[Shalala v. Illinois Council on Long Term Care, Inc. (2000) — Rehnquist Court (1994-2005) — Facts]
The Illinois Council on Long Term Care, Inc. (Council), an association of nursing homes participating in Medicare, sued the Secretary of Health and Human Services, Donna Shalala, challenging the validity of various Medicare regulations establishing sanctions and remedies for nursing homes found guilty of violating minimum health and safety standards. The Council alleged that certain terms in the new regulations were unconstitutionally vague, that the regulations created administrative procedures inconsistent with the U.S. Constitution's Due Process Clause, and that the regulations' legislative rules that were not promulgated consistent with the Administrative Procedure Act. The Council invoked the Federal District Court's federal-question jurisdiction, which states that "district courts shall have original jurisdiction of all civil actions arising under the Constitution, laws, or treaties of the United States," to rule on its claims. The District Court dismissed the suit on the ground that it lacked jurisdiction. The court concluded that set of special statutory provisions under the Medicare Act create a separate, virtually exclusive, system of administrative and judicial review for such claims. The Court of Appeals reversed and remanded the case for further proceedings.


[Shalala v. Illinois Council on Long Term Care, Inc. (2000) — Rehnquist Court (1994-2005) — Conclusion]
Yes. In a 5-4 opinion delivered by Justice Stephen G. Breyer, the Court held that the Medicare Act barred federal-question jurisdiction of the Council's challenges to the validity of various Medicare regulations. The Court concluded that the Council must proceed instead through the special review channel that the Medicare statutes create. Justice Clarence Thomas wrote in his dissent that, "[d]elayed review...may mean no review at all. For when the costs of presenting a claim via the delayed review route exceed the costs of simply complying with the regulation, the regulated entity will buckle under and comply, even when the regulation is plainly invalid."


[Public Lands Council v. Babbitt (2000) — Rehnquist Court (1994-2005) — Facts]
The Taylor Grazing Act grants the Secretary of the Interior authority to divide the public rangelands into grazing districts, to specify the amount of grazing permitted in each district, and to issue grazing leases or permits to "settlers, residents, and other stock owners." When Interior Secretary Bruce Babbitt announced new regulations governing the administration of livestock on 170 million acres of public range, the Public Lands Council (Council), a group of nonprofit ranching-related organizations, objected. The Council's members who held grazing permits brought an action against Secretary Babbitt challenging 10 of the new federal grazing regulations issued by the Secretary in 1995. The Council claimed that the Secretary acted beyond his power in regulating the grazing patterns. The District Court found 4 of the 10 regulations unlawful. Reversing in part, the Court of Appeals upheld three previously overturned regulations, which changed the definition of "grazing preference," permitted those who were not "engaged in the livestock business" to qualify for grazing permits; and granted the United States title to all future range improvements.


[Public Lands Council v. Babbitt (2000) — Rehnquist Court (1994-2005) — Conclusion]
No. In a unanimous opinion delivered by Justice Stephen G. Breyer, the Court held that "[t]he regulatory changes do not exceed the Secretary's Taylor Grazing Act authority." "Congress itself has directed development of land-use plans, and their use in the allocation process in order to preserve, improve and develop the public rangelands," wrote Justice Stephen G. Breyer. "And the secretary [of the Interior] has always had the statutory authority...to reclassify and withdraw range land from grazing use."


[Apprendi v. New Jersey (2000) — Rehnquist Court (1994-2005) — Facts]
Charles C. Apprendi, Jr. fired several shots into the home of an African- American family. While in custody, Apprendi made a statement, which he later retracted, that he did not want the family in his neighborhood because of their race. Apprendi was charged under New Jersey law with second-degree possession of a firearm for an unlawful purpose, which carries a prison term of 5 to 10 years. The count did not refer to the state's hate crime statute, which provides for an enhanced sentence if a trial judge finds, by a preponderance of the evidence, that the defendant committed the crime with a purpose to intimidate a person or group because of race. After Apprendi pleaded guilty, the prosecutor filed a motion to enhance the sentence. The court found, by a preponderance of the evidence, that the shooting was racially motivated and sentenced Apprendi to a 12-year term on the firearms count. In upholding the sentence, the appeals court rejected Apprendi's claim that the Due Process Clause requires that a bias finding be proved to a jury beyond a reasonable doubt. The State Supreme Court affirmed.


[Apprendi v. New Jersey (2000) — Rehnquist Court (1994-2005) — Conclusion]
Yes. In an 5-4 opinion delivered by Justice John Paul Stevens, the Court held that the Due Process Clause requires that any fact that increases the penalty for a crime beyond the prescribed statutory maximum, other than the fact of a prior conviction, must be submitted to a jury and proved beyond a reasonable doubt. Justice Stevens wrote for the Court that "the New Jersey procedure challenged in this case is an unacceptable departure from the jury tradition that is an indispensable part of our criminal justice system." Justices Sandra Day O'Connor and Stephen G. Breyer wrote dissenting opinions that were joined by Chief Justice William H. Rehnquist and Justice Anthony M. Kennedy.


[Stenberg v. Carhart (2000) — Rehnquist Court (1994-2005) — Facts]
A Nebraska law prohibited any "partial birth abortion" unless that procedure was necessary to save the mother's life. It defined "partial birth abortion" as a procedure in which the doctor "partially delivers vaginally a living unborn child before killing the... child," and defined the latter phrase to mean "intentionally delivering into the vagina a living unborn child, or a substantial portion thereof, for the purpose of performing a procedure that the [abortionist] knows will kill the... child and does kill the... child." Violation of the law is a felony, and it provides for the automatic revocation of a convicted doctor's state license to practice medicine. Leroy Carhart, a Nebraska physician who performs abortions in a clinical setting, brought suit seeking a declaration that the statute violates the U.S. Constitution, claiming the law was unconstitutionally vague and placed an undue burden on himself and female patients seeking abortions. The District Court held the statute unconstitutional. The Court of Appeals affirmed.


[Stenberg v. Carhart (2000) — Rehnquist Court (1994-2005) — Conclusion]
Yes. In a complicated 5-4 decision delivered by Justice Stephen G. Breyer, the Court held that "Nebraska's statute criminalizing the performance of "partial birth abortion[s]" violates the U.S. Constitution, as interpreted in Casey and Roe." The sharply divided Court struck down the statute because it placed an undue burden on a woman's right to have an abortion and did not allow for exception in cases of threatened health. "All those who perform abortion procedures using that method must fear prosecution, conviction, and imprisonment," that results in "an undue burden upon a woman's right to make an abortion decision," wrote Justice Breyer for the Court. Justice Antonin Scalia's dissent concluded that "[t]he notion that the Constitution of the United States... prohibits the States from simply banning this visibly brutal means of eliminating our half-born posterity is quite simply absurd."
Learn more about the Supreme Court and abortion law in Body Politic, a nonpartisan Oyez resource.


[Wal-Mart Stores Inc. v. Samara Bros. Inc. (2000) — Rehnquist Court (1994-2005) — Facts]
Samara Brothers, Inc. designs and manufactures a line of children's clothing. Wal-Mart Stores, Inc., contracted with a supplier, Judy-Philippine, Inc. (JPI), to manufacture outfits based on photographs of Samara garments and to be offered under Wal-Mart's house label, "Small Steps." When JPI manufactured the clothes, it copied sixteen of Samara's garments with some small modifications to produce the line of clothes required under its contract with Wal-Mart. After discovering that Wal-Mart and other retailers were selling the so-called knockoffs, Samara brought an action for infringement of unregistered trade dress under section 43(a) of the Trademark Act of 1946. The jury found for Samara and awarded the company more than $1 million in damages. Wal-Mart then renewed a motion for judgment as a matter of law, claiming that there was insufficient evidence to support a conclusion that Samara's clothing designs could be legally protected as distinctive trade dress for purposes of section 43(a). The District Court denied the motion and awarded Samara relief. The Court of Appeals affirmed the denial of the motion and concluded that "copyrights depicting familiar objects, such as the hearts, daisies, and strawberries in Samara's copyrights are entitled to very narrow protection. It is only the virtually identical copying...which will result in a successful claim of infringement of familiar objects."


[Wal-Mart Stores Inc. v. Samara Bros. Inc. (2000) — Rehnquist Court (1994-2005) — Conclusion]
No. In a unanimous opinion delivered by Justice Antonin Scalia, the Court held that "[i]n a section 43(a) action for infringement of unregistered trade dress, a product's design is distinctive, and therefore protectible, only upon a showing of secondary meaning. The fact that product design almost invariably serves purposes other than source identification not only renders inherent distinctiveness problematic; it also renders application of an inherent-distinctiveness principle more harmful to other consumer interests," Justice Scalia wrote for the Court. "Consumers should not be deprived of the benefits of competition with regard to the utilitarian and esthetic purposes that product design ordinarily serves by a rule of law that facilitates plausible threats of suit against new entrants based upon alleged inherent distinctiveness," Justice Scalia concluded.


