to manage this land "so as not to impair the suitability of such areas for preservation as wilderness."

The Southern Utah Wilderness Alliance (SUWA) and several other environmentalist groups brought suit in federal district court under section 706 (1) of the Administrative Procedure Act (APA), which allows federal courts to compel government action when an agency has failed to meet its legal duties. SUWA claimed that the BLM had failed to take a "hard look," as required by the National Environmental Policy Act of 1969, at the effects of off-road vehicles on the Wilderness Study Areas. It also claimed that the permitted off-road vehicle use was in fact damaging the study areas in violation of the agency's FLPMA obligations.

The district court dismissed the case, holding that SUWA's charge that the bureau had failed to adequately protect the study areas was not specific enough for the court to hear under the Administrative Procedure Act. On appeal, a divided panel of the 10th Circuit Court of Appeals reversed the decision. It held that the bureau's discretion was limited to deciding how to implement the act, not if to implement it, and that SUWA could therefore bring suit to force it at least to take a "hard look" at the effects of the off-road vehicle policy.

Question

Does section 706 (1) of the Administrative Procedure Act authorize federal courts to review the management of public lands under statutory standards and the land use plans of the Bureau of Land Management?

Conclusion

Decision: 9 votes for Norton, 0 vote(s) against
Legal provision: Administrative Procedure, or Administrative Orders Review

Yes, but only to a limited extent. In a unanimous opinion written by Justice Antonin Scalia, the Court ruled that the APA only allows courts to examine government agencies' failures to meet specific statutory requirements. A general complaint based on policy differences - like SUWA's view that the off- road vehicles made the Wilderness Study Areas unsuitable for preservation as wilderness - could not be heard under the APA. Justice Scalia wrote, "If courts were empowered to enter general orders compelling compliance with broad statutory mandates ... it would ultimately become the task of the supervising court, rather than the agency, to work out compliance with the broad statutory mandate, injecting the judge into day-to-day agency management."

South Florida Water Management District v. Miccosukee Tribe

Wed, 14 Jan 2004 13:00:00 +0000

Case Basics

Docket No.

02-626

Petitioner

South Florida Water Management District

Petitioner Type

Petitioner

Respondent

Miccosukee Tribe of Indians, et al.

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

541 U.S. 95 (2004)

Granted

Friday, June 27, 2003

Argued

Wednesday, January 14, 2004

Decided

Tuesday, March 23, 2004

Advocates

Timothy S. Bishop (argued the cause for Petitioner)

Jeffrey P. Minear (argued the cause for Petitioner, on behalf of the United States, as amicus curiae)

Dexter W. Lehtinen (argued the cause for Respondents)

Facts of the Case

The Miccosukee Tribe of Indians and the Friends of the Everglades sued the South Florida Water Management District under the Clean Water Act (CWA) in federal district court. The suit alleged that the water district violated the Clean Water Act by releasing pollutants from a pump system without a discharge elimination system permit. The Clean Water Act prohibits the "addition of any pollutant... from any point source" without a specific permit. The water district defended its action by claiming that it was not actually adding pollutants to the water, but merely transporting polluted water from one body of water to another, less polluted, body.

The district court ruled against the water district and found that it had violated the CWA by using the pump. The 11th Circuit Court of Appeals affirmed on this point, "conclud[ing] that the release of water caused by the... pump station's operation constitutes an addition of pollutants from a point source."

Question

Does pumping water into a water conservation area - where the water being pumped contains a pollutant but the pumping station itself adds no pollutants to the water - violate the Clean Water Act's prohibition of adding pollutants from a point source?

Conclusion

Decision: 9 votes for South Florida Water Management District, 0 vote(s) against
Legal provision: Federal Water Pollution Control (Clean Water), plus amendments

In an opinion delivered by Justice Sandra Day O'Connor, the Court sent the case back to the district court to consider whether the water conservation area and the canal used to transport the water are distinct. If the district court decides the two are not distinct, then the water district will not need a permit under the Clean Water Act. The Court rejected the water district's argument that the act covers a point source only when pollutants originate from that source, not when pollutants originating elsewhere pass through the point source. A point source need only convey the pollutant to navigable waters. The Court was unanimous in sending the case back to district court. Justice Antonin Scalia dissented from part of the Court's reasoning.

Department of Transportation v. Public Citizen

Wed, 21 Apr 2004 13:00:00 +0000

Case Basics

Docket No.

03-358

Petitioner

Department of Transportation, et al.

Petitioner Type

Petitioner

Respondent

Public Citizen, et al.

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

541 U.S. 752 (2004)

Granted

Monday, December 15, 2003

Argued

Wednesday, April 21, 2004

Decided

Monday, June 7, 2004

Advocates

Edwin S. Kneedler (argued the cause for Petitioners)

Jonathan Weissglass (argued the cause for Respondents)

Facts of the Case

In 2001, President Bush announced that he planned to lift a temporary ban on Mexican trucking companies in the United States once new regulations were prepared by the Federal Motor Carrier Safety Administration (FMCSA) to regulate safety inspections and applications to transport materials. Congress specified certain standards that those regulations would have to meet before it would appropriate money to register the new carriers.

When the FMCSA formulated its regulations, it performed an Environmental Assessment (EA) to examine their effects on the environment. Under the National Environmental Policy Act of 1969 (NEPA), federal agencies must perform an Environmental Impact Study (EIS) of policies that are likely to have significant environmental effects. If an agency feels that its policies will not have significant effects, however, it may perform a more limited Environmental Assessment (EA) - which is what FMCSA chose to do. Public Citizen, a watchdog group that monitors government actions, challenged this decision in federal court. It argued that, because FMCSA knew that a large number of Mexican trucks would be admitted into the United States once it issued its regulations, it should have considered the environmental impact of the increased number of trucks in addition to the more limited impact of the safety inspections. The impact of the trucks would have been significant enough to warrant an EIS, so Public Citizen argued that FMCSA had violated NEPA by not conducting the more stringent study. The district court side with the FMCSA, holding that, while the passage of the regulations was necessary before the trucks could be admitted, the FMCSA nevertheless did not have control of those trucks and therefore did not have to account for them in its Environmental Assessment; a Ninth Circuit Court of Appeals panel reversed.

Question

Should the Federal Motor Carrier Safety Administration, knowing that its passage of certain regulations would cause Congress and the President to lift a ban on Mexican motor carriers, have considered the environmental impact of the motor carriers when determining whether to perform an Environmental Impact Study of its regulations?

Conclusion

Decision: 9 votes for Department of Transportation, 0 vote(s) against
Legal provision: National Environmental Policy

No. In a unanimous decision written by Justice Clarence Thomas, the Court held that the FMCSA had no control of the trucks once the regulations were passed, and would therefore be unable to act on the findings of an EIS even if it did conduct one. Further, the Court found that the passage of the regulations was not sufficiently responsible for the increased pollution caused by the trucks to warrant an EIS.

Hamdi v. Rumsfeld

Wed, 28 Apr 2004 13:00:00 +0000

Location

Guantanamo Bay, Cuba Cuba

United States

19° 54' 7.9992" N, 75° 5' 56.0004" W

See map: Google Maps

Case Basics

Docket No.

03-6696

Petitioner

Yaser Esam Hamdi and Esam Fouad Hamdi, as Next Friend of Yaser Esam Hamdi

Respondent

Donald H. Rumsfeld, Secretary of Defense, et al.

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

542 U.S. 507 (2004)

Granted

Friday, January 9, 2004

Argued

Wednesday, April 28, 2004

Decided

Monday, June 28, 2004

Advocates

Paul D. Clement (argued the cause for Respondents)

Frank W. Dunham, Jr. (argued the cause for Petitioners)

Facts of the Case

In the fall of 2001, Yaser Hamdi, an American citizen, was arrested by the United States military in Afghanistan. He was accused of fighting for the Taliban against the U.S., declared an "enemy combatant," and transfered to a military prison in Virginia. Frank Dunham, Jr., a defense attorney in Virginia, filed a petition for a writ of certiorari in federal district court there, first on his own and then for Hamdi's father, in an attempt to have Hamdi's detention declared unconstitutional. He argued that the government had violated Hamdi's Fifth Amendment right to Due Process by holding him indefinitely and not giving him access to an attorney or a trial. The government countered that the Executive Branch had the right, during wartime, to declare people who fight against the United States "enemy combatants" and thus restrict their access to the court system.

The district court ruled for Hamdi, telling the government to release him. On appeal, a Fourth Circuit Court of Appeals panel reversed, finding that the separation of powers required federal courts to practice restraint during wartime because "the executive and legislative branches are organized to supervise the conduct of overseas conflict in a way that the judiciary simply is not." The panel therefore found that it should defer to the Executive Branch's "enemy combatant" determination.

Question

Did the government violate Hamdi's Fifth Amendment right to Due Process by holding him indefinitely, without access to an attorney, based solely on an Executive Branch declaration that he was an "enemy combatant" who fought against the United States? Does the separation of powers doctrine require federal courts to defer to Executive Branch determinations that an American citizen is an "enemy combatant"?

Conclusion

Decision: 6 votes for Hamdi, 3 vote(s) against
Legal provision: Due Process

Yes and no. In an opinion backed by a four-justice plurality and partly joined by two additional justices, Justice Sandra Day O'Connor wrote that although Congress authorized Hamdi's detention, Fifth Amendment due process guarantees give a citizen held in the United States as an enemy combatant the right to contest that detention before a neutral decisionmaker. The plurality rejected the government's argument that the separation-of-powers prevents the judiciary from hearing Hamdi's challenge. Justice David H. Souter, joined by Justice Ruth Bader Ginsburg, concurred with the plurality that Hamdi had the right to challenge in court his status as an enemy combatant. Souter and Ginsburg, however, disagreed with the plurality's view that Congress authorized Hamdi's detention. Justice Antonin Scalia issued a dissent joined by Justice John Paul Stevens. Justice Clarence Thomas dissented separately.

Sosa v. Alvarez-Machain

Tue, 30 Mar 2004 13:00:00 +0000

Case Basics

Docket No.

03-339

Petitioner

Jose Francisco Sosa

Petitioner Type

Petitioner

Respondent

Humberto Alvarez-Machain, et al.

