Cases by Issue - Confrontation

Davis v. Washington

Mon, 05 Jan 2009 17:45:10 +0000

Case Basics

Docket No.

05-5224

Petitioner

Adrian Martell Davis

Petitioner Type

Petitioner

Respondent

Washington

Respondent Type

Respondent

Heard By

Roberts Court (2006-2009)

Decided By

Roberts Court (2006-2009)

Opinion

547 U.S. ___ (2006)

Granted

Monday, October 31, 2005

Argued

Monday, March 20, 2006

Decided

Monday, June 19, 2006

Advocates

Jeffrey L. Fisher (argued the cause for Petitioner)

Michael R. Dreeben (argued the cause for Respondent)

James M. Whisman (argued the cause for Respondent)

Facts of the Case

Davis was arrested after Michelle McCottry called 911 and told the operator that he had beaten her with his fists and then left. At trial, McCottry did not testify, but the 911 call was offered as evidence of the connection between Davis and McCottry's injuries. Davis objected, arguing that presenting the recording without giving him the opportunity to cross-examine McCottry violated his Sixth Amendment right to confront his accuser as interpreted by the U.S. Supreme Court in Crawford v. Washington. The Washington Supreme Court disagreed, finding that the call was not "testimonial" and was therefore different from the statements at issue in Crawford.

Question

Under the U.S. Supreme Court's interpretation of the Sixth Amendment in Crawford v. Washington, may statements made to police during investigation of a crime, though not made with the intent to preserve evidence, be admitted in court without allowing defendants to cross-examine the person who made the original statements?

Conclusion

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

Yes. In a 9-0 decision authored by Justice Antonin Scalia, the Court ruled that the Confrontation Clause of the Sixth Amendment, as interpreted in Crawford v. Washington, does not apply to "non-testimonial" statements not intended to be preserved as evidence at trial. Although McCottry identified her attacker to the 911 operator, she provided the information intending to help the police resolve an "ongoing emergency," not to testify to a past crime. The Court reasoned that under the circumstances, McCottry was not acting as a "witness," and the 911 transcript was not "testimony." Therefore, the Sixth Amendment did not require her to appear at trial and be cross- examined. Justice Clarence Thomas wrote a separate opinion concurring in part and dissenting in part. He argued that though McCottry's statements were not testimonial, the Court should not "guess" at the primary motive behind the statements. This case was decided with Hammon v. Indiana.

Hammon v. Indiana

Mon, 05 Jan 2009 17:45:29 +0000

Case Basics

Docket No.

05-5705

Petitioner

Hershel Hammon

Petitioner Type

Petitioner

Respondent

Indiana

Respondent Type

Respondent

Heard By

Roberts Court (2006-2009)

Decided By

Roberts Court (2006-2009)

Opinion

547 U.S. ___ (2006)

Granted

Monday, October 31, 2005

Argued

Monday, March 20, 2006

Decided

Monday, June 19, 2006

Advocates

Richard D. Friedman (argued the cause for Petitioner)

Thomas M. Fisher (argued the cause for Respondent)

Irving L. Gornstein (argued the cause for Respondent)

Facts of the Case

Hershel Hammon was charged with domestic abuse after police responded to a call from his house. When they arrived, Hammon's wife told police that her husband had beaten her. While Mrs. Hammon did not testify at Mr. Hammon's trial, the police officer did testify about what she had told him. Mr. Hammon's attorney objected to the admission of the testimony without cross- examination, but the judge allowed it under the "excited utterance" exception to the general rule against hearsay testimony (second-hand reports of what someone said or did). The police officer was not trying to preserve evidence but merely to assess the incident, so Mrs. Hammon's statements to him were not the sort of testimony prohibited under the U.S. Supreme Court's decision in Crawford v. Washington.

Question

Conclusion

Yes. In an 8-1 decision authored by Justice Antonin Scalia, the Court ruled that the Confrontation Clause of the Sixth Amendment, as interpreted in Crawford v. Washington, does not apply to "non-testimonial" statements not intended to be preserved as evidence at trial. In Hammon's case, however, the Court ruled that Mrs. Hammon's statements to the police were testimonial. At the time of her questioning, Hammon faced "no emergency in progress" and "no immediate threat to her person." Instead, the relative safety of the conversation between Mrs. Hammon and the officer made it "formal enough" to qualify as a "testimonial" statement intended as evidence of the past crime. The Court left open the possibility that Hershel Hammon could have forfeited his constitutional right to confront the witnesses against him by coercively preventing his wife from testifying. Otherwise, however, the Court ruled that the Sixth Amendment did not allow Mrs. Hammon's testimony to be used against Mr. Hammon without her presence at the trial. Justice Clarence Thomas wrote a dissent criticizing the Court's test as unworkable. In Justice Thomas's view, Hammon's statement was not testimonial, because the conversation was not a "formalized dialogue." This case was decided along with Davis v. Washington.

Crawford v. Washington

Mon, 05 Jan 2009 17:44:37 +0000

Case Basics

Docket No.

02-9410

Petitioner

Michael D. Crawford

Petitioner Type

Petitioner

Respondent

Washington

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

541 U.S. 36 (2004)

Granted

Monday, June 9, 2003

Argued

Monday, November 10, 2003

Decided

Monday, March 8, 2004

Advocates

Steven C. Sherman (argued the cause for Respondent)

Jeffrey L. Fisher (argued the cause for Petitioner)

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

Facts of the Case

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

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

Question

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

Conclusion

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

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

United States v. Recio

Mon, 05 Jan 2009 17:48:38 +0000

Case Basics

Docket No.

01-1184

Petitioner

United States

Petitioner Type

Petitioner

Respondent

Recio

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

537 U.S. 270 (2003)

Argued

Tuesday, November 12, 2002

Decided

Tuesday, January 21, 2003

Advocates

M. Karl Shurtliff (Argued the cause for the respondents)

Michael R. Dreeben (Argued the cause for the petitioner)

Facts of the Case

In 1997, police stopped a truck in Nevada and seized the illegal drugs that it was carrying. With the help of the truck drivers, the police set up a sting. Francisco Jimenez Recio and Adrian Lopez-Meza came for the truck and were subsequently arrested. A jury convicted Jimenez Recio and Lopez-Meza of conspiracy, but the trial judge ordered a new trial under Ninth Circuit Court of Appeals precedent that held a conspiracy terminates when "'there is affirmative evidence of...defeat of the object of the conspiracy.'" In other words, the federal government could not prosecute the drug conspiracy defendants unless they had joined the conspiracy before the government seized the drugs. The new jury convicted the two men once again. In reversing, the Ninth Circuit held that the evidence presented at the second trial was insufficient to show that Jimenez Recio and Lopez-Meza had joined the conspiracy before the drug seizure.

Question

Is the Ninth Circuit rule -- that a conspiracy ends automatically when the object of the conspiracy becomes impossible to achieve -- valid?

Conclusion

Decision: 8 votes for United States, 1 vote(s) against
Legal provision:

No. In a 9-0 opinion delivered by Justice Stephen G. Breyer, the Court held that a conspiracy does not automatically terminate simply because the federal government has defeated its object, such that Ninth Circuit's conspiracy- termination law is erroneous. Justice Breyer stated that the Ninth Circuit's rule is inconsistent with basic conspiracy law and that the agreement to commit an unlawful act is "'a distinct evil,'" which "'may exist and be punished whether or not the substantive crime ensues.'" Justice John Paul Stevens filed an opinion concurring in part and dissenting in part.

Becker v. Montgomery

Mon, 05 Jan 2009 17:44:19 +0000

Case Basics

Docket No.