[Rotella v. Wood (2000) — Rehnquist Court (1994-2005) — Facts]
Mark Rotella was admitted to a Brookhaven Psychiatric Pavilion in 1985 and discharged in 1986 after Brookhaven allegedly coerced him to stay longer than he intended. In 1994, the facility's parent company pleaded guilty to charges of fraud, conspiracy and violations of RICO, for giving physicians monetary incentives to needlessly admit, treat and retain patients at their hospitals. Rotella learned of the plea that same year, and in 1997 he filed a civil damages action under the Racketeer Influenced and Corrupt Organizations Act (RICO), claiming that the Brookhaven doctors and related business entities, had conspired to keep him hospitalized to maximize their profits. RICO makes it criminal "to conduct" an "enterprise's affairs through a pattern of racketeering activity." A "pattern" requires at least two acts of racketeering activity, the last of which occurred within 10 years after the commission of a prior act. Brookhaven countered that the statute of limitations under RICO had run on the charge. The District Court granted Brookhaven summary judgment on the ground that the 4-year limitation period for civil RICO claims had expired in 1990, four years after Rotella admitted discovering his injury. In affirming, the Court of Appeals rejected Rotella's argument that the limitations period does not begin to run until a plaintiff discovers (or should have discovered) both the injury and the pattern of racketeering activity.


[Rotella v. Wood (2000) — Rehnquist Court (1994-2005) — Conclusion]
Yes. In a unanimous opinion delivered by Justice David H. Souter, the Court held that Rotella's action was not timely, because the start of the 4-year limitations period applicable to a civil RICO action was not governed by an "injury and pattern discovery" accrual rule under which such a civil claim would accrue only when the claimant discovered, or should have discovered, both an injury and a pattern of racketeering activity. In a footnote, Justice Souter noted that "[w]e do not...settle upon a final rule."


[Beck v. Prupis (2000) — Rehnquist Court (1994-2005) — Facts]
Robert A. Beck, II, of Southeastern Insurance Group (SIG), alleged that after he discovered former senior officer and director Ronald M. Prupis' unlawful conduct and contacted regulators, Prupis enacted a scheme to remove him from SIG. Beck sued Prupis under the Racketeer Influenced and Corrupt Organizations Act (RICO). Beck alleged that his injury, the loss of his employment, served to further Prupis' conspiracy and therefore provided a cause of action under RICO. The District Court dismissed Beck's RICO conspiracy claim. The court agreed with Prupis that employees who are terminated for refusing to participate in RICO activities, or who threaten to report RICO activities, do not have standing to sue under RICO for damages from their loss of employment. In affirming, the Court of Appeals held that because the act causing Beck's injury was not an act of racketeering, it could not support a RICO cause of action.


[Beck v. Prupis (2000) — Rehnquist Court (1994-2005) — Conclusion]
No. In a 7-2 opinion delivered by Justice Clarence Thomas, the Court held that an injury caused by an overt act that is not an act of racketeering or otherwise wrongful under the Racketeer Influenced and Corrupt Organizations Act does not give rise to a cause of action under RICO. Thus, because Prupis' scheme to remove Beck from SIG was not an act of racketeering itself, Beck had no ground to sue him under RICO. Although Prupis did engage in acts of racketeering, Justice Thomas wrote for the Court that, "the alleged overt act (terminating) in the present case was not independently wrongful under any substantive provision of RICO."


[Florida v. J. L. (2000) — Rehnquist Court (1994-2005) — Facts]
On October 13, 1995 Miami-Dade police received an anonymous tip that a black male wearing a plaid shirt was standing near a bus stop carrying a gun. The two officers who responded found three black males, one of which, J.L., a 15 -year-old, was wearing a plaid shirt. After frisking him, the officers did find a firearm. J.L. was charged with carrying a concealed weapon without a license. At trial, he moved to suppress the gun as evidence, arguing that the frisking performed by the officers was illegal under the Fourth Amendment. The trial court granted the motion, but was reversed by the immediate appellate court. The Florida Supreme Court overruled the appellate court and suppressed the evidence.


[Florida v. J. L. (2000) — Rehnquist Court (1994-2005) — Conclusion]
Yes. In a unanimous opinion authored by Justice Ruth Bader Ginsburg, the Court concluded that J.L. the anonymous tip did not meet the minimum requirements to perform a warrantless search. Justice Ginsburg, drawing from the Court's logic in Terry v. Ohio and Adams v. Williams, indicated that an anonymous tip must posses a moderate level of reliability, including "predictive information" that offers police a "means to test the informant's knowledge or credibility." An accurate description of a person without a reliable assertion of illegality or description of the crime in question, as was the anonymous tip in this case, does not meet this standard. "All the police had to go on in this case was the bare report of an unknown, unaccountable informant who neither explained how he knew about the gun nor supplied any basis for believe he had inside information."


[Reno v. Condon (2000) — Rehnquist Court (1994-2005) — Facts]
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.


[Reno v. Condon (2000) — Rehnquist Court (1994-2005) — Conclusion]
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.


[Weisgram v. Marley Company (2000) — Rehnquist Court (1994-2005) — Facts]
Bonnie Weisgram died of carbon monoxide poisoning during a fire in her home. Chad Weisgram, her son, brought a diversity suit in federal District Court, seeking wrongful death damages, alleging that a defective heater, manufactured by Marley Company and used by Bonnie Weisgram, cause both the fire and her death. At trial, Weisgram introduced the testimony of three supposed experts to prove the alleged heater defect and its causal connection to the fire. Marley's objection that the testimony was unreliable, and therefore inadmissible under Federal Rule of Evidence 702, was overruled by the District Court. After Weisgram's evidence was introduced, Marley again unsuccessfully moved under Federal Rule of Civil Procedure 50(a) for judgment as a matter of law on the ground that Weisgram had failed to meet his burden of proof on the issues of defect and causation. Ultimately, the jury returned a verdict for Weisgram. Afterwards, Marley, once again, requested judgment as a matter of law. Additionally, Marley requested a new trial. The court denied the motions and entered judgment for Weisgram. In reversing, the Court of Appeals held that Marley's motion for judgment as a matter of law should have been granted because the testimony of Weisgram's expert witnesses, the sole evidence supporting the product defect charge, was speculative and not shown to be scientifically sound. The appeals court did not order a new trial.


[Weisgram v. Marley Company (2000) — Rehnquist Court (1994-2005) — Conclusion]
Yes. In a unanimous opinion delivered by Justice Ruth Bader Ginsburg, the Court held that Federal Rule of Civil Procedure 50 permits an appellate court to direct the entry of judgment as a matter of law when it determines that evidence was erroneously admitted at trial and that the remaining, properly admitted, evidence is insufficient to constitute a submissible case. Justice Ginsburg wrote for the Court that "if...the court of appeals concludes that further proceedings are unwarranted because the loser on appeal has had a full and fair opportunity to present the case, including arguments for a new trial, the appellate court may appropriately instruct the district court to enter judgment against the jury-verdict winner. "


[Nixon v. Shrink Missouri Government PAC (2000) — Rehnquist Court (1994-2005) — Facts]
In 1976, Buckley v. Valeo established a $1,000 cap on individuals' contributions to candidates for federal office. Missouri law imposes campaign contribution limits, ranging from $250 to $1,000, to candidates for state office. The statute allows for periodic adjustments, which increased the 1998 contribution limit to $1,075 for candidates for statewide office, including state auditor. In 1998, Zev David Fredman, a candidate for the Republican nomination for Missouri state auditor, and the Shrink Missouri Government PAC, a political action committee, filed suit, alleging that the Missouri statute imposing limits on contributions to candidates for state office violated their First and Fourteenth Amendment rights. The PAC had contributed $1,075 to Fredman and argued, without the limitation, it would contribute more to Fredman's campaign. Additionally, Fredman alleged he could campaign effectively only with more generous contributions. The Federal District Court, applying Buckley v. Valeo, upheld the statute. The court rejected Fredman's and the PAC's contention that inflation since Buckley's approval of a federal $1,000 restriction meant that the state limit of $1,075 for a statewide office could not be constitutional today. In reversing, the Court of Appeals, found that Missouri's interest in avoiding the corruption or the perception of corruption caused by candidates' acceptance of large campaign contributions was insufficient to satisfy Buckley's strict scrutiny standard of review.


[Nixon v. Shrink Missouri Government PAC (2000) — Rehnquist Court (1994-2005) — Conclusion]
Yes, no, and no. In a 6-3 opinion delivered by Justice David H. Souter, the Court held that Buckley is the authority for comparable state regulation and, but that the federal limits approved in Buckley, with or without adjustment for inflation, do not define the scope of permissible state limitations. The Court held the Missouri statute not to violate the First Amendment. "Even without the authority of Buckley, there would be no serious question about the legitimacy of the interests claimed, wrote Justice Souter for the Court, "the cynical assumption that large donors call the tune could jeopardize the willingness of voters to take part in democratic governance." Justices Anthony Kennedy, Antonin Scalia and Clarence Thomas dissented, voting to overturn Buckley as a violation of First Amendment speech rights.