Respondent Type

Respondent

Consolidation

United States v. Humberto Alvarez-Machain, No. 03-485

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

542 U.S. 692 (2004)

Granted

Monday, December 1, 2003

Argued

Tuesday, March 30, 2004

Decided

Tuesday, June 29, 2004

Advocates

Paul D. Clement (argued the cause for Petitioner United States)

Carter G. Phillips (argued the cause for Petitioner Sosa)

Paul L. Hoffman (argued the cause for Respondents)

Facts of the Case

A U.S. Drug Enforcement Agency (DEA) special agent was kidnapped and murdered by a Mexican drug cartel in 1985. After an investigation, the DEA concluded that Humberto Alvarez-Machain had participated in the murder. A warrant for his arrest was issued by a federal district court. The DEA, however, was unable to convince Mexico to extradite Alvarez-Machain, so they hired several Mexican nationals to capture him and bring him back to the United States. His subsequent trial went all the way to the Supreme Court, which found that the government could try a person who had been forcibly abducted, but that the abduction itself might violate international and provide grounds for a civil suit. When the case went back to the district court for trial, Alvarez-Machain was found not guilty for lack of evidence.

Alvarez-Machain then filed a group of civil suits in federal court against the United States and the Mexican nationals who had captured him under the Federal Tort Claims Act (FTCA), which allows the federal government to be sued on tort claims, and the Alien Tort Statute (ATS), which permits suits against foreign citizens in American courts. The government argued that the FTCA applied only to claims arising from actions that took place in the United States and therefore did not cover Alvarez-Machain's case because the arrest took place in Mexico. Further, the government and the Mexican nationals argued that the ATS gave federal courts jurisdiction to hear tort claims against foreign citizens, but did not allow private individuals to bring those suits.

The federal district court disagreed with the government's contention that the FCTA claim did not apply, finding that plan to capture Alvarez-Machain was developed on U.S. soil and therefore covered. However, the court then ruled that the DEA had acted lawfully when they arrested Alvarez-Machain and was therefore not liable. On the ATS claims, the court rejected the argument that private individuals could not bring suit under the Act. The court found that Jose Francisco Sosa, one of the Mexican nationals who kidnapped Alvarez- Machain, had violated international law and was therefore liable under the ATS.

On appeal, the Ninth Circuit Court of Appeals overturned the district court's FTCA decision, ruling that the DEA could not authorize a citizen's arrest of Alvarez-Machain in another country and was therefore liable. The appeals court did, however, affirm the lower court's finding on the ATS claim, upholding the judgment against Sosa.

Question

Does the Alien Tort Statute permit private individuals to bring suit against foreign citizens for crimes committed in other countries in violation of the law of nations or treaties of the United States? May an individual bring suit under the Federal Tort Claims Act for a false arrest that was planned in the United States but carried out in a foreign country?

Conclusion

Decision: 6 votes for Sosa, 3 vote(s) against
Legal provision: Federal Tort Claims, or Alien Tort Statute

No and No. On the Alien Tort Statute claim, the Court unanimously ruled that the ATS did not create a separate ground of suit for violations of the law of nations. Instead, it was intended only to give courts jurisdiction over traditional law of nations cases - those involving ambassadors, for example, or piracy. Because Alvarez-Machain's claim did not fall into one of these traditional categories, it was not permitted by the ATS. On the FTCA claim, the Court ruled that the arrest had taken place outside the United States and therefore was exempted from the Act. It rejected Alvarez-Machain's argument that the exemption should not apply because the arrest had been planned in the United States.

Iowa v. Tovar

Wed, 21 Jan 2004 13:00:00 +0000

Case Basics

Docket No.

02-1541

Petitioner

Iowa

Petitioner Type

Petitioner

Respondent

Felipe Edgardo Tovar

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

541 U.S. 77 (2004)

Granted

Tuesday, September 30, 2003

Argued

Wednesday, January 21, 2004

Decided

Monday, March 8, 2004

Advocates

Thomas J. Miller (argued the cause for Petitioner)

Malcolm L. Stewart (argued the cause for Petitioner, on behalf of the United States, as amicus curiae)

Theresa R. Wilson (argued the cause for Respondent)

Facts of the Case

Felipe E. Tovar was charged with drunk-driving in Iowa three times in four years. Tovar pleaded guilty both times and waived his right to an attorney the first time. The third time, because Iowa law increases sentencing for successive drunk-driving, Tovar faced up to five years in prison. Tovar argued that his first conviction was an invalid waiver of his 6th Amendment right to counsel and should not increase his third sentence. The waiver was invalid, Tovar argued, because the judge did not warn him of the consequences of entering a guilty plea without an attorney. The Iowa district court rejected Tovar's argument and sentenced him to 30 days in jail. The court of appeals affirmed. The Iowa Supreme Court reversed.

Question

Given the 6th Amendment's right to counsel, to what extent must a defendant be informed of the consequences of pleading guilty while waiving the right to an attorney?

Conclusion

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

In a unanimous opinion delivered by Justice Ruth Bader Ginsburg, the Court held that Tovar's Sixth Amendment right to counsel was not violated. In a case like Tovar's, the Sixth Amendment requires the judge to inform the accused of the charges against him, of his right to counsel regarding his plea, and of the range of punishments he faces if he pleads guilty. The Court decided Tovar's trial court judge satisfied these requirements and that Tovar's waiver of his right to counsel was "knowing, voluntary, and intelligent."

Intel Corp. v. Advanced Micro Devices, Inc.

Tue, 20 Apr 2004 13:00:00 +0000

Case Basics

Docket No.

02-572

Petitioner

Intel Corporation

Petitioner Type

Petitioner

Respondent

Advanced Micro Devices, Inc.

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

542 U.S. 241 (2004)

Granted

Monday, November 10, 2003

Argued

Tuesday, April 20, 2004

Decided

Monday, June 21, 2004

Advocates

Jeffrey P. Minear (argued the cause for Respondent, on behalf of the United States, as amicus curiae)

Carter G. Phillips (argued the cause for Petitioner)

Patrick Lynch (argued the cause for Respondent)

Seth P. Waxman (argued the cause for Petitioner)

Facts of the Case

Advanced Micro Devices (AMD) filed a complaint against Intel with the European Commission, alleging that Intel was using its size to unfairly dominate the computer microprocessor market. Complaints filed with the European Commission are first reviewed by the commission's directorate general, which does fact- finding to decide whether or not to pursue the complaint. AMD asked the directorate to review documents containing some of Intel's trade secrets from a separate American court case involving Intel. The directorate declined.

Because European law did not provide a way for AMD to gain access to the documents, AMD filed suit against Intel in United States federal district court seeking access to the documents so that it could use them to support its complaint. The suit was filed under Title 28, Section 1782 of U.S. Code, which allows (but does not require) federal district courts to give "interested persons" access to material for proceedings before "foreign or international tribunal(s)." AMD argued that, though the directorate was only a fact-finding body, the case could eventually be appealed to a trial court and was therefore covered under section 1782. Further, it argued that the directorate's unwillingness to demand the documents was irrelevant. Intel, on the other hand, argued that the directorate was not a "foreign or international tribunal" and that the federal district court therefore did not have the authority to compel Intel to release the documents. It also argued that the directorate's unwillingness to compel production of the documents should preclude U.S. action.

The district court sided with Intel, ruling that the directorate's investigation was not a foreign tribunal and that the court therefore could not give AMD access to the documents. A Ninth Circuit Court of Appeals panel unanimously reversed the decision. After the case was accepted for review by the U.S. Supreme Court, the European Commission filed a brief in the case supporting Intel's position that the directorate was not a foreign tribunal.

Question

Does Section 1782 of Title 28 of U.S. Code authorize a federal district court to compel the release of material for use in a "foreign tribunal" when the foreign tribunal itself is unwilling to demand production of the material? Does Section 1782 authorize a federal district court to compel the release of material for a fact-finding investigation by the directorate general of the European Commission on the theory that the information may eventually lead to an investigation by a foreign tribunal?

Conclusion

Decision: 7 votes for Advanced Micro Devices, Inc., 1 vote(s) against
Legal provision: 28 U.S.C. 1782

Yes and Yes. In a 7-to-1 decision, the Court ruled that just because a foreign tribunal was unwilling to demand certain documents did not mean that it would be unwilling to accept them if provided to them by other means. By permitting, but not forcing, American judges to allow discovery of certain documents, Congress allowed judges to exercise their discretion to decide whether a foreign tribunal would be receptive to the the documents at question. The Court also ruled that it would be impractical to limit the fact-finding to only the actual trial before a foreign tribunal because, in cases like this one, the foreign tribunal does not gather evidence itself but instead relies on the evidence presented to the investigatory commission (in this case the directorate general). In order to make the evidence available for the tribunal, therefore, it would be necessary to present it first to the commission.

Groh v. Ramirez

Tue, 04 Nov 2003 13:00:00 +0000

Case Basics

Docket No.

02-811

Petitioner

Jeff Groh

Petitioner Type

Petitioner

Respondent

Joseph R. Ramirez, et al.

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

540 U.S. 551 (2004)

Granted

Monday, March 3, 2003

Argued

Tuesday, November 4, 2003

Decided

Tuesday, February 24, 2004

Advocates

Richard A. Cordray (argued the cause for Petitioner)

Vincent J. Kozakiewicz (on behalf of the Respondent)

Austin C. Schlick (argued the cause for Petitioner, on behalf of the United States, as amicus curiae)

Facts of the Case

Jeff Groh, a special agent for the U.S. Bureau of Alcohol, Tobacco, and Firearms, applied for a search warrant to search the Ramirez ranch for illegal weapons. On the warrant, Groh mistakenly omitted the exact items sought (though he correctly listed the items on the application itself). A federal magistrate issued the warrant.

The Ramirezes later sued Groh and the law enforcement officers involved in the search in federal court for violating their Fourth Amendment rights. They argued that the incorrectly completed warrant violated the Fourth Amendment requirement that any items searched for be described in the warrant.

The district court ruled that no constitutional violation took place. The officers, the court held, retained "qualified immunity" - meaning they are legally immune while doing their jobs unless they violate a "clearly established" constitutional right.

A Ninth Circuit Court of Appeals panel reversed. The court held that the warrant violated the Fourth Amendment and that Groh is not immune to lawsuit because he was personally responsible for using the warrant.

