Cases by Issue - Federalism

Merrill Lynch v. Dabit

Mon, 05 Jan 2009 17:45:00 +0000

Case Basics

Docket No.

04-1371

Petitioner

Merrill Lynch, Pierce, Fenner & Smith Inc.

Petitioner Type

Petitioner

Respondent

Shadi Dabit

Respondent Type

Respondent

Heard By

Roberts Court (2005-2006)

Decided By

Roberts Court (2006-2009)

Opinion

547 U.S. ___ (2006)

Granted

Tuesday, September 27, 2005

Argued

Wednesday, January 18, 2006

Decided

Tuesday, March 21, 2006

Advocates

Jay B. Kasner (argued the cause for Petitioner)

Thomas G. Hungar (argued the cause for Petitioner)

David C. Frederick (argued the cause for Respondent)

Facts of the Case

Shadi Dabit, formerly a stockbroker at Merrill Lynch, brought a class action suit against his former employer alleging that the company had defrauded brokers by deceptively inflating stock prices, causing the brokers to hold onto stocks they would otherwise have sold. Dabit's class action was filed in the U.S. District Court based on federal diversity jurisdiction, but was based on Oklahoma state law.

In response to perceived abuses of the class-action vehicle in securities litigation, Congress had passed the Private Securities Litigation Reform Act of 1995, which placed restrictions on federal securities fraud class actions. When plaintiffs began avoiding the law by bringing the suits in state courts instead of federal courts, Congress passed the Securities Litigation Uniform Standards Act of 1998 (SLUSA), which pre-empts federal class action securities fraud claims brought under state law that allege misrepresentation "in connection with the purchase or sale of a covered security."

Merrill Lynch argued that Dabit's suit was pre-empted by SLUSA and therefore could not be brought under state law. Dabit countered that the suit alleged misrepresentation concerning only the holding of stocks, and therefore was beyond the scope of SLUSA. The District Court for the Southern District of New York ruled for Merrill Lynch, finding the language of SLUSA broad enough to include suits such as Dabit's. The Second Circuit Court of Appeals reversed, holding that suits by holders of stocks are distinct from suits by sellers and purchasers and that SLUSA was meant to pre-empt only the latter.

Question

Are class action securities fraud suits brought under state law pre-empted by the Securities Litigation Uniform Standards Act of 1998 if the suits allege that misleading statements or omissions induced brokers to hold, not sell or purchase, securities?

Conclusion

Decision: 8 votes for Merrill Lynch, 0 vote(s) against
Legal provision: 15 U.S.C. 78

Yes. In an 8-0 decision (Justice Alito not participating), the Court held that "holder" class actions such as Dabit's are "in connection with the purchase or sale" of a security and therefore are pre-empted by SLUSA. The opinion by Justice John Paul Stevens reasoned that Congress must have been aware of the broad interpretation the Court had given that phrase when it passed SLUSA, and that a broad interpretation of SLUSA is more consistent with the law's stated purpose. "For purposes of SLUSA pre-emption, that distinction [between sellers/purchasers and holders] is irrelevant," Justice Stevens wrote.

United States v. Georgia

Mon, 05 Jan 2009 17:45:30 +0000

Case Basics

Docket No.

04-1203

Petitioner

United States

Petitioner Type

Petitioner

Respondent

Georgia, et al.

Respondent Type

Respondent

Consolidation

Goodman v. Georgia et al., No. 04-1236

Heard By

Roberts Court (2005-2006)

Decided By

Roberts Court (2005-2006)

Opinion

546 U.S. ___ (2006)

Granted

Monday, May 16, 2005

Argued

Wednesday, November 9, 2005

Decided

Tuesday, January 10, 2006

Advocates

Paul D. Clement (argued the cause for Petitioner in No. 04-1203)

Gregory A. Castanias (argued the cause for Respondents)

Gregory Andrew Castanias (argued the cause for Respondents)

Samuel R. Bagenstos (argued the cause for Petitioner in No. 04-1236)

Gene C. Schaerr (argued the cause for Respondents)

Facts of the Case

Goodman, a paraplegic held in a Georgia state prison, sued Georgia in federal court for maintaining prison conditions that allegedly discriminated against disabled people and violated Title II of the Americans with Disabilities Act (ADA). Georgia claimed the 11th Amendment provided the state immunity from such suits. The district court ruled for Georgia, but the 11th Circuit reversed.

Before the 11th Circuit ruled in the case, the United States sued Georgia, arguing that the ADA's Title II abolished state sovereign immunity from monetary suits. Congress could do this, the U.S. argued, by exercising its 14th Amendment power to enforce equal protection.

Question

Did Title II of the Americans with Disabilities Act of 1990 validly abrogate state sovereign immunity for suits by prisoners with disabilities challenging discrimination by state prisons? Was Title II a proper exercise of Congress's power under Section 5 of the Fourteenth Amendment, as applied to the administration of prison systems?

Conclusion

Decision: 9 votes for United States, 0 vote(s) against
Legal provision: Americans with Disabilities Act (ADA)

Yes and yes. In a unanimous decision authored by Justice Antonin Scalia, the Court ruled that Title II abrogates sovereign immunity in cases where violations of the 8th Amendment are alleged. The 14th Amendment incorporates the 8th Amendment (that is, applies it to the states). Congress can enforce the 14th Amendment against the states "by creating private remedies against the States for actual violations" of its provisions, which can involve abrogating state sovereign immunity. However, the Court did not address the question of whether Title II validly abrogates sovereign immunity when the 8th Amendment is not involved.

Central VA Comm. College v. Katz

Mon, 05 Jan 2009 17:45:15 +0000

Case Basics

Docket No.

04-885

Petitioner

Central Virginia Community College, et al.

Petitioner Type

Petitioner

Respondent

Bernard Katz, Liquidating Supervisor for Wallace's Bookstores, Inc.

Respondent Type

Respondent

Heard By

Roberts Court (2005-2006)

Decided By

Roberts Court (2005-2006)

Opinion

546 U.S. ___ (2006)

Granted

Monday, April 4, 2005

Argued

Monday, October 31, 2005

Decided

Monday, January 23, 2006

Advocates

William E. Thro (argued the cause for Petitioners)

Kim Martin Lewis (argued the cause for Respondent)

Facts of the Case

Katz, the supervisor of a bookstore that declared bankruptcy, filed a suit to collect debts owed to the bookstore by Central Virginia Community College and several other schools operated by the state of Virginia. Katz also petitioned to prevent the schools from filing claims to collect money from the bookstore because of its bankruptcy status. The colleges argued that they could not be sued by Katz because of state sovereign immunity (which holds that a state must consent in order to be sued). The bankruptcy court disagreed, however, finding that Congress's authority under the Bankruptcy Clause of the Constitution (Article I Section 8) was sufficient to allow them to waive states' sovereign immunity in bankruptcy cases.

Question

Does the Bankruptcy Clause of the U.S. Constitution (Article I Section 8), waive the states' sovereign immunity?

Conclusion

Decision: 5 votes for Katz, 4 vote(s) against
Legal provision: Article 1, Section 8, Paragraph 4: Bankruptcy Clause

Yes. In a 5-4 decision written by Justice John Paul Stevens, the Court ruled that states cannot invoke sovereign immunity as a defense in bankruptcy proceedings. Rather than ruling on the power of Congress under the Bankruptcy Clause to waive states' immunity, as the bankruptcy court did, the Court held that ratification of the Clause itself involved a subordination of state sovereign immunity. The Court relied on the history and intent of the Bankruptcy Clause, which indicated that "the power to enact bankruptcy legislation was understood to carry with it the power to subordinate state sovereignty, albeit within a limited sphere." Justice Clarence Thomas wrote a dissent, which was joined by Justices Antonin Scalia and Anthony Kennedy and Chief Justice John Roberts.

Mid-Con Freight Systems, Inc. v. Michigan Pub. Serv. Comm'n

Mon, 05 Jan 2009 17:47:21 +0000

Case Basics

Docket No.

03-1234

Petitioner

Mid-Con Freight Systems, Inc., et al.

Petitioner Type

Petitioner

Respondent

Michigan Public Service Commission, et al.

Respondent Type

Respondent

Consolidation

American Trucking Assns., Inc. v. Michigan Pub. Serv. Comm'n, No. 03-1230

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

545 U.S. ___ (2005)

Granted

Friday, January 14, 2005

Argued

Tuesday, April 26, 2005

Decided

Monday, June 20, 2005

Advocates

Henry J. Boynton (argued the cause for Respondents)

Malcolm L. Stewart (argued the cause for Respondents)

James H. Hanson (argued the cause for Petitioners in 03-1234)

Robert Digges, Jr. (argued the cause for Petitioners in 03-1230)

Facts of the Case

A Michigan law imposed an annual $100 fee on each Michigan license-plated truck that operated entirely in interstate commerce. A group of interstate trucking companies sought unsuccesfully to have Michigan courts invalidate the law. The companies claimed that the federal law that had created the Single State Registration System (SSRS) preempted and prohibited such state fees. Under the federal law a trucking company could obtain a permit applicable in every state by registering once in a single state. While the initial state could demand a fee equal to the sum of its individual state fee, the law prohibited a state from imposing an additional "state registration requirement."

Question

Did federal law establishing for trucks the Single State Registration System (SSRS) preempt a separate Michigan registration fee?

Conclusion

Decision: 6 votes for Michigan Pub. Serv. Comm'n, 3 vote(s) against
Legal provision: 49 U.S.C. 14504

No. In a 6-3 opinion delivered by Justice Stephen Breyer, the Court held that "reference to text, historical context, and purpose" proved that the words "state registration requirement" in the federal law applied only to state requirements concerning SSRS registration. The Michigan statute, the majority reasoned, had nothing to do with SSRS.

San Remo Hotel v. San Francisco

Mon, 05 Jan 2009 17:47:47 +0000

Case Basics

Docket No.

04-340

Petitioner

San Remo Hotel, L.P., et al.

Petitioner Type

Petitioner

Respondent

City and County of San Francisco, California, et al.

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

545 U.S. ___ (2005)

Granted

Friday, December 10, 2004

Argued

Monday, March 28, 2005

Decided

Monday, June 20, 2005

Advocates

Paul F. Utrecht (argued the cause for Petitioners)

Seth P. Waxman (argued the cause for Respondents)

Facts of the Case

The owners and operators of a hotel in San Francisco sued the city in state court, arguing a $567,000 conversion fee they had to pay in 1996 was an unconstitutional taking of private property. After California courts rejected this argument, the hoteliers argued in federal district court that the fee violated the Fifth Amendment's takings clause. This claim depended on issues identical to those that had been resolved in their state-court suit. The federal full faith and credit statute, however, barred litigants from suing in federal court when that suit was based on issues that had been resolved in state court (the rule of "issue preclusion"). The hoteliers asked the district court to exempt from the statute claims brought under the takings clause.

Question

Should federal courts make an exception to the full faith and credit statute for Fifth Amendment takings clause claims?

Conclusion

Decision: 9 votes for San Francisco, 0 vote(s) against
Legal provision: Takings Clause

No. In a 9-0 judgment delivered by Justice John Paul Stevens, the Court refused to create an exception to the full faith and credit statute in order to provide a federal forum for litigants seeking to advance federal takings claims. The Court rejected the argument that whenever plaintiffs reserved their federal takings claims in state court, federal courts should review the reserved federal claims, regardless of the issues decided by the state court. Moreover, federal courts were not free to disregard the full faith and credit statute simply to guarantee that all takings plaintiffs can sue in federal court.

Bates v. Dow Agrosciences LLC

Mon, 05 Jan 2009 17:47:17 +0000

Case Basics

Docket No.