[Mitchell v. Helms (2000) — Rehnquist Court (1994-2005) — Facts]
Chapter 2 of the Education Consolidation and Improvement Act of 1981 provides for the allocation of funds for educational materials and equipment, including library materials and computer software and hardware, to public and private elementary and secondary schools to implement "secular, neutral, and nonideological" programs. In Jefferson Parish, Louisiana, about 30% of Chapter 2 funds are allocated for private schools, most of which are Catholic or otherwise religiously affiliated. Mary Helms and other public school parents file suit alleging that Chapter 2, as applied in Jefferson Parish, violated the First Amendment's Establishment Clause. The District Court initially agreed, finding that Chapter 2 had the primary effect of advancing religion because the materials and equipment loaned to the Catholic schools were direct aid and that the schools were pervasively sectarian. However, after the presiding judge who made the initial ruling retired, the case was reviewed by a new judge, who reversed that decision. Thereafter, based on different precedent, the court upheld Chapter 2. In reversing, the Court of Appeals held Chapter 2 unconstitutional.


[Mitchell v. Helms (2000) — Rehnquist Court (1994-2005) — Conclusion]
No. In a 6-3 plurality decision delivered by Justice Clarence Thomas, the Court held that that Chapter 2, as applied in Jefferson Parish, is not a law respecting an establishment of religion simply because many of the private schools receiving Chapter 2 aid in the parish are religiously affiliated. Turning to neutrality to distinguish between indoctrination attributable to the State and that which is not, Justice Thomas wrote for the Court, "[i]f the religious, irreligious, and areligious are all alike eligible for governmental aid, no one would conclude that any indoctrination that any particular recipient conducts has been done at the behest of the government."


[Kimel v. Florida Board of Regents (2000) — Rehnquist Court (1994-2005) — Facts]
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.


[Kimel v. Florida Board of Regents (2000) — Rehnquist Court (1994-2005) — Conclusion]
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.


[Miller v. French (2000) — Rehnquist Court (1994-2005) — Facts]
In 1975, inmates at the Pendleton Correctional Facility filed a class action lawsuit, which ultimately led the District Court to issue an injunction to remedy Eighth Amendment violations regarding conditions of confinement. In 1996, Congress enacted the Prison Litigation Reform Act of 1995 (PLRA), which sets a standard for the entry and termination of prospective relief in civil actions challenging prison conditions. The PLRA provides that a motion to terminate such relief "shall operate as a stay" of that relief beginning 30 days after the motion is filed and ending when the court rules on the motion. In 1997, the State of Indiana filed a motion to terminate the remedial order against the correctional facility. Under the PLRA, the motion stayed the court's original remedial order. The prisoners of Pendleton moved to enjoin the operation of the automatic stay, arguing that the automatic stay provision of the PLRA violated due process and the separation of powers doctrine. The District Court enjoined the stay. In affirming, the Court of Appeals found that the provision precluded courts from exercising their equitable powers to enjoin the stay, but concluded that the statute was unconstitutional on separation of powers grounds.


[Miller v. French (2000) — Rehnquist Court (1994-2005) — Conclusion]
Yes and no. In a 5-4 opinion delivered by Justice Sandra Day O'Connor, the Court held that Congress clearly intended to make operation of the PLRA's automatic stay provision mandatory, precluding courts from exercising their equitable power to enjoin the stay and that the PLRA does not violate separation of powers principles. Thus, Congress lawfully imposed deadlines for federal judges to review states officials' motions to discontinue court monitoring and supervision of state prison conditions. Justice O'Connor, in addressing whether the PLRA violated the separation of powers, remarked in a footnote that, "[t]he PLRA does not deprive courts of their adjudicatory role, but merely provides a new legal standard for relief and encourages courts to apply that standard promptly." Justices David H. Souter, Ruth Bader Ginsburg, Stephen G. Breyer and John Paul Stevens dissented.


[United States v. Hubbell (2000) — Rehnquist Court (1994-2005) — Facts]
In 1994, Webster Hubbell, in a plea agreement, promised to provide the Independent Counsel with information about matters relating to the Whitewater investigation. Subsequently, the Independent Counsel served Hubbell with a subpoena calling for such information, and Hubbell invoked his Fifth Amendment privilege against self-incrimination and refused to state whether he had the documents the Independent Counsel demanded. After being granted immunity, pursuant to 18 USC section 6003 (a), Hubbell produced the desired documents. The Independent Counsel then used those documents to indict Hubbell on tax and fraud charges. The District Court dismissed the indictment because the evidence that would be used against Hubbell was derived either directly or indirectly from his immunized act of producing those documents. Vacating that decision, the Court of Appeals directed the District Court to determine the scope of the Government's knowledge of Hubbell's financial affairs on the day the subpoena was issued. The court determined that if the Government could not demonstrate with reasonable particularity that there existed a prior awareness of the contents of the documents and that those documents were in Hubbell's possession, then the indictment was tainted. After acknowledging he could not meet this standard, the Independent Counsel entered into a conditional plea agreement providing for the dismissal of the indictment, unless the Supreme Court's disposition of the case made it reasonably likely that Hubbell's immunity would not pose a significant bar to his prosecution.


[United States v. Hubbell (2000) — Rehnquist Court (1994-2005) — Conclusion]
Yes and no. In an 8-1 opinion delivered by Justice John Paul Stevens, the Court, in order to determine the precise scope of a grant of immunity with respect to the production of documents in response to a subpoena, held that a person responding to subpoena, pursuant to a court order granting immunity, could not be prosecuted on the basis of information in the documents produced if the government did not have any prior, independent knowledge of the documents. Thus, the indictment against Hubbell was dismissed because it was not derived from sources independent of documents produced under his grant of immunity. Justice Stevens wrote for the Court, "we have no doubt that the constitutional privilege against self-incrimination protects the target of a grand jury investigation from being compelled to answer questions designed to elicit information about the existence of sources of potentially incriminating evidence." Chief Justice William H. Rehnquist was the lone dissenter.


[New York v. Hill (2000) — Rehnquist Court (1994-2005) — Facts]
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.


[New York v. Hill (2000) — Rehnquist Court (1994-2005) — Conclusion]
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.


[Troxel v. Granville (2000) — Rehnquist Court (1994-2005) — Facts]
During Tommie Granville and Brad Troxel's relationship, which ended in 1991, they had two daughters. Until Brad's suicide in 1993, Brad's parents Jenifer and Gary Troxel, the paternal grandparents, had regularly seen their granddaughters on weekends. However, after Brad's suicide, Granville informed the Troxels that she wished to reduced their visitation time to one short visit per month. The Troxels filed suit for the right to visit their grandchildren, under section 26.10.160(3) of the Revised Code of Washington, which permits "any person" to petition for visitation rights "at any time" and authorizes state superior courts to grant such rights whenever visitation may serve a child's best interest. Granville did not oppose the petition outright but did oppose the amount of visitation time sought by the Troxels. Subsequently, a Washington Superior Court ordered more visitation than Granville desired. On appeal, the Washington Court of Appeals reversed that decision, holding that non-parents lacked standing to sue under the statute. In affirming, the Washington Supreme Court ruled that the statute unconstitutionally interfered with parents' right to rear their children.


[Troxel v. Granville (2000) — Rehnquist Court (1994-2005) — Conclusion]
Yes. In a 6-3 decision delivered by Justice Sandra Day O'Connor, the Court held that the Washington Statute violated the right of parents, under the due process clause of the Constitution's Fourteenth Amendment, to make decisions concerning the care, custody, and control of their children. Justice O'Connor wrote for the Court that "[t]he liberty interest at issue in this case -- the interest of parents in the care, custody, and control of their children -- is perhaps the oldest of the fundamental liberty interests recognized by this Court." Justices John Paul Stevens, Antonin Scalia, and Anthony Kennedy dissented.


[Bond v. United States (2000) — Rehnquist Court (1994-2005) — Facts]
While checking the immigration status of passengers on a bus in Texas, Border Patrol Agent Cesar Cantu squeezed the soft luggage which passengers had placed in the overhead storage space. When Agent Cantu squeezed a canvas bag above Steven Dewayne Bond, Agent Cantu noticed that it contained a "brick-like" object. After Bond admitted owning the bag and consented to its search, Agent Cantu discovered a "brick" of methamphetamine. Bond was indicted on federal drug charges. Bond moved to suppress the drugs, arguing that the agent conducted an illegal search of his bag, when squeezing it, in alleged violation of the Federal Constitution's Fourth Amendment prohibition against unreasonable searches and seizures. The District Court denied the motion and subsequently found Bond guilty. On appeal, Bond conceded that other passengers had access to his bag, but contended that Agent Cantu manipulated the bag (by squeezing)in a way that other passengers would not, thus constituting an unreasonable search. In affirming the denial of the motion, the Court of Appeals held that Agent Cantu's manipulation of the bag was not a search under the Fourth Amendment.


[Bond v. United States (2000) — Rehnquist Court (1994-2005) — Conclusion]
Yes. In a 7-2 opinion delivered by Chief Justice William H. Rehnquist, the Court held that "Agent Cantu's physical manipulation of petitioner's carry-on bag violated the Fourth Amendment's proscription against unreasonable searches." The Court concluded that Bond "possessed a privacy interest in his bag," and that such an expectation of privacy is reasonable. "Physically invasive inspection is simply more intrusive than purely visual inspection," Chief Justice Rehnquist wrote for the Court, a bus passenger "does not expect that other passengers or bus employees will, as a matter of course, feel the bag in an exploratory manner." Justice Stephen G. Breyer, joined by Justice Antonin Scalia, dissented, seeing no "reasonable expectation" that strangers would not manipulate luggage in a bus.