Question

If law enforcement officers use a search warrant that does not describe the items sought but is approved by a magistrate judge (and the items sought are described in the application for the warrant), does the search violate the Fourth's Amendment prohibition of unreasonable searches and seizures? If such a search is unconstitutional, can law enforcement officers be sued for executing the warrants, despite the fact that no court had previously held such a search unconstitutional?

Conclusion

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

Yes and yes. Justice John Paul Stevens delivered the Court's 5-4 opinion holding that the search was "unreasonable" under the Fourth Amendment. Groh's warrant was invalid because it did not meet the Fourth Amendment requirement that a warrant particularly describe the persons or things to be seized. True, the magistrate judge approved a complete warrant - but what matters is that the Ramirezes did not know what the search was after. Because the particularity requirement is stated in the Fourth Amendment's text, "no reasonable officer could believe that a warrant that did not comply with that requirement was valid." Groh therefore did not have "qualified immunity" from suit.

Rasul v. Bush

Tue, 20 Apr 2004 13:00:00 +0000

Case Basics

Docket No.

03-334

Petitioner

Fawzi Khalid Abdullah Fahad Al Odah, et al.

Petitioner Type

Petitioner

Respondent

George W. Bush, President of the United States, et al.

Respondent Type

Respondent

Consolidation

al Odah v. United States, No. 03-343

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

542 U.S. 466 (2004)

Granted

Monday, November 10, 2003

Argued

Tuesday, April 20, 2004

Decided

Monday, June 28, 2004

Advocates

Theodore B. Olson (argued the cause for Respondents)

John J. Gibbons (argued the cause for Petitioners)

Facts of the Case

Four British and Australian citizens were captured by the American military in Pakistan or Afghanistan during the United States' War on Terror. The four men were transported to the American military base in Guantanamo Bay, Cuba. When their families learned of the arrests, they filed suit in federal district court seeking a writ of habeas corpus that would declare the detention unconstitutional. They claimed that the government's decision to deny the men access to attorneys and to hold them indefinitely without access to a court violated the Fifth Amendment's Due Process clause. The government countered that the federal courts had no jurisdiction to hear the case because the prisoners were not American citizens and were being held in territory over which the United States did not have sovereignty (the Guantanamo Bay base was leased from Cuba indefinitely in 1903, and Cuba retains "ultimate sovereignty").

The district court agreed with the government, dismissing the case because it found that it did not have jurisdiction. The U.S. Court of Appeals for the District of Columbia affirmed the district court's decision.

Question

Do United States courts have jurisdiction to consider legal appeals filed on behalf of foreign citizens held by the United States military in Guantanamo Bay Naval Base, Cuba?

Conclusion

Decision: 6 votes for Rasul, 3 vote(s) against
Legal provision: 28 USC 2241-2255 (habeas corpus)

Yes. In a 6-to-3 opinion written by Justice John Paul Stevens, the Court found that the degree of control exercised by the United States over the Guantanamo Bay base was sufficient to trigger the application of habeas corpus rights. Stevens, using a list of precedents stretching back to mid-17th Century English Common Law cases, found that the right to habeas corpus can be exercised in "all ... dominions under the sovereign's control." Because the United States exercised "complete jurisdiction and control" over the base, the fact that ultimate sovereignty remained with Cuba was irrelevant. Further, Stevens wrote that the right to habeas corpus is not dependent on citizenship status. The detainees were therefore free to bring suit challenging their detention as unconstitutional.

Yarborough v. Gentry

Sat, 27 Apr 2013 20:11:44 +0000

Case Basics

Docket No.

02-1597

Petitioner

Yarborough

Petitioner Type

Petitioner

Respondent

Gentry

Respondent Type

Respondent

Decided By

Rehnquist Court (1994-2005)

Opinion

540 U.S. 1 (2003)

Decided

Monday, October 20, 2003

Facts of the Case

A jury convicted Gentry in state court for stabbing his girlfriend. Gentry appealed, arguing his lawyer's closing argument deprived him of his federal Sixth Amendment right to effective assistance of counsel. While Gentry's appeal lost in state courts, the U.S. Ninth Circuit Court of Appeals reversed Gentry's conviction.

Question

Was a federal appellate court correct in determining that a state appellate court was "objectively unreasonable" for ruling that Gentry's Sixth Amendment right to effective counsel was not violated?

Conclusion

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

No. In a unanimous per curiam opinion, the Court ruled that the state appellate court was not "objectively unreasonable" in determining that Gentry's effective-counsel right was not violated. If a state court rejects an ineffective-assistance claim, a federal court may reverse this only if the decision was "objectively unreasonable." The right to effective assistance of counsel "is denied when a defense attorney's performance falls below an objective standard of reasonableness." While Gentry's lawyer "was no Aristotle," the federal judiciary must respect the state court's reasonable conclusion that the lawyer was sufficient.

Virginia v. Maryland

Tue, 07 Oct 2003 13:00:00 +0000

Case Basics

Docket No.

129 ORIG

Plaintiff

Virginia

Petitioner Type

Plaintiff

Defendant

Maryland

Respondent Type

Defendant

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

540 U.S. 56 (2003)

Argued

Tuesday, October 7, 2003

Decided

Tuesday, December 9, 2003

Advocates

Andrew H. Baida (on behalf of the Plaintiff)

Stuart A. Raphael (on behalf of the Defendant)

Facts of the Case

In 1632, King Charles I gave the Potomac River to Lord Baltimore and, through that charter, to the colony of Maryland. More than 360 years later, Virginia developed a plan to build a water intake pipe in the middle of the river to provide water to Virginia residents. Maryland objected to Virginia's plan and initially refused to grant Virginia a permit to build the pipe. After losing in administrative and state court, Maryland agreed to let Virginia build the pipe, but Virginia refused to let the issue die. Instead, it filed suit with the Supreme Court, asking the court to declare that while Maryland owns the river, Virginia has the right to build in it. Virginia cites a 1785 agreement between the states that gave each "the privilege of making and carrying out wharfs and other improvements" in the river. Maryland, however, argues that while Virginia may be able to build in the river, it does not have the right to draw water from the river without Maryland's consent. A "special master" appointed to evaluate the case by the Supreme Court issued a non-binding holding agreeing with Virginia.

Question

Does Virginia have a right to build in the Potomac river (and, as a result of that building, draw water from the river)?

Conclusion

In a 7-2 opinion delivered by Chief Justice William Rehnquist, the Court held that Virginia has sovereign authority to build improvements to its shore and withdraw water from the Potomac without Maryland's interference. Agreeing with the Special Master's conclusion in favor of Virginia, the Court reasoned that Virginia did not lose its sovereignty to build on its shore and withdraw water under the 1785 Compact between the two states and the Black-Jenkins arbitration agreement.

Nixon v. Missouri Municipal League

Mon, 12 Jan 2004 13:00:00 +0000

Case Basics

Docket No.

02-1238

Petitioner

Southwestern Bell Telephone, L.P., fka Southwestern Bell Telephone Company

Respondent

Missouri Municipal League, et al.

Consolidation

Federal Communications Commission and United States v. Missouri Municipal League, No. 02-1386

Southwestern Bell Telephone v. Missouri Municipal League, No. 02-1405

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

541 U.S. 125 (2004)

Granted

Monday, June 23, 2003

Argued

Monday, January 12, 2004

Decided

Wednesday, March 24, 2004

Advocates

Ronald S. Molteni (argued the cause for Petitioner Nixon)

David A. Strauss (argued the cause for Respondents)

James A. Feldman (argued the cause for Petitioners)

Facts of the Case

The Telecommunications Act of 1996 allowed federal preemption of state and local regulations "prohibiting the ability of any entity" to provide telecommunications services. Based on this act, a group of local governments in Missouri (the Missouri Municipal League) asked the Federal Communications Commission (FCC) to nullify a state law that prevented municipalities from providing telecommunications services. Missouri argued that municipal governments were not separate entities but merely subsections of the state government and that the state could therefore restrict their authority. The FCC agreed with the state, refusing to nullify the law.

The Municipal League appealed, and an Eighth Circuit Court of Appeals panel reversed the decision. The panel held the words "any entity" were intentionally broad and that a proper understanding of them would include municipal governments. The state could therefore not regulate attempts by municipalities to provide telecommunications services. The FCC, along with the state of Missouri and Southwestern Bell Telephone Company, appealed the decision to the Supreme Court.

Question

Under the Telecommunications Act of 1996, are states permitted to regulate the provision of telecommunications services by municipal governments?

Conclusion

Decision: 8 votes for Nixon, 1 vote(s) against
Legal provision: 47 U.S.C. 253

Yes. In an 8-1 opinion delivered by Justice David Souter, the Court held that the act allows states to prevent municipalities from providing telecommunications services. The act only allows federal preemption of state and local efforts to prevent "any private entity" from providing telecommunications services. The Court concluded it would be "unlikely" and "strange" if Congress intended to free municipal governments from state regulations because municipal governments rely on state governments for authority to regulate.

Aetna Health, Inc. v. Davila

Tue, 23 Mar 2004 13:00:00 +0000

Case Basics

Docket No.

02-1845

Petitioner

Aetna Health Inc., fka Aetna U.S. Healthcare Inc. and Aetna U.S. Healthcare of North Texas Inc.

Petitioner Type

Petitioner

Respondent

Ruby R. Calad, et al.

Respondent Type

Respondent

Consolidation

CIGNA Healthcare of Texas, Inc., dba CIGNA v. Ruby R. Calad, No. 03-83

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

542 U.S. 200 (2004)

Granted

Monday, November 3, 2003

Argued

Tuesday, March 23, 2004

Decided

Monday, June 21, 2004

Advocates

Miguel A. Estrada (argued the cause for Petitioners)

David C. Mattax (argued the cause for Respondents)

George Parker Young (argued the cause for Respondents)

James A. Feldman (argued the cause for Petitioners, on behalf of the United States, as amicus curiae)

Facts of the Case

Juan Davila sued his HMO in state court because it had refused to provide certain procedures, and the refusal led to certain injuries. He brought the suit under a Texas law that requires HMOs "to exercise ordinary care" for their patients. The HMO asked that the case be moved to federal court, arguing that the case should be governed under the Employee Retirement Income Security Act of 1974 (ERISA) rather than the Texas law, because ERISA is a federal law the takes precedence over any state laws dealing with the same subject matter. Davila objected, arguing that the case did not fall under ERISA and should be heard in state court. The federal district court sided with the HMO, finding that ERISA prohibits individuals from filing state suits against HMOs when they refuse to pay for a particular treatment. A Fifth Circuit Court of Appeals panel reversed.