00-6374

Petitioner

Becker

Petitioner Type

Petitioner

Respondent

Montgomery

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

532 U.S. 757 (2001)

Argued

Monday, April 16, 2001

Decided

Tuesday, May 29, 2001

Advocates

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

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

Facts of the Case

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

Question

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

Conclusion

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

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

New York v. Hill

Mon, 05 Jan 2009 16:14:38 +0000

Case Basics

Docket No.

98-1299

Petitioner

New York

Petitioner Type

Petitioner

Respondent

Hill

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

528 U.S. 110 (2000)

Argued

Tuesday, November 2, 1999

Decided

Tuesday, January 11, 2000

Advocates

Lisa S. Blatt (Argued the cause for the United States as amicus curiae supporting the petitioner and urging reversal)

Robert Mastrocola (Rochester, New York, argued the cause for petitioner)

Brian Shiffrin (Rochester, New York, argued the cause for the respondent)

Facts of the Case

The Interstate Agreement on Detainers (IAD) is a congressionally sanctioned interstate compact to establish procedures for resolution of one state's outstanding charges against a prisoner of another state. Under the Compact Clause, the IAD is a federal law subject to federal construction. In order to resolve outstanding murder and robbery charges against Michael Hill, an Ohio prisoner, the State of New York lodged a detainer against him under the IAD. Hill filed a request for disposition of the detainer, pursuant to IAD Article III, and was returned to New York. Article III provides that, upon such a request, that the prisoner be brought to trial within 180 days. Thereafter, Hill's counsel agreed to a trial date outside the 180-day period. Subsequently, Hill moved to dismiss his indictment, arguing that the IAD's time limit had expired. The trial court denied Hill's motion, concluding that his defense counsel's explicit agreement to the trial date constituted a waiver or abandonment of Hill's IAD rights. After his conviction and subsequent appeal, the Appellate Division of the New York Supreme Court affirmed the trial court's refusal to dismiss. In reversing, the state Court of Appeals ordered that Hill's indictment be dismissed because his counsel's agreement to a later trial date, it held, did not waive his IAD speedy trial rights.

Question

Does a defense counsel's agreement to a trial date outside the 180-day time period required by Article III of the Interstate Agreement on Detainers waive the defendant's right to a speedy trial?

Conclusion

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

Yes. In a unanimous opinion delivered by Justice Antonin Scalia, the Court held that a defense counsel's agreement to a trial date outside the period provided for by the IAD bars the defendant from seeking dismissal on the ground that trial did not occur within that period. Noting scheduling matters are generally controlled by counsel without the fully informed and publicly acknowledged consent of the client, Justice Scalia wrote, "[w]hat suffices for waiver depends on the nature of the right at issue." In such cases, "[a]bsent a demonstration of ineffectiveness, counsel's word on such matters is the last." Thus, defense counsel's agreement to a later trial date waived Hill's speedy trial rights under the IAD.

Lilly v. Virginia

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

Case Basics

Docket No.

98-5881

Petitioner

Lilly

Petitioner Type

Petitioner

Respondent

Virginia

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

527 U.S. 116 (1999)

Argued

Monday, March 29, 1999

Decided

Thursday, June 10, 1999

Advocates

Kathleen P. Baldwin (Argued the cause for the respondent)

Katherine P. Baldwin (Argued the cause for the petitioner)

Ira S. Sacks ()

Facts of the Case

Benjamin Lee Lilly, his brother Mark Lilly, and Gary Barker were arrested after stealing liquor and guns and abducting Alex DeFilippis, who was later shot and killed. Under police questioning, Mark admitted stealing liquor, but claimed that Benjamin and Barker stole the guns and that Benjamin shot DeFilippis. When Virginia called Mark as a witness at Benjamin's subsequent criminal trial, Mark invoked his Fifth Amendment privilege against self- incrimination. The trial court then admitted his statements to the police as declarations of an unavailable witness against penal interest. The court overruled Benjamin's objections that the statements were not against Mark's penal interest because they shifted responsibility for the crimes to Barker and Benjamin, and that their admission would violate the Sixth Amendment's Confrontation Clause. Subsequently, Benjamin was convicted of the DeFilippis murder and other crimes. In affirming, the Virginia Supreme Court found that the Confrontation Clause was satisfied because Mark's statements fell within a firmly rooted exception to the hearsay rule. The court also held that the statements were reliable because Mark knew that he was implicating himself as a participant in numerous crimes and because the statements were independently corroborated by other evidence at trial.

Question

Does trial evidence that includes out-of-court statements, that admit some wrongdoing but place primary blame on the defendant, by an alleged, nontestifying accomplice violate a criminal defendant's Sixth Amendment Confrontation Clause right to confront all adverse witnesses?

Conclusion

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

Yes. In an opinion delivered by Justice John Paul Stevens, the Court held that the admission of Mark's confession violated Benjamin's Confrontation Clause right "to be confronted with the witnesses against him." All nine justices voted to overturn the Virginia Supreme Court's decision that had allowed such hearsay testimony under an exception for statements made against penal interest. Justice Stevens wrote for a plurality that the confession could not be considered "sufficiently reliable as to be admissible without allowing [the defendant] to cross-examine him." Chief Justice William H. Rehnquist and Justices Antonin Scalia, Clarence Thomas and Stephen G. Breyer wrote concurring opinions.

Gray v. Maryland

Mon, 05 Jan 2009 16:14:47 +0000

Case Basics

Docket No.

96-8653

Petitioner

Gray

Petitioner Type

Petitioner

Respondent

Maryland

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

523 U.S. 185 (1998)

Argued

Monday, December 8, 1997

Decided

Monday, March 9, 1998

Advocates

Roy W. McLeese (Argued the cause for the United States, as amicus curiae, by special leave of court, supporting the respondent)

Carmen M. Shepard (Argued the cause for the respondent)

Arthur A. Delano, Jr. (Argued the cause for the petitioner)

Facts of the Case

In 1993, the State of Maryland tried Anthony Bell and Kevin Gray jointly for the murder of Stacy Williams. The State entered Bell's confession into evidence at trial. According to the trial judge's order, the police detective who read the confession said the word "deleted" or "deletion" whenever Gray's name appeared. Subsequently, the prosecutor asked the detective if Bell's confession led to Gray's arrest. The detective answered that it did. Ultimately, Gray testified and Bell did not. When instructing the jury, the trial judge specified that the confession was evidence only against Bell. The jury convicted both Bell and Gray. Setting aside Gray's conviction, Maryland's intermediate appellate court applied Bruton v. United States, 391 U.S. 123, in which the Court held that, despite a limiting instruction that the jury should consider the confession as evidence only against the confessing codefendant, the introduction of such a confession at a joint trial violates the nonconfessing defendant's Sixth Amendment right to cross-examine witnesses. Maryland's highest court reinstated the conviction.

Question

Does Bruton v. United States apply to a redaction that replaces a name with an obvious blank space or a symbol or a word such as "deleted?"

Conclusion

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

Yes. In a 5-4 opinion delivered by Justice Stephen G. Breyer, the Court held that the confession, which substituted blanks and the word "delete" for the respondent's proper name, falls within the class of statements to which Bruton's protections apply. Applying Bruton, Justice Breyer wrote that a jury will often react to an unredacted confession and a confession redacted with the word "delete" similarly by realizing that the confession refers to the defendant. Justice Anton Scalia, joined by Chief Justice William H. Rehnquist and Justices Anthony M. Kennedy and Clarence Thomas, dissented. Justice Scalia argued that Bell's confession could constitutionally have been admitted with a limiting instruction to the jury.

United States v. Scheffer

Mon, 05 Jan 2009 16:15:08 +0000

Case Basics

Docket No.