[Geier v. American Honda Motor Company, Inc. (2000) — Rehnquist Court (1994-2005) — Facts]
The Department of Transportation, under the National Traffic and Motor Vehicle Safety Act of 1966 (Act), promulgated Federal Motor Vehicle Safety Standard (FMVSS) 208, which required auto manufacturers to equip some of their 1987 vehicles with passive restraints. To comply with FMVSS 208, Honda installed manual seat belts and a warning light, instead of a driver-side airbag, for the 1987 Honda Accord. Alexis Geier suffered severe head and facial injuries in an accident while driving a 1987 Honda Accord that did not have a driver-side airbag. Geier and her parents sought damages under District of Columbia tort law, claiming that American Honda Motor Company was negligent in not equiping the Accord with a driver's side airbag. The District Court ruled in favor of Honda, finding that Geier's claims were expressly pre-empted by the Act because a jury verdict in Geier's favor "might establish a safety standard that was not identical to Standard 208." In affirming, the Court of Appeals concluded that, because Geier's state tort claims posed an obstacle to the accomplishment of the objectives of FMVSS 208, those claims conflicted with that standard and that the Act consequently pre-empted the lawsuit.


[Geier v. American Honda Motor Company, Inc. (2000) — Rehnquist Court (1994-2005) — Conclusion]
Yes. In a 5-4 opinion delivered by Justice Stephen G. Breyer, the Court held that "[Geier's] 'no airbag' lawsuit conflicts with the objectives of FMVSS 208 and is therefore pre-empted by the Act." Justice Breyer wrote for the Court that a rule of state tort law imposing a duty to install airbags in cars such as Honda's would have presented an obstacle to the variety and mix of devices that the federal regulation sought and to the phase-in that the federal regulation deliberately imposed. It would also have made adoption of state mandatory seatbelt laws less likely." The dissent found fault in the majority's "unprecedented use of inferences from regulatory history and commentary as a basis for implied pre-emption."


[United States v. Morrison (2000) — Rehnquist Court (1994-2005) — Facts]
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.


[United States v. Morrison (2000) — Rehnquist Court (1994-2005) — Conclusion]
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."


[Portuondo v. Agard (2000) — Rehnquist Court (1994-2005) — Facts]
Ray Agard was tried in New York on sodomy, assault, and weapons counts. Ultimately, Agard's trial turned on whether the jury believed the testimony of the victim and her friend or the conflicting testimony of Agard. The prosecutor challenged Agard's credibility. During summation, the prosecutor remarked, "[h]e gets to sit here and listen to the testimony of all the other witnesses before he testifies," and "[t]hat gives [him] a big advantage, doesn't it?" The prosecutor alleged that Agard had tailored his testimony to fit evidence that he heard from witnesses through the course of the trial. The trial court rejected Agard's objection that these comments violated his right to be present at trial. After exhausting his state appeals, Agard petitioned for federal habeas corpus, claiming that the prosecutor's comments violated his Fifth and Sixth Amendment rights to be present at trial and confront his accusers, and his Fourteenth Amendment right to due process. The District Court denied his petition. The Court of Appeals reversed.


[Portuondo v. Agard (2000) — Rehnquist Court (1994-2005) — Conclusion]
No. In a 7-2 opinion delivered by Justice Antonin Scalia, the Court held that the prosecutor's comments did not violate Agard's Fifth and Sixth Amendment rights and that the prosecutor's comments also did not violate Agard's right to due process. "Allowing comment upon the fact that a defendant's presence in the courtroom provides him a unique opportunity to tailor his testimony is appropriate and...sometimes essential to the central function of the trial, which is to discover the truth," Justice Scalia wrote for the Court. Dissenting, Justice Ruth Bader Ginsburg, joined by Justice David H. Souter, observed that the majority's holding "transforms a defendant's presence at trial from a Sixth Amendment right into an automatic burden on his credibility."


[Johnson v. United States (2000) — Rehnquist Court (1994-2005) — Facts]
The Sentencing Reform Act of 1984 replaced most forms of parole with supervised release. If release conditions are violated, the sentencing court may revoke the release and order the violator to serve part or all of the release term in prison without credit for time previously served on release. In 1994, Cornell Johnson was convicted of conspiring to produce and use counterfeit credit cards. Johnson was sentenced to imprisonment followed by a term of supervised release. While on supervised release, Johnson violated its terms. Subsequently, the District Court revoked Johnson's release and ordered him to serve an 18-month prison term to be followed by an additional 12 months of supervised release. The court cited no authority for ordering the new supervised release. The court could have cited a subsection added to the Act in 1994, 18 USC section 3583(h), which explicitly gave it the authority to add the new term; however, Congress made the amendment after Johnson's conviction. On appeal, Johnson argued that the application of the federal law established after his conviction violated the Ex Post Facto Clause of the Constitution. The Court of Appeals affirmed the District Court's decision.


[Johnson v. United States (2000) — Rehnquist Court (1994-2005) — Conclusion]
Yes. In an 8-1 opinion delivered by Justice David H. Souter, the Court held that 18 USC section 3583(h) is not retroactively applicable; however, its prior version, 18 USC section 3583(e)(3), authorizes a Federal District Court to impose additional term of supervised release after revocation of initial term and reimprisonment. Thus, Johnson's judgment was affirmed because the federal sentencing statute, which was in effect at the time of his original offense, permitted the imposition of supervised release following recommitment. Justice Souter wrote for the Court that "[p]re-Guidelines practice, linguistic continuity from the old scheme to the current one, and the obvious thrust of congressional sentencing policy confirm that, in applying the law as before the enactment of subsection (h), district courts have the authority to order terms of supervised release following reimprisonment." Justice Antonin Scalia dissented.


[Harris Trust & Savings Bank v. Salomon Smith Barney, Inc. (2000) — Rehnquist Court (1994-2005) — Facts]
Section 406(a) of the Employee Retirement Income Security Act of 1974 (ERISA) bars a fiduciary of an employee benefit plan from causing the plan to engage in certain prohibited transactions with a "party in interest." Such a party encompasses entities that a fiduciary might be inclined to favor at the expense of the plan's beneficiaries. After the Ameritech Pension Trust (APT), an ERISA pension plan, allegedly entered into a transaction prohibited by ERISA with Salomon Smith Barney Inc., APT's fiduciaries sued Salomon under section 502(a)(3), which authorizes a fiduciary to bring a civil action to obtain appropriate equitable relief." Salomon arguing that section 502(a)(3) only authorizes a suit against the fiduciary who caused the plan to enter the prohibited transaction. Ultimately, the District Court held that ERISA provides a private cause of action against nonfiduciaries who participate in a prohibited transaction. In reversing, the Court of Appeals held that the authority to sue under section 502(a)(3) does not extend to a suit against a nonfiduciary "party in interest" to a transaction barred by section 406(a).


[Harris Trust & Savings Bank v. Salomon Smith Barney, Inc. (2000) — Rehnquist Court (1994-2005) — Conclusion]
Yes. In a unanimous opinion delivered by Justice Clarence Thomas, the Court held that Section 502(a)(3)'s authorization to a plan "participant, beneficiary, or fiduciary" to bring a civil action for "appropriate equitable relief" extends to a suit against a nonfiduciary "party in interest" to a prohibited transaction barred by section 406(a). "We reject," wrote Justice Thomas that, "absent a substantive provision of ERISA expressly imposing a duty upon a nonfiduciary party in interest, the nonfiduciary party may not be held liable under [section 502(a)(3)]." Justice Thomas concluded that "[section 502(a)(3)] itself imposes certain duties, and therefore that liability under that provision does not depend on whether ERISA's substantive provisions impose a specific duty on the party being sued."


[Hartford Underwriters Ins. Company v. Union Planters Bank, N.A. (2000) — Rehnquist Court (1994-2005) — Facts]
Hen House Interstate, Inc. filed for reorganization under Chapter 11 of the Bankruptcy Code. During the reorganization attempt, Hen House obtained workers' compensation insurance from Hartford Underwriters Insurance Company. Hen House repeatedly failed to make the monthly premium payments required by the policy. Ultimately, Hen House's reorganization failed and the court converted the case to a Chapter 7 liquidation proceeding and appointed a trustee. Hartford, learning of the bankruptcy proceedings, sought to recover its premiums as an administrative expense. Recognizing that the estate lacked unencumbered funds to pay the premiums, Hartford attempted to charge the premiums to Union Planters Bank, the secured creditor for all of the property of Hen House, by filing a claim with the Bankruptcy Court under 11 USC Section 506(c). The Bankruptcy Court ruled in favor of Hartford and the ruling was affirmed by the Court of Appeals. However, the Court of Appeals granted a rehearing en banc and reversed, on the ground that an administrative claimant could not invoke section 506(c).