Question

Does the Employee Retirement Income Security Act of 1974 prohibit individuals from suing their HMOs in state court when the HMOs refuse to provide a recommended treatment?

Conclusion

Decision: 9 votes for Aetna Health, Inc., 0 vote(s) against
Legal provision: Employee Retirement Income Security

Yes. In a unanimous opinion written by Justice Clarence Thomas, the Court held that Congress intended ERISA to provide a uniform system for regulating retirement schemes and benefits. If a state law conflicts with ERISA, therefore, ERISA must be used in its place. Justice Thomas wrote, "[A]ny state-law cause of action that duplicates, supplements or supplants the ERISA civil enforcement remedy conflicts with the clear congressional intent to make the ERISA remedy exclusive and is therefore preempted."

Verizon v. Trinko, LLP

Tue, 14 Oct 2003 13:00:00 +0000

Case Basics

Docket No.

02-682

Petitioner

Verizon Communications Inc.

Respondent

Law Offices of Curtis V. Trinko, LLP

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

540 U.S. 398 (2004)

Granted

Monday, March 10, 2003

Argued

Tuesday, October 14, 2003

Decided

Tuesday, January 13, 2004

Advocates

Donald B. Verrilli, Jr. (argued the cause for Respondent)

Richard G. Taranto (argued the cause for Petitioner)

Theodore B. Olson (argued the cause for Petitioner, on behalf of the United States, as amicus curiae)

Facts of the Case

Curtis Trinko was an AT&T; customer but received service on lines owned by Verizon, which AT&T; was permitted to use for a fee under the anti-monopoly 1996 Telecommunications Act. Trinko claimed that Verizon discriminated against AT&T; customers by providing them worse service than it provided to its own customers. He claimed that this violated both the Telecommunications Act and the Sherman Anti-Trust Act of 1890, which prohibits monopolies from aggressively defending their monopoly position in the market. A federal district court ruled that Trinko had no grounds to sue because he was not a direct customer of Verizon. A 2nd Circuit Court of Appeals panel, however, reinstated the charges leveled under the Sherman Act.

Question

When a company fails to meet its duty to share its network with competitors under the Telecommunications Act, can it be sued under the Sherman Act?

Conclusion

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

No. In a unanimous opinion delivered by Justice Antonin Scalia, the Court held that the complaint alleging breach of Verizon's Telecommunication Act duties to share its network with competitors did not state a claim under the Sherman Act. The Court reasoned that the 1996 act did not alter antitrust law or add new claims and that Verizon did not violate preexisting antitrust standards. The justices declined to add a new claim by making an exception to the rule that businesses need not aid competitors.

Singleton v. Norris

Sat, 27 Apr 2013 20:11:44 +0000

Case Basics

Docket No.

02-10605

Petitioner

Charles Laverne Singleton

Petitioner Type

Petitioner

Respondent

Larry Norris, Director, Arkansas Department of Correction

Respondent Type

Respondent

Decided

Monday, October 6, 2003

Facts of the Case

Charles Singleton was convicted of first-degree murder in the stabbing death of Mary Lou York, and sentenced to death. Singleton had schizophrenia, and was considered legally sane only when on medication. While in prison, Singleton stopped voluntarily taking his medication. Determining that Singleton was a danger to himself and others, prison officials administered the medication against his will. Singleton appealed, arguing that since taking the medication would cause him to be eligible for execution, the forced medication was no longer in his medical interest, as required by the Supreme Court's due process precedents. Singleton also argued that the Constitution's Eighth Amendment prohibits the execution of an "artificially competent" prisoner. After exhausting Arkansas state remedies, Singleton appealed to a federal District Court, which denied his petition for habeas corpus. On appeal, the Circuit Court of Appeals for the Eighth Circuit rejected Singleton's arguments and reaffirmed his death sentence. The Circuit Court held that since Singleton did not deny that his medication was in his medical interest while the execution was on hold, the forcible administration of medication could not become unconstitutional once an execution date was set. The fact that Singleton's medication would make his execution possible was not to be considered when evaluating "medical interest." The Circuit Court also held that under the Supreme Court’s precedents, the Eighth Amendment only prohibits the execution of actually incompetent prisoners, and not those able to be made competent through medication. Singleton appealed to the Supreme Court.

Question

Does the Eighth Amendment permit a death row inmate - who is legally insane unless taking medication - to be forcibly medicated to the point where he is eligible for execution?

Conclusion

Unanswered. The Court denied Singleton's petition for certiorari, letting the Eighth Circuit's ruling stand. Singleton was executed by the state of Arkansas in 2004.

Schriro v. Summerlin

Mon, 19 Apr 2004 13:00:00 +0000

Case Basics

Docket No.

03-526

Petitioner

Dora B. Schriro, Director, Arizona Department of Corrections

Petitioner Type

Petitioner

Respondent

Warren Wesley Summerlin

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

542 U.S. 348 (2004)

Granted

Monday, December 1, 2003

Argued

Monday, April 19, 2004

Decided

Thursday, June 24, 2004

Advocates

Ken Murray (argued the cause for Respondent)

John Pressley Todd (argued the cause for Petitioner)

James A. Feldman (argued the cause for Petitioner, on behalf of the United States, as amicus curiae)

Facts of the Case

Warren Summerlin killed a loan collector with a hatchet in 1982 and was subsequently convicted of murder. He was sentenced to death by a state trial judge because of the heinous nature of the crime and his previous criminal history. He appealed the sentence, arguing that his attorney's romantic relationship with the prosecutor and the trial judge's proven use of marijuana had prevented him from receiving a fair trial, but the Arizona state courts rejected his appeals.

In June 2002, however, the U.S. Supreme Court issued its decision in Ring v. Arizona. The decision found that the Sixth Amendment right to jury trial meant that only juries, not judges, could sentence someone to death. The Ring decision gave Summerlin new hope. He appealed his conviction, arguing that the decision changed the substance of the law rather than just the procedure used to apply it, and that it should therefore be applied retroactively. The state countered that the change dealt only with who did the actual sentencing, not with the burden of proof, and was therefore only procedural. Because procedural changes are not applied retroactively under the Supreme Court's 1989 decision in Teague v. Lane, the state argued that Summerlin's sentence should be upheld. A divided Ninth Circuit Court of Appeals disagreed, siding instead with Summerlin and ordering the state to reopen his trial for re- sentencing.

Question

Was the change announced by the Supreme Court in Ring v. Arizona substantive in nature and therefore retroactively applicable?

Conclusion

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

No. In a 5-to-4 decision written by Justice Antonin Scalia, the Court held that the changed announced in Ring v. Arizona was merely procedural and therefore not retroactively applicable. Justice Scalia wrote, "[W]e give retroactive effect to only a small set of 'watershed rules of criminal procedure implementing the fundamental fairness and accuracy of the criminal proceeding.' That a new procedural rule is 'fundamental' in some abstract sense is not enough; the rule must be one 'without which the likelihood of an accurate conviction is seriously diminished." (Italics Scalia's, citation omitted). Because the Court could not confidently say that fact-finding by a judge rather than a jury seriously diminished accuracy, it could not apply its Ring ruling retroactively.

Till v. SCS Credit Corp.

Tue, 02 Dec 2003 13:00:00 +0000

Case Basics

Docket No.

02-1016

Petitioner

Lee M. Till, et ux.

Petitioner Type

Petitioner

Respondent

SCS Credit Corporation

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

541 U.S. 465 (2004)

Granted

Monday, June 16, 2003

Argued

Tuesday, December 2, 2003

Decided

Monday, May 17, 2004

Advocates

G. Eric Brunstad, Jr. (argued the cause for Respondent)

David B. Salmons (argued the cause for Petitioners, on behalf of the United States, as amicus curiae)

Rebecca J. Harper (argued the cause for Petitioners)

Facts of the Case

Lee Till owed $4,000 in payments on his truck when he filed for Chapter 13 bankruptcy. Under the Bankruptcy Code, a Chapter 13 debtor must promise each creditor future payments "not less than the [claim's] allowed amount." When a repayment plan includes a series of payments (installments), as Till's did, the installments must equal the "total present value" of the amount owed. Till proposed that he make monthly payments on the truck to SCS Credit with a 9.5 percent yearly interest rate, which was slightly higher than the average loan rate to make up for the increased risk that Till would fail to make a payment (because he had already declared bankruptcy once). SCS, however, argued that it was entitled to 21 percent interest because that was how much it would have made if it had foreclosed on the loan, taken the truck, sold it, and reinvested the proceeds. SCS argued that this 21 percent plan was necessary to ensure that the payments were equal to the "total present value" or "not less than the [claim's] allowed amount." The bankruptcy court ruled for Till. The district court reversed, imposing SCS's 21 percent rate. A divided Seventh Circuit Court of Appeals panel modified that approach slightly, ruling that the 21 percent rate was probably correct but that the parties could introduce evidence that a higher or lower rate should apply.

Question

What is the proper interest rate when a bankruptcy filer seeks to reschedule his payments on a loan so that they are equal to the "total present value" of the loan?

Conclusion

Decision: 5 votes for Till, 4 vote(s) against
Legal provision: Bankruptcy Code, Bankruptcy Act or Rules, or Bankruptcy Reform Act of 1978

In a decision that had no majority opinion, four justices held that the proper rate was the 9.5 percent one arrived at by modifying the average national loan rate to make up for the increased risk of non-payment. While this would not give the creditors the same amount of money that they might have gotten had they seized the collateral for the loan, it nevertheless met the statutory requirement that the repayments equal the "total present value." Justice Clarence Thomas, in a separate opinion that provided the fifth vote needed for judgment, found that the 9.5 percent rate was acceptable, but that it could be even lower because the Bankruptcy Code did not require the judge to accommodate for the risk of non-payment.

Ashcroft v. American Civil Liberties Union

Tue, 02 Mar 2004 13:00:00 +0000

Case Basics

Docket No.

03-218

Petitioner

John D. Ashcroft, Attorney General

Petitioner Type

Petitioner

Respondent

American Civil Liberties Union, et al.