03-388

Petitioner

Dennis Bates, et al.

Petitioner Type

Petitioner

Respondent

Dow Agrosciences LLC

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

544 U.S. 431 (2005)

Granted

Monday, June 28, 2004

Argued

Monday, January 10, 2005

Decided

Wednesday, April 27, 2005

Advocates

Lisa S. Blatt (argued the cause for Respondent, on behalf of the United States, as amicus curiae)

David C. Frederick (argued the cause for Petitioners)

Seth P. Waxman (argued the cause for Respondent)

Facts of the Case

A group of peanut farmers in Texas threatened to sue Dow Agrosciences in state court for damages caused by one of Dow's herbicides. The farmers alleged Dow violated Texas labeling requirements. Dow asked a federal district court to rule the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) preempted and therefore prohibited the farmers' state law claims. The district court and the Fifth Circuit Court of Appeals ruled FIFRA expressly prohibited additional state labeling requirements such as Texas'.

Question

Does the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) preempt farmers' state tort claims alleging that Dow's herbicide damaged crops?

Conclusion

Decision: 7 votes for Bates, 2 vote(s) against
Legal provision: Federal Insecticide, Fungicide, and Rodenticide

No. In a 7-2 opinion delivered by Justice John Paul Stevens, the Court held that the peanut farmers could sue Dow in state court. The Court reasoned that FIFRA preempts only state-law "requirements for labeling or packaging." The peanut farmers' defective manufacture, negligent testing, and breach of warranty claims were based on common-law and did not necessarily require that Dow label or package products in a particular way. The farmers' fraud and negligent-failure to warn claims, by contrast, were based on common-law rules that qualified as "requirements for labeling or packaging." However, FIFRA preempted only state-law labeling requirements" that were "in addition to or different from" FIFRA's labeling standards. The Court sent back to the Fifth Circuit Court of Appeals the question whether Texas law governing fraud and failure-to-warn claims was parallel to FIFRA.

Gonzales v. Raich

Mon, 05 Jan 2009 17:46:52 +0000

Case Basics

Docket No.

03-1454

Petitioner

Alberto R. Gonzales, Attorney General, et al.

Petitioner Type

Petitioner

Respondent

Angel McClary Raich, et al.

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

545 U.S. 1 (2005)

Granted

Monday, June 28, 2004

Argued

Monday, November 29, 2004

Decided

Monday, June 6, 2005

Advocates

Paul D. Clement (argued the cause for Petitioners)

Randy E. Barnett (argued the cause for Respondents)

Facts of the Case

In 1996 California voters passed the Compassionate Use Act, legalizing marijuana for medical use. California's law conflicted with the federal Controlled Substances Act (CSA), which banned possession of marijuana. After the Drug Enforcement Administration (DEA) seized doctor-prescribed marijuana from a patient's home, a group of medical marijuana users sued the DEA and U.S. Attorney General John Ashcroft in federal district court.

The medical marijuana users argued the Controlled Substances Act - which Congress passed using its constitutional power to regulate interstate commerce - exceeded Congress' commerce clause power. The district court ruled against the group. The Ninth Circuit Court of Appeals reversed and ruled the CSA unconstitutional as it applied to intrastate (within a state) medical marijuana use. Relying on two U.S. Supreme Court decisions that narrowed Congress' commerce clause power - U.S. v. Lopez (1995) and U.S. v. Morrison (2000) - the Ninth Circuit ruled using medical marijuana did not "substantially affect" interstate commerce and therefore could not be regulated by Congress.

Question

Does the Controlled Substances Act (21 U.S.C. 801) exceed Congress' power under the commerce clause as applied to the intrastate cultivation and possession of marijuana for medical use?

Conclusion

Decision: 6 votes for Gonzales, 3 vote(s) against
Legal provision: 21 U.S.C. 801

No. In a 6-3 opinion delivered by Justice John Paul Stevens, the Court held that the commerce clause gave Congress authority to prohibit the local cultivation and use of marijuana, despite state law to the contrary. Stevens argued that the Court's precedent "firmly established" Congress' commerce clause power to regulate purely local activities that are part of a "class of activities" with a substantial effect on interstate commerce. The majority argued that Congress could ban local marijuana use because it was part of such a "class of activities": the national marijuana market. Local use affected supply and demand in the national marijuana market, making the regulation of intrastate use "essential" to regulating the drug's national market. The majority distinguished the case from Lopez and Morrison. In those cases, statutes regulated non-economic activity and fell entirely outside Congress' commerce power; in this case, the Court was asked to strike down a particular application of a valid statutory scheme.

Aetna Health, Inc. v. Davila

Mon, 05 Jan 2009 17:44:40 +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."

Sabri v. United States

Mon, 05 Jan 2009 17:44:37 +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.

Tennessee Student Assistance Corporation v. Hood

Mon, 05 Jan 2009 17:44:39 +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.

Hibbs v. Winn

Mon, 05 Jan 2009 17:44:41 +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.

Engine Mfrs. Assoc. v. South Coast Air Quality

Mon, 05 Jan 2009 17:44:39 +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.

Tennessee v. Lane

Mon, 05 Jan 2009 17:44:48 +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.

Nixon v. Missouri Municipal League

Mon, 05 Jan 2009 17:44:50 +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.

Alaska Dept. of Environmental Conserv. v. EPA

Mon, 05 Jan 2009 17:44:49 +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.

Frew v. Hawkins

Mon, 05 Jan 2009 17:44:51 +0000

Case Basics

Docket No.

02-628

Petitioner

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

Petitioner Type

Petitioner

Respondent

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

Respondent Type

Respondent

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 state officials waived 11th Amendment immunity when they asked the court to approve the consent decree. 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.

Entergy Louisiana, Inc. v. Louisiana Public Service Comm.

Mon, 05 Jan 2009 17:48:06 +0000

Case Basics

Docket No.

02-299

Petitioner

Entergy Louisiana, Inc.

Petitioner Type

Petitioner

Respondent

Louisiana Public Service Comm.

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

539 U.S. 39 (2003)

Argued

Monday, April 28, 2003

Decided

Monday, June 2, 2003

Advocates

David W. Carpenter (Argued the cause for the petitioner)

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

Michael R. Fontham (Argued the cause for the respondents)

Facts of the Case

Several Louisiana cotton gins sued Entergy, an electric utility company, because it had over-billed them for electricity between 1988 and 1994. The gins claimed that Entergy had failed to notify them of a lower rate that would have saved them more than $2 million over the six-year period. Louisiana law requires that utility companies notify customers when they are eligible for a lower rate. Furthermore, the gins claimed that Entergy had discriminated against them by notifying several other gins in the state of the lower rate. Deferring to the decision of the Louisiana Public Service Commission, the state's utility regulatory agency, a state district court ruled against Entergy. The Supreme Court of Louisiana affirmed the decision on appeal.

Question

Does a Federal Energy Regulatory Commission approved tariff that delegates discretion to the regulated entity to determine the precise cost allocation similarly preempt a state order that adjudges those costs imprudent?

Conclusion

Decision: 9 votes for Entergy Louisiana, Inc., 0 vote(s) against
Legal provision: Federal Power

Yes. In a unanimous opinion delivered by Justice Clarence Thomas, the Court held that the LPSC's order was preempted by the filed rate doctrine articulated in Nantahala Power & Light Co. v. Thornburg, 476 U.S. 953, and Mississippi Power & Light Co. v. Mississippi ex rel. Moore, 487 U.S. 354. Applying Nantahala and MP&L;, the Court reasoned that the LPSC's order impermissibly "traps" costs that have been allocated in a FERC tariff. The Court noted that it did not matter whether the FERC has spoken to the precise classification of ERS units, but only whether the FERC tariff dictates how and by whom that classification should be made. "The amended system agreement clearly does so, and therefore the LPSC's second-guessing of the classification of ERS units is pre-empted," wrote Justice Thomas.

American Insurance Association v. Garamendi

Mon, 05 Jan 2009 17:48:47 +0000

Case Basics

Docket No.

02-722

Petitioner

American Insurance Association

Petitioner Type

Petitioner

Respondent

Garamendi

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

539 U.S. 396 (2003)

Argued

Wednesday, April 23, 2003

Decided

Monday, June 23, 2003

Advocates

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

Frank Kaplan (Argued the cause for the respondent)

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

Facts of the Case

In 1999 the California legislature enacted the Holocaust Victim Insurance Relief Act (HVIRA) in an attempt to facilitate Holocaust-era insurance claims by California residents. The Act required all insurance companies doing business in California that sold policies to people in Europe between 1920 and 1945 to make public all of those policies, including the names of policy owners and the status of the policies. A group of insurance companies and a trade organization sued, saying that only the federal government, with its jurisdiction over commerce and foreign affairs, had the right to enact such legislation. They also said the law violated the Due Process and Equal Protection clauses of the U.S. Constitution because the companies, if they failed to comply, could lose their insurance licenses. The District Court ruled for the insurance companies; the 9th Circuit Court of Appeals reversed.

Question

Did California's passage of the HVIRA interfere with the federal government's sovereignty over foreign affairs established by Article I of the Constitution?

Conclusion

Decision: 5 votes for American Insurance Association, 4 vote(s) against
Legal provision: Article 2, Section 1: Executive Power

Yes. In a 5-4 opinion delivered by Justice David H. Souter, the Court held that California's HVIRA interferes with the president's ability to conduct the nation's foreign policy and is therefore preempted. The Court reasoned that an exercise of state power that concerns foreign relations must yield to the Federal Government's policy or that generally there is executive authority to decide what policy should be implemented. Based on an account of related international negotiations, the Court found sufficiently clear conflict between HVIRA and the President's foreign policy. "The basic fact is that California seeks to use an iron fist where the President has consistently chosen kid gloves," wrote Justice Souter. Justice Ruth Bader Ginsburg, joined by Justices John Paul Stevens, Antonin Scalia, and Clarence Thomas, dissented, arguing that no executive agreement or other formal expression of foreign policy expressly disapproved of state disclosure laws like California's HVIRA.

Pharmaceutical Research v. Walsh

Mon, 05 Jan 2009 17:48:39 +0000

Case Basics

Docket No.

01-188

Petitioner

Pharmaceutical Research

Petitioner Type

Petitioner

Respondent

Walsh

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

538 U.S. 644 (2003)

Argued

Wednesday, January 22, 2003

Decided

Monday, May 19, 2003

Advocates

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

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

Andrew S. Hagler (Augusta, Maine, argued the cause for the respondents)

Facts of the Case

In order to achieve savings on Medicaid purchases above federal cost-saving measures, the "Maine Rx" Program reduces prescription drug prices for state residents. Under the program, Maine attempts negotiate rebates with drug manufacturers. If a company does not enter into a rebate agreement, its Medicaid sales are subjected to a prior authorization procedure that requires state agency approval to qualify a doctor's prescription for reimbursement. The Pharmaceutical Research and Manufacturers of America, an association of nonresident drug manufacturers, challenged the program, claiming that it is pre-empted by the Medicaid Act and violates the Commerce Clause. Without resolving any factual issues, the District Court entered a preliminary injunction preventing the statute's implementation, concluding that any obstacle to the federal program's administration is sufficient to establish pre-emption. The Court of Appeals reversed.

Question

Is a Maine statute providing for affordable prescription drugs pre-empted by the Supremacy Clause? Does the statute violate the Commerce Clause?