[Hartford Underwriters Ins. Company v. Union Planters Bank, N.A. (2000) — Rehnquist Court (1994-2005) — Conclusion]
No. In a unanimous opinion delivered by Justice Antonin Scalia, the Court held that "Section 506(c) does not provide an administrative claimant of a bankruptcy estate an independent right to seek payment of its claim from property encumbered by a secured creditor's lien, or subject to secured claims. Justice Scalia noted that plain meaning of the language in Section 506(c) and the "most natural reading" of the section persuaded the court that no one other than the trustee has an independent right to seek payment of administrative claim, like premiums from property secured by a creditor's lien, under the section.


[Gutierrez v. Ada (2000) — Rehnquist Court (1994-2005) — Facts]
The Organic Act of Guam provides that that "if no [slate of] candidates [for Governor and Lieutenant Governor of Guam] receives a majority of the votes cast in any election...a runoff election shall be held." The Election Commission certified that the Democratic slate of Carl T.C. Gutierrez for governor and Madeleine Z. Bordallo for lieutenant governor had defeated the Republican slate, Joseph F. Ada and Felix P. Camacho. Gutierrez and Bordallo had received a majority of the votes cast for gubernatorial slates in the 1998 Guam general election, but did not receive a majority of the total number of ballots that voters cast due to voters selecting write-in candidates, people voting for both slates, and blank ballots. The opposing Republican slate sought a writ of mandamus ordering a runoff election. According to Ada and Camacho, the phrase "in any election" means the majority as measured by the votes cast in the entire election, not simply in the race for governor. Gutierrez responded that "votes cast" meant actual votes cast for governor and lieutenant governor, rather than ballots in which the governor's contest is left blank. The District Court issued the writ and the Court of Appeals ultimately affirmed, interpreting the statutory phrase "majority of the votes cast in any election" to require that a slate receive a majority of the total number of ballots cast in the general election.


[Gutierrez v. Ada (2000) — Rehnquist Court (1994-2005) — Conclusion]
No. In a unanimous opinion delivered by Justice David H. Souter, the Court held that "[t]he Guam Organic Act does not require a runoff election when a candidate slate has received a majority of the votes cast for Governor and Lieutenant Governor of the Territory, but not a majority of the number of ballots cast in the simultaneous general election." Justice Souter wrote for the Court that an "obvious reading" of the law requires only a majority of votes cast in that one specific race, "Congress did not shift its attention when it used 'any election' unadorned by a gubernatorial reference or other definite modifier."


[Weeks v. Angelone (2000) — Rehnquist Court (1994-2005) — Facts]
Lonnie Weeks, Jr., was found guilty of capital murder in the death of Virginia State Trooper Jose Cavazos. During the penalty phase of his trial, the prosecution sought to prove two aggravating circumstances. Weeks' defense presented 10 witnesses in mitigation. During deliberations, the jurors sent the trial judge a note asking whether, if they believed Weeks guilty of at least one of the aggravating circumstances, it was their duty to issue the death penalty, or whether they must decide whether to issue the death penalty or a life sentence. In responding, the trial judge only referred the jury to their instructions, which stated: "If you find from the evidence that the Commonwealth has proved, beyond a reasonable doubt, either of the two [aggravating circumstances], and as to that alternative, you are unanimous, then you may fix the punishment...at death, or if you believe from all the evidence that the death penalty is not justified, then you shall fix the punishment...at life imprisonment." The defense counsel objected, arguing for the judge to instruct the jury it could find one or both of the aggravating circumstances and still impose a life sentence. In finding one of the aggravating circumstances and after considering the evidence in mitigation, the jury returned a unanimous verdict fixing Weeks' punishment at death. On appeal to the Virginia Supreme Court, Weeks' presented 47 assignments of error, of which his assignment of error respecting the judge's answering the jury's question about mitigating circumstances was number 44. The court affirmed Weeks' conviction and sentence. Weeks' petition for federal habeas relief was ultimately denied.


[Weeks v. Angelone (2000) — Rehnquist Court (1994-2005) — Conclusion]
No. In a 5-4 opinion delivered by Chief Justice William H. Rehnquist, the Court held that the Constitution was not violated by the Virginia trial judge who, during a capital trial's penalty phase, directed the jury's attention to the allegedly ambiguous paragraph of the jury's instruction in response to the jury's question as to mitigating evidence. "Given that petitioner's jury was adequately instructed, and given that the trial judge responded to the jury's question by directing its attention to the precise paragraph of the constitutionally adequate instruction that answers its inquiry, the question becomes whether the Constitution requires anything more," wrote Chief Justice Rehnquist, "[w]e hold that it does not." Writing for the dissenting minority, Justice John Paul Stevens argued that "[t]he record in this case establishes, not just a 'reasonable likelihood' of jury confusion, but a virtual certainty that the jury did not realize that there were two distinct legal bases for concluding that a death sentence was not 'justified.'"


[Edwards v. Carpenter (2000) — Rehnquist Court (1994-2005) — Facts]
Robert Carpenter was indicted on charges of aggravated murder and aggravated robbery, pleaded guilty, and sentenced to life imprisonment, with parole possible after 30 years. On direct appeal, Carpenter unsuccessfully challenged only the length of the minimum sentence. After unsuccessfully pursuing state post-conviction relief and represented by new counsel, Carpenter petitioned the Ohio Court of Appeals to reopen his direct appeal on the ground that his original appellate counsel had been constitutionally ineffective in failing to challenge the sufficiency of the evidence supporting his conviction and sentence. The court dismissed the application as untimely, and the Ohio Supreme Court affirmed. Carpenter then filed a federal habeas corpus petition, raising the sufficiency-of-the-evidence claim, and alleging that his appellate counsel was constitutionally ineffective in not raising that claim on direct appeal. The District Court determined that, while the sufficiency claim had been procedurally defaulted, the ineffective-assistance-of-counsel claim could excuse that default; concluded that Carpenter's appellate counsel was constitutionally ineffective; and granted the writ. The Court of Appeals concluded that the ineffective-assistance-of-counsel claim could serve as cause to excuse the procedural default of the sufficiency claim, regardless of whether the ineffective-assistance-of-counsel claim had been procedurally defaulted; and found prejudice from counsel's failure to raise the sufficiency-of-the-evidence claim on direct appeal.


[Edwards v. Carpenter (2000) — Rehnquist Court (1994-2005) — Conclusion]
No. In a opinion delivered by Justice Antonin Scalia, the Court held that a state prisoner's procedurally defaulted claim of ineffective assistance of counsel can excuse the procedural default of another habeas claim only if the inmate can demonstrate that the poor lawyering rises to a constitutional level, not only that it prejudiced them at trial. The 7-2 decision means that ineffective-assistance claims filed too late in a state appellate court generally cannot be used in federal court to excuse an inmate's default on other claims. Justice Scalia wrote for the court that it is not enough to say such a claim "was presented to the state courts even though it was not presented in the manner that state law requires."


[United States v. Johnson (2000) — Rehnquist Court (1994-2005) — Facts]
Roy Lee Johnson had been serving time in federal prison for multiple drug and firearms felonies when two of his convictions were declared invalid. The District Court ordered his immediate release. Johnson's 3-year term of supervised release that was yet to be served on the remaining convictions then went into effect. As a result of serving time for the two invalid convictions, Johnson had served 2.5 years' too much prison time. After his release, Johnson filed a motion to credit the excess two and one-half years he was erroneously incarcerated toward his three-year supervised release sentence. The District Court denied relief, explaining that the supervised release commenced upon Johnson's actual release from incarceration, not before. In reversing, the Court of Appeals accepted Johnson's argument that his supervised release term commenced not on the day he left prison, but when his lawful term of imprisonment expired.


[United States v. Johnson (2000) — Rehnquist Court (1994-2005) — Conclusion]
No. In a unanimous opinion delivered by Justice Anthony M. Kennedy, the Court held that the length of a supervised release term cannot be reduced by reason of excess time served in prison. Justice Kennedy wrote for the Court that, "[t]he objectives of supervised release would be unfulfilled if excess prison time were to offset and reduce terms of supervised release." The Court found that Congress intended supervised release to assist individuals in their transition to community life and that supervised release fulfills rehabilitative ends, distinct from those served by incarceration.


[Sims v. Apfel (2000) — Rehnquist Court (1994-2005) — Facts]
After a state agency denied Juatassa Sims' application for Social Security disability and Supplemental Security Income benefits, she obtained a hearing before a Social Security Administrative Law Judge (ALJ). The ALJ also denied Sims' claims, concluding that, although she did have some medical impairments, she had not been and was not under a "disability." Sims then sought review by the Social Security Appeals Council, which denied review. She next filed suit in the Federal District Court, contending that the ALJ erred in three ways by making selective use of the record, by posing defective questions to a vocational expert, and by failing to order a consultative examination. The District Court rejected her contentions. In affirming, the Court of Appeals concluding that it lacked jurisdiction over two of the contentions because they were not included in Sims' request for review by the Appeals Council.


[Sims v. Apfel (2000) — Rehnquist Court (1994-2005) — Conclusion]
No. In a plurality opinion delivered by Justice Clarence Thomas, the Court held, 5 to 4, that Social Security claimants who exhaust administrative remedies need not also exhaust issues administratively in order to preserve judicial review of those issues. Justice Thomas wrote that the issue-exhaustion requirement, usually required even in the absence of a statute or regulation, does not apply in a non-adversarial proceeding, as in Social Security cases. Justice O'Connor filed a separate opinion concurring in part and concurring in the judgment Justice Stephen G. Breyer filed a dissenting opinion joined by Chief Justice William H. Rehnquist and Justices Antonin Scalia and Anthony M. Kennedy.