96-1133

Petitioner

United States

Petitioner Type

Petitioner

Respondent

Scheffer

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

523 U.S. 303 (1998)

Argued

Monday, November 3, 1997

Decided

Tuesday, March 31, 1998

Advocates

Kim L. Sheffield (Argued the cause for the respondent)

Michael R. Dreeben (Argued the cause for the petitioner)

Facts of the Case

While defending himself before a military court martial on, among other things, substance abuse charges, airman Edward G. Scheffer sought to introduce his polygraph examination results. The results indicated there was "no deception" in Scheffer's denial that he used drugs while enlisted. Relying on Military Rule of Evidence 707 ("Rule 707"), prohibiting the use of polygraph results in court-martial proceedings, the military judge refused Scheffer's request to admit his results into evidence. On successive appeals, following his conviction on all charges, the Air Force Court of Appeals affirmed but the Court of Appeals for the Armed Forces reversed, finding the evidentiary exclusion to be unconstitutional. The United States appealed and the Supreme Court granted certiorari.

Question

Does Military Rule of Evidence 707, excluding the admission of polygraph results into evidence, violate a defendant's Sixth Amendment right to present a fair defense?

Conclusion

Decision: 8 votes for United States, 1 vote(s) against
Legal provision: Amendment 6: Other Sixth Amendment Provisions

No. In an 8-to-1 decision, the Court held that Rule 707 was consistent with the legitimate interest of state and federal authorities to admit only reliable evidence. In addition to noting the even-handed scope of Rule 707, excluding from evidence both favorable and unfavorable polygraph results, the Court emphasized the poor reliability of polygraph evidence as a whole. In the absence of sounder detection methods, the Court noted that the fundamental premise of the criminal justice system is that juries are the ultimate and most reliable evaluators of credibility and truthfulness.

Klehr Et Ux. v. A. O. Smith Corp.

Mon, 05 Jan 2009 16:15:58 +0000

Case Basics

Docket No.

96-663

Petitioner

Klehr Et Ux.

Petitioner Type

Petitioner

Respondent

A. O. Smith Corp. et al.

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

521 U.S. 179 (1997)

Argued

Monday, April 21, 1997

Decided

Thursday, June 19, 1997

Advocates

Bruce J. Ennis, Jr. (on behalf of the Respondents)

Charles A. Bird (on behalf of the Petitioners)

Facts of the Case

Marvin Klehr purchased inadequate cattle feed containers from A. O. Smith Harvestore Products, Inc. (Harvestore) in 1974. Over a long period of time, the containers damaged Klehr's cattle feed. In 1993, Klehr filed a civil claim against Harvestore under the Racketeer Influenced and Corrupt Organizations Act of 1970 (RICO). The District Court dismissed Klehr's suit, ruling that the four-year time limit for bringing a civil RICO suit had expired. Klehr claimed that he was not at fault for failing to discover the injury within four years, because Harvestore purposely designed the containers to conceal their inadequacy.

The U.S. Court of Appeals for the Eighth Circuit upheld the lower court. The Eighth Circuit held that Klehr should have discovered the pattern of racketeering activity much earlier. Since the statute of limitations began from the time Klehr could reasonably be expected to have discovered the pattern, Klehr was out of time. The Eighth Circuit's "pattern of activity" rule contradicted the Third Circuit's "last predicate act" rule, which allows a plaintiff to recover damages accumulated since the first injury as long as the last RICO violation ("last predicate act") happened within four years of the lawsuit.

Question

1)Does the time limit for filing a civil claim under the Racketeer Influenced and Corrupt Organizations Act of 1970 (RICO) begin after the plaintiff discovers the last illegal act ("last predicate act") at the end of a pattern of racketeering activity?

2)If the plaintiff demonstrates "fraudulent concealment" of the injury inflicted, can RICO's civil-claim limitations period be extended?

Conclusion

Decision: 9 votes for A. O. Smith Corp., 0 vote(s) against
Legal provision: Racketeer Influenced and Corrupt Organizations

No and No. Justice Stephen Breyer wrote the opinion for a unanimous Court. The "last predicate rule...lengthens the limitations period dramatically" and thereby contradicts Congress's intention of ensuring a time limit for civil RICO claims. Also, "the plaintiff cannot use an independent, new act as a bootstrap to recover for injuries caused by other predicate acts that took place outside the limitations period."

RICO intends "not only to compensate victims but also to encourage those victims diligently to investigate and thereby to uncover unlawful activity." To demonstrate "fraudulent concealment", a plaintiff must have failed to discover injuries inflicted upon him after acting with "reasonable diligence" to discover the source and pattern of the injuries.

Old Chief v. United States

Mon, 05 Jan 2009 16:15:43 +0000

Case Basics

Docket No.

95-6556

Petitioner

Old Chief

Petitioner Type

Petitioner

Respondent

United States

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

519 U.S. 172 (1997)

Argued

Wednesday, October 16, 1996

Decided

Tuesday, January 7, 1997

Advocates

Miguel A. Estrada (Department of Justice, argued the cause for the respondent)

Daniel Donovan (Montana, argued the cause for the petitioner)

Facts of the Case

Johnny Lynn Old Chief was involved in a disturbance involving gunfire. Subsequently, Old Chief was charged with violating federal law, 18 U. S. C. Section(s) 922(g)(1), which prohibits possession of a firearm by anyone with a prior felony conviction. The earlier crime that was charged in the indictment against Old Chief was assault causing serious bodily injury. Old Chief moved for an order requiring the Government to refrain from revealing the name and nature of his prior assault conviction, which, he argued, would unfairly tax the jury's capacity to hold the Government to its burden of proof beyond a reasonable doubt, in violation of Federal Rules of Evidence, on current charges of assault, possession, and violence with a firearm. Old Chief offered to stipulate, or concede, to the fact of the prior conviction without releasing its name or nature. The Government refused to join the stipulation. The Government argued it had the right to present its own evidence of the prior conviction. The District Court ruled in favor of the Government. In affirming the conviction, the Court of Appeals found that the Government was entitled to introduce probative evidence to prove the prior offense regardless of the stipulation offer.

Question

Does a District Court have the authority to reject a defendant's offer to conceded a prior conviction and admit the prosecution's presentation of it when the name or nature of the conviction raises the risk of a verdict tainted by improper considerations, and when the purpose of the evidence is solely to prove the element of prior conviction?

Conclusion

Decision: 5 votes for Old Chief, 4 vote(s) against
Legal provision: Federal Rules of Evidence

No. In an opinion authored by Justice David Souter, the Court ruled that a district court abuses its discretion under the Federal Rules of Evidence if it spurns a defendant's offer to concede a prior judgment and admits the full judgment record over the defendant's objection, when the name or nature of the prior offense raises the risk of a verdict tainted by improper considerations, and when the purpose of the evidence is solely to prove the element of prior conviction.

Degen v. United States

Mon, 05 Jan 2009 16:24:49 +0000

Case Basics

Docket No.

95-173

Petitioner

Degen

Petitioner Type

Petitioner

Respondent

United States

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

517 U.S. 820 (1996)

Argued

Monday, April 22, 1996

Decided

Monday, June 10, 1996

Advocates

Miguel A. Estrada (Argued the cause for the respondent)

Lawrence S. Robbins (Argued the cause for the petitioner)

Facts of the Case

Brian Degen was indicted in 1989 for distributing marijuana, laundering money, and related crimes. On the same day the district court unsealed the indictment, it also unsealed a civil forfeiture complaint for properties allegedly worth $5.5 million and purchased with proceeds of Degen's drug sales or used to facilitate the sales. Degen is a citizen of both the U.S. and Switzerland, and in 1988 he and his family moved to Switzerland. He has not returned to the U.S. to face criminal charges and by treaty the Swiss are not obliged to extradite their nationals to the U.S. While residing in Switzerland, Degen filed an answer in the civil case, claiming that the forfeiture was barred by the statute of limitations and was an unlawful retroactive application of forfeiture laws. The district court did not consider his arguments. Instead, it entered summary judgment against him, holding that he was not entitled to be heard in the civil action because he remained outside the country, unamenable to criminal prosecution. On appeal, the government argued that the district court's inherent powers authorized it to strike Degen's claims under the "fugitive disentitlement doctrine."

