The Oyez Project: Judicial Power Issues - Federal Rules of Civil Procedure Decisions

Amchem Products, Inc. v. Windsor

May settlement play a role, under FRCP 23, in determining the propriety of class certification?

Yes, but a limited one. While the court of appeals had erred by stating that settlement was not relevant to class certification determinations, the lower court had, in fact, closely examined the terms of the settlement, and remand was therefore not merited. A court considering a class for settlement need not consider whether certification would present intractable management problems at the trial stage, but the remaining requirements of FRCP 23 must be met. Here those requirements were not fulfilled. First, despite the over-arching issue of asbestos-related health problems, common issues did not predominate given the very different injuries suffered by the plaintiffs, and the fact that some class members had not yet manifested physical disease. FRCP 23(b)(3). Second, the named parties would not adequately represent the class because those currently injured had interests distinct from those who had been exposed to asbestos but had not yet exhibited any physical symptoms. FRCP 23(a)(4). In resolving the case the Court declined to reach the issue of whether the settlement proceeding was a justiciable case or controversy under Article III because, it held, determination of class certification was logically antecedent to these issues.

American Pipe & Construction Co. v. Utah

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Bankers Trust Co. v. Mallis

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Beech Aircraft Corp. v. Rainey

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Bose Corp. v. Consumers Union of U.S., Inc.

Was Consumer Union's article written with "actual malice," thereby placing it outside the First Amendment's freedom of speech protections?

No. The Court held that while the record revealed that the article's author mistakenly described the sound path of Bose speakers, he did not do so with actual malice. A review of the author's testimony showed that he heard the Bose speaker sounds as tending to wander "along the wall" between speakers, rather then "about the room." Despite this disparity, the Court held that the description of Bose speaker sounds as wondering "about the room," though a misconception, was not written with actual malice since its author was not aware of his mischaracterization in time to remedy the error. Therefore, his speech was entitled to First Amendment protection.

Browder v. Director, Ill. Dept. Of Corrections

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Burlington Northern R. Co. v. Woods

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Business Guides v. Chromatic Comm. Enterprises

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Celotex Corp. v. Catrett

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Cold Metal Process Co. v. United Co.

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Colgrove v. Battin

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Cooter & Gell v. Hartmarx Corp.

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Crawford Fitting Co. v. J. T. Gibbons, Inc.

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Crown, Cork & Seal Co. v. Parker

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Curtiss-Wright Corp. v. General Electric Co.

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Delta Air Lines, Inc. v. August

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Devlin v. Scardelletti

Does a nonnamed member of a class certified under Federal Rule of Civil Procedure 23(b)(1) have the power to appeal the approval of a settlement over objections he stated at the fairness hearing?

Yes. In a 6-3 opinion delivered by Justice Sandra Day O'Connor, the Court held that nonnamed class members like Devlin, who have objected in a timely manner to approval of the settlement at the fairness hearing, have the power to bring an appeal without first intervening. The Court reasoned that the District Court's approval of the settlement, which bound the nonnamed class member as a member of the class, amounted to a final decision of the nonnamed class member's right or claim sufficient to trigger his right to appeal. Moreover, the Court concluded, appealing the approval of the settlement was the nonnamed class member's only means of protecting himself from being bound by a disposition of his rights he found unacceptable, given that the nonnamed class member had no ability to opt out of the settlement. Justice Antonin Scalia filed a dissent, in which Justices Anthony M. Kennedy and Clarence Thomas joined.

East Texas Motor Freight v. Rodriguez

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Eisen v. Carlisle & Jacquelin

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Farmer v. Arabian American Oil Co.

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Foman v. Davis

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GE v. Joiner

Is the abuse of discretion standard the correct standard an appellate court should apply in reviewing a trial court's decision to admit or exclude expert testimony?

Yes. In an opinion delivered by Chief Justice William H. Rehnquist, the Court held that abuse of discretion, the standard ordinarily applicable to review of evidentiary rulings, is the proper standard by which to review a district court's decision to admit or exclude expert scientific evidence. Additionally, the Court held that the proper application of the correct standard of review indicates that the District Court did not err in excluding the expert testimony at issue. "The Federal Rules of Evidence," wrote Chief Justice Rehnquist, "leave in place the 'gatekeeper' role of the trial judge in screening such evidence. A court of appeals applying 'abuse of discretion' review to such rulings may not categorically distinguish between rulings allowing expert testimony and rulings which disallow it."