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

542 U.S. 656 (2004)

Granted

Tuesday, October 14, 2003

Argued

Tuesday, March 2, 2004

Decided

Tuesday, June 29, 2004

Advocates

Ann E. Beeson (argued the cause for Respondents)

Theodore B. Olson (argued the cause for Petitioner)

Facts of the Case

Congress passed the Child Online Protection Act (COPA) to prevent minors from accessing pornography online. The American Civil Liberties Union (ACLU) and online publishers sued in federal court to prevent enforcement of the act, arguing that it violated the Free Speech clause of the First Amendment. The District Court agreed. On appeal, a Third Circuit Court of Appeals panel affirmed, holding that because the act used "community standards" to decide which material was harmful to minors, it would prohibit material that was felt offensive in the most "puritanical" communities from being displayed in more "tolerant" ones.

On appeal, the Supreme Court ruled that the "community standards" provision alone did not make the act unconstitutional and sent the case back to the Third Circuit for further evaluation.

The Third Circuit again prohibited implementation of the act, holding that it was likely to fail the "strict scrutiny" test because it was not narrowly tailored - that is, it prevented online publishers from publishing some material that adults had a right to access - and because it did not use the least restrictive means possible to protect children (the court found that blocking software installed on home computers by parents would do as good a job without preventing free speech). For similar reasons, the panel found that the act was unconstitutionally "overbroad" - that is, it applied to too much protected material.

Question

Is the Child Online Protection Act's requirement that online publishers prevent children from accessing "material that is harmful to minors" likely to violate the First Amendment by restricting too much protected speech and using a method that is not the least restrictive one available?

Conclusion

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

Yes. In an interesting 5-to-4 vote, with Justices Kennedy, Stevens, Souter, Thomas and Ginsburg on one side and Chief Justice Rehnquist and Justices Scalia, Breyer and O'Connor on the other, the Court found that Congress had not yet met its burden to show that the COPA requirements were more effective than other methods of preventing minors. Justice Anthony Kennedy, in the majority opinion, wrote that the district court's injunction "was not an abuse of discretion, because on this record there are a number of plausible, less restrictive alternatives to the statute." The majority also emphasized that barring the statute's enforcement during the trial would be less harmful than allowing it, because allowing it would be likely to prevent online publishers from publishing certain material.

Grupo Dataflux v. Atlas Global Group, L.P.

Wed, 03 Mar 2004 13:00:00 +0000

Case Basics

Docket No.

02-1689

Petitioner

Grupo Dataflux

Petitioner Type

Petitioner

Respondent

Atlas Global Group, L.P., et al.

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

541 U.S. 567 (2004)

Granted

Tuesday, October 14, 2003

Argued

Wednesday, March 3, 2004

Decided

Monday, May 17, 2004

Advocates

William J. Boyce (argued the cause for Petitioner)

Roger B. Greenberg (argued the cause for Respondents)

Facts of the Case

Atlas Global Group was a limited partnership company created under Texas law. They filed a suit in federal court against Grupo Dataflux, a Mexican corporation. The suit dealt with a state law, but Atlas filed the case in federal court because, it claimed, the court had "diversity jurisdiction" (when a case involves citizens of two different states, or an American citizen and a foreign citizen, it is heard in federal court). However, at the time the case was filed, two of Atlas's partners were Mexican citizens (they left the partnership before the trial began). After the case was decided, but before the judgment was announced, Grupo Dataflux filed a motion to dismiss the case because the court did not have diversity jurisdiction. The judge granted the motion, finding that Atlas was a Mexican "citizen" at the time of filing because of the citizenship of its partners, and that the federal courts therefore did not have jurisdiction. On appeal, Atlas argued that even if the necessary diversity had not been present at the time of filing, it was present before the trial began and the court should therefore ignore the error under an exception for cases that have already been decided. A Fifth Circuit Court of Appeals panel agreed, reversing the decision.

Question

If a suit is filed in federal court without the diversity necessary to establish jurisdiction, but the citizenship of one of the parties changes before the case begins so that diversity is present, should the court ignore the filing error?

Conclusion

Decision: 5 votes for Grupo Dataflux, 4 vote(s) against
Legal provision: 28 U.S.C. 1332

No. In a 5-to-4 decision written by Justice Antonin Scalia, the Court ruled that allowing diversity jurisdiction to change after a case is filed would create uncertainty and expensive litigation that dealt with jurisdiction rather than the merits of the case. "Uncertainty regarding the question of jurisdiction is particularly undesirable, and collateral litigation on the point particularly wasteful," wrote Justice Scalia. "The stability provided by our time tested rule (of requiring diversity at the time of filing) weighs heavily against the approval of any new deviation."

Elk Grove Unified School District v. Newdow

Wed, 24 Mar 2004 13:00:00 +0000

Location

Elk Grove Unified School District

9510 Elk Grove-Florin Blvd Elk Grove CA 95624

Elk Grove, CA 95624

United States

38° 24' 47.5416" N, 121° 22' 20.946" W

See map: Google Maps

Case Basics

Docket No.

02-1624

Petitioner

Elk Grove Unified School District and David W. Gordon, Superintendent

Respondent

Michael A. Newdow, et al.

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

542 U.S. 1 (2004)

Granted

Tuesday, October 14, 2003

Argued

Wednesday, March 24, 2004

Decided

Monday, June 14, 2004

Advocates

Terence J. Cassidy (argued the cause for Petitioners)

Michael A. Newdow (argued the cause for Respondent)

Theodore B. Olson (argued the cause for Respondent United States, in support of petitioners)

Facts of the Case

Michael Newdow's daughter attended public school in the Elk Grove Unified School District in California. Elk Grove teachers began school days by leading students in a voluntary recitation of the Pledge of Allegiance, including the words "under God" added by a 1954 Congressional act. Newdow sued in federal district court in California, arguing that making students listen - even if they choose not to participate - to the words "under God" violates the establishment clause of the U.S. Constitution's First Amendment.

The district court dismissed Newdow's complaint for lack of standing, because he and the mother of his daughter are divorced and he does not have custody. The U.S. Ninth Circuit Court of Appeals reversed, holding that Newdow did have standing "to challenge a practice that interferes with his right to direct the religious education of his daughter." The Ninth Circuit ruled that Congress's 1954 act adding the words "under God" to the Pledge and the school district policy requiring it be recited both violated the First Amendment's establishment clause.

Question

Does Michael Newdow have standing to challenge as unconstitutional a public school district policy that requires teachers to lead willing students in reciting the Pledge of Allegiance? Does a public school district policy that requires teachers to lead willing students in reciting the Pledge of Allegiance, which includes the words "under God," violate the Establishment Clause of the First Amendment?

Conclusion

Decision: 8 votes for Elk Grove Unified School District, 0 vote(s) against
Legal provision:

In an opinion authored by Justice John Paul Stevens, the Supreme Court found that Newdow did not have standing to bring suit because he did not have sufficient custody over his daughter. "When hard questions of domestic relations are sure to affect the outcome, the prudent course is for the federal court to stay its hand rather than reach out to resolve a weighty question of federal constitutional law," Justice Stevens wrote. Because it found that Newdow did not have standing, the Court failed to reach the constitutional question. Chief Justice Renquist and Justices Sandra Day O'Connor and Clarence Thomas all wrote seperate concurrences, saying that requiring teachers to lead the Pledge is constitutional.

Beard v. Banks

Tue, 24 Feb 2004 13:00:00 +0000

Case Basics

Docket No.

02-1603

Petitioner

Jeffrey A. Beard, Secretary, Pennsylvania Department of Corrections, et al.

Petitioner Type

Petitioner

Respondent

George E. Banks

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

542 U.S. 406 (2004)

Granted

Tuesday, September 30, 2003

Argued

Tuesday, February 24, 2004

Decided

Thursday, June 24, 2004

Advocates

Ronald Eisenberg (argued the cause for Petitioners)

Albert J. Flora, Jr. (argued the cause for Respondent)

Facts of the Case

In 1982, George Banks was sentenced to death in Pennsylvania for the murder of 13 people. After the Pennsylvania Supreme Court upheld the conviction, Banks unsuccessfully sought a writ of habeas corpus in federal district court. Reversing the district court, the Third Circuit Court of Appeals found Banks's death sentence unconstitutional. The court held that jury instructions during sentencing led jurors to believe they could not vote against the death penalty unless they all agreed on mitigating evidence (that is, evidence that would have inclined them to vote against the death penalty). This, the court reasoned, violated the U.S. Supreme Court's ruling in Mills v. Maryland (1988). The U.S. Supreme Court reversed the decision (in part) and remanded it. Pointing to its opinion in Teague v. Lane (1989) and the fact that Mills was decided after Banks's conviction, the Court reasoned that the appeals court did not consider whether Mills could be "retroactively" applied. The Third Circuit Court - reviewing its ruling - did not change its original opinion. It found that "Mills did not announce a new rule of constitutional law for retroactivity purposes" and that Banks's death sentence was unconstitutional.

Question

Does the Supreme Court's decision in Mills v. Maryland (1988) create a new rule of law that cannot be applied retroactively to award sentencing relief to a prisoner whose conviction became final before Mills was announced? 2. If Mills applies retroactively and a state supreme court rejects a Mills challenge because the jury was not told that it must unanimously agree on mitigating factors, is that decision consistent with Supreme Court precedent?

Conclusion

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

Ruling yes on the first question, the Court did not need to reach the second question. In a 5-to-4 decision written by Justice Clarence Thomas, the Court found that the rule announced in Mills - that sentencing schemes could not prevent jurors from considering mitigating evidence that had not been accepted unanimously when deciding whether to apply the death penalty - was a new rule, because it was not compelled by previous Court decisions. As a new rule, it could only be applied retroactively if it was a "watershed rule[] of criminal procedure implicating the fundamental fairness and accuracy of the criminal proceeding." Finding that it was not a watershed rule, the Court found that it could not be applied retroactively and that Beards' conviction was therefore constitutional.

Locke v. Davey

Tue, 02 Dec 2003 13:00:00 +0000

Case Basics

Docket No.

02-1315

Petitioner

Gary Locke, Governor of Washington, et al.