Question

Should the fugitive disentitlement doctrine be extended to allow a court in a civil forfeiture suit to enter judgment against a claimant, without any opportunity to be heard, because the claimant is a fugitive from, or otherwise is resisting, a related criminal prosecution?

Conclusion

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

No. Principles of deference to the other branches of government require a court to invoke its inherent power only as a reasonable response to the problems and needs that provoke it. No sufficient reason justifies disentitlement here. Since the court's jurisdiction over the property is secure despite Degen's absence, there is no risk of delay or frustration in determining the merits of the government's forfeiture claims or in enforcing the resulting judgment. Also, the court has alternatives, other than disentitlement, to keep Degen from using liberal civil discovery rules to gain an improper advantage in the criminal prosecution, where discovery is more limited. Finally, disentitlement is an excessive response to the court's interests in redressing the indignity visited upon it by Degen's absence from the criminal proceeding, and in deterring flight from criminal prosecution in general; it is a response that erodes rather than enhances the dignity of the court.

North Star Steel Co. v. Thomas

Mon, 05 Jan 2009 16:15:37 +0000

Case Basics

Docket No.

94-834

Petitioner

North Star Steel Co.

Petitioner Type

Petitioner

Respondent

Thomas

Respondent Type

Respondent

Consolidation

No. 94-835

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

515 U.S. 29 (1995)

Argued

Tuesday, April 25, 1995

Decided

Tuesday, May 30, 1995

Advocates

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

Steven B. Feirson (Argued the cause for the petitioners)

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

Facts of the Case

The Worker Adjustment and Retraining Notification Act (WARN) authorizes a civil enforcement action by aggrieved employees or their union against a covered employer who fails to give 60 days notice of a plant closing or mass layoff, but provides no limitations period for such an action. In 94-835, the United Steelworkers of America filed a WARN claim, charging Crown Cork & Seal Co., Inc. with laying off 85 employees without giving the required 60-day notice. In rejecting Crown Cork's contention that the statute of limitations had run, the District Court held that the source of the limitations period for WARN suits is state law and that the union's suit was timely under any of the arguably applicable Pennsylvania statutes. In 94-834, another District Court granted summary judgment for North Star Steel Company, holding the nonunion employees' suit barred under a limitations period borrowed from the National Labor Relations Act, which the court believed was more analogous to WARN than any state law. The Court of Appeals consolidated the cases and held that a WARN limitations period should be borrowed from state, not federal, law.

Question

Is state law the proper source of the limitations period for civil actions brought to enforce the Worker Adjustment and Retraining Notification Act?

Conclusion

Decision: 9 votes for Thomas, 0 vote(s) against
Legal provision: 29 U.S.C. 2101

Yes. In a 9-0 opinion delivered by Justice David H. Souter, the Court held that State law is the proper source of the limitations period for civil actions brought to enforce WARN. Where a federal statute fails to provide any limitations period for a new cause of action, the Court noted that its longstanding practice has been to borrow the limitations period from the most closely analogous state statute. The Court reasoned that North Star did not fall within the exception where the relevant state limitations periods would frustrate or interfere with the implementation of national policies or be at odds with the purpose or operation of federal substantive law. Justice Antonin Scalia concurred in the judgment.

Reno, Attorney General v. Koray

Mon, 05 Jan 2009 16:15:30 +0000

Case Basics

Docket No.

94-790

Petitioner

Reno, Attorney General, et al.

Petitioner Type

Petitioner

Respondent

Koray

Respondent Type

Respondent

Heard By

Rehnquist Court (1994-2005)

Decided By

Rehnquist Court (1994-2005)

Opinion

515 U.S. 50 (1995)

Argued

Monday, April 24, 1995

Decided

Monday, June 5, 1995

Advocates

Miguel A. Estrada (on behalf of the Petitioners)

Irwin Rochman (on behalf of the Respondent)

Facts of the Case

None

Question

None

Conclusion

Decision: 8 votes for Reno, Attorney General, 1 vote(s) against
Legal provision: 18 U.S.C. 3585

None

United States v. Alvarez-Sanchez

Mon, 05 Jan 2009 16:23:52 +0000

Case Basics

Docket No.

92-1812

Petitioner

United States

Petitioner Type

Petitioner

Respondent

Alvarez-Sanchez

Respondent Type

Respondent

Heard By

Rehnquist Court (1993-1994)

Decided By

Rehnquist Court (1993-1994)

Opinion

511 U.S. 350 (1994)

Argued

Tuesday, March 1, 1994

Decided

Monday, May 2, 1994

Advocates

Miguel A. Estrada (on behalf of the Petitioner)

Carlton F. Gunn (on behalf of the Respondent)

Facts of the Case

Three days after his arrest by local police on state narcotics charges, Pedro Alvarez-Sanchez confessed to the Secret Service that federal reserve notes found in his home were counterfeit. When he was subsequently charged with the federal offense of possession of counterfeit currency, Alvarez defended himself by claiming that the delay between his arrest on state charges and his presentment on the federal charge rendered his confession inadmissible. Alvarez cited 18 U.S.C. Section 3501(c), which pronounced separate charge- based confessions inadmissible if obtained after the first six hours of detention. On appeal from a reversal of a district court's decision to uphold the confession, the Supreme Court granted the United States certiorari.

Question

Does federal statute 18 U.S.C. Section 3501(c), declaring separate charge- based confessions inadmissible if obtained after the first six hours of detention, apply to suspects that are held only on state or federal charges?

Conclusion

Decision: 9 votes for United States, 0 vote(s) against
Legal provision: 18 U.S.C. 3501

No. In a unanimous decision, the Court held that the provisions of the federal statute in question do not apply to suspects being held solely on state charges. The Court explained that no delay is said to occur until the suspect is arrested and detained for a federal crime. The six-hour period only begins to expire from the point of a suspect's federal arrest and charging. In this case, Alvarez-Sanchez was presented before a federal judge within six hours of his arrest on a federal counterfeit charge. The fact that he was held for some two and a half days prior has no bearing on his federal status under the statute since he was detained on state and local charges only during this time.

Ortega-Rodriguez v. United States

Mon, 05 Jan 2009 16:01:19 +0000

Case Basics

Docket No.

91-7749

Petitioner

Ortega-Rodriguez

Petitioner Type

Petitioner

Respondent

United States

Respondent Type

Respondent

Heard By

Rehnquist Court (1991-1993)

Decided By

Rehnquist Court (1991-1993)

Opinion

507 U.S. 234 (1993)

Argued

Monday, December 7, 1992

Decided

Monday, March 8, 1993

Advocates

James Robert Gailey (on behalf of the Petitioner)

Amy L. Wax (on behalf of the Respondent)

Facts of the Case

None

Question

None

Conclusion

Decision: 5 votes for Ortega-Rodriguez, 4 vote(s) against
Legal provision:

None

United States v. Dunnigan

Mon, 05 Jan 2009 16:01:02 +0000

Case Basics

Docket No.