[United States v. Locke (2000) — Rehnquist Court (1994-2005) — Facts]
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.


[United States v. Locke (2000) — Rehnquist Court (1994-2005) — Conclusion]
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.


[Christensen v. Harris County (2000) — Rehnquist Court (1994-2005) — Facts]
The Fair Labor Standards Act of 1938 (FLSA) permits governmental entities to compensate their employees for overtime work by granting them compensatory time in lieu of cash payment. If the employees do not use their accumulated compensatory time, the employer must pay cash compensation under certain circumstances. Harris County, Texas, found that too many of its deputy sheriffs had too many hours of accrued compensatory time. Fearing a budget crisis, the county adopted a policy under which its employees could be ordered to schedule compensatory time at specified times in order to reduce the amount of accrued time that would otherwise require cash payment. Edward Christensen and 128 other deputy sheriffs in Harris County believed they had the right to use their compensatory time when they saw fit. The sheriffs sued, claiming that the FLSA does not permit an employer to compel an employee to use compensatory time in the absence of an agreement permitting the employer to do so. The District Court ruled in favor of the sheriffs, concluding that the policy violated the FLSA. In reversing, the Court of Appeals held that the FLSA did not address the issue in question and thus did not prohibit the county from implementing a compensatory time policy.


[Christensen v. Harris County (2000) — Rehnquist Court (1994-2005) — Conclusion]
No. In an opinion delivered by Justice Clarence Thomas, the Court held 6-3 that "[n]othing in the FLSA or its implementing regulations prohibits a public employer from compelling the use of compensatory time." Justice Thomas wrote for the Court that, "under the FLSA, an employer is free to require an employee to take time off work, and an employer is also free to use the money it would have paid in wages to cash out accrued compensatory time. The compelled use of compensatory time challenged in this case merely involves doing both of these steps at once."


[Crosby v. National Foreign Trade Council (2000) — Rehnquist Court (1994-2005) — Facts]
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.


[Crosby v. National Foreign Trade Council (2000) — Rehnquist Court (1994-2005) — Conclusion]
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."


[United States  v. Martinez-Salazar (2000) — Rehnquist Court (1994-2005) — Facts]
Abel Martinez-Salazar was charged with a variety of federal narcotics and weapons offenses. The District Court allotted him 10 peremptory challenges exercisable in the selection of 12 jurors. After prospective juror Don Gilbert indicated several times that he would favor the prosecution, Martinez- Salazar's counsel challenged him for cause. The court declined to excuse Gilbert. After twice objecting, unsuccessfully, to the for-cause ruling, Martinez-Salazar used a peremptory challenge to remove him. Subsequently, Martinez-Salazar exhausted all of his peremptory challenges. Thereafter, Martinez-Salazar's counsel did not object to the final seating of the jurors. Martinez-Salazar was then convicted on all counts. On appeal, Martinez-Salazar argued that the District Court abused its discretion in refusing to strike Gilbert for cause and that this error used one of his peremptory challenges wrongly. The Court of Appeals agreed that the District Court's refusal to strike Gilbert for cause was an abuse of discretion. Ultimately, the court found that the District Court's error resulted in a violation of Martinez- Salazar's Fifth Amendment due process rights because it forced him to use a peremptory challenge curatively, which impaired his right to a full complement of peremptory challenges. The Court of Appeals held that the error required an automatic reversal.


[United States  v. Martinez-Salazar (2000) — Rehnquist Court (1994-2005) — Conclusion]
No. In a unanimous decision delivered by Justice Ruth Bader Ginsburg, the Court held that a defendant's exercise of peremptory challenges is not denied or impaired when the defendant chooses to use such a challenge to remove a juror who should have been excused for cause. Justice Ginsburg wrote for the Court that "if the defendant elects to cure such an error by exercising a peremptory challenge, and is subsequently convicted by a jury on which no biased juror sat, he has not been deprived of any rule-based or constitutional right." The Court also concluded that the loss of a peremptory challenge did not constitute a violation of the Sixth Amendment right to an impartial jury.


[Williams v. Taylor (2000) — Rehnquist Court (1994-2005) — Facts]
Michael Wayne Williams was sentenced to death after he was convicted of two capital murders. Ultimately, Williams sought federal habeas relief, in which he requested an evidentiary hearing on three constitutional claims, regarding the fairness of his trial, which he had tried unsuccessfully to develop in the state-court proceedings. The District Court granted Williams' evidentiary hearing. However, before any hearing could be held, the Court of Appeals granted the Commonwealth's requests for an emergency stay and for a writ of mandamus and prohibition. The Commonwealth argued that Williams' evidentiary hearing was prohibited by federal law as amended by the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA). On remand, the District Court dismissed Williams' petition citing the AEDPA statute and finding that Williams failed to show "actual innocence." In affirming, the Court of Appeals found that Williams could not satisfy the statute's conditions for excusing his failure to develop the facts of his claims and barred him from receiving an evidentiary hearing.


[Williams v. Taylor (2000) — Rehnquist Court (1994-2005) — Conclusion]
No. In a unanimous opinion delivered by Justice Anthony M. Kennedy, the Court held that under federal law, as amended by the AEDPA, "a 'failure to develop' a claim's factual basis in state court proceedings is not established unless there is lack of diligence, or some greater fault, attributable to the prisoner or his counsel." Justice Kennedy wrote for the Court that "comity is not served by saying a prisoner 'has failed to develop the factual basis of a claim' where he was unable to develop his claim in state court despite diligent effort. In that circumstance, an evidentiary hearing is not barred."


[Hunt-Wesson, Inc. v. Franchise Tax Board of California (2000) — Rehnquist Court (1994-2005) — Facts]
California's "unitary business" income-calculation system for determining the State's taxable share of a multistate corporation's business income authorizes a deduction for interest expense. The system, however, permits use of that deduction only to the extent that the amount exceeds certain out-of-state income arising from the unrelated business activity of a discrete business enterprise. Hunt-Wesson, Inc. is a successor in interest to a nondomiciliary corporation that incurred interest expense. California disallowed a deduction for the expense insofar as it had received nonunitary dividend and interest income. Hunt-Wesson challenged the validity of the disallowance. The California Court of Appeal found the disallowance constitutional. The California Supreme Court denied review.


[Hunt-Wesson, Inc. v. Franchise Tax Board of California (2000) — Rehnquist Court (1994-2005) — Conclusion]
Yes. In a unanimous opinion delivered by Justice Stephen G. Breyer, the Court held that the provision violates the Due Process and Commerce Clauses. "California's statute does not directly impose a tax on nonunitary income. Rather, it simply denies the taxpayer use of a portion of a deduction from unitary income..., income which does bear a 'rational relationship' or 'nexus' to California," wrote Justice Breyer. "Because California's offset provision is not a reasonable allocation of expense deductions to the income that the expense generates, it constitutes impermissible taxation of income outside its jurisdictional reach," concluded Justice Breyer.


[Village of Willowbrook v. Olechon (2000) — Rehnquist Court (1994-2005) — Facts]
Grace Olech asked the Village of Willowbrook to connect her property to the municipal water supply. The Village conditioned the connection on Olech's granting of a 33-foot easement. Olech refused, claiming that the Village only required a 15-foot easement from other property owners seeking access to the water supply. Olech sued the Village claiming that the Village's demand of an additional 18-foot easement violated the Equal Protection Clause of the Fourteenth Amendment. The District Court dismissed the case for failure to state a cognizable claim under the Equal Protection Clause. In reversing, the Court of Appeals held that a plaintiff can allege an equal protection violation by asserting that state action was motivated solely by a "spiteful effort to 'get' him for reasons wholly unrelated to any legitimate state objective."


[Village of Willowbrook v. Olechon (2000) — Rehnquist Court (1994-2005) — Conclusion]
Yes. In a per curiam opinion, the Court held that Olech's allegations were sufficient to state a claim for relief under traditional equal protection analysis. "Our cases have recognized successful equal protection claims brought by a 'class of one,' where the plaintiff alleges that she has been intentionally treated differently from others similarly situated and that there is no rational basis for the difference in treatment," stated the unanimous, unsigned opinion. Justice Stephen G. Breyer concurred.


[Reeves v. Sanderson Plumbing Products, Inc. (2000) — Rehnquist Court (1994-2005) — Facts]
Roger Reeves, 57, and Joe Oswalt, in his mid-thirties, were supervisors in different Sanderson Plumbing Products, Inc. departments. Reeves' duties included making sure workers under his supervision were on time and at work and logging such data. Reeves' department was managed by Russell Caldwell, 45, who was responsible for reviewing Reeves' work. Caldwell informed the company's director of manufacturing, Powe Chesnut, that production in Revees' department was down because employees were often absent, coming in late, and leaving early. Chesnut ordered an audit, which revealed numerous timekeeping errors and misrepresentations by Caldwell, Reeves, and Oswalt. Chesnut recommended that Reeves and Caldwell be fired and, subsequently, their employment was terminated. Reeves filed suit, alleging that he had been terminated because of his age in violation of the Age Discrimination in Employment Act of 1967 (ADEA). At trial, Sanderson contended that Reeves was fired because of his failure to maintain accurate attendance records. Reeves attempted to demonstrate that this explanation was a pretext for age discrimination and introduced evidence that he had accurately recorded the attendance of employees under his supervision and that Chesnut had demonstrated age-related animosity when dealing with him. Ultimately, the case went to a jury, which returned a verdict for Reeves. In reversing, the Court of Appeals concluded that Reeves had not presented sufficient evidence to sustain a finding of age-based discrimination.