Petitioner Type

Petitioner

Respondent

Joshua Davey

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

540 U.S. 712 (2004)

Granted

Monday, May 19, 2003

Argued

Tuesday, December 2, 2003

Decided

Wednesday, February 25, 2004

Advocates

Narda Pierce (argued the cause for Petitioners)

Jay A. Sekulow (argued the cause for Respondent)

Theodore B. Olson (argued the cause for Respondent, on behalf of the United States, as amicus curiae)

Facts of the Case

The Washington State Promise Scholarship, created by the state legislature in 1999, gives college scholarship money to talented students. However, this money cannot be used to obtain a degree in theology if the program is taught to cause belief. Washington's constitution prohibits funding religious instruction. The 1969 state code applied this ban to college financial aid.

Joshua Davey forfeited his Promise Scholarship money in order to major in pastoral ministries at a private Christian college. Davey filed suit in U.S. district court, claiming the state constitution's ban on funding religious instruction violated his First Amendment right to free exercise of religion (in the U.S. Constitution). The district court rejected Davey's claim. The Ninth Circuit Court of Appeals reversed, concluding Davey's free exercise rights were violated.

Question

If a state provides college scholarships for secular instruction, does the First Amendment's free exercise clause require a state to fund religious instruction?

Conclusion

Decision: 7 votes for Locke, 2 vote(s) against
Legal provision: Free Exercise of Religion

No. In a 7-2 opinion delivered by Chief Justice William Rehnquist, the Court ruled that a state does not violate the First Amendment's free exercise clause when it funds secular college majors but excludes devotional theology majors. The Court rejected Davey's argument that the state scholarship program is unconstitutional because it is not neutral toward religion. "The State has merely chosen not to fund a distinct category of instruction," the Court wrote. Similarly the Washington Constitution - which explicitly prohibits state money from going to religious instruction - does not violate the free exercise clause. Unlike laws and programs the Court has struck down under the free exercise clause, nothing in either the scholarship program or the state constitution "suggests animus towards religion." States have a "historic and substantial interest" in excluding religious activity from public funding.

Crawford v. Washington

Mon, 10 Nov 2003 13:00:00 +0000

Case Basics

Docket No.

02-9410

Petitioner

Michael D. Crawford

Petitioner Type

Petitioner

Respondent

Washington

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

541 U.S. 36 (2004)

Granted

Monday, June 9, 2003

Argued

Monday, November 10, 2003

Decided

Monday, March 8, 2004

Advocates

Steven C. Sherman (argued the cause for Respondent)

Jeffrey L. Fisher (argued the cause for Petitioner)

Michael R. Dreeben (argued the cause for Petitioner, on behalf of the United States, as amicus curiae)

Facts of the Case

Michael Crawford stabbed a man he claimed tried to rape his wife. During Crawford's trial, prosecutors played for the jury his wife's tape-recorded statement to the police describing the stabbing. The statement contradicted Crawford's argument that he stabbed the man in defense of his wife. Because it was pre-recorded, Crawford could not cross-examine the statement. The jury convicted Crawford for assault.

Crawford claimed the playing of his wife's statement, with no chance for cross-examination, violated the Sixth Amendment guarantee that "[i]n all criminal prosecutions, the accused shall enjoy the right...to be confronted with the witnesses against him." The state supreme court upheld the conviction, relying on the U.S. Supreme Court's decision in Ohio v. Roberts (1980). That decision allowed the admission of out-of-court testimony against a defendant if that testimony was reliable.

Question

Does playing out-of-court testimony to a jury, with no chance for cross- examination, violate a defendant's Sixth Amendment guarantee that "[i]n all criminal prosecutions, the accused shall enjoy the right...to be confronted with the witnesses against him?"

Conclusion

Decision: 9 votes for Crawford, 0 vote(s) against
Legal provision: Right to Confront and Cross-Examine, Compulsory Process

Yes. In a 9-0 opinion delivered by Justice Antonin Scalia, the Court sided with Crawford and ruled that the Sixth Amendment's Confrontation Clause gives defendants the right to confront witnesses and cross-examine their testimony. This includes testimony police gather. The Court reasoned that the Framers intended the Confrontation Clause to prohibit out-of-court testimony as evidence against defendants. By allowing out-of-court testimony if it was "reliable," the Roberts decision departed from the Framers' intent. The Court overruled Roberts. Chief Justice Rehnquist, joined by Justice Sandra Day O'Connor, concurred but opposed overruling Roberts.

Sabri v. United States

Wed, 03 Mar 2004 13:00:00 +0000

Case Basics

Docket No.

03-44

Petitioner

Basim Omar Sabri

Petitioner Type

Petitioner

Respondent

United States

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

541 U.S. 600 (2004)

Granted

Tuesday, October 14, 2003

Argued

Wednesday, March 3, 2004

Decided

Monday, May 17, 2004

Advocates

Andrew Stuart Birrell (argued the cause for Petitioner)

Michael R. Dreeben (argued the cause for Respondent)

Facts of the Case

Basim Omar Sabri, a Minneapolis landlord and developer, tried to bribe a Minneapolis City Council member who sat on the board of an organization that dispersed funding for economic revitalization of city neighborhoods. Some of the funds dispersed by the organization were federal funds.

Sabri was charged in federal court with bribery. He moved to dismiss the charges, claiming that the section of United States Code that he was charged under was unconstitutional. He claimed that Congress could only regulate the dispersal of federal funds; because the statute did not require the prosecutors to show that the bribery had affected any federal funds, only that it had affected an organization that received federal funds, he argued that it was outside of Congress's power to legislate. The district court sided with Sabri and dismissed the charges.

On appeal, an Eighth Circuit Court of Appeals panel reversed. It found that, because federal funds were often mixed with other funds by organizations that distributed them, it would be difficult for prosecutors to prove that the funds affected by an attempted bribe were federal funds. As a result, the government would have to regulate all bribes to organizations that dispersed federal funds in order to meaningfully protect federal funds. Because Congress had authority under the necessary and proper clause and the spending clause (both found in Article I, Section 8 of the Constitution) to ensure that government funds were not misspent, the bribery statute was therefore constitutional.

Question

May Congress make it a federal crime to bribe officials of non-federal organizations that distribute some federal funds without requiring prosecutors to prove that the bribe actually affected federal funds?

Conclusion

Decision: 9 votes for United States, 0 vote(s) against
Legal provision: 18 U.S.C. 666

Yes. In a unanimous opinion authored by Justice David Souter, the Court held that Article I of the Constitution allows Congress to prohibit bribery of organizations that distribute federal funds. The Justices found that the Spending Clause authorizes Congress to spend money for the general welfare, and that the Necessary and Proper Clause authorizes it to take any reasonable steps to prevent such money from being misspent. These reasonable steps include prohibiting bribery. The Court rejected Sabri's argument that the law was unconstitutional because it applied to all bribes, not just those made in connection with actual federal funds. The Court held that to require proof of a connection between the bribes and federal funds would unreasonable and impractical; it was within Congress's power to prohibit all bribes to all federally-funded organizations. Justice Clarence Thomas wrote a separate opinion concurring in the judgment, in which he questioned whether the Court had been correct to interpret the Necessary and Proper Clause so expansively.

United States v. Patane

Tue, 09 Dec 2003 13:00:00 +0000

Case Basics

Docket No.

02-1183

Petitioner

United States

Petitioner Type

Petitioner

Respondent

Samuel Francis Patane

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

542 U.S. 630 (2004)

Granted

Monday, April 21, 2003

Argued

Tuesday, December 9, 2003

Decided

Monday, June 28, 2004

Advocates

Michael R. Dreeben (argued the cause for Petitioner)

Jill M. Wichlens (argued the cause for Respondent)

Facts of the Case

Samuel Patane was arrested at his home for calling his ex-girlfriend in violation of a restraining order. During the arrest, police offers began reading Patane his Miranda rights. Patane told the officers that he knew his rights. The officers then stopped reading them, at which point Patane told police that he had a gun in his house. They searched the house with his permission and found the gun. As an ex-felon, Patane was not permitted to possess a gun and was prosecuted for possession.

During the trial on gun possession charges, Patane argued that his arrest violated the Fourth Amendment prohibition of unreasonable searches and seizures and the Fifth Amendment right not to incriminate oneself because there was not probable cause to arrest him and because the gun had been found as a result of an un-Mirandized confession.

The district court initially ruled that there was not probable cause for his arrest and that it was therefore unconstitutional. A 10th Circuit Court of Appeals panel disagreed, holding that Patane's ex-girlfriend had given police probable cause for the arrest. However, the panel held that gun could not be used as evidence because it had been found as the result of an un-Mirandized (and therefore unconstitutional) confession. The government appealed, arguing that physical evidence found as the result of un-Mirandized testimony could be used in court, despite the fact that the testimony itself was inadmissable.

Question

Can physical evidence found as a result of un-Mirandized but voluntary testimony be used in court?

Conclusion

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

Yes. In a decision without a majority opinion, three justices wrote that the Miranda warnings were merely intended to prevent violations of the Constitution, and that because Patane's un-Mirandized testimony was not admitted at trial the Constitution (specifically the Fifth Amendment's protection against self-incrimination) had not been violated. Physical evidence obtained from un-Mirandized statements, as long as those statement were not forced by police, were constitutionally admissible. Two other justices also held that the physical evidence was constitutionally admissible, but did so with the understanding that the Miranda warnings must be accommodated to other objectives of the criminal justice system. They did not discuss whether the Miranda warnings were, in themselves, constitutionally required.

Fellers v. United States

Wed, 10 Dec 2003 13:00:00 +0000

Case Basics

Docket No.

02-6320

Petitioner

John J. Fellers

Petitioner Type

Petitioner

Respondent

United States

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

540 U.S. 519 (2004)

Granted

Monday, March 10, 2003

Argued

Wednesday, December 10, 2003

Decided

Monday, January 26, 2004

Advocates

Michael R. Dreeben (argued the cause for Respondent)

Seth P. Waxman (argued the cause for Petitioner)

Facts of the Case

After a grand jury indicted Fellers, police arrested him at home. Fellers made incriminating statements during the arrest. Police officially interrogated Fellers at county jail and told him of his Miranda rights. Fellers signed a waiver of these rights and restated incriminating statements he had made at home. Fellers later argued that, when he was arrested in his home without a lawyer, police "deliberately elicited" incriminating statements. Pointing to his Sixth Amendment right to counsel, Fellers argued it would be unconstitutional to admit at trial his incriminating statements made in jail, because these were the "fruits" of comments made at home without a lawyer.