91-1300

Petitioner

United States

Petitioner Type

Petitioner

Respondent

Dunnigan

Respondent Type

Respondent

Heard By

Rehnquist Court (1991-1993)

Decided By

Rehnquist Court (1991-1993)

Opinion

507 U.S. 87 (1993)

Argued

Wednesday, December 2, 1992

Decided

Tuesday, February 23, 1993

Advocates

Brent E. Beveridge (on behalf of the Respondent)

Paul J. Larkin, Jr. (on behalf of the Petitioner)

Facts of the Case

None

Question

None

Conclusion

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

None

United States v. Salerno

Mon, 05 Jan 2009 16:24:10 +0000

Case Basics

Docket No.

91-872

Petitioner

United States

Petitioner Type

Petitioner

Respondent

Salerno et al.

Respondent Type

Respondent

Heard By

Rehnquist Court (1991-1993)

Decided By

Rehnquist Court (1991-1993)

Opinion

505 U.S. 317 (1992)

Argued

Monday, April 20, 1992

Decided

Friday, June 19, 1992

Advocates

Michael E. Tigar (on behalf of the Respondent)

James A. Feldman (on behalf of the Petitioner)

Facts of the Case

None

Question

None

Conclusion

Decision: 8 votes for United States, 1 vote(s) against
Legal provision: Federal Rules of Evidence

None

United States v. Alvarez-Machain

Mon, 05 Jan 2009 16:24:10 +0000

Case Basics

Docket No.

91-712

Petitioner

United States

Petitioner Type

Petitioner

Respondent

Alvarez-Machain

Respondent Type

Respondent

Heard By

Rehnquist Court (1991-1993)

Decided By

Rehnquist Court (1991-1993)

Opinion

504 U.S. 655 (1992)

Argued

Wednesday, April 1, 1992

Decided

Monday, June 15, 1992

Advocates

Kenneth W. Starr (on behalf of the Petitioner)

Paul L. Hoffman (on behalf of the Respondent)

Facts of the Case

None

Question

None

Conclusion

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

None

United States v. Williams

Mon, 05 Jan 2009 16:24:09 +0000

Case Basics

Docket No.

90-1972

Petitioner

United States

Petitioner Type

Petitioner

Respondent

Williams

Respondent Type

Respondent

Heard By

Rehnquist Court (1991-1993)

Decided By

Rehnquist Court (1991-1993)

Opinion

504 U.S. 36 (1992)

Argued

Wednesday, January 22, 1992

Decided

Monday, May 4, 1992

Advocates

Kenneth W. Starr (on behalf of the Petitioner)

James C. Lang (on behalf of the Respondent)

Facts of the Case

None

Question

None

Conclusion

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

None

United States v. Wilson

Mon, 05 Jan 2009 16:24:17 +0000

Case Basics

Docket No.

90-1745

Petitioner

United States

Petitioner Type

Petitioner

Respondent

Wilson

Respondent Type

Respondent

Heard By

Rehnquist Court (1991-1993)

Decided By

Rehnquist Court (1991-1993)

Opinion

503 U.S. 329 (1992)

Argued

Wednesday, January 15, 1992

Decided

Tuesday, March 24, 1992

Advocates

Henry A. Martin (on behalf of the Respondent)

Amy L. Wax (on behalf of the Petitioner)

Facts of the Case

None

Question

None

Conclusion

Decision: 7 votes for United States, 2 vote(s) against
Legal provision: 18 U.S.C. 3585

None

Jacobson v. United States

Mon, 20 Jun 2011 04:06:25 +0000

Location

Residence of Jacobson Omaha, NE

United States

41° 15' 14.4216" N, 95° 59' 57.3288" W

See map: Google Maps

Case Basics

Docket No.

90-1124

Petitioner

Keith Jacobson

Petitioner Type

Petitioner

Respondent

United States

Respondent Type

Respondent

Heard By

Rehnquist Court (1991-1993)

Decided By

Rehnquist Court (1991-1993)

Opinion

503 U.S. 540 (1992)

Argued

Wednesday, November 6, 1991

Decided

Monday, April 6, 1992

Advocates

George H. Moyer, Jr. (on behalf of the Petitioner)

Paul J. Larkin, Jr. (on behalf of the Respondent)

Facts of the Case

Before the Child Protection Act of 1984 rendered it illegal, Keith Jacobson, the petitioner, purchased a magazine including photographs of nude minors. In 1985, government agencies began investigating Jacobson's interest in child pornography. Over the course of about 2 ½ years, they sent him mailings from 5 fictitious organizations and one non-existent pen pal all promoting sexual liberation and challenging government censorship. After Jacobson was somewhat responsive, a government agency attempted to sting him by selling him child pornography which he purchased, resulting in his arrest and conviction. The United States Court of Appeals for the Eighth Circuit affirmed.

Question

Did the prosecution against Jacobson prove, beyond a reasonable doubt, that agencies of the United States Government did not incite his violation of the Child Protection Act?

Conclusion

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

No. In a majority decision authored by Justice Byron R. White, the Court determined that, the prosecution was unable to prove, beyond a reasonable doubt, that Jacobson was inclined to commit the criminal act of purchasing child pornography independent of government interference. Doubt stems from the fact that government agencies may have actually encouraged Jacobson to break the law in their effort to prosecute him. Since the Court found that the prosecution failed, the decision of the Court of Appeals and Jacobson's conviction were reversed.

White v. Illinois

Mon, 05 Jan 2009 16:24:02 +0000

Case Basics

Docket No.

90-6113

Petitioner

White

Petitioner Type

Petitioner

Respondent

Illinois

Respondent Type

Respondent

Heard By

Rehnquist Court (1991-1993)

Decided By

Rehnquist Court (1991-1993)

Opinion

502 U.S. 346 (1992)

Argued

Tuesday, November 5, 1991

Decided

Wednesday, January 15, 1992

Advocates

Stephen L. Nightingale (as amicus curiae, supporting the Respondent)

Gary R. Peterson (on behalf of the Petitioner)

Arleen C. Anderson (on behalf of the Respondent)

Facts of the Case

None

Question

None

Conclusion

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

None

Peretz v. United States

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

Case Basics

Docket No.

90-615

Petitioner

Peretz

Petitioner Type

Petitioner

Respondent

United States

Respondent Type

Respondent

Heard By

Rehnquist Court (1990-1991)

Decided By

Rehnquist Court (1991)

Opinion

501 U.S. 923 (1991)

Argued

Tuesday, April 23, 1991

Decided

Thursday, June 27, 1991

Advocates

William C. Bryson (on behalf of the Respondent)

Joel B. Rudin (on behalf of the Petitioner)

Facts of the Case

None

Question

None

Conclusion

Decision: 5 votes for United States, 4 vote(s) against
Legal provision: 28 U.S.C. 636

None

Michigan v. Lucas

Mon, 05 Jan 2009 16:16:07 +0000

Case Basics

Docket No.

90-149

Petitioner

Michigan

Petitioner Type

Petitioner

Respondent

Lucas

Respondent Type

Respondent

Heard By

Rehnquist Court (1990-1991)

Decided By

Rehnquist Court (1990-1991)

Opinion

500 U.S. 145 (1991)

Argued

Tuesday, March 26, 1991

Decided

Monday, May 20, 1991

Advocates

Mark H. Magidson (on behalf of the Respondent)

Kenneth W. Starr (on behalf of the United States, as amicus curiae, supporting the Petitioner)

Don W. Atkins (on behalf of the Petitioner)

Facts of the Case

None

Question

None

Conclusion

Decision: 7 votes for Michigan, 2 vote(s) against
Legal provision: Right to Confront and Cross-Examine, Compulsory Process

None

Demarest v. Manspeaker

Mon, 05 Jan 2009 16:16:07 +0000

Case Basics

Docket No.