Conclusion

Decision: 6 votes for Walsh, 3 vote(s) against
Legal provision: Article 1, Section 8, Paragraph 3: Interstate Commerce Clause

No and no. In an opinion delivered by Justice John Paul Stevens, the Court held, 9-0, that the Pharmaceutical Research and Manufacturers of America had not carried its burden of showing a probability of success on the merits of its Commerce Clause claims and, 6-3, that their showing was insufficient to support a finding that the Medicaid Act pre-empts Maine's Rx Program insofar as it threatens to coerce manufacturers into reducing their prices on non- Medicaid sales. The Court's decision upheld the Court of Appeal's reversal of the District Court's injunction. Justice Sandra Day O'Connor, joined by Chief Justice William H. Rehnquist and Justice Anthony M. Kennedy, dissented from the plurality's opinion. "By imposing prior authorization on Maine's Medicaid population to achieve wholly non-Medicaid related goals, Maine Rx 'stands as an obstacle to the accomplishment and execution of the full purposes and objectives' of the federal Medicaid Act," argued Justice O'Connor.

Nevada Dept. of Human Resources v. Hibbs

Mon, 05 Jan 2009 17:48:19 +0000

Case Basics

Docket No.

01-1368

Petitioner

Nevada Dept. of Human Resources

Petitioner Type

Petitioner

Respondent

Hibbs

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

538 U.S. 721 (2003)

Argued

Wednesday, January 15, 2003

Decided

Tuesday, May 27, 2003

Advocates

Paul G. Taggart (Carson City, Nevada, argued the cause for the petitioners)

Cornelia T. L. Pillard (Argued the cause for the respondent Hibbs)

Viet D. Dinh (Office of Legal Policy, Department of Justice, argued the cause for the respondent United States)

Facts of the Case

William Hibbs, an employee of the Nevada Department of Human Resources, sought leave to care for his wife under the Family and Medical Leave Act of 1993 (FMLA). The FMLA entitles an eligible employee to take up to 12 workweeks of unpaid leave annually for the onset of a "serious health condition" in the employee's spouse. The Department granted Hibbs's request for the full 12 weeks of FMLA leave and, after he had exhausted that leave, informed him that he must report to work by a certain date. When Hibbs failed to do so, he was fired. Pursuant to FMLA provisions creating a private right of action "against any employer" that "interfered with, restrained, or denied the exercise of" FMLA rights, Hibbs sued in Federal District Court, seeking money damages for FMLA violations. The District Court concluded that the Eleventh Amendment barred the FMLA claim. The Court of Appeals reversed.

Question

May an individual sue a State for money damages in federal court for violation of the Family and Medical Leave Act of 1993?

Conclusion

Decision: 6 votes for Hibbs, 3 vote(s) against
Legal provision: Fourteenth Amendment Enforcement Clause

Yes. In a 6-3 opinion delivered by Chief Justice William H. Rehnquist, the Court held that State employees may recover money damages in federal court in the event of the State's failure to comply with the FMLA's family-care provision. The Court reasoned that Congress both clearly stated its intention to abrogate the States' Eleventh Amendment immunity from suit in federal court under the FMLA and acted within its authority under section 5 of the Fourteenth Amendment by enacting prophylactic, rather than substantively redefining, legislation. "In sum, the States' record of unconstitutional participation in, and fostering of, gender-based discrimination in the administration of leave benefits is weighty enough to justify the enactment of prophylactic [section] 5 legislation," wrote Chief Justice Rehnquist. Justices Antonin Scalia and Anthony M. Kennedy, who was joined by Justices Clarence Thomas and Scalia, filed dissents.

Kentucky Assoc. of Health Plans, Inc. v. Miller

Mon, 05 Jan 2009 17:47:57 +0000

Case Basics

Docket No.

00-1471

Petitioner

Kentucky Assoc. of Health Plans, Inc.

Petitioner Type

Petitioner

Respondent

Miller

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

538 U.S. 329 (2003)

Argued

Tuesday, January 14, 2003

Decided

Wednesday, April 2, 2003

Advocates

Robert N. Eccles (On behalf of the petitioners)

Elizabeth A. Johnson (On behalf of the respondent)

James A. Feldman (Argued the cause for the United States, as amicus curiae, supporting the respondent)

Facts of the Case

Kentucky's two "Any Willing Provider" (AWP) statutes prohibit "[a] health insurer [from] discriminating against any provider who is...willing to meet the terms and conditions for participation established by the?insurer," and require a "health benefit plan that includes chiropractic benefits [to]...permit any licensed chiropractor who agrees to abide by the terms [and] conditions?of the?plan to serve as a participating primary chiropractic provider." Certain health maintenance organizations (HMOs) filed suit asserting that Kentucky's AWP laws are preempted by the Employee Retirement Income Security Act of 1974 (ERISA), which preempts all state laws "insofar as they?relate to any employee benefit plan," but saves from preemption state "laws...which regulate insurance." The District Court concluded that although both AWP statutes "relate to" employee benefit plans each law "regulates insurance" and is therefore saved from preemption. The Court of Appeals affirmed.

Question

Does the Employee Retirement Income Security Act of 1974 preempt any of Kentucky's "Any Willing Provider" statutes?

Conclusion

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

No. In a unanimous opinion delivered by Justice Antonin Scalia, the Court held that Kentucky's AWP statutes are "laws...which regulate insurance" under ERISA. The Court reasoned that the statutes were specifically directed toward entities engaged in insurance, regardless of the fact that the statutes also had the effect of prohibiting providers from entering into limited network contracts with the HMOs. Moreover, the Court concluded that, by expanding the number of providers from whom an insured may receive health services, AWP laws alter the scope of permissible bargains between insurers and insureds thus affecting the type of risk pooling arrangements that the HMOs could offer, thereby constituting regulation of the business of insurance.

Sprietsma v. Mercury Marine

Mon, 05 Jan 2009 17:48:47 +0000

Case Basics

Docket No.

01-706

Petitioner

Sprietsma

Petitioner Type

Petitioner

Respondent

Mercury Marine

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

537 U.S. 51 (2002)

Argued

Tuesday, October 15, 2002

Decided

Tuesday, December 3, 2002

Advocates

Leslie A. Brueckner (on behalf of the Petitioner)

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

Stephen M. Shapiro (on behalf of the Respondent)

Facts of the Case

Rex Sprietsma's wife was killed in a boating accident when she was struck by the propeller of a motor made by Mercury Marine. Sprietsma sued Mercury Marine under Illinois common law, alleging that his wife's injuries were caused by an unreasonably dangerous motor. The trial court, the intermediate court, and the Illinois Supreme Court all dismissed the complaint, finding the Federal Boat Safety Act of 1971 (FBSA) preempted such state common-law claims.

Question

Does the Federal Boat Safety Act of 1971 preempt state common-law claims related to propeller safety?

Conclusion

Decision: 9 votes for Sprietsma, 0 vote(s) against
Legal provision: 46 U.S.C. 4301

No. In an opinion delivered by Justice John Paul Stevens, the Court held 8-0 that neither the text nor the intent of the FBSA preempts Sprietsma's common law claims, either explicitly or implicitly. Justice Stevens wrote, "Absent a contrary decision by the Coast Guard" - the agency in charge of propeller- safety regulations - "the concern with uniformity does not justify the displacement of state common-law remedies that compensate accident victims..."

City of Columbus v. Ours Garage and Wrecker Service

Mon, 05 Jan 2009 17:46:11 +0000

Case Basics

Docket No.

01-419

Petitioner

City of Columbus

Petitioner Type

Petitioner

Respondent

Ours Garage and Wrecker Service

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

536 U.S. 424 (2002)

Argued

Tuesday, April 23, 2002

Decided

Thursday, June 20, 2002

Advocates

Richard A. Cordray (Argued the cause for the respondents)

Malcolm L. Stewart (Argued the cause for the United States, as amicus curiae, supporting the petitioners)

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

Facts of the Case

Pursuant to 49 USC section 14501(c)(2)(A), federal preemption prescriptions relating to motor carriers "shall not restrict the safety regulatory authority of a State with respect to motor vehicles." Columbus, Ohio, extensively regulates the operation of tow trucks seeking to pick up vehicles within city limits. Ours Garage and Wrecker Service, Inc., a tow-truck operator and a trade association of such operators, sought to enjoin enforcement of the City's tow-truck regulations on the ground that they were preempted. The District Court granted Ours Garage summary judgment. In affirming, the Court of Appeals relied on precedent that section 14501(c)(1)'s preemption rule explicitly applies to "a State [or] political subdivision of a State," while the exception for safety regulations, section 14501(c)(2)(A), refers only to the "authority of a State." The appellate court also noted that precedent determined that the contrast in statutory language indicated that Congress meant to limit the safety exception to States alone.

Question

May the state power reserved in 49 USC section 14501(c)(2)(A) be delegated to municipalities, permitting them to exercise safety regulatory authority over local tow-truck operations?

Conclusion

Decision: 7 votes for City of Columbus, 2 vote(s) against
Legal provision: Interstate Commerce, as amended

Yes. In a 7-2 opinion delivered by Justice Ruth Bader Ginsburg, the Court held that section 14501(c) does not bar a State from delegating to municipalities and other local units the State's authority to establish safety regulations governing motor carriers of property, including tow trucks. "A locality, as section 14501(c) recognizes, is a 'political subdivision' of the State," wrote Justice Ginsburg. "Ordinarily, a political subdivision may exercise whatever portion of state power the State...chooses to delegate to the subdivision. Absent a clear statement to the contrary, Congress' reference to the 'regulatory authority of a State' should be read to preserve, not preempt, the traditional prerogative of the States to delegate their authority to their constituent parts." Justice Antonin Scalia wrote a dissent, in which Justice Sandra Day O'Connor joined.

Lapides v. Board of Regents of University System of Georgia

Mon, 05 Jan 2009 17:46:01 +0000

Case Basics

Docket No.

01-298

Petitioner

Lapides

Petitioner Type

Petitioner

Respondent

Board of Regents of University System of Georgia

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

535 U.S. 613 (2002)

Argued

Monday, February 25, 2002

Decided

Monday, May 13, 2002

Advocates

David J. Bederman (Argued the cause for the petitioner)

Julie C. Parsley (Austin, Texas, argued the cause for the Texas, e al., as amicus curiae, supporting the respondents)

Devon Orland (Atlanta, Georgia, argued the cause for the respondents)

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

Facts of the Case

Paul Lapides, a professor employed by the Georgia state university system, filed a state-court lawsuit against the system?s board of regents and other university officials, alleging that the officials had violated state tort law and 42 USC section 1983 when they placed sexual harassment allegations in his personnel files. The defendants removed the case to Federal District Court and then sought a dismissal. Conceding that a state statute had waived Georgia's sovereign immunity from state-law suits in state court, the State claimed Eleventh Amendment immunity from suit in the federal court. The District Court held that Georgia had waived such immunity when it removed the case to federal court. In reversing, the Court of Appeals found that, because state law was unclear as to whether the state attorney general had the legal authority to waive Georgia's Eleventh Amendment immunity, the State retained the legal right to assert immunity, even after the removal.

Question

Does a State's act of removing a lawsuit from state court to federal court waive the State's Eleventh Amendment immunity from suit in federal court by citizens of other States?

Conclusion

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

Yes. In a unanimous opinion delivered by Justice Stephen G. Breyer, the Court held that a State waives its Eleventh Amendment immunity when it removes a case from state court to federal court. The Court concluded that that the university officials' voluntary removal of the action expressly invoked the jurisdiction of the federal courts and thus constituted a waiver of sovereign immunity with regard to state law claims for which immunity was waived in state court. Under the general principle that a State's voluntary appearance in federal court amounts to a waiver of its Eleventh Amendment immunity, the Court reasoned that Georgia was brought involuntarily into the case as a defendant in state court, but it then voluntarily removed the case to federal court, thus voluntarily invoking that court's jurisdiction.