Fellers was convicted in federal district court. A federal appellate court affirmed the conviction and ruled that officers did not violate Fellers' Sixth Amendment right to counsel either at home or in the jailhouse.

Question

(1) Was the appellate court correct to rule that officers did not violate Fellers' Sixth Amendment right to counsel because officers did not interrogate him? (2) Should Fellers' statements in the jailhouse - given after police Mirandized him - be suppressed because they were fruits of an unconstitutional interview in his home?

Conclusion

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

Question 1: No. Question 2: Remanded. In a unanimous decision delivered by Justice Sandra Day O'Connor, the Court held that officers violated Fellers' Sixth Amendment right to counsel by deliberately eliciting incriminating information from him after an indictment and in the absence of a lawyer. The Court rejected the appellate court's argument that the Sixth Amendment right to counsel was irrelevant because police did not "interrogate" Fellers at his home. The Court sent the case back to the appellate court to determine - under the Sixth Amendment - whether Fellers' statements in jail should be suppressed because they were "fruits" of his unconstitutional questioning at home.

Raytheon v. Hernandez

Wed, 08 Oct 2003 13:00:00 +0000

Case Basics

Docket No.

02-749

Petitioner

Raytheon Company

Petitioner Type

Petitioner

Respondent

Joel Hernandez

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

540 U.S. 44 (2003)

Granted

Monday, February 24, 2003

Argued

Wednesday, October 8, 2003

Decided

Tuesday, December 2, 2003

Advocates

Paul D. Clement (argued the cause for Petitioner, on behalf of the United States, as amicus curiae)

Stephen G. Montoya (argued the cause for Respondent)

Carter G. Phillips (argued the cause for Petitioner)

Facts of the Case

In 1991, Joel Hernandez tested positive for cocaine use in a drug test administered by his employer. As a result of the incident, he was forced to resign. In 1994, he reapplied for a job from the company. His application was rejected. Hernandez claimed that the company was discriminating against him because of his drug and alcohol addiction (though at the time he reapplied he had been sober for two years) in violation of the Americans with Disabilities Act of 1990. The district court sided with the company, dismissing the case before it ever went to trial. A Ninth Circuit Court of Appeals panel unanimously reversed, however, holding that Raytheon's decision not to rehire Hernandez because of an incident related to his past addiction could constitute discrimination under the act.

Question

Does the Americans with Disabilities Act permit employers to refuse to rehire job applicants because of prior workplace rule infractions related to drug or alcohol addiction?

Conclusion

Decision: 7 votes for Raytheon, 0 vote(s) against
Legal provision: Americans with Disabilities Act (ADA)

Yes. The Court unanimously held that an employer may refuse to rehire an employee who was terminated in connection with drug or alcohol-related incidents as long as the refusal is based on a policy of not rehiring employees who previously violated workplace rules rather than on the worker's addiction. That is, an employer may refuse to hire someone who was terminated for coming to work under the influence, but may not refuse to hire someone whose previous addiction did not result in any workplace rule infractions. Justices David Souter and Stephen Breyer took no part in this case.

United States v. Lara

Wed, 21 Jan 2004 13:00:00 +0000

Case Basics

Docket No.

03-107

Petitioner

United States

Petitioner Type

Petitioner

Respondent

Billy Jo Lara

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

541 U.S. 193 (2004)

Granted

Tuesday, September 30, 2003

Argued

Wednesday, January 21, 2004

Decided

Monday, April 19, 2004

Advocates

Edwin S. Kneedler (argued the cause for Petitioner)

Alexander F. Reichert (argued the cause for Respondent)

Facts of the Case

Bureau of Indian Affairs officials arrested Billy Jo Lara on the Spirit Lake Nation Reservation for public intoxication (though Lara is not a member of the reservation). During the arrest Lara attacked an officer.

A tribal court convicted Lara of assault. The federal government then indicted Lara for assaulting a federal officer. Lara moved to dismiss the indictment, claiming the federal charges violated the Fifth Amendment's prohibition against double jeapordy (being charged twice for the same crime). The district court denied Lara's motion. Lara then entered a conditional guilty plea, reserving the right to appeal the denial of his Fifth Amendment motion.

A panel of the U.S. Eighth Circuit Court of Appeals affirmed the district court ruling. However, the Eight Circuit reversed when it reviewed the case en banc (with the full court), ruling that Lara's federal charges violated the double jeapordy clause. The court reasoned that the only source of authority for Spring Lake Nation to prosecute a nonmember (like Lara) came from the federal Indian Civil Rights Act (1968). Because the federal government delegated this prosecutorial authority to Indian Tribes, charging Lara for the same crime in tribal and federal courts was essentially trying Lara twice under federal authority.

Question

Does the Indian Civil Rights Act (1968) give Indian tribes separate sovereignty to prosecute nonmembers (as opposed to delegating federal power to the tribes for prosecution purposes) such that prosecution in tribal and federal courts for the same crime would not violate the Fifth Amendment double jeopardy clause?

Conclusion

Decision: 7 votes for United States, 2 vote(s) against
Legal provision: Article 1, Section 1: Delegation of Powers

Yes. In an opinion written by Justice Stephen G. Breyer and joined by Chief Justice Rehnquist and three other Justices, the Court found that the right to prosecute nonmember Indians is inherent in the sovereignty of Native American tribes. Congress may constitutionally choose to restrict this right, but its choice not to (or its choice to relax earlier-imposed restrictions) is different from a delegation of federal prosecutorial power. Prosecuting a crime under both federal and tribal law, therefore, does not violate the Constitution.

Tennard v. Dretke

Mon, 22 Mar 2004 13:00:00 +0000

Case Basics

Docket No.

02-10038

Petitioner

Robert James Tennard

Petitioner Type

Petitioner

Respondent

Doug Dretke, Director, Texas Department of Criminal Justice, Correctional Institutions Division

Respondent Type

Respondent

Consolidation

Robert Smith v. Doug Dretke, Director, Texas Department of Criminal Justice, Correctional Institutions Division, No. 02-11309

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

542 U.S. 274 (2004)

Granted

Tuesday, October 14, 2003

Argued

Monday, March 22, 2004

Decided

Thursday, June 24, 2004

Advocates

Edward L. Marshall (argued the cause for Respondent)

Robert C. Owen (argued the cause for Petitioner)

Facts of the Case

Robert Tennard was convicted of murder. During the sentencing phase, he presented evidence that he had an IQ of 67. The instructions given to the jury by the judge when it was considering whether to apply the death penalty, however, did not account for this - they instructed they jury to determine whether the crime was committed deliberately and whether Tennard posed a future risk. Under Penry v. Lynaugh, 492 U.S. 302, those instructions are not enough to allow the jury to weigh a defendant's mental retardation in his favor. After he was sentenced to death, Tennard filed a habeas corpus petition in federal district court, claiming that the sentence, given the shortcomings of the jury instructions, violated the Eighth Amendment's prohibition of Cruel and Unusual Punishment. The district court rejected the petition. The Fifth Circuit Court of Appeals affirmed, ruling that Tennard had no shown that his mental retardation was constitutionally relevant. To be constitutionally relevant, Tennard's retardation would have had to be responsible for his crime, and Tennard had not shown that this was the case.

After the Supreme Court decided, in Atkins v. Virginia, 536 U.S. 304, that executing the mentally retarded violated the Eighth Amendment, the Fifth Circuit reconsidered its holding. It affirmed the decision on the grounds that execution was only unconstitutional if the defendant could show that his mental retardation had actually caused the crime; being mentally retarded in and of itself did not exempt someone from the death penalty.

Question

Does the Supreme Court's prohibition of executing mentally retarded people in Atkins v. Virginia apply if the crime cannot be attributed to mental retardation?

Conclusion

Decision: 6 votes for Tennard, 3 vote(s) against
Legal provision: 28 USC 2241-2255 (habeas corpus)

In a fairly narrow ruling 6-to-3 decision written by Justice Sandra Day O'Connor, the Court held that Tennard's mental retardation could reasonably be understood as relevant to his crime. Especially given the fact that the prosecutor emphasized Tennard's retardation when discussing the likelihood that he would be dangerous in the future, the Court found that the jury instructions did not sufficiently permit the jury to weigh Tennard's mental retardation in his favor.

F. Hoffman-LaRoche, Ltd. v. Empagran S.A.

Mon, 26 Apr 2004 13:00:00 +0000

Case Basics

Docket No.

03-724

Petitioner

F. Hoffmann-La Roche Ltd, et al.

Petitioner Type

Petitioner

Respondent

Empagran S.A., et al.

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

542 U.S. 155 (2004)

Granted

Monday, December 15, 2003

Argued

Monday, April 26, 2004

Decided

Monday, June 14, 2004

Advocates

R. Hewitt Pate, III (argued the cause for Petitioners, on behalf of the United States, as amicus curiae)

Stephen M. Shapiro (argued the cause for Petitioners)

Thomas C. Goldstein (argued the cause for Respondents)

Facts of the Case

Under the Foreign Trade Antitrust Improvements Act of 1982 (FTAIA), the Sherman Act (which regulates monopolies and attempts to unfairly raise prices) does not apply to foreign commerce unless that commerce significantly harms domestic commerce, American imports, or American exporters. In this case, several companies that purchase and resell vitamins sued several vitamin manufacturers for illegal attempts to raise prices, both within the United States and in foreign countries. The manufacturers asked the district judge to dismiss several of the vitamin purchasers from the case because they only did business in other countries and, the manufacturers argued, could therefore not bring claims under the Sherman Act. The purchasers countered that the foreign price-fixing attempts were linked to the domestic attempts and could therefore be heard under the exception to the FTAIA. The district court sided with the manufacturers. On appeal, a D.C. Circuit Court of Appeals panel reversed, finding that the price fixing schemes were independent of each other but that Congress' intent had been to prevent price-fixing both at home and abroad, and that even the foreign claims could therefore be brought under the exception to the FTAIA.

Question

Under the Foreign Trade Antitrust Improvements Act of 1982, do Sherman Act claims apply to the effects of foreign price-fixing schemes if those schemes do not have domestic effects?