89-5916

Petitioner

Demarest

Petitioner Type

Petitioner

Respondent

Manspeaker

Respondent Type

Respondent

Heard By

Rehnquist Court (1990-1991)

Decided By

Rehnquist Court (1990-1991)

Opinion

498 U.S. 184 (1991)

Argued

Tuesday, November 6, 1990

Decided

Tuesday, January 8, 1991

Advocates

James E. Scarboro (on behalf of the Petitioner)

Michael R. Lazerwitz (on behalf of the Respondent)

Facts of the Case

None

Question

None

Conclusion

Decision: 9 votes for Demarest, 0 vote(s) against
Legal provision: 28 U.S.C. 1821

None

United States v. France

Mon, 05 Jan 2009 16:16:23 +0000

Case Basics

Docket No.

89-1363

Petitioner

United States

Petitioner Type

Petitioner

Respondent

France

Respondent Type

Respondent

Heard By

Rehnquist Court (1990)

Decided By

Rehnquist Court (1990-1991)

Opinion

498 U.S. 335 (1991)

Argued

Tuesday, October 2, 1990

Decided

Tuesday, January 22, 1991

Advocates

William C. Bryson (on behalf of the Petitioner)

Michael R. Levine (on behalf of the Respondent (appointed by the Court))

Facts of the Case

None

Question

None

Conclusion

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

None

Idaho v. Wright

Mon, 05 Jan 2009 17:30:03 +0000

Case Basics

Docket No.

89-260

Petitioner

Idaho

Petitioner Type

Petitioner

Respondent

Wright

Respondent Type

Respondent

Heard By

Rehnquist Court (1988-1990)

Decided By

Rehnquist Court (1988-1990)

Opinion

497 U.S. 805 (1990)

Argued

Wednesday, April 18, 1990

Decided

Wednesday, June 27, 1990

Advocates

William C. Bryson (as amicus curiae, supporting the Petitioner)

Rolf Michael Kehne (on behalf of the Respondent)

James Thomas Jones (on behalf of the Petitioner)

Facts of the Case

None

Question

None

Conclusion

Decision: 5 votes for Wright, 4 vote(s) against
Legal provision: Right to Confront and Cross-Examine, Compulsory Process

None

Maryland v. Craig

Mon, 20 Jun 2011 04:06:22 +0000

Location

Circuit Court for Howard County

8360 Court Avenue Ellicott City MD 21043

Ellicott City, MD 21043

United States

39° 16' 5.9304" N, 76° 47' 56.5152" W

See map: Google Maps

Case Basics

Docket No.

89-478

Petitioner

Maryland

Petitioner Type

Petitioner

Respondent

Craig

Respondent Type

Respondent

Heard By

Rehnquist Court (1988-1990)

Decided By

Rehnquist Court (1988-1990)

Opinion

497 U.S. 836 (1990)

Argued

Wednesday, April 18, 1990

Decided

Wednesday, June 27, 1990

Advocates

J. Joseph Curran, Jr. (Argued the cause for the petitioner)

William H. Murphy, Jr. (Argued the cause for the respondent)

Facts of the Case

Sandra Ann Craig, the operator of a kindergarten and pre-school facility, was accused of sexually abusing a six-year-old child. Over Craig's objections, a trial court allowed the alleged child victim to testify via one-way closed circuit television. The child testified outside the courtroom while Mrs. Craig, through electronic communication with her lawyer, could make objections. The judge and jury also viewed the testimony in the courtroom. This was done in order to avoid the possibility of serious emotional distress for the child witness. The trial court convicted Craig, but the Maryland high court reversed.

Question

Did the closed-circuit testimony violate the Confrontation Clause of the Sixth Amendment?

Conclusion

Decision: 5 votes for Maryland, 4 vote(s) against
Legal provision: Right to Confront and Cross-Examine, Compulsory Process

No. In a 5-to-4 decision, the Court held that the Confrontation Clause of the Sixth Amendment, which guarantees criminal defendants face-to-face meetings with witnesses against them at trial, was not absolute. The Court found that "in certain narrow circumstances, 'competing interests, if closely examined, may warrant dispensing with confrontation at trial." The State's interest in protecting the physical and psychological well-being of children, the Court held, could be sufficiently important to outweigh defendants' rights to face their accusers in court.

Gomez v. United States

Mon, 05 Jan 2009 17:26:36 +0000

Case Basics

Docket No.

88-5014

Petitioner

Gomez

Petitioner Type

Petitioner

Respondent

United States

Respondent Type

Respondent

Consolidation

No. 88-5158

Heard By

Rehnquist Court (1988-1990)

Decided By

Rehnquist Court (1988-1990)

Opinion

490 U.S. 858 (1989)

Argued

Monday, April 24, 1989

Decided

Monday, June 12, 1989

Advocates

Michael K. Kellogg (on behalf of the Respondent)

Joel B. Rudin (on behalf of the Petitioners)

Facts of the Case

None

Question

None

Conclusion

Decision: 9 votes for Gomez, 0 vote(s) against
Legal provision: 28 U.S.C. 636

None

Houston v. Lack

Mon, 05 Jan 2009 17:25:42 +0000

Case Basics

Docket No.

87-5428

Petitioner

Houston

Petitioner Type

Petitioner

Respondent

Lack

Respondent Type

Respondent

Heard By

Rehnquist Court (1988-1990)

Decided By

Rehnquist Court (1988-1990)

Opinion

487 U.S. 266 (1988)

Argued

Wednesday, April 27, 1988

Decided

Friday, June 24, 1988

Advocates

Jerry L. Smith (On behalf of the Respondent)

Penny J. White (On behalf of the Petitioner)

Facts of the Case

None

Question

None

Conclusion

Decision: 5 votes for Houston, 4 vote(s) against
Legal provision: Federal Rules of Civil Procedure, including Appellate Procedure (or relevant rules of a circuit court)

None

Bank Of Nova Scotia v. United States

Mon, 05 Jan 2009 17:26:01 +0000

Case Basics

Docket No.

87-578

Petitioner

Bank Of Nova Scotia

Petitioner Type

Petitioner

Respondent

United States

Respondent Type

Respondent

Consolidation

No. 87-602

Heard By

Rehnquist Court (1988-1990)

Decided By

Rehnquist Court (1988-1990)

Opinion

487 U.S. 250 (1988)

Argued

Wednesday, April 27, 1988

Decided

Wednesday, June 22, 1988

Advocates

William C. Bryson (On behalf of the Respondent)

James E. Nesland (On behalf of the Petitioners)

Facts of the Case

None

Question

None

Conclusion

Decision: 8 votes for United States, 1 vote(s) against
Legal provision: Federal Rules of Criminal Procedure (or relevant rules of a circuit court)

None

Coy v. Iowa

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

Location

Iowa District Court for Clinton County

612 N 2nd St Clinton IA 52732

Clinton, IA 52732

United States

41° 51' 0.6408" N, 90° 11' 15.18" W

See map: Google Maps

Case Basics

Docket No.

86-6757

Appellee

Iowa

Petitioner Type

Appellee

Appellant

John Coy

Respondent Type

Appellant

Heard By

Rehnquist Court (1987-1988)

Decided By

Rehnquist Court (1988-1990)

Opinion

487 U.S. 1012 (1988)

Argued

Wednesday, January 13, 1988

Decided

Wednesday, June 29, 1988

Advocates

Paul Papak (by appointment of the Court, argued the cause for the appellant)

Gorden E. Allen (Deputy Attorney General of Iowa, argued the cause for appellee)

Facts of the Case

John Coy was tried in an Iowa court for sexually assaulting two 13-year-old girls. When the girls were testifying against Coy, the court placed a large screen in front of him so that the girls would not have to see him. The jury proceeded to convict him. Coy argued that Iowa Code 910A, which provides for the use of a screen in child sexual abuse cases, violated his Sixth Amendment right to confront his accusers face-to-face. He also claimed that the code violated his right to due process, since having a screen placed between him and the girls made him appear guilty before he was properly tried. The trial court dismissed these claims and the Iowa Supreme Court affirmed.