Federal Maritime Commission v. South Carolina Ports Authority

Mon, 20 Jun 2011 04:06:33 +0000

Location

South Carolina State Ports Authority

176 Concord Street Charleston SC 29401

Charleston, SC 29401

United States

32° 47' 9.2256" N, 79° 55' 36.7788" W

See map: Google Maps

Case Basics

Docket No.

01-46

Petitioner

Federal Maritime Commission

Petitioner Type

Petitioner

Respondent

South Carolina Ports Authority

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

535 U.S. 743 (2002)

Argued

Monday, February 25, 2002

Decided

Tuesday, May 28, 2002

Advocates

Paul D. Clement (Argued the cause for the United States, supporting the petitioner)

Phillip C. Hughey (Argued the cause for the petitioner Federal Maritime Commission)

Warren L. Dean, Jr. (Argued the cause for the respondent)

Facts of the Case

South Carolina Maritime Services, Inc. (Maritime Services), asked the South Carolina State Ports Authority (SCSPA) five times for permission to berth a cruise ship, the M/V Tropic Sea, at the SCSPA's port facilities in Charleston, South Carolina. Some cruises offered by Maritime Services would allow passengers to participate in gambling activities while on board. The SCSPA repeatedly denied Maritime Services' requests, contending that it had an established policy of denying berths in the Port of Charleston to vessels whose primary purpose was gambling. Maritime Services file a complaint with the Federal Maritime Commission (FMC), arguing that SCSPA violated the Shipping Act by its denials. The complaint was referred to an Administrative Law Judge (ALJ), who found that the SCSPA, as an arm of the State of South Carolina, was entitled to sovereign immunity and thus dismissed the complaint. Reversing on its own motion, the FMC concluded that state sovereign immunity covers proceedings before judicial tribunals, not Executive Branch agencies. In reversing, Court of Appeals fund that the proceedings were an adjudication and thus subject to state sovereign immunity.

Question

Does a State's sovereign immunity preclude the Federal Maritime Commission from adjudicating a private party's complaint that a state-run port has violated the Shipping Act of 1984?

Conclusion

Decision: 5 votes for South Carolina Ports Authority, 4 vote(s) against
Legal provision: Amendment 11: Eleventh Amendment

Yes. In a 5-4 opinion delivered by Justice Clarence Thomas, the Court held that state sovereign immunity bars the FMC from adjudicating a private party's complaint against a nonconsenting State. Historically, the Court noted, states were not subject to private suits in administrative adjudications when the Constitution was adopted, and states were thus presumptively immune from such actions. Moreover, the Court pointed to the similarities between the FMC's proceedings and civil litigation to conclude that there was no basis for distinguishing between the actions for purposes of sovereign immunity. "Although the Framers likely did not envision the intrusion on state sovereignty at issue in today's case, we are nonetheless confident that it is contrary to their constitutional design," wrote Justice Thomas.

Rush Prudential HMO, Inc. v. Moran

Mon, 05 Jan 2009 17:45:57 +0000

Case Basics

Docket No.

00-1021

Petitioner

Rush Prudential HMO, Inc.

Respondent

Moran

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

536 U.S. 355 (2002)

Argued

Wednesday, January 16, 2002

Decided

Thursday, June 20, 2002

Advocates

John G. Roberts, Jr. (on behalf of the petitioner)

Edwin S. Kneedler (on behalf of the United States, as amicus curiae)

Daniel P. Albers (on behalf of the Respondent)

Facts of the Case

Rush Prudential HMO, Inc., a health maintenance organization that provides medical services for employee welfare benefits plans covered by the Employee Retirement Income Security Act of 1974 (ERISA), denied Debra Moran's request to have surgery by an unaffiliated specialist. Under the Illinois HMO Act (Act), which provides that "in the event that the reviewing physician determines the covered service to be medically necessary," the HMO "shall provide" the service, Moran made a written demand for an independent medical review of her claim. After Rush refused her demand, Moran sued in state court to compel compliance with the Act. The court ordered the review, which found the treatment necessary. While the suit was pending, Moran had the surgery and amended her complaint to seek reimbursement. Rush removed the case to federal court, arguing that the amended complaint stated a claim for ERISA benefits. Ultimately, the Court of Appeals found Moran's reimbursement claim preempted by ERISA so as to place the case in federal court, but it concluded that the Act was not preempted as a state law that "relates to" an employee benefit plan because it also "regulates insurance" under ERISA's saving clause.

Question

Is the Illinois Health Maintenance Organization Act, as applied to health benefits provided by a health maintenance organization under contract with an employee welfare benefit plan, preempted by the Employee Retirement Income Security Act of 1974?

Conclusion

Decision: 5 votes for Moran, 4 vote(s) against
Legal provision: Employee Retirement Income Security

No. In a 5-4 opinion delivered by Justice David H. Souter, the Court held that ERISA does not preempt the Illinois HMO Act. Under its common-sense view of the matter, the Court reasoned that, because HMOs are risk-bearing organizations subject to state insurance regulation and almost universally regulated as insurers under state law, "the Illinois HMO Act is a law 'directed toward' the insurance industry and an 'insurance regulation'" and is, thus, saved from preemption under ERISA's saving clause. Justice Clarence Thomas, with whom Chief Justice William H. Rehnquist and Justices Antonin Scalia and Anthony M. Kennedy joined, dissented. Justice Thomas argued that ERISA's civil enforcement provision provides the exclusive means for actions asserting a claim for benefits under health plans governed by ERISA and therefore state laws that create additional remedies are preempted.

Verizon Maryland Inc. v. Public Service Commission of Maryland

Mon, 05 Jan 2009 17:45:52 +0000

Case Basics

Docket No.

00-1531

Petitioner

Verizon Maryland Inc.

Petitioner Type

Petitioner

Respondent

Public Service Commission of Maryland

Respondent Type

Respondent

Consolidation

No. 00-1711

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

535 U.S. 635 (2002)

Argued

Wednesday, December 5, 2001

Decided

Monday, May 20, 2002

Advocates

Mark L. Evans (Argued the cause for the petitioner in No. 00-1531)

Barbara B. McDowell (Argued the cause for the petitioner United States)

Susan S. Miller (Public Service Commission, Baltimore, Maryland, argued the cause for the State Respondent)

Facts of the Case

The Telecommunications Act of 1996 requires that incumbent local-exchange carriers (LECs) provide interconnection with their existing networks; that the carriers then establish reciprocal compensation arrangements for transporting and terminating the calls of each others' customers; and that their interconnection agreements be approved by a state utility commission. Verizon Maryland Inc., the incumbent LEC in Maryland, negotiated an interconnection agreement with MCI WorldCom, Inc. After the Maryland Public Service Commission approved the agreement, Verizon informed WorldCom that it would no longer pay reciprocal compensation for calls made by Verizon's customers to the local access numbers of Internet Service Providers (ISPs) because ISP traffic was not local traffic subject to the reciprocal compensation agreement. WorldCom filed a complaint with the Commission, which ordered Verizon to make the payments for past and future ISP-bound calls. Verizon then filed an action in federal district court, seeking an injunction prohibiting its enforcement, alleging that the determination that Verizon must pay reciprocal compensation for ISP traffic violated the Act. The District Court dismissed the action. In affirming, the Court of Appeals held that the Commission had not waived its Eleventh Amendment immunity and that the Act did not provide a basis for jurisdiction over Verizon's claims.

Question

Do federal district courts have jurisdiction over a telecommunication carrier's claim that the order of a state utility commission requiring reciprocal compensation for telephone calls to Internet Service Providers violates the Telecommunications Act of 1996?

Conclusion

Decision: 8 votes for Verizon Maryland Inc., 0 vote(s) against
Legal provision: 47 U.S.C. 251

Yes. In an 8-0 opinion delivered by Justice Antonin Scalia, the Court held that the district court had jurisdiction, so as to review the Commission's order for compliance with federal law, to entertain the suit because resolution of the LEC's claim turned on whether the Act, or an FCC ruling issued thereunder, precluded the state commission from ordering payment of reciprocal compensation. Under the Ex parte Young doctrine, the Court also reasoned that Verizon's request for injunctive relief to restrain state officials from enforcing an order allegedly in contravention of controlling federal law avoided an Eleventh Amendment bar to suit. Justice Sandra Day O'Connor took no part in the consideration or decision of the cases.

Wisconsin Department of Health and Family Services v. Blumer

Mon, 05 Jan 2009 17:45:54 +0000

Case Basics

Docket No.

00-952

Petitioner

Wisconsin Department of Health and Family Services

Petitioner Type

Petitioner

Respondent

Blumer

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

534 U.S. 473 (2002)

Argued

Monday, December 3, 2001

Decided

Wednesday, February 20, 2002

Advocates

Mitchell Hagopian (Argued the cause for the respondent)

Maureen M. Flanagan (Madison, Wisconsin, argued the cause for the petitioner)

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

Facts of the Case

The spousal impoverishment provisions of the Medicare Catastrophic Coverage Act of 1988 (MCCA) permit a spouse living at home to reserve certain income and assets to meet the minimum monthly maintenance needs he or she will have when the other spouse is institutionalized, usually in a nursing home, and becomes eligible for Medicaid. The MCCA's resource allocation rules provide that, in determining the institutionalized spouse's Medicaid eligibility, a portion of the couple's resources, called the "community spouse resource allowance" (CSRA), shall be reserved for the benefit of the community spouse. The MCCA allows an increase in the standard allowance if either spouse shows, at a state-administered hearing, that the community spouse will not be able to maintain the statutorily defined minimum level of income on which to live after the institutionalized spouse gains Medicaid eligibility. In 1996, after entering a Wisconsin nursing home, Irene Blumer applied for Medicaid through her husband Burnett and ultimately sought a higher CSRA. Under the "income- first" method for determining whether the community spouse is entitled to a higher CSRA, which Wisconsin uses, the State considers first whether potential income transfers from the institutionalized spouse will suffice to enable the community spouse to meet monthly needs once the institutionalized spouse qualifies for Medicaid. Subsequently, an examiner denied Blumer's request. The Court of Appeals affirmed, but the Wisconsin Court of Appeals reversed, concluding that the State's income-first statute conflicted with the MCCA, which, the appeals court held, unambiguously mandates the resources-first method.

Question

Is the income-first method of determining whether a community spouse is entitled to a higher community spouse resource allowance consistent with the Medicare Catastrophic Coverage Act of 1988?

Conclusion

Decision: 6 votes for Wisconsin Department of Health and Family Services, 3 vote(s) against
Legal provision: 42 U.S.C. 1396

Yes. In a 6-3 opinion delivered by Justice Ruth Bader Ginsburg, the Court held that the income-first method qualified as a permissible interpretation of the MCCA. The Court reasoned that neither the text not the structure of the MCCA barred Wisconsin's use of the income-first method. Among the Court's findings were that that income-first method did not render meaningless the MCCA's key prohibition against deeming income of the community spouse available to the institutionalized spouse and that the Secretary of Health and Human Services, who possessed the authority to prescribe standards relevant to the issue at hand, had declared in a proposed rule that the Federal Government ought to leave to states the decision whether to use the income-first method or the resources-first method. Justice John Paul Stevens, joined by Justices Sandra Day O'Connor and Antonin Scalia, dissented.

Buckman Co. v. Plaintiffs' Legal Committee

Mon, 05 Jan 2009 17:44:10 +0000

Case Basics

Docket No.

98-1768

Petitioner

Buckman Co.