Conclusion

Decision: 8 votes for F. Hoffman-LaRoche, Ltd., 0 vote(s) against
Legal provision: 15 U.S.C. 6

No. The Court unanimously ruled that Congress' intent in passing the FTAIA was to prevent American courts from interfering in foreign commerce. Congress made an exception for foreign commerce that affected domestic commerce, but the exception should not be read as a general prohibition against price-fixing in all parts of the world. In the majority opinion (Justices Clarence Thomas and Antonin Scalia filed a separate opinion concurring in judgment), Justice Stephen G. Breyer wrote, "Why should American law supplant, for example, Canada's or Great Britain's or Japan's own determination about how best to protect (their own) customers from anticompetitive conduct engaged in" by their own companies?

United States v. Dominguez Benitez

Wed, 21 Apr 2004 13:00:00 +0000

Case Basics

Docket No.

03-167

Petitioner

United States

Petitioner Type

Petitioner

Respondent

Carlos Dominguez Benitez

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

542 U.S. 74 (2004)

Granted

Monday, December 8, 2003

Argued

Wednesday, April 21, 2004

Decided

Monday, June 14, 2004

Advocates

Myra D Mossman (argued the cause for Respondent)

Dan Himmelfarb (argued the cause for Petitioner)

Facts of the Case

Carlos Dominguez Benitez confessed to selling drugs to an informant. He made a plea agreement with the government in which he would plead guilty to conspiracy to sell drugs, which normally carried a 10-year minimum sentence. However, the government agreed to ask the judge to reduce the sentence below that minimum. The plea agreement also said that, if the judge did not agree to the government's request to lower the sentence, Dominguez could not withdraw his guilty plea. During discussions of the plea, the judge failed to mention the fact that it prohibited him from withdrawing his plea (the written statement, which did contain the fact, was read to him at another time). When the judge ruled that he could not lower the sentence, Dominguez appealed. He argued that the judge's failure to tell him that he would be unable to withdraw his appeal was a "plain error" under Federal Rule of Criminal Procedure 52 and therefore required reversal. The prosecutors countered that, in order to show that the judge had made a "plain error" Dominguez would need to show not just that he had made a mistake but also that it was reasonably likely that, without the error, Dominguez would not have pled guilty. A Ninth Circuit Court of Appeals rejected that argument, siding with Dominguez to reverse the decision.

Question

In order to show that a judge's mistake is a reversible "plain error" under Federal Rule of Criminal Procedure 52, must a defendant show that it is reasonably likely he would not have pled guilty without the mistake?

Conclusion

Decision: 9 votes for United States, 0 vote(s) against
Legal provision: Federal Rules of Criminal Procedure (or relevant rules of a circuit court)

Yes. In a unanimous decision, the Court ruled that the judge's error most likely had no effect on Dominguez's decision to plead guilty, because he had already confessed to the crime and had little chance of winning at trial. Under Rule 52, a plain error is an "error that affects substantial rights." Because the error did not harm Dominguez - he would likely have pled guilty anyway - it was not a reversible plain error. Justice David H. Souter, writing for 8 members of the Court (Justice Antonin Scalia wrote a separate opinion concurring in judgment), wrote, "The point of the question is not to second- guess a defendant's actual decision... The point, rather, is to enquire whether the omitted warning would have made the difference required by the standard of reasonable probability; it is hard to see here how the warning could have had an effect on Dominguez's assessment of his strategic position."

Scarborough v. Principi

Mon, 23 Feb 2004 13:00:00 +0000

Case Basics

Docket No.

02-1657

Petitioner

Randall C. Scarborough

Petitioner Type

Petitioner

Respondent

Anthony J. Principi, Secretary of Veterans Affairs

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

541 U.S. 401 (2004)

Granted

Tuesday, September 30, 2003

Argued

Monday, February 23, 2004

Decided

Monday, May 3, 2004

Advocates

Jeffrey P. Minear (argued the cause for Respondent)

Brian Wolfman (argued the cause for Petitioner)

Facts of the Case

Randall Scarborough won a case against the Department of Veterans Affairs. He then applied for attorney's fees to the U.S. Veterans' Court under the federal Equal Access to Justice Act (EAJA). Under the EAJA, the government must pay attorney's fees to anyone who wins against the federal government in litigation unless the government can show that its position was "substantially justified." However, Scarborough's attorney submitted an incomplete application, neglecting to assert that the government's position was not substantially justified. Though he amended and resubmitted it, he did so after the 30-day filing deadline. The Veterans' Court dismissed the application for "lack of subject matter jurisdiction" - that is, because it was not filed in its complete form within the 30-day deadline. The Court of Appeals for the Federal Circuit affirmed.

Question

May someone who won a suit against the government and applied for repayment of attorney's fees under the Equal Access to Justice Act amend his application to assert that the government's position in the suit was not "substantially justified"?

Conclusion

Decision: 7 votes for Scarborough, 2 vote(s) against
Legal provision: Equal Access to Justice

Yes. In a 7-to-2 opinion written by Justice Ruth Bader Ginsburg, the Court held that the statement on the application that the government's position had not been "substantially justified" was merely procedural. There was no need to prove the assertion - the applicant merely had to make the claim to shift the burden of proof to the government. Because the government was not harmed by the initial omission of the statement - filing the claim made it obvious that the applicant thought the government's position was not substantially justified, even without the specific statement - Scarborough should be able to amend his application even after the 30-day filing period had passed.

Household Credit Services v. Pfennig

Mon, 23 Feb 2004 13:00:00 +0000

Case Basics

Docket No.

02-857

Petitioner

Household Credit Services, Inc. and MBNA America Bank, N.A.

Petitioner Type

Petitioner

Respondent

Sharon R. Pfennig

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

541 U.S. 232 (2004)

Granted

Friday, June 27, 2003

Argued

Monday, February 23, 2004

Decided

Wednesday, April 21, 2004

Advocates

Barbara B. McDowell (argued the cause for Petitioners, on behalf of the United States, as amicus curiae)

Sylvia Antalis Goldsmith (argued the cause for Respondent)

Seth P. Waxman (argued the cause for Petitioners)

Facts of the Case

Sharon Pfennig went over her $2000 credit limit. The company that issued Pfennig her credit card, Household Credit Services, Inc., charged her a fee of $29 for each month that her balance remained over $2000. This fee was listed in the "Purchases" category on her monthly statement rather than as a "finance charge." Under the Truth in Lending Act (TILA), any charges "incident to the extension of credit" must be listed separately as "finance charges."

Household Credit Services chose not to list the over-limit fee as a "finance charge," however, based on the Federal Reserve Board's definition of the term, which explicitly excludes "charges ... for exceeding a credit limit." Pfenning countered that the Board's definition was an unreasonable interpretation of TILA's plain language and should therefore be disregarded.

The district court sided with Household Credit Services, finding that the the Federal Reserve Board had properly exercised its authority under TILA to define the term, that the definition was a reasonable interpretation of TILA, and that the credit company was therefore justified in relying on its definition. The Sixth Circuit Court of Appeals reversed.

Question

Was the Federal Reserve Board's exclusion of over-limit fees from the definition of "finance charges" a reasonable interpretation of the Truth in Lending Act?

Conclusion

Decision: 9 votes for Household Credit Services, 0 vote(s) against
Legal provision: Truth in Lending

Yes. In a unanimous decision written by Justice Clarence Thomas, the Court found that the Board's definition of "finance charge" was reasonable under the language of TILA. Because neither side challenged the authority of the Board to interpret the act (Pfennig just challenged its end result as unreasonable), under Chevron USA Inc. v. Natural Resources Defense Council, 467 U.S. 837, the Court would have to find that the Board's regulation was clearly contrary to the unambiguous intent of Congress in order to overturn it. Finding that Congress's intent with respect to over-limit fees was ambiguous, Justice Thomas wrote that the regulation was entitled to deference and the credit company's reliance on it could therefore not be punished.

Missouri v. Seibert

Tue, 09 Dec 2003 13:00:00 +0000

Case Basics

Docket No.

02-1371

Petitioner

Missouri

Petitioner Type

Petitioner

Respondent

Patrice Seibert

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

542 U.S. 600 (2004)

Granted

Monday, May 19, 2003

Argued

Tuesday, December 9, 2003

Decided

Monday, June 28, 2004

Advocates

Amy M. Bartholow (argued the cause for Respondent)

Karen K. Mitchell (argued the cause for Petitioner)

Irving L. Gornstein (argued the cause for Petitioner, on behalf of the United States, as amicus curiae)

Facts of the Case

Patrice Seibert was convicted of second degree murder for the death of 17 -year-old Donald Rector, who died in a fire set in the mobile home where he lived with Seibert. Several days after the fire, Seibert was interogated by a police officer. The officer initially withheld her Miranda warnings, hoping to get a confession from her first. Once she had confessed, the officer took a short break from questioning, then read her her Miranda rights and resumed questioning her after she waived those rights. He prompted her to restate the confession that she had made earlier. Based on this second, Mirandized confession, Seibert was convicted.

She appealed, charging that the officer's intentional use of an un-Mirandized interrogation to get the initial confession made the later confession, though it occurred after she had waived her Miranda rights, inadmissable. The prosecution cited Oregon v. Elstad to argue that an initial, un-Mirandized confession did not make a defendant incapable of voluntarily waiving her Miranda rights and confessing later.

The Supreme Court of Missouri agreed with Seibert, overturning the conviction.

Question

Does the rule from Oregon v. Elstad that a defendant who has made an un- Mirandized confession may later waive her Miranda rights to make a second confession (admissible in court) still apply when the initial confession is the result of an intentional decision by a police officer to withhold her Miranda warnings?

Conclusion

Decision: 5 votes for Seibert, 4 vote(s) against
Legal provision: Miranda Warnings

No. In a decision with no majority, a four-justice plurality found that the post-Miranda confession is only admissible - even if the two-stage interview was unintentional, as it was in Elstad - if the Miranda warning and accompanying break are sufficient to give the suspect the reasonable belief that she has the right not to speak with the police. Justice Anthony Kennedy, in a concurring opinion that provided the fifth vote, found that evaluating the warning and accompanying break was only necessary if the police used the two-stage interrogation intentionally. Justice Kennedy wrote, "The admissibility of postwarning statements should continue to be governed by Elstad's principles unless the deliberate two-step strategy is employed. Then, the postwarning statements must be excluded unless curative measures are taken before they were made."