Question

Does a defendant have the right to confront his alleged victims "face-to-face" under the Sixth Amendment if they testify against him before a jury?

Conclusion

Decision: 6 votes for Coy, 2 vote(s) against
Legal provision: Right to Confront and Cross-Examine, Compulsory Process

Yes. Justice Antonin Scalia delivered the opinion of a 6-2 court. The Sixth Amendment explicitly states that the accused has the right "to be confronted with the witnesses against him." The Court maintained this "confrontation is essential to fairness." The screen clearly disrupted this confrontation in a way that could have biased the trial. While acknowledging that "face-to-face presence may, unfortunately, upset the truthful rape victim or abused child," the Court insisted that "by the same token it may confound and undo the false accuser, or reveal the child coached by a malevolent adult." A trial court cannot abridge the right to confrontation using a generalized law, and in Coy's case no specific reason was given for using a screen.

Mathews v. United States

Mon, 05 Jan 2009 17:25:28 +0000

Case Basics

Docket No.

86-6109

Petitioner

Mathews

Petitioner Type

Petitioner

Respondent

United States

Respondent Type

Respondent

Heard By

Rehnquist Court (1987-1988)

Decided By

Rehnquist Court (1988-1990)

Opinion

485 U.S. 58 (1988)

Argued

Wednesday, December 2, 1987

Decided

Wednesday, February 24, 1988

Advocates

Charles A. Rothfeld (on behalf of the Respondent)

Franklyn M. Gimbel (on behalf of the Petitioner)

Facts of the Case

None

Question

None

Conclusion

Decision: 6 votes for Mathews, 2 vote(s) against
Legal provision: Federal Rules of Criminal Procedure (or relevant rules of a circuit court)

None

United States v. Owens

Mon, 05 Jan 2009 17:25:38 +0000

Case Basics

Docket No.

86-877

Petitioner

United States

Petitioner Type

Petitioner

Respondent

Owens

Respondent Type

Respondent

Heard By

Rehnquist Court (1987-1988)

Decided By

Rehnquist Court (1988-1990)

Opinion

484 U.S. 554 (1988)

Argued

Wednesday, November 4, 1987

Decided

Tuesday, February 23, 1988

Advocates

William C. Bryson (on behalf of the petitioner)

Allan Ides (on behalf of the respondent)

Facts of the Case

None

Question

None

Conclusion

Decision: 6 votes for United States, 2 vote(s) against
Legal provision: Right to Confront and Cross-Examine, Compulsory Process

None

Taylor v. Illinois

Mon, 05 Jan 2009 17:25:45 +0000

Case Basics

Docket No.

86-5963

Petitioner

Taylor

Petitioner Type

Petitioner

Respondent

Illinois

Respondent Type

Respondent

Heard By

Rehnquist Court (1987-1988)

Decided By

Rehnquist Court (1987-1988)

Opinion

484 U.S. 400 (1988)

Argued

Wednesday, October 7, 1987

Decided

Monday, January 25, 1988

Advocates

Richard E. Cunningham (on behalf the Petitioner)

Michael Shabat (on behalf of the Respondent)

Facts of the Case

None

Question

None

Conclusion

Decision: 5 votes for Illinois, 3 vote(s) against
Legal provision: Right to Confront and Cross-Examine, Compulsory Process

None

Ray v. United States

Mon, 05 Jan 2009 17:33:47 +0000

Case Basics

Docket No.

86-281

Petitioner

Ray

Petitioner Type

Petitioner

Respondent

United States

Respondent Type

Respondent

Heard By

Rehnquist Court (1986-1987)

Decided By

Rehnquist Court (1986-1987)

Opinion

481 U.S. 736 (1987)

Argued

Tuesday, April 28, 1987

Decided

Monday, May 18, 1987

Advocates

Joseph A. Connors, III (on behalf of the petitioner)

William C. Bryson (on behalf of the respondent)

Facts of the Case

None

Question

None

Conclusion

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

None

California v. Superior Court Of California

Mon, 05 Jan 2009 17:34:04 +0000

Case Basics

Docket No.

86-381

Petitioner

California

Petitioner Type

Petitioner

Respondent

Superior Court Of California

Respondent Type

Respondent

Heard By

Rehnquist Court (1986-1987)

Decided By

Rehnquist Court (1986-1987)

Opinion

482 U.S. 400 (1987)

Argued

Wednesday, April 22, 1987

Decided

Tuesday, June 9, 1987

Advocates

Dennis P. Riordan (on behalf of Respondent)

J. Robert Jibson (on behalf of Petitioner)

Facts of the Case

None

Question

None

Conclusion

Decision: 7 votes for California, 2 vote(s) against
Legal provision: 18 U.S.C. 3182

None

Kentucky v. Stincer

Mon, 05 Jan 2009 17:33:32 +0000

Case Basics

Docket No.

86-572

Petitioner

Kentucky

Petitioner Type

Petitioner

Respondent

Stincer

Respondent Type

Respondent

Heard By

Rehnquist Court (1986-1987)

Decided By

Rehnquist Court (1986-1987)

Opinion

482 U.S. 730 (1987)

Argued

Wednesday, April 22, 1987

Decided

Friday, June 19, 1987

Advocates

Mark A. Posnansky (on behalf of Respondent)

Penny R. Warren (on behalf of Petitioner)

Facts of the Case

None

Question

None

Conclusion

Decision: 6 votes for Kentucky, 3 vote(s) against
Legal provision: Right to Confront and Cross-Examine, Compulsory Process

None

Agency Holding Corp. v. Malley-Duff & Assocs.

Mon, 05 Jan 2009 17:33:29 +0000

Case Basics

Docket No.

86-497

Petitioner

Agency Holding Corp.

Petitioner Type

Petitioner

Respondent

Malley-Duff & Assocs.

Respondent Type

Respondent

Consolidation

Crown Life Insurance Co. v. Malley-Duff & Associates, Inc., No. 86-531

Heard By

Rehnquist Court (1986-1987)

Decided By

Rehnquist Court (1986-1987)

Opinion

483 U.S. 143 (1987)

Argued

Tuesday, April 21, 1987

Decided

Monday, June 22, 1987

Advocates

John H. Bingler, Jr. (on behalf of Petitioner)

Henry Woodruff Turner (on behalf of Respondent)

Robert L. Frantz (on behalf of Petitioner)

Facts of the Case

None

Question

None

Conclusion

Decision: 9 votes for Malley-Duff & Assocs., 0 vote(s) against
Legal provision: Racketeer Influenced and Corrupt Organizations

None

Puerto Rico v. Branstad

Mon, 05 Jan 2009 17:33:37 +0000

Case Basics

Docket No.

85-2116

Petitioner

Puerto Rico

Petitioner Type

Petitioner

Respondent

Branstad

Respondent Type

Respondent

Heard By

Rehnquist Court (1986-1987)

Decided By

Rehnquist Court (1986-1987)

Opinion

483 U.S. 219 (1987)

Argued

Monday, March 30, 1987

Decided

Tuesday, June 23, 1987

Advocates

Lino J. Saldana (Argued the cause for the petitioner)

Brent R. Appel (Argued the cause for the respondents)

Facts of the Case

Ronald Calder was a native of Iowa working in Puerto Rico, He was charged with first degree murder and attempted murder. After posting bail, he fled to his home state. Puerto Rico submitted a petition to Branstad, Iowa's governor at the time, to extradite Calder for court proceedings. Branstad refused.