Petitioner Type

Petitioner

Respondent

Plaintiffs' Legal Committee

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

531 U.S. 341 (2001)

Argued

Monday, December 4, 2000

Decided

Wednesday, February 21, 2001

Advocates

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

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

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

Facts of the Case

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

Question

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

Conclusion

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

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

Egelhoff v. Egelhoff

Mon, 05 Jan 2009 17:44:25 +0000

Case Basics

Docket No.

99-1529

Petitioner

Egelhoff

Petitioner Type

Petitioner

Respondent

Egelhoff

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

532 U.S. 141 (2001)

Argued

Wednesday, November 8, 2000

Decided

Wednesday, March 21, 2001

Advocates

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

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

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

Facts of the Case

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

Question

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

Conclusion

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

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

Board of Trustees v. Garrett

Mon, 20 Jun 2011 04:06:31 +0000

Location

University of Alabama Tuscaloosa, AL 35487

United States

33° 12' 33.84" N, 87° 34' 10.2" W

See map: Google Maps

Case Basics

Docket No.

99-1240

Petitioner

Board of Trustees

Petitioner Type

Petitioner

Respondent

Garrett

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

531 U.S. 356 (2001)

Argued

Wednesday, October 11, 2000

Decided

Thursday, February 1, 2001

Advocates

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

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

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

Facts of the Case

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

Question

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

Conclusion

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

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

Crosby v. National Foreign Trade Council

Mon, 20 Jun 2011 04:06:31 +0000

Location

Massachusetts Office for Administration and Finance

24 Beacon St Boston MA 02133

Boston, MA 02133

United States

42° 21' 27.9036" N, 71° 3' 50.058" W

See map: Google Maps

Case Basics

Docket No.

99-474

Petitioner

Crosby

Petitioner Type

Petitioner

Respondent

National Foreign Trade Council

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

530 U.S. 363 (2000)

Argued

Wednesday, March 22, 2000

Decided

Monday, June 19, 2000

Advocates

Thomas A. Barnico (Argued the cause for the petitioners)

Timothy B. Dyk (Argued the cause for the respondent)

Seth P. Waxman (Argued the cause for the United States, as amicus curiae, by special leave of court, supporting affirmance)

Facts of the Case

In 1996, the Massachusetts Burma Law, which restricted state entities from buying goods or services from companies doing business with Burma, was passed. Afterwards, Congress also imposed mandatory and conditional sanctions on Burma. Businesses with ties to Burma landed on Massachusetts' "restricted trade" list. The list came to include 34 members of the National Foreign Trade Council (Council), a non-profit advocate for American companies that do business abroad. The Council filed suit against Stephen Crosby, the Massachusetts Secretary of Administration and Finance, and other state officials in federal court, claiming that the state act unconstitutionally infringes on the federal foreign affairs power, violates the Foreign Commerce Clause, and is preempted by the Federal Burma Law. The District Court permanently enjoined the state act's enforcement, and the Court of Appeals affirmed. The court also found that the Massachusetts Burma Law violated the Supremacy Clause because the state was acting in an area of unique federal concern, foreign policy, through a balanced, tailored approach.

Question

Is the Massachusetts Burma Law, which restricts the authority of its agencies to purchase goods or services from companies doing business with Burma, unconstitutional under the Supremacy Clause?

Conclusion

Decision: 9 votes for National Foreign Trade Council, 0 vote(s) against
Legal provision: Article 6, Section 2: Supremacy Clause

Yes. In a opinion delivered by Justice David H. Souter, the Court held that "the state Act is preempted, and its application unconstitutional, under the Supremacy Clause." Justice Souter wrote for the Court that Massachusetts' law created an obstacle to the President's discretion to control economic sanctions against Burma, interfered with Congress's intention to limit economic pressure against the Burmese Government, and was at odds with the President's authority to speak for the United States among the world's nations to develop a comprehensive, multilateral Burma strategy. Therefore, the Massachusetts Burma Law "is invalid under the Supremacy Clause...owing to its threat of frustrating federal statutory objectives."

Norfolk Southern R. Co. v. Shanklin

Mon, 05 Jan 2009 16:14:40 +0000

Case Basics

Docket No.

99-312

Petitioner

Norfolk Southern R. Co.

Petitioner Type

Petitioner

Respondent

Shanklin

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

529 U.S. 344 (2000)

Argued

Wednesday, March 1, 2000

Decided

Monday, April 17, 2000

Advocates

Gregory S. Coleman (Austin, Texas, argued the cause for the Texas, et al., as amici curiae, by special leave of the Court, supporting the petitioner)

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

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

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

Facts of the Case

In 1993, Eddie Shanklin was struck and killed by a Norfolk Southern train at a railroad intersection. At the time of the accident, the intersection was equipped with advanced warning signs and reflectorized crossbucks, which were installed with federal funds under the Federal Railway-Highway Crossings Program and were fully compliant with the federal standards for such devices. Afterwards, Dedra Shanklin, Mr. Shanklin's widow, brought a diversity wrongful death action against Norfolk Southern. Shanklin alleged, based on Tennessee statutory and common law, that Norfolk Southern had been negligent by failing to maintain adequate warning devices at the crossing. Norfolk Southern moved for summary judgment on the ground that the Federal Railroad Safety Act of 1970 (FRSA) pre-empted Shanklin's suit. The FRSA contains an express pre- emption provision, which allows States to enforce their railroad safety measures until the Secretary of Transportation prescribes a regulation or issues an order covering the subject matter of the State requirement. The District Court held that Shanklin's allegation that the signs installed at the crossing were inadequate was not pre-empted and, ultimately, entered judgement for her. In affirming, the Court of Appeals reasoned that federal funding alone was insufficient to trigger pre-emption of state tort actions under the FRSA. The court concluded that because the Tennessee Department of Transportation had installed the signs for the purpose of providing "minimum protection," no individualized determination of adequacy had be made by the Federal Highway Administration (FHWA) under the Crossings Program.

Question

Does the Federal Railroad Safety Act of 1970 pre-empt tort claims, based on State statutory and common law, concerning a railroad's failure to maintain adequate warning devices at crossings where federal funds have participated in the installation of the devices?

Conclusion

Decision: 7 votes for Norfolk Southern R. Co., 2 vote(s) against
Legal provision: 49 U.S.C. 2010

Yes. In a 7-2 opinion delivered by Justice Sandra Day O'Connor, the Court held that railroads cannot b sued under state tort law over allegedly inadequate warning devices at rail crossings if the equipment installed was federally funded. Justice O'Connor wrote for the Court that "[o]nce the FHWA approved the project and the signs were installed using federal funds, the federal standard for adequacy displaced Tennessee statutory and common law addressing the same subject, thereby pre-empting [Shanklin's] claim." Justice Ruth Bader Ginsburg, in a dissenting opinion joined by Justice John Paul Stevens, wrote that the consequence of the Court's decision "is that state negligence law is displaced with no substantive federal standard of conduct to fill the void."

United States v. Morrison

Mon, 20 Jun 2011 04:06:31 +0000

Location

US District Court for the Eastern District of Pennsylvania

601 Market St Philadelphia PA 19106

Philadelphia, PA 19106

United States

39° 57' 2.7504" N, 75° 9' 1.3464" W

See map: Google Maps

Case Basics

Docket No.

99-5

Petitioner

United States

Petitioner Type

Petitioner

Respondent

Morrison

Respondent Type

Respondent

Consolidation

No. 99-29

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

529 U.S. 598 (2000)

Argued

Tuesday, January 11, 2000

Decided

Monday, May 15, 2000

Advocates

Michael E. Rosman (Argued the cause for the respondents)

Julie Goldscheid (Argued the cause for the petitioner in No. 99-29, Brzonkala v. Morrison)

Seth P. Waxman (Department of Justice, argued the cause for the United States in No. 99-5)

Facts of the Case

In 1994, while enrolled at Virginia Polytechnic Institute (Virginia Tech), Christy Brzonkala alleged that Antonio Morrison and James Crawford, both students and varsity football players at Virginia Tech, raped her. In 1995, Brzonkala filed a complaint against Morrison and Crawford under Virginia Tech's Sexual Assault Policy. After a hearing, Morrison was found guilty of sexual assault and sentenced to immediate suspension for two semesters. Crawford was not punished. A second hearing again found Morrison guilty. After an appeal through the university's administrative system, Morrison's punishment was set aside, as it was found to be "excessive." Ultimately, Brzonkala dropped out of the university. Brzonkala then sued Morrison, Crawford, and Virginia Tech in Federal District Court, alleging that Morrison's and Crawford's attack violated 42 USC section 13981, part of the Violence Against Women Act of 1994 (VAWA), which provides a federal civil remedy for the victims of gender-motivated violence. Morrison and Crawford moved to dismiss Brzonkala's suit on the ground that section 13981's civil remedy was unconstitutional. In dismissing the complaint, the District Court found that that Congress lacked authority to enact section 13981 under either the Commerce Clause or the Fourteenth Amendment, which Congress had explicitly identified as the sources of federal authority for it. Ultimately, the Court of Appeals affirmed.

Question

Does Congress have the authority to enact the Violence Against Women Act of 1994 under either the Commerce Clause or Fourteenth Amendment?

Conclusion

Decision: 5 votes for Morrison, 4 vote(s) against
Legal provision: 42 U.S.C. 1398

No. In a 5-4 opinion delivered by Chief Justice William H. Rehnquist, the Court held that Congress lacked the authority to enact a statute under the Commerce Clause or the Fourteenth Amendment since the statute did not regulate an activity that substantially affected interstate commerce nor did it redress harm caused by the state. Chief Justice Rehnquist wrote for the Court that [i]f the allegations here are true, no civilized system of justice could fail to provide [Brzonkala] a remedy for the conduct of...Morrison. But under our federal system that remedy must be provided by the Commonwealth of Virginia, and not by the United States." Dissenting, Justice Stephen G. Breyer argued that the majority opinion "illustrates the difficulty of finding a workable judicial Commerce Clause touchstone." Additionally, Justice David H. Souter, dissenting, noted that VAWA contained a "mountain of data assembled by Congress...showing the effects of violence against women on interstate commerce."

United States v. Locke

Mon, 05 Jan 2009 16:14:22 +0000

Case Basics

Docket No.

98-1701

Petitioner

United States

Petitioner Type

Petitioner

Respondent

Locke

Respondent Type

Respondent

Consolidation

No. 98-1706

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

529 U.S. 89 (2000)

Argued

Tuesday, December 7, 1999

Decided

Monday, March 6, 2000

Advocates

William B. Collins (Olympia, Washington, argued the cause for respondents)

C. Jonathan Benner (Argued the cause for petitioner in No. 98-1706)

David C. Frederick (Department of Justice, argued the cause for petitioner in No. 98-1701)

Facts of the Case

In the aftermath of the Exxon Valdez oil spill, the State of Washington created the Office of Marine Safety, which was directed to establish standards to provide the "best achievable protection" (BAP) from oil spill damage. The agency promulgated tanker design, equipment, reporting, and operating requirements. The International Association of Independent Tanker Owners (Intertanko), a trade association of tanker operators, filed suit against the state and local officials responsible for enforcing the BAP regulations. Intertanko argued that Washington's BAP standards had entered an area occupied by the federal government and imposed unique requirements in an area where national uniformity was mandated. Further, Intertanko argued that if every political subdivision were to promulgate such maritime regulations, the goal of national governments to develop effective international environmental and safety would be undermined. The District Court upheld Washington's regulations. Thereafter, the Federal Government intervened on Intertanko's behalf, contending that the District Court's ruling failed to give sufficient weight to the substantial foreign affairs interests of the Federal Government. The Court of Appeals affirmed.