General Telephone Co. Of Southwest v. Falcon

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General Telephone Co. v. EEOC

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Gonzalez v. Crosby

Did Gonzalez's Rule 60(b) motion constitute a second or successive habeas petition?

No. In 7-2 opinion delivered by Justice Antonin Scalia, the Court held that Gonzalez's Rule 60(b) motion challenged only the district court's previous ruling on the federal statute of limitations. That motion was therefore not the equivalent of a successive habeas petition and could be ruled on by the district court without the 11th Circuit's precertification.

Green v. Bock Laundry Machine Co.

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Gulf Oil Co. v. Bernard

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Hanna v. Plumer

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Henderson v. United States

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

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

Ingalls Shipbuilding v. Office of Worker's Comp. Prog.

Is an injured worker's spouse, who may be eligible to receive death benefits under the Longshore and Harbor Workers' Compensation Act after the worker dies, a "person entitled to compensation" when the spouse enters into a settlement agreement with a third party before the worker's death?

No. In a unanimous opinion delivered by Justice Sandra Day O'Connor, the Court held that before an injured worker's death, the worker's spouse is not a "person entitled to compensation" for death benefits and did not forfeit the right to collect death benefits under the LHWCA for failure to obtain the worker's employer's approval of settlements entered into by the worker's spouse with third parties before the worker's death. In a 7-2 decision, the Court held that rule 15(a) of the Federal Rules of Appellate Procedure, which provided that the "agency" had to be named respondent in an appeal of an order of a federal administrative agency or board to a Federal Court of Appeals, conferred upon the Director the right to appear as a respondent before the Courts of Appeals in appeals from final orders of the Benefits Review Board.

Jaffee v. Redmond

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

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

Kumho Tire Co. Ltd. v. Carmichael

Does a federal trial judge's "gatekeeping" obligation, under the Federal Rules of Evidence, apply to testimony based on skill or experience as it does to testimony based on scientific knowledge?

Yes. In an opinion delivered by Justice Stephen G. Breyer, the Court held that a federal trial judge's "gatekeeping" obligation applies not only to "scientific" testimony, but to all expert testimony. Justice Breyer wrote for the Court that Federal Rule of Evidence 702 "makes no relevant distinction between 'scientific' knowledge and 'technical' or 'other specialized knowledge. It makes clear that any such knowledge might become the subject of expert testimony." The Court concluded that this interpretation of Rule 702 would insure that an expert witness's testimony rests on a reliable foundation and is relevant to the task at hand. The Court also concluded that the District Court's determination that Carlson's methodology was not reliable was within the court's discretion.

Link v. Wabash Railroad Co.

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Marino v. Ortiz

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National Rental v. Szukhent

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Oppenheimer Fund, Inc. v. Sanders

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Ortiz v. Fibreboard Corp.

Is a mandatory settlement class in asbestos personal injury litigation certifiable on limited fund theory under Rule 23(b)(1)(B) of Federal Rules of Civil Procedure?

No. In a 7-2 opinion delivered by Justice David H. Souter, the Court held that "applicants for contested certification [of a mandatory settlement class on a limited fund theory under Rule 23(b)(1)(B)] must show that the fund is limited by more than the agreement of the parties, and has been allocated to claimants belonging within the class by a process addressing any conflicting interests of class members." "The record on which the District Court rested its certification of the class for the purpose of the global settlement did not support the essential premises of mandatory limited fund actions. It failed to demonstrate that the fund was limited except by the agreement of the parties, and it showed exclusions from the class and allocations of assets at odds with the concept of limited fund treatment and the structural protections of Rule 23(a) explained in [Amchem Products, Inc. v. Windsor]," concluded Justice Souter.

Osterneck v. Ernst & Whinney

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Pavelic & LeFlore v. Marvel Entertainment

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Provident Bank v. Patterson

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Sam Fox Publishing Co. v. U.S.

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Schiavone v. Fortune

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Schlagenhauf v. Holder

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Sears, Roebuck & Co. v. Mackey

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Smith v. Barry

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Snyder v. Harris

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Societe Internationale v. Rogers

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Surowitz v. Hilton Hotels Corp.

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Torres v. Oakland Scavenger Co.

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Trammel v. United States

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U.S. v. Schaefer Brewing Co.

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United Airlines, Inc. v. Mcdonald

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United States v. Diebold, Inc.

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United States v. Merz

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United States v. Procter & Gamble

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Walker v. Armco Steel Corp.

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Willy v. Coastal Corp.

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Zahn v. International Paper Co.

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