[Reeves v. Sanderson Plumbing Products, Inc. (2000) — Rehnquist Court (1994-2005) — Conclusion]
Yes. In a unanimous opinion deliver by Justice Sandra Day O'Connor, the Court held that "[a] plaintiff's prima facie case of discrimination, combined with sufficient evidence for a reasonable factfinder to reject the employer's nondiscriminatory explanation for its decision, may be adequate to sustain a finding of liability for intentional discrimination under the ADEA." The ruling means that an employer is liable to a former employee under the Age Discrimination in Employment Act of 1967 if a reasonable jury can find that the employer's explanation for the employee's dismissal was pretext for discrimination.


[Ohler v. United States (2000) — Rehnquist Court (1994-2005) — Facts]
In 1997, Maria Ohler was arrested and charged with importation of marijuana and possession of marijuana with the intent to distribute, after a customs inspector noticed that someone had tampered with one of Ohler's van interior panels and discovered approximately 81 pounds of marijuana. Before the trial, the government filed in limine motions to admit Ohler's prior felony conviction as character evidence under Federal Rule of Evidence 404(b) and as impeachment evidence under Rule 609(a)(1). Also before the trial, the District Court denied the motion to admit the conviction as character evidence. After the beginning of the trail, the court ruled that if Ohler testified, evidence of her prior conviction would be admissible under Rule 609(a)(1). While testifying, Ohler admitted on direct examination that she had been convicted of possession of methamphetamine in 1993. Subsequently, Ohler was found guilty. On appeal, Ohler challenged the District Court's in limine ruling, allowing the government to use her prior conviction for impeachment purposes. In affirming, the Court of Appeals held that Ohler waived her objection by introducing evidence of the conviction during her direct examination.


[Ohler v. United States (2000) — Rehnquist Court (1994-2005) — Conclusion]
Yes. In a 5-4 opinion delivered by Chief Justice William H. Rehnquist, the Court held that "a defendant who preemptively introduces evidence of a prior conviction on direct examination may not on appeal claim that the admission of such evidence was error." Thus, federal defendants, who choose to acknowledge their prior convictions, waive the right to appeal the evidence's admissibility. Writing for the dissenting minority, Justice David H. Souter argued, [t]here is no reason to discourage the defendant from introducing the conviction herself, as the majority's waiver rule necessarily does."


[Illinois v. Wardlow (2000) — Rehnquist Court (1994-2005) — Facts]
Sam Wardlow, who was holding an opaque bag, inexplicably fled an area of Chicago known for heavy narcotics trafficking after noticing police officers in the area. When officers caught up with him on the street, one stopped him and conducted a protective pat-down search for weapons because in his experience there were usually weapons in the vicinity of narcotics transactions. The officers arrested Wardlow after discovering that he was carrying handgun. In a trial motion to suppress the gun, Wardlow claimed that in order to stop an individual, short of actually arresting the person, police first had to point to "specific reasonable inferences" why the stop was necessary. The Illinois trial court denied the motion, finding that the gun was recovered during a lawful stop and frisk. Wardlow was convicted of unlawful use of a weapon by a felon. In reversing, the Illinois Appellate Court found that the officer did not have reasonable suspicion to make the stop. The Illinois Supreme Court affirmed, determining that sudden flight in a high crime area does not create a reasonable suspicion justifying a stop because flight may simply be an exercise of the right to "go on one's way."


[Illinois v. Wardlow (2000) — Rehnquist Court (1994-2005) — Conclusion]
Yes. In an opinion delivered by Chief Justice William H. Rehnquist, the Court held, 5 to 4, that the police officers did not violate the Fourth Amendment when they stopped Wardlow, because the officer was justified in suspecting that the accused was involved in criminal activity and, therefore, in investigating further. Chief Justice Rehnquist wrote for the majority that, "[n]ervous, evasive behavior is a pertinent factor in determining reasonable suspicion" to justify a stop. The Chief Justice noted that "flight is the consummate act of evasion." Stevens, joined by three other justices, concurred in avoiding a per se rule but dissented from the majority holding.


[Arizona v. California (2000) — Rehnquist Court (1994-2005) — Facts]
In 1952, Arizona invoked the U.S. Supreme Court's original jurisdiction to resolve a dispute with California over the extent of each state's right to use water from the Colorado River. The United States intervened, seeking water rights on behalf of five Indian reservations. Culminating in Arizona I, the Court held that the United States had reserved water rights for the five reservations. In a 1964 decree, the Court specified the water entitlements for the parties and the reservations, but held that the water rights for the reservations would be subject to adjustment in the event that the reservations' disputed boundaries were finally determined. Thereafter in Arizona II, the Court concluded that the reservations' boundaries had yet to be determined. Ultimately, the Quechan Tribe (Tribe) of the Fort Yuma Indian Reservation and the United States entered an agreement returning land encompassing some 25,000 acres of disputed boundary lands not attributed to that reservation in earlier litigation. In 1983, the Court of Claims consented to the settlement. The Tribe and the United States then filed claims seeking increased water rights for the Fort Yuma Reservation. In 1989, the Court granted the motion of Arizona, California, and two municipal water districts (State parties) to reopen the 1964 decree to determine whether the Fort Yuma Reservation was entitled to claim additional boundary lands and, if so, additional water rights. The State parties asserted that the Fort Yuma claims of the Tribe and the United States were precluded by Arizona I and by the Claims Court consent judgment.


[Arizona v. California (2000) — Rehnquist Court (1994-2005) — Conclusion]
No. In a opinion deliver by Justice Ruth Bader Ginsburg, the Court rejected both grounds for preclusion and remanded the case to a Special Master for a determination on the merits of the outstanding claims for additional water rights associated with disputed Fort Yuma Reservation boundary lands. "Those claims are the only ones that remain to be decided in Arizona v. California; their resolution will enable the Court to enter a final consolidated decree and bring this case to a close," wrote Justice Ginsburg for the Court.


[City of Erie v. Pap's A.M. (2000) — Rehnquist Court (1994-2005) — Facts]
"Kandyland," operated by Pap's A. M. in Erie PA, featured totally nude female erotic dancing. The city council enacted an ordinance making it an offense to knowingly or intentionally appear in public in a "state of nudity," To comply with the ordinance, dancers had to wear, at a minimum, "pasties" and a "G-string." Pap's filed suit against Erie, seeking a permanent injunction against the ordinance's enforcement. The Court of Common Pleas struck down the ordinance as unconstitutional, but the Commonwealth Court reversed. In reversing, the Pennsylvania Supreme Court found that the ordinance's public nudity sections violated Pap's right to freedom of expression as protected by the First and Fourteenth Amendments. The court explained that, although one purpose of the ordinance was to combat negative secondary effects, there was also an unmentioned purpose to "impact negatively on the erotic message of the dance." Additionally, because the ordinance was not content neutral, the court subjected it to strict scrutiny and found that it failed the narrow tailoring requirement of such a test. After the U.S Supreme Court granted certiorari, Pap's filed a motion to dismiss the case as moot, noting that Kandyland no longer operated as a nude dancing club, and that Pap's did not operate such a club at any other location. The Court denied the motion.


[City of Erie v. Pap's A.M. (2000) — Rehnquist Court (1994-2005) — Conclusion]
No. In an opinion delivered by Justice Sandra Day O'Connor, the Court held that Erie's public indecency ordinance did not violate any cognizable First Amendment protections of expressive conduct. In splintered voting that did not yield a majority opinion, Justice O'Connor wrote for the Court that, "[e]ven if Erie's public nudity ban has some minimal effect on the erotic message by muting that portion of the expression that occurs when the last stitch is dropped, the dancers... are free to perform wearing pasties and G-strings." "The requirement... is a minimal restriction in furtherance of the asserted government interests, and the restriction leaves ample capacity to convey the dancers' erotic message."


[Slack v. McDaniel (2000) — Rehnquist Court (1994-2005) — Facts]
Antonio Tonton Slack was convicted of second-degree murder in Nevada. In 1991, after an unsuccessful direct appeal, Slack filed a petition for a writ of habeas corpus in federal court. In federal court, Slack attempted to litigate claims he had not yet presented to the Nevada courts and was prevented from doing so. Slack, therefore, filed a motion to hold his federal petition in abeyance while he returned to state court to exhaust his new claims. The Federal District Court ordered the habeas petition dismissed and granted Slack leave to file an application to renew upon his exhaustion of state remedies. In 1995, after unsuccessful state post-conviction proceedings, Slack filed again in the federal court. The state moved to dismiss, arguing that Slack's petition raised claims that had not been presented to the state courts and that claims not raised in Slack's 1991 federal petition had to be dismissed as an abuse of the writ. The District Court granted the state's motion. Slack then filed a notice of appeal. The court denied Slack leave to appeal, concluding the appeal would raise no substantial issue. The Court of Appeals also denied Slack leave to appeal.