Question

Are the State of Washington's maritime regulations on tanker design, equipment, reporting, and operating requirements pre-empted by federal law?

Conclusion

Decision: 9 votes for United States, 0 vote(s) against
Legal provision: 46 U.S.C. 3703

Yes. In a unanimous opinion delivered by Justice Anthony Kennedy, the Court held that Washington's regulations regarding general navigation watch procedures, crew English-language skills and training, and maritime casualty reporting are pre-empted by the comprehensive federal regulatory scheme governing oil tankers. "The State of Washington has enacted legislation in an area where the federal interest has been manifest since the beginning of our Republic and is now well established," wrote Justice Kennedy for the Court. Justice Kennedy also noted that States may regulate their own ports and waterways so long as the rules are based on "the peculiarities of local waters" and do not conflict with federal regulation.

Reno v. Condon

Mon, 20 Jun 2011 04:06:30 +0000

Location

Congress

Constitution and Delaware Street Washington D.C. 20002

Washington 20002

United States

38° 53' 31.1496" N, 77° 0' 29.1744" W

See map: Google Maps

Case Basics

Docket No.

98-1464

Petitioner

Reno

Petitioner Type

Petitioner

Respondent

Condon

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

528 U.S. 141 (2000)

Argued

Wednesday, November 10, 1999

Decided

Wednesday, January 12, 2000

Advocates

Charles Condon (Columbia, South Carolina, argued the cause for respondents)

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

Facts of the Case

State departments of motor vehicles (DMVs) require drivers and automobile owners to provide personal information, which may include a person's name, address, telephone number, Social Security number, and photograph, as a condition of obtaining a driver's license or registering an automobile. Congress enacted the Driver's Privacy Protection Act of 1994 (DPPA),which establishes a regulatory scheme that restricts the States' ability to disclose a driver's personal information without the driver's consent, after finding that many States sell such information. The DPPA conflicts with South Carolina law, under which information contained in the State's DMV records is available to any person or entity that fills out a form listing the requester's name and address and stating that the information will not be used for telephone solicitation. The Attorney General of South Carolina filed suit, alleging the DPPA violated the Tenth and Eleventh Amendments. The District Court concluded that the DPPA was incompatible with the principles of federalism, granted summary judgement for the State, and permanently enjoined the DPPA's enforcement against the State. In affirming, the Court of Appeals also concluded that the DPPA violated the constitutional principles of federalism.

Question

Does the Driver's Privacy Protection Act of 1994 violate the constitutional principles of federalism?

Conclusion

Decision: 9 votes for Reno, 0 vote(s) against
Legal provision: 18 U.S.C. 2721

No. In a unanimous opinion delivered by Chief Justice William H. Rehnquist, the Court held that the DPPA is a proper exercise of Congress' regulation of interstate commerce under the Commerce Clause and doesn't run afoul of federalism principles. The law "does not require the states in their sovereign capacity to regulate their own citizens," Chief Justice Rehnquist wrote for the Court. "It does not require the South Carolina Legislature to enact any laws or regulations, and it does not require state officials to assist in the enforcement of federal statutes regulating private individuals," the Chief Justice added.

Kimel v. Florida Bd. Of Regents

Mon, 20 Jun 2011 04:06:30 +0000

Location

Florida State University

600 W College Ave Tallahassee FL 32306

Tallahassee, FL 32306

United States

30° 26' 26.7324" N, 84° 17' 26.9592" W

See map: Google Maps

Case Basics

Docket No.

98-791

Petitioner

Kimel

Petitioner Type

Petitioner

Respondent

Florida Bd. Of Regents

Respondent Type

Respondent

Consolidation

No. 98-796

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

528 U.S. 62 (2000)

Argued

Wednesday, October 13, 1999

Decided

Tuesday, January 11, 2000

Advocates

Jeremiah A. Collins (Argued the cause for petitioners in No. 98-791 (Kimel, et al.), and respondents under the Court's Rule 12.6 in support of petitioner in No. 98-796)

Barbara D. Underwood (Argued for the United States, as petitioner in No. 98-796, and respondent in support of petitioners in No. 98-791)

Jeffrey S. Sutton (Argued the cause for state respondents in both cases)

Facts of the Case

The Age Discrimination in Employment Act of 1967 (ADEA) makes it unlawful for a private employer "to fail or refuse to hire or to discharge any individual or otherwise discriminate against any individual...because of such individual's age." In 1974, Congress extended the ADEA's substantive requirements to the states. First, in 1994, employees of the University of Montevallo filed suit against the university, a branch of the State of Alabama, alleging that the university had discriminated against them on the basis of their age. The federal District Court dismissed the case based on the state's Eleventh Amendment immunity. The court determined that, although the ADEA shows Congress' intent to abrogate a state's Eleventh Amendment immunity, Congress did not enact or extend the ADEA under its Fourteenth Amendment enforcement powers. The court, therefore, held that the ADEA did not abrogate the state's Eleventh Amendment immunity. Second, in 1995, a group of faculty and librarians of Florida State University filed suit against the Board of Regents, alleging that the university's fiscal actions had violated the ADEA because the actions had a disparate impact on the pay of older employees. When the Florida Board of Regents moved to dismiss the suit on Eleventh Amendment grounds, the District Court denied the motion, holding that Congress expressed its intent to abrogate state Eleventh Amendment immunity in the ADEA, and that the ADEA is a proper exercise of congressional authority under the Fourteenth Amendment. Likewise, in 1996, a third case, involving an employee of the Florida Department of Corrections, was similarly decided. The Court of Appeals, in deciding all three cases, held that the ADEA does not abrogate the states' Eleventh Amendment immunity.

Question

Does the Age Discrimination in Employment Act of 1967 abrogate the states' Eleventh Amendment immunity?

Conclusion

Decision: 5 votes for Florida Bd. Of Regents, 4 vote(s) against
Legal provision: Age Discrimination in Employment (ADEA)

Split Vote

No. In a 5-4 opinion delivered by Justice Sandra Day O'Connor, the Court held that the ADEA contains a clear statement of Congress' intent to abrogate the states' immunity, but that the abrogation exceeds Congress' authority under the Fourteenth Amendment. "States may discriminate on the basis of age without offending the Fourteenth Amendment if the age classification in question is rationally related to a legitimate state interest," wrote Justice O'Connor for the Court. Justice O'Connor noted that, "[o]ld age also does not define a discrete and insular minority because all persons, if they live out their normal life spans, will experience it." Justice O'Connor concluded that "[i]n contrast, when a State discriminates on the basis of race or gender, we require a tighter fit between the discriminatory means and the legitimate ends they serve." Justices John Paul Stevens, David H. Souter, Ruth Bader Ginsburg and Stephen G. Breyer dissented.

College Savings Bank v. Florida Prepaid

Mon, 05 Jan 2009 16:25:05 +0000

Case Basics

Docket No.

98-149

Petitioner

College Savings Bank

Petitioner Type

Petitioner

Respondent

Florida Prepaid

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

527 U.S. 666 (1999)

Argued

Tuesday, April 20, 1999

Decided

Wednesday, June 23, 1999

Advocates

William B. Mallin (on behalf of the Respondents Florida Prepaid Postsecondary Education Expense Board, et al)

David C. Todd (Argued the cause for the petitioner)

Seth P. Waxman (Argued the cause for the United States as respondent)

Facts of the Case

This case is the second tier of a patent infringement action. College Savings Bank, a New Jersey chartered bank, markets and sells certificates of deposit designed to finance college costs. Florida Prepaid Postsecondary Education Expense Board (Florida Prepaid), a Florida state entity, administers a tuition prepayment program. In addition to its original patent infringement action, College Savings filed an action alleging that Florida Prepaid violated section 43 of the Lanham Act by making misstatements about its tuition savings plans in its brochures and annual reports. The Trademark Remedy Clarification Act (TRCA) subjects states to suits brought under section 43(a) of the Lanham Act for false and misleading advertising. The District Court granted Florida Prepaid's motion to dismiss on sovereign immunity grounds. The court rejected arguments from College Savings and the United States that Florida Prepaid had waived its sovereign immunity by engaging in interstate marketing and administration of its program after the TRCA made clear that such activity would subject it to suit; and that Congress's abrogation of sovereign immunity in the TRCA was effective, since it was enacted to enforce the Fourteenth Amendment's Due Process Clause. The Court of Appeals affirmed.

Question

Does the Trademark Remedy Clarification Act (TRCA) permit suits against states for alleged misrepresentations of their own products by providing a constitutionally permissible abrogation of state sovereign immunity? Does the TRCA permit suits against states for alleged misrepresentations of their own products by operating as a waiver of sovereign immunity when a state engages in activities regulated by the Lanham Act?

Conclusion

Decision: 5 votes for Florida Prepaid, 4 vote(s) against
Legal provision: 15 U.S.C. 1125

No and no. In a 5-4 opinion delivered by Justice Antonin Scalia, the Court held that "the federal courts are without jurisdiction to entertain this suit against an arm of the State of Florida." Justice Scalia concluded that "the sovereign immunity of the State of Florida was neither validly abrogated by the Trademark Remedy Clarification Act, nor voluntarily waived by the State's activities in interstate commerce." Writing for the dissenting minority, Justice Stephen G. Breyer expressed the view that Congress possesses the authority to abrogate a state's sovereign immunity where necessary and proper to the exercise of a congressional power under the Constitution's Article I. Justice John Paul Stevens filed his own dissenting opinion and joined that of Justice Breyer.

Florida Prepaid v. College Savings Bank

Mon, 05 Jan 2009 16:25:10 +0000

Case Basics

Docket No.

98-531

Petitioner

Florida Prepaid

Petitioner Type

Petitioner

Respondent

College Savings Bank

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

527 U.S. 627 (1999)

Argued

Tuesday, April 20, 1999

Decided

Wednesday, June 23, 1999

Advocates

Kevin J. Culligan (Argued the cause for College Savings Bank)

Jonathan A. Glogau (Tallahassee, Florida; argued the cause for the petitioner)

Seth P. Waxman (Argued the cause for the United States)

Facts of the Case

Immediately after the Patent and Plant Variety Protection Remedy Clarification Act (Act) changed patent laws to abrogate state's sovereign immunity, College Savings Bank (College) filed a patent infringement suit against Florida Prepaid Postsecondary Education Expense Board (Florida Prepaid), a Florida state entity. Florida Prepaid asked that College's suit be dismissed and that the Act be declared unconstitutional, based on Seminole Tribe of Florida v. Florida (517 US 44) which upheld state sovereign immunity. The United States joined College looking to uphold the Act's constitutionality. After agreeing with College, the District Court denied Florida Prepaid's dismissal motion. When the Federal Circuit affirmed, Florida Prepaid appealed and the Supreme Court granted certiorari.

Question

Did nullification of state sovereign immunity, under the Patent and Plant Variety Protection Remedy Clarification Act, constitute valid legislation?

Conclusion

Decision: 5 votes for Florida Prepaid, 4 vote(s) against
Legal provision: 35 U.S.C. 271

No. In a 5-to-4 opinion, the Court began by noting that there was no doubt that the Act intended to abrogate states' immunity from patent infringement. The Court then added that neither the Commerce Clause nor the Patent Clause give Congress the power to curtail state sovereign immunity from patent infringement claims. The Court reasoned that although the Fourteenth Amendment authorizes Congress to pass "appropriate legislation" to protect parties from being deprived of property without due process, this in itself does not permit the abrogation of state sovereign immunity. Only a showing of a consistent pattern of state patent violations, and a lack of adequate legal remedies to address such violations, would justify a limited effort to suspend a state's sovereign immunity. Since College made no such showing, and since the Act's language was overly broad in its scope, the Court dismissed College's suit and declared unconstitutional corresponding segments of the Act.