Question

Do federal courts have the power to order governors to fulfill obligations under the Constitution's Extradition Clause in Article IV, Section 2?

Conclusion

Decision: 9 votes for Puerto Rico, 0 vote(s) against
Legal provision: Article 4, Section 2, Paragraph 2: Extradition Clause

Yes. The Court overturned its decision in Kentucky v. Dennison (1861) which had rendered federal courts powerless to enforce the Extradition Clause. The unanimous Court concluded that the precedent in Kentucky was "the product of another age" and "fundamentally incompatible with more than a century of constitutional development."

Rock v. Arkansas

Mon, 05 Jan 2009 17:33:48 +0000

Case Basics

Docket No.

86-130

Petitioner

Rock

Petitioner Type

Petitioner

Respondent

Arkansas

Respondent Type

Respondent

Heard By

Rehnquist Court (1986-1987)

Decided By

Rehnquist Court (1986-1987)

Opinion

483 U.S. 44 (1987)

Argued

Monday, March 23, 1987

Decided

Monday, June 22, 1987

Advocates

J. Steven Clark (on behalf of Respondent)

James M. Luffman (on behalf of Petitioner)

Facts of the Case

None

Question

None

Conclusion

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

None

Richardson v. Marsh

Mon, 05 Jan 2009 17:33:56 +0000

Case Basics

Docket No.

85-1433

Petitioner

Richardson

Petitioner Type

Petitioner

Respondent

Marsh

Respondent Type

Respondent

Heard By

Rehnquist Court (1986-1987)

Decided By

Rehnquist Court (1986-1987)

Opinion

481 U.S. 200 (1987)

Argued

Wednesday, January 14, 1987

Decided

Tuesday, April 21, 1987

Advocates

Timothy A. Baughman (on behalf of Petitioner)

Lawrence S. Robbins (on behalf of the United States as amicus curiae, in support of Petitioner)

R. Steven Whalen (on behalf of Respondent)

Facts of the Case

None

Question

None

Conclusion

Decision: 6 votes for Richardson, 3 vote(s) against
Legal provision: Right to Confront and Cross-Examine, Compulsory Process

None

Cruz v. New York

Mon, 05 Jan 2009 17:33:34 +0000

Case Basics

Docket No.

85-5939

Petitioner

Cruz

Petitioner Type

Petitioner

Respondent

New York

Respondent Type

Respondent

Heard By

Rehnquist Court (1986-1987)

Decided By

Rehnquist Court (1986-1987)

Opinion

481 U.S. 186 (1987)

Argued

Monday, December 1, 1986

Decided

Tuesday, April 21, 1987

Advocates

Peter D. Coddington (on behalf of the respondent)

Robert H. Klonoff (as amicus curiae, supporting respondent)

Robert S. Dean (on behalf of the petitioner)

Facts of the Case

None

Question

None

Conclusion

Decision: 5 votes for Cruz, 4 vote(s) against
Legal provision: Right to Confront and Cross-Examine, Compulsory Process

None

New Mexico v. Earnest

Mon, 05 Jan 2009 17:26:57 +0000

Case Basics

Docket No.

85-162

Petitioner

New Mexico

Petitioner Type

Petitioner

Respondent

Earnest

Respondent Type

Respondent

Heard By

Burger Court (1981-1986)

Decided By

Burger Court (1981-1986)

Opinion

477 U.S. 648 (1986)

Argued

Tuesday, April 1, 1986

Decided

Friday, June 27, 1986

Advocates

Paul G. Bardacke (on behalf of Petitioner)

J. Thomas Sullivan (on behalf of Respondent)

Facts of the Case

None

Question

None

Conclusion

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

None

Delaware v. Van Arsdall

Mon, 05 Jan 2009 17:27:05 +0000

Case Basics

Docket No.

84-1279

Petitioner

Delaware

Petitioner Type

Petitioner

Respondent

Van Arsdall

Respondent Type

Respondent

Heard By

Burger Court (1981-1986)

Decided By

Burger Court (1981-1986)

Opinion

475 U.S. 673 (1986)

Argued

Wednesday, January 22, 1986

Decided

Monday, April 7, 1986

Advocates

Richard E. Fairbanks, Jr. (on behalf of the petitioner)

Paul J. Larkin, Jr. (on behalf of the United States as amicus curiae in support of the petitioner)

John R. Williams (on behalf of the respondents)

Facts of the Case

None

Question

None

Conclusion

Decision: 7 votes for Delaware, 2 vote(s) against
Legal provision: harmless error

None

Lee v. Illinois

Mon, 05 Jan 2009 17:27:13 +0000

Case Basics

Docket No.

84-6807

Petitioner

Lee

Petitioner Type

Petitioner

Respondent

Illinois

Respondent Type

Respondent

Heard By

Burger Court (1981-1986)

Decided By

Burger Court (1981-1986)

Opinion

476 U.S. 530 (1986)

Argued

Monday, December 9, 1985

Decided

Tuesday, June 3, 1986

Advocates

Dan W. Evers (on behalf of the petitioner)

Jill Wine-Banks (on behalf of the respondent)

Facts of the Case

None

Question

None

Conclusion

Decision: 5 votes for Lee, 4 vote(s) against
Legal provision: Right to Confront and Cross-Examine, Compulsory Process

None

United States v. Inadi

Mon, 05 Jan 2009 17:26:47 +0000

Case Basics

Docket No.

84-1580

Petitioner

United States

Petitioner Type

Petitioner

Respondent

Inadi

Respondent Type

Respondent

Heard By

Burger Court (1981-1986)

Decided By

Burger Court (1981-1986)

Opinion

475 U.S. 387 (1986)

Argued

Tuesday, December 3, 1985

Decided

Monday, March 10, 1986

Advocates

Holly Macuican (on behalf of the respondent)

Andrew L. Frey (on behalf of the petitioner)

Facts of the Case

None

Question

None

Conclusion

Decision: 7 votes for United States, 2 vote(s) against
Legal provision: Right to Confront and Cross-Examine, Compulsory Process

None

Thomas v. Arn

Mon, 05 Jan 2009 17:26:47 +0000

Case Basics

Docket No.

84-5630

Petitioner

Thomas

Petitioner Type

Petitioner

Respondent

Arn

Respondent Type

Respondent

Heard By

Burger Court (1981-1986)

Decided By

Burger Court (1981-1986)

Opinion

474 U.S. 140 (1985)

Argued

Monday, October 7, 1985

Decided

Wednesday, December 4, 1985

Advocates

Christopher Danahy Stanley (on behalf of the petitioner)

Richard David Drake (on behalf of the respondent)

Facts of the Case

None

Question

None

Conclusion

Decision: 6 votes for Arn, 3 vote(s) against
Legal provision: 28 U.S.C. 636

None

Carchman v. Nash

Mon, 05 Jan 2009 17:20:28 +0000

Case Basics

Docket No.

84-776

Petitioner

Carchman

Petitioner Type

Petitioner

Respondent

Nash

Respondent Type

Respondent

Consolidation

No. 84-835

Heard By

Burger Court (1981-1986)

Decided By

Burger Court (1981-1986)

Opinion

473 U.S. 716 (1985)

Argued

Monday, April 22, 1985

Decided

Tuesday, July 2, 1985

Advocates

Philip S. Carchman (on behalf of the petitioners)

John Burke, III (on behalf of the respondent)

Facts of the Case

None

Question

None

Conclusion

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

None