[Slack v. McDaniel (2000) — Rehnquist Court (1994-2005) — Conclusion]
No. In an 7-2 opinion delivered by Justice Anthony M. Kennedy, the Court held that a federal habeas corpus petition filed by a state prisoner, after an initial petition was dismissed without adjudication on the merits, does not constitute a "second or successive" petition, subject to dismissal for abuse of writ. That "a vexatious litigant could inject undue delay into the collateral review process," wrote Justice Kennedy, can be countered, "the State remains free to impose proper procedural bars to restrict repeated returns to state court for postconviction proceedings."


[Nelson v. Adams USA, Inc. (2000) — Rehnquist Court (1994-2005) — Facts]
The Ohio Cellular Products Corporation (OCP) sued Adams USA, Inc. (Adams), for patent infringement. After the District Court ruled in Adams' favor by dismissing the suit, Adams motioned for attorney fees and costs. In granting the motion, the court found that Donald Nelson, who was at all relevant times president and sole shareholder of OCP, had acted in a way that constituted inequitable conduct chargeable to OCP. Fearing it would be unable to collect the award, Adams moved under Rule 15 of the Federal Rules of Civil Procedure to amend its pleading to add Nelson, personally, as a party from whom fees could be collected. Additionally, Adams asked the court, under Rule 59(e), to amend the judgment to make Nelson immediately liable for the fee award. The District Court granted the motion in full. The Court of Appeals affirmed the decision simultaneously making Nelson a party and subjecting him to judgement.


[Nelson v. Adams USA, Inc. (2000) — Rehnquist Court (1994-2005) — Conclusion]
No. In a unanimous opinion delivered by Justice Ruth Bader Ginsburg, the Court held that the District Court erred in amending the judgment immediately upon permitting the amendment of the pleading. Justice Ginsburg wrote for the Court that "[d]ue process, as reflected in Rule 15 as well as Rule 12, required that Nelson be given an opportunity to respond and contest his personal liability for the award after he was made a party and before the entry of judgment against him." Thus, the District Court's granting of Adams' motion to simultaneously make Nelson a party and personally liable violated due process.


[Williams v. Taylor (2000) — Rehnquist Court (1994-2005) — Facts]
After Terry Williams was convicted of robbery and capital murder; his punishment was fixed at death. In state habeas corpus proceedings a judge determined that his conviction was valid. However, the judge also found that Williams' counsel's failure to discover and present significant mitigating evidence violated his right to effective counsel and recommended that he be re-sentenced. Rejecting this, the Virginia Supreme Court held that Williams had not suffered sufficient prejudice to warrant relief. In habeas corpus proceedings under the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA), a federal trial judge also found that the death sentence was constitutionally weak on ineffective-assistance grounds. The court, under the AEDPA, concluded that the Virginia Supreme Court's decision "was contrary to, or involved an unreasonable application of, clearly established Federal law, as determined by the Supreme Court of the United States." In reversing, the Court of Appeals determined that it could not conclude that the Virginia Supreme Court's decision on prejudice was an unreasonable application of standards established by the Supreme Court.


[Williams v. Taylor (2000) — Rehnquist Court (1994-2005) — Conclusion]
Yes and yes. In a judgment announced by Justice John Paul Stevens, the Court, with different majorities of Justices for each holding, held that Williams had been deprived of the constitutional right to the effective assistance of counsel and that the Virginia Supreme Court's refusal to set aside the Williams death sentence was a decision that was contrary to or involved an unreasonable application of clearly established federal law, as determined by the Court. This conclusion followed from "'a reasonable probability that the result of the sentencing proceeding would have been different' if competent counsel had presented and explained the significance of all the available evidence.'"


[Dickerson v. United States (2000) — Rehnquist Court (1994-2005) — Facts]
During questioning about a robbery he was connected to, Charles Dickerson made statements to authorities admitting that he was the getaway driver in a series of bank robberies. Dickerson was then placed under arrest. The timing of his statement is disputed. The FBI and local detectives testified that Dickerson was advised of his Miranda rights, established in Miranda v. Arizona, and waived them before he made his statement. Dickerson said he was not read his Miranda warnings until after he gave his statement. After his indictment for bank robbery, Dickerson filed a motion to suppress the statement that he made on the ground that he had not received Miranda warnings before being interrogated. The government argued that even if the Miranda warnings were not read, the statement was voluntary and therefore admissible under 18 USC Section 3501, which provides that "a confession shall be admissible in evidence if it is voluntarily given." The District Court granted Dickerson's motion, finding that he had not been read his Miranda rights or signed a waiver until after he made his statement, but the court did not address section 3501. In reversing, the Court of Appeals acknowledged that Dickerson had not received Miranda warnings, but held that section 3501 was satisfied because his statement was voluntary. The court held that "Congress enacted section 3501 with the express purpose of legislatively overruling Miranda and restoring voluntariness as the test for admitting confessions in federal court."


[Dickerson v. United States (2000) — Rehnquist Court (1994-2005) — Conclusion]
No. In a 7-2 opinion delivered by Chief Justice William H. Rehnquist, the Court held that Miranda governs the admissibility of statements made during custodial interrogation in both state and federal courts. "Miranda has become embedded in routine police practice to the point where the warnings have become part of our national culture," wrote Rehnquist. "Miranda announced a constitutional rule that Congress may not supersede legislatively. We decline to overrule Miranda ourselves," concluded the Chief Justice. Dissenting, Justice Antonin Scalia, joined by Justice Clarence Thomas, blasted the Court's ruling, writing that the majority opinion gave needless protection to "foolish (but not compelled) confessions."


[Ramdass v. Angelone (2000) — Rehnquist Court (1994-2005) — Facts]
A Virginia jury found Bobby Ramdass guilty of murdering Mohammed Kayani, a clerk in the 7-Eleven he held up, and recommended the death sentence. At the time of the sentencing phase of his trial, final judgment had been entered against Ramdass for an armed robbery and he had been found guilty of a second armed robbery, but no final judgment had been entered. Under Virginia law, a conviction does not become final until the jury returns a verdict and the judge enters a final judgment of conviction and pronounces sentence. The Kayani judge paused and scheduled a future hearing to consider whether to impose the recommended sentence. During the interval between the jury trial and this hearing, final judgment had been entered on the second armed robbery conviction. At the sentencing hearing in the capital murder case, Ramdass, in arguing for a life sentence, claimed that his prior convictions made him ineligible for parole under Virginia's three-strikes law. The court sentenced Ramdass to death, and the Virginia Supreme Court affirmed. On remand from the U.S Supreme Court, the Virginia Supreme Court again affirmed the sentence over Ramdass' argument that he should have been allowed to inform the jury of his parole ineligibility. The court declined to apply a previous U.S Supreme Court holding that a jury considering imposing death should be told if the defendant is parole ineligible under state law. The court concluded that Ramdass was not parole ineligible when the jury was considering his sentence because the second armed robbery, in which no final judgment had been entered, did not count as a conviction for purposes of the three-strikes law. Ultimately, Ramdass sought federal habeas corpus relief. The District Court granted his petition, ruling that the jury should have been advised that he was ineligible for parole. In reversing, the Court of Appeals determined that Ramdass was not, at the time of his sentencing proceedings, legally ineligible for parole.


[Ramdass v. Angelone (2000) — Rehnquist Court (1994-2005) — Conclusion]
No. In a 5-4 opinion delivered by Justice Anthony M. Kennedy, the Court held that Ramdass was not entitled to federal habeas corpus relief because he was not entitled to instruction on parole ineligibility at sentencing since conviction had not been entered yet on the earlier jury verdict making him parole ineligible. In a plurality opinion, Justice Kennedy wrote for the Court that the Virginia Supreme Court's finding that the state's three-strikes law did not cover the defendant until shortly after he was sentenced must be honored because it "was neither contrary to, nor an unreasonable application" of a decision in which the justices said that defendants have the right to tell jurors about their parole status in such cases.


[Board of Regents , University of Wisconsin System v. Southworth (2000) — Rehnquist Court (1994-2005) — Facts]
The University of Wisconsin, a public university, requires students to pay an activity fee. The fee supports various campus services and extracurricular student activities including the Future Financial Gurus of America; the International Socialist Organization; the College Democrats and Republicans; and the American Civil Liberties Union Campus Chapter. Scott Harold Southworth filed suit against the University, alleging that the fee violated his rights of free speech, free association, and free exercise under the First Amendment. Southworth argued that the University must grant him the choice not to fund registered student organizations (RSO) that engage in political and ideological expression offensive to his personal beliefs. In granting Southworth judgment, the Federal District Court concluded that the fee program compelled students to support political and ideological activities with which they disagree in violation of their First Amendment rights to freedom of speech and association. The court declared the fee program invalid and enjoined the University from using the fees to fund any RSO engaging in political or ideological speech. In affirming, the Court of Appeals concluded that the fee program was "not germane to the University's mission, did not further a vital University policy, and imposed too much of a burden on [Southworth's] free speech rights."