Alden v. Maine

Mon, 20 Jun 2011 04:06:30 +0000

Location

Alden's Workplace Cumberland County, ME

United States

43° 48' 47.8728" N, 70° 23' 13.4124" W

See map: Google Maps

Case Basics

Docket No.

98-436

Petitioner

Alden

Petitioner Type

Petitioner

Respondent

Maine

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

527 U.S. 706 (1999)

Argued

Wednesday, March 31, 1999

Decided

Wednesday, June 23, 1999

Advocates

Peter J. Brann (Argued the cause for the respondent)

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

Seth P. Waxman (Argued the cause for the United States, as amicus curiae, by special leave of the Court)

Facts of the Case

A group of probation officers sued their employer, the State of Maine, in 1992 alleging that the state had violated the overtime provisions of the 1938 Fair Labor Standards Act. Following the Court's decision in Seminole Tribe v. Florida (1996)which held that States are immune from private suits in federal court and that Congress lacks the authority to abrogate that immunitythe probation officers' suit was dismissed in Federal district court. Alden and the other probation officers then sued Maine again for violating the Fair Labor Standards Act, this time in state court. The state trial court and the state supreme court both held that Maine had sovereign immunity and could not be sued by private parties in their own court.

Question

May Congress use its powers under Article I of the Constitution to abrogate a state's sovereign immunity from private suits in its own courts?

Conclusion

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

No. A sharply divided court held in a 5-4 decision that Congress may not use its Article I powers to abrogate the states' sovereign immunity. Both the terms and history of the eleventh amendment suggest that States are immune from suits in their own courts. And more generally, the original understanding of the Constitution's structure and the terms of the tenth amendment confirm that states retained much of their sovereignty despite their agreeing that the national government would be supreme when exercising its enumerated powers.

UNUM Life Ins. Co. of America v. Ward

Mon, 05 Jan 2009 16:25:11 +0000

Case Basics

Docket No.

97-1868

Petitioner

UNUM Life Ins. Co. of America

Petitioner Type

Petitioner

Respondent

Ward

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

526 U.S. 358 (1999)

Argued

Wednesday, February 24, 1999

Decided

Tuesday, April 20, 1999

Advocates

Jeffrey I. Erlich (Argued the cause for the respondent)

Jeffrey L. Ehrlich (on behalf of the Respondent)

Edwin S. Kneedler (On behalf of the United States as amicus curiae supporting the Petitioner in part and the Respondent in part)

William J. Kayatta, Jr. (Argued the cause for the petitioner)

Facts of the Case

UNUM Life Insurance Company of America (UNUM) issued a long-term group disability policy to Management Analysis Company (MAC) as an insured welfare benefit plan governed the Employee Retirement Income Security Act of 1974 (ERISA). The policy provides that proof of claims must be furnished to UNUM within one year and 180 days after the onset of disability. John E. Ward, a California MAC employee, became permanently disabled in May 1992. Ward informed MAC of his disability in late February or early March 1993. UNUM received proof of Ward's claim on April 11, 1994. Ward was notified that his claim was denied as untimely because his notice was late under the terms of the policy. Ward then filed suit under ERISA's civil enforcement provision to recover the disability benefits provided by the plan. Ward argued that, under California's common-law agency rule, an employer administering an insured group health plan should be deemed to act as the insurance company's agent; therefore, his notice of permanent disability to MAC, in late February or early March 1993, sufficed to supply timely notice to UNUM. The District Court rejected Ward's argument and ruled in favor of UNUM, citing ERISA's preemption clause, which states that ERISA provisions "shall supersede ... State laws" to the extent that those laws "relate to any employee benefit plan." In reversing, the Court of Appeals noted that Ward might prevail under California's "notice-prejudice" rule, under which an insurer cannot avoid liability although the proof of claim is untimely, unless the insurer shows it suffered actual prejudice from the delay.

Question

Does the Employee Retirement Income Security Act of 1974 preempt California's common-law agency rule, under which a California employer administering an insured group health plan should be deemed to act as the insurance company's agent? Does ERISA preempt California's "notice-prejudice" rule?

Conclusion

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

Yes and no. In a unanimous opinion, delivered by Justice Ruth Bader Ginsburg, the Court held that California's agency rule is preempted by the Employee Retirement Income Security Act of 1974. Justice Ginsburg wrote for the Court that California's common-law agency rule "would have a marked effect on plan administration," adding that it would force employers to take on a role for which they had not volunteered. Further, the Court held that California's notice-prejudice rule is not preempted by ERISA because it is a "law ... which regulates insurance." Thus, Ward's insurance claim may go forward even though he filed for benefits after the deadline because UNUM did not suffer any prejudice from the delay. "By allowing a longer period to file than the minimum filing terms mandated by federal law, the [California] rule complements rather than contradicts ERISA and the regulations," wrote Justice Ginsburg.

Arizona Department of Revenue v. Blaze Constr. Co.

Mon, 05 Jan 2009 16:25:06 +0000

Case Basics

Docket No.

97-1536

Petitioner

Arizona Department of Revenue

Petitioner Type

Petitioner

Respondent

Blaze Constr. Co.

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

526 U.S. 32 (1999)

Argued

Tuesday, December 8, 1998

Decided

Tuesday, March 2, 1999

Advocates

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

Patrick Irvine (Argued the cause for the petitioner)

Bruce C. Smith (Argued the cause for the respondent)

Facts of the Case

Over several years, the Federal Bureau of Indian Affairs contracted with Blaze Construction Company to build, repair, and improve roads on several Indian reservations located in Arizona. When the various contracts expired, the Arizona Department of Revenue issued a tax deficiency assessment against Blaze for its failure to pay Arizona's transaction privilege tax, the tax levied on the gross receipts of companies doing business in the state, on the proceeds from its contracts with the Bureau. Blaze protested the assessment and prevailed in administrative proceedings. On review, the Arizona Tax Court granted summary judgment for the Department. In reversing, the Arizona Court of Appeals held that federal law pre-empted the tax's application to Blaze. The Supreme Court of Arizona denied review.

Question

May a state impose a nondiscriminatory tax upon a private company's proceeds from contracts with the Federal Government when the federal contractor renders its services on an Indian reservation?

Conclusion

Decision: 9 votes for Arizona Department of Revenue, 0 vote(s) against
Legal provision:

Yes. In a unanimous opinion delivered by Justice Clarence Thomas, the Court held that a "State generally may impose a nondiscriminatory tax upon a private company's proceeds from contracts with the Federal Government, regardless of whether the federal contractor renders its services on an Indian reservation." Justice Thomas wrote for the Court that, "[a]bsent a constitutional immunity or congressional exemption, federal law does not shield Blaze (a federal contractor) from Arizona's transaction privilege tax."

Humana Inc. v. Forsyth

Mon, 05 Jan 2009 16:25:06 +0000

Case Basics

Docket No.

97-303

Petitioner

Humana Inc.

Petitioner Type

Petitioner

Respondent

Forsyth

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

525 U.S. 299 (1999)

Argued

Monday, November 30, 1998

Decided

Wednesday, January 20, 1999

Advocates

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

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

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

Facts of the Case

Mary Forsyth, the beneficiary of a group health insurance policy issued by Humana Health Insurance of Nevada, Inc., received medical care at a hospital owned by Humana Inc. Humana Insurance agreed to pay 80 percent of Forsyth's hospital charges over a designated deductible. Forsyth bore responsibility for the remaining 20 percent of the charges. Forsyth complained that the hospital gave Human Insurance large discounts on their portion of the hospital charges. Thus, Humana Insurance paid the hospital significantly less than the actual 80 percent of the original bill and, in turn, Forsyth paid significantly more than her 20 percent of the hospital charges. Forsyth alleged that Humana Insurance and Humana Inc. had violated the federal Racketeer Influenced and Corrupt Organizations Act (RICO) through fraudulent activity. The District Court ruled in favor of Humana, citing the McCarran-Ferguson Act, which prevents acts of Congress from encroaching on state insurance law unless the act specifically relates to insurance. The Court of Appeals reversed and adopted a "direct conflict" test for determining when a federal law "invalidate[s], impair[s], or supersede[s]" a state insurance law. Under such a test, the McCarran-Ferguson Act did not bar Forsyth's suit because the Act does not preclude application of a federal statute prohibiting acts that are also prohibited under state insurance laws. The Act and Nevada law only provided for different damages to be collected.

Question

May plaintiffs use the federal anti-racketeering law to sue their health insurers over alleged fraud?

Conclusion

Decision: 9 votes for Forsyth, 0 vote(s) against
Legal provision: 15 U.S.C. 1012

Yes. In a unanimous decision, announce by Justice Ruth Bader Ginsburg, the Court ruled that because RICO advances states' interests in preventing insurance fraud, and since RICO does not encroach on Nevada law, the McCarran- Ferguson Act did not block Forsyth's recourse to RICO in this case.

El Al Israel Airlines v. Tseng

Mon, 05 Jan 2009 16:24:55 +0000

Case Basics

Docket No.

97-475

Petitioner

El Al Israel Airlines

Petitioner Type

Petitioner

Respondent

Tseng

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

525 U.S. 155 (1999)

Argued

Tuesday, November 10, 1998

Decided

Tuesday, January 12, 1999

Advocates

Jonathan E. Nuechtherlein (for the United States, as amicus curiae, supporting the Petitioner)

Jonathan Nuechterlein (For the United States, as amicus curiae, supporting the petitioner)

Robert H. Silk (Argued the cause for the respondent)

Diane W. Wilson (Argued the cause for the petitioner)

Facts of the Case

In a New York State court, Tsui Yuan Tseng alleged El Al Israel Airlines subjected her to an intrusive security search resulting in assault and false imprisonment before a flight from New York to Tel Aviv. Tseng alleged that psychic or psychosomatic personal injuries followed the incident, but no bodily injury occurred. El Al moved the case to federal court. The District Court dismissed the case due to the Warsaw Convention treaty. Convention provisions describe air carrier liability for international transportation of persons, baggage, or goods. Bodily injury, baggage or goods destruction, loss, or damage, and damage caused by delay are compensable under the Convention. Psychic or psychosomatic injury is not covered. Thus, Tseng's claim was not justicible. Moreover, New York tort law prevents El Al from liability suits covered under the Convention. The Court of Appeals held, in reversing, that the Convention drafters did not intend to remove all liability from an airline carrier, that the Convention does not shield routine operating procedures from the laws of signatory nations, and that the Convention precludes recourse to local law only when an incident is not exclusively covered. The Court of Appeals rejected the argument that the Convention would create uniformity because doing so would supplant applicable laws.

Question

Does the Warsaw Convention preclude international passengers from pursuing personal injury suits under local law?

Conclusion

Decision: 8 votes for El Al Israel Airlines, 1 vote(s) against
Legal provision: Treaty

Yes. In an 8-1 decision, announced by Justice Ruth Bader Ginsburg, the Court ruled that the Warsaw Convention precludes a passenger from maintaining an action for personal injury damages under local law when her claim does not satisfy the conditions for liability under the Convention. In her opinion, Justice Bader wrote, "[w]e would be hard put to conclude that the delegates at Warsaw meant to subject air carriers to the distinct, non-uniform liability rules of the individual signatory nations."

AT&T v. Central Office Telephone, Inc.

Mon, 05 Jan 2009 16:14:45 +0000

Case Basics

Docket No.

97-679

Petitioner

AT&T

Petitioner Type

Petitioner

Respondent

Central Office Telephone, Inc.

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

524 U.S. 214 (1998)

Argued

Monday, March 23, 1998

Decided

Monday, June 15, 1998

Advocates

David W. Carpenter (Argued the cause for the petitioner)

Bruce M. Hall (Argued the cause for the respondent)

Facts of the Case

Under the Communications Act of 1934, AT&T; must file "tariffs" containing all its charges for interstate services and all "classifications, practices and regulations affecting such charges" with the Federal Communications Commission (FCC). Under section 203(c) of the Act, a common carrier, such as AT&T;, may not "extend to any person any privileges or facilities in such communication, or employ or enforce any classifications, regulations, or practices affecting such charges, except as specified in such [tariff]."In 1989, AT&T; sold Central Office Telephone, Inc. its Software Defined Network, a long-distance service. Subsequently, Central Office experienced problems with the service and withdrew from the contract. Central Office sued AT&T; in Federal District Court, asserting state-law claims for breach of contract and for tortious interference with contractual relations for failure to deliver various service, provisioning, and billing options in addition to those set forth in the tariff. Ultimately, the Court of Appeals affirmed a jury's damages award.

Question

Do the federally filed tariff requirements of section 203 of the Communications Act of 1934 pre-empt state-law claims?

Conclusion

Decision: 7 votes for AT&T, 1 vote(s) against
Legal provision: Communication Act of 1934

Yes. In a 7-1 opinion delivered by Justice Antonin Scalia, the Court held that Communications Act's filed-tariff requirements pre-empt Central Office Telephone, Inc.'s state-law claims. Invoking the "filed-rate" doctrine, under which the rate a carrier duly files is the only lawful charge, the Court denied Central Office's claims of AT&T;'s failure to fulfill promised preferences not specified in its tariff filed with the FCC. "Because [Central Office Telephone, Inc.] asks for privileges not included in the tariff," wrote Justice Scalia, "its state-law claims are barred in either case." Justice John Paul Stevens wrote a dissenting opinion. Justice Sandra Day O'Connor took no part in the consideration or decision of the case.

Johnson v. Fankell

Mon, 05 Jan 2009 16:15:38 +0000

Case Basics

Docket No.

96-292

Petitioner

Johnson

Petitioner Type

Petitioner

Respondent

Fankell

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

520 U.S. 911 (1997)

Argued

Wednesday, February 26, 1997

Decided

Monday, June 9, 1997

Advocates

Michael S. Gilmore (Argued the cause for the petitioners)

W. B. Latta, Jr. (Argued the cause for the respondent)

Facts of the Case

Kristine L. Fankell filed an action for damages in Idaho State Court, alleging that the termination of her state employment by Marian Johnson, and other officials of the Idaho Liquor Dispensary, deprived her of property without due process in violation of the Fourteenth Amendment. The trial court dismissed Johnson and others' motion to dismiss, which asserted that they were entitled to qualified immunity. The Idaho Supreme Court dismissed their appeal from that ruling, explaining that the denial was neither an appealable final order under Idaho Appellate Rule 11(a)(1) nor appealable as a matter of federal right.

Question

Do defendants in an action brought under 42 USC section 1983 in state court have a federal right to an interlocutory appeal from a denial of qualified immunity?

Conclusion

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

No. In unanimous opinion delivered by John Paul Stevens, the Court held that defendants in a state-court section 1983 action do not have a federal right to an interlocutory appeal from a denial of qualified immunity. The Court reasoned that in construing state rules allowing appeals from final judgments, state courts did not need to accept the federal definition of a "final decision" within the meaning of federal law. The right to an interlocutory appeal of a denial of immunity "is a federal procedural right that simply does not apply in a non-federal forum," Justice Stevens wrote for the court.

United States v. Alaska

Mon, 05 Jan 2009 16:15:40 +0000

Case Basics

Docket No.

84 ORIG

Petitioner

United States

Respondent

Alaska

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

521 U.S. 1 (1997)

Argued

Monday, February 24, 1997

Decided

Thursday, June 19, 1997

Advocates

G. Thomas Koester (Argued the cause for the defendant)

Jeffrey P. Minear (Department of Justice, argued the cause for the plaintiff)

Facts of the Case

The United States disputed the ownership of submerged lands along Alaska's Arctic Coast. The Alaska Statehood Act expressly provided that the federal Submerged Lands Act (Act) applies to Alaska. The Act entitles Alaska to submerged lands beneath tidal and inland navigable waters and submerged lands extending three miles seaward of the State's coastline. The United States claimed a right to submerged lands along the Alaska's Arctic Coast for mineral leasing. Alaska, in a counterclaim, sought to quiet its title to coastal submerged lands within two federal reservations, the National Petroleum Reserve Alaska and the Arctic National Wildlife Refuge, formerly known as the Arctic National Wildlife Range.

Question

Does the United States own disputed submerged lands along Alaska's Arctic Coast?

Conclusion

Decision: 6 votes for United States, 3 vote(s) against
Legal provision: Submerged Lands Acts

Yes. In a decision authored by Justice Sandra Day O'Connor, the Court ruled that the federal government, the United States, owned the disputed submerged lands - adjacent to the National Wildlife Refuge and the National Petroleum Reserve - along Alaska's Arctic Coast.

DeBuono v. NYSA-ILA Med. and Clin. Service Fund

Mon, 05 Jan 2009 16:15:39 +0000

Case Basics

Docket No.

95-1594

Petitioner

DeBuono

Petitioner Type

Petitioner

Respondent

NYSA-ILA Med. and Clin. Service Fund

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

520 U.S. 806 (1997)

Argued

Monday, February 24, 1997

Decided

Monday, June 2, 1997

Advocates

Donato Caruso (Argued the cause for the respondents)

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

M. Patricia Smith (Argued the cause for the petitioners)

Facts of the Case

New York's Health Facility Assessment (HFA) imposes a tax on gross receipts for patient services at diagnostic and treatment centers. The NYSA ILA Medical and Clinical Services Fund, which administers a plan subject to the Employee Retirement Income Security Act (ERISA), owns and operates New York treatment centers for longshore workers, retirees and their dependents. The Fund's trustees discontinued paying the New York tax and filed to enjoin the state from making future assessments and to obtain a refund. Lawyers for the Fund alleged that the HFA is preempted by the ERISA, as it applies to hospitals run by it. The District Court ruled that the HFA is not preempted because it is a tax of general application having only an incidental impact on benefit plans. In reversing, the Court of Appeals found that the HFA directly reduces the amount of Fund assets that would otherwise be available to provide plan members with benefits, and could cause the plan to limit its benefits or to charge plan members higher fees; therefore, the HFA was preempted by the ERISA.

Question

Does the Employee Retirement Income Security Act preclude New York's Health Facility Assessment from imposing a gross-receipts tax on the income of medical centers operated by ERISA funds?

Conclusion

Decision: 7 votes for DeBuono, 0 vote(s) against
Legal provision: Employee Retirement Income Security

No. In a 7-2 decision, authored by Justice John Paul Stevens, the Court ruled that the Employee Retirement Income Security Act does not preclude New York from imposing a gross receipts tax on ERISA funded medical centers. Justice Stevens wrote, "Any state tax, or other law, that increases the cost of providing benefits to covered employees" will affect the benefit plan, "but that simply cannot mean that every state law with such an effect is pre- empted.

Boggs v. Boggs

Mon, 05 Jan 2009 16:15:41 +0000

Case Basics

Docket No.

96-79

Petitioner

Boggs

Petitioner Type

Petitioner

Respondent

Boggs

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

520 U.S. 833 (1997)

Argued

Wednesday, January 15, 1997

Decided

Monday, June 2, 1997

Advocates

Edward J. Deano, Jr. (Argued the cause for the respondent)

Marian M. Livaudais (Argued the cause for the petitioner)

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

Facts of the Case

Isaac Boggs married Sandra Boggs, the petitioner, after the death of Dorothy, his previous wife. When Isaac retired in 1985, he received various benefits from his employer's retirement plans, including a lump sum savings plan distribution, shares of stock from the company's employee stock ownership plan, and a monthly annuity payment. In 1989, following Issac's death a dispute over ownership of the benefits arose between Sandra and Issac's sons, Thomas F., Harry M., and David B. Boggs. The sons' claim is based on Dorothy's purported testamentary transfer to them, under Louisiana law, of a portion of her community property interest in Isaac's undistributed pension plan benefits. Sandra contested the validity of that transfer, arguing that the sons' claim is pre-empted by the Employee Retirement Income Security Act of 1974. The Federal District Court disagreed and granted summary judgment against Sandra. The Court of Appeals affirmed.

Question

Does the Employee Retirement Income Security Act of 1974 pre-empt state community-property law allowing a non-participant spouse to transfer by a testamentary instrument an interest in undistributed pension plan benefits?

Conclusion

Decision: 5 votes for Boggs, 4 vote(s) against
Legal provision: Employee Retirement Income Security

Yes. In a opinion authored by Justice Anthony Kennedy, the Court ruled that the Employee Retirement Income Security Act of 1974 (ERISA) preempts state community-property law allowing a non-participant spouse to transfer by a testamentary instrument an interest in undistributed pension plan benefits. Justice Kennedy said "ERISA's solicitude for the economic security of surviving spouses would be undermined" by allowing a previous spouse's heirs to claim a share of such benefits."

Printz v. United States

Mon, 20 Jun 2011 04:06:28 +0000

Location

Sheriff Printz's Office

205 Bedford Street Hamilton MT 59840

Hamilton, MT 59840

United States

46° 14' 41.6544" N, 114° 9' 24.75" W

See map: Google Maps

Case Basics

Docket No.

95-1478

Petitioner

Printz

Petitioner Type

Petitioner

Respondent

United States

Respondent Type

Respondent

Consolidation

No. 95-1503

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

521 U.S. 898 (1997)

Argued

Tuesday, December 3, 1996

Decided

Friday, June 27, 1997

Advocates

Stephen P. Halbrook (Argued the cause for the petitioners)

David Dellinger (Argued the cause for the United States)

Walter E. Dellinger, III (on behalf of the Respondent)

Facts of the Case

The Brady Handgun Violence Prevention Act (Brady Bill) required "local chief law enforcement officers" (CLEOs) to perform background-checks on prospective handgun purchasers, until such time as the Attorney General establishes a federal system for this purpose. County sheriffs Jay Printz and Richard Mack, separately challenged the constitutionality of this interim provision of the Brady Bill on behalf of CLEOs in Montana and Arizona respectively. In both cases District Courts found the background-checks unconstitutional, but ruled that since this requirement was severable from the rest of the Brady Bill a voluntary background-check system could remain. On appeal from the Ninth Circuit's ruling that the interim background-check provisions were constitutional, the Supreme Court granted certiorari and consolidated the two cases deciding this one along with Mack v. United States.

Question

Using the Necessary and Proper Clause of Article I as justification, can Congress temporarily require state CLEOs to regulate handgun purchases by performing those duties called for by the Brady Bill's handgun applicant background-checks?

Conclusion

Decision: 5 votes for Printz, 4 vote(s) against
Legal provision: 18 U.S.C. 922

No. The Court constructed its opinion on the old principle that state legislatures are not subject to federal direction. The Court explained that while Congress may require the federal government to regulate commerce directly, in this case by performing background-checks on applicants for handgun ownership, the Necessary and Proper Clause does not empower it to compel state CLEOs to fulfill its federal tasks for it - even temporarily. The Court added that the Brady Bill could not require CLEOs to perform the related tasks of disposing of handgun-application forms or notifying certain applicants of the reasons for their refusal in writing, since the Brady Bill reserved such duties only for those CLEO's who voluntarily accepted them.