[Pliler v. Ford (2004) — Rehnquist Court (1994-2005) — Conclusion]
No. In an opinion by Justice Clarence Thomas, the Court ruled that a judge is not required to warn a habeas corpus petitioner who is representing himself of the consequences of his legal decision. Justice Thomas wrote, "District judges have no obligation to act as counsel or paralegal to pro se litigants." Five justices joined Thomas' opinion, while two others concurred in his judgment.


[United States v. Flores-Montano (2004) — Rehnquist Court (1994-2005) — Facts]
When Manuel Flores-Montano approached the U.S.-Mexico border, U.S. Customs inspectors noticed his hand shaking; an inspector tapped Flores-Montano's gas tank with a screwdriver and noticed that the tank sounded solid; a drug-sniffing dog alerted to the vehicle. After a mechanic began disassembling the car's fuel tank, inspectors found 37 kilograms of marijuana bricks in the tank.
Flores-Montano was charged in federal district court in California for importing and possessing marijuana with intent to distribute. Flores-Montano moved to suppress the marijuana finding on Fourth Amendment grounds. He argued that the search that yielded the marijuana finding was intrusive and non-routine and therefore required reasonable suspicion (which, he argued, was not present in his case).
Relying on U.S. v. Molina-Tarazon, a case decided by the U.S. Ninth Circuit Court of Appeals in 2002 (with similar circumstances), the district court agreed that the search was non-routine and thus required reasonable suspicion. The government, the court held, failed to prove that reasonable suspicion prompted its search. The Ninth Circuit Court of Appeals affirmed.


[United States v. Flores-Montano (2004) — Rehnquist Court (1994-2005) — Conclusion]
No. In a unanimous opinion delivered by Chief Justice William Rehnquist, the Court held that the government had authority to inspect a vehicle's fuel tank at the border without suspicion. Though the Fourth Amendment "'protects property as well as privacy,'" interference with a vehicle owner's gas tank "is justified by the Government's paramount interest in protecting the border." The Court rejected the argument that the requirement of suspicion for highly intrusive searches of people be carried over to cars (especially at the border): "Complex balancing tests...have no place in border searches of vehicles."


[Groh v. Ramirez (2004) — Rehnquist Court (1994-2005) — Facts]
Jeff Groh, a special agent for the U.S. Bureau of Alcohol, Tobacco, and Firearms, applied for a search warrant to search the Ramirez ranch for illegal weapons. On the warrant, Groh mistakenly omitted the exact items sought (though he correctly listed the items on the application itself). A federal magistrate issued the warrant.
The Ramirezes later sued Groh and the law enforcement officers involved in the search in federal court for violating their Fourth Amendment rights. They argued that the incorrectly completed warrant violated the Fourth Amendment requirement that any items searched for be described in the warrant.
The district court ruled that no constitutional violation took place. The officers, the court held, retained "qualified immunity" - meaning they are legally immune while doing their jobs unless they violate a "clearly established" constitutional right.
A Ninth Circuit Court of Appeals panel reversed. The court held that the warrant violated the Fourth Amendment and that Groh is not immune to lawsuit because he was personally responsible for using the warrant.


[Groh v. Ramirez (2004) — Rehnquist Court (1994-2005) — Conclusion]
Yes and yes. Justice John Paul Stevens delivered the Court's 5-4 opinion holding that the search was "unreasonable" under the Fourth Amendment. Groh's warrant was invalid because it did not meet the Fourth Amendment requirement that a warrant particularly describe the persons or things to be seized. True, the magistrate judge approved a complete warrant - but what matters is that the Ramirezes did not know what the search was after. Because the particularity requirement is stated in the Fourth Amendment's text, "no reasonable officer could believe that a warrant that did not comply with that requirement was valid." Groh therefore did not have "qualified immunity" from suit.


[Raytheon Company v. Hernandez (2003) — Rehnquist Court (1994-2005) — Facts]
In 1991, Joel Hernandez tested positive for cocaine use in a drug test administered by his employer. As a result of the incident, he was forced to resign. In 1994, he reapplied for a job from the company. His application was rejected. Hernandez claimed that the company was discriminating against him because of his drug and alcohol addiction (though at the time he reapplied he had been sober for two years) in violation of the Americans with Disabilities Act of 1990. The district court sided with the company, dismissing the case before it ever went to trial. A Ninth Circuit Court of Appeals panel unanimously reversed, however, holding that Raytheon's decision not to rehire Hernandez because of an incident related to his past addiction could constitute discrimination under the act.


[Raytheon Company v. Hernandez (2003) — Rehnquist Court (1994-2005) — Conclusion]
Yes. The Court unanimously held that an employer may refuse to rehire an employee who was terminated in connection with drug or alcohol-related incidents as long as the refusal is based on a policy of not rehiring employees who previously violated workplace rules rather than on the worker's addiction. That is, an employer may refuse to hire someone who was terminated for coming to work under the influence, but may not refuse to hire someone whose previous addiction did not result in any workplace rule infractions. Justices David Souter and Stephen Breyer took no part in this case.


[Beard v. Banks (2004) — Rehnquist Court (1994-2005) — Facts]
In 1982, George Banks was sentenced to death in Pennsylvania for the murder of 13 people. After the Pennsylvania Supreme Court upheld the conviction, Banks unsuccessfully sought a writ of habeas corpus in federal district court. Reversing the district court, the Third Circuit Court of Appeals found Banks's death sentence unconstitutional. The court held that jury instructions during sentencing led jurors to believe they could not vote against the death penalty unless they all agreed on mitigating evidence (that is, evidence that would have inclined them to vote against the death penalty). This, the court reasoned, violated the U.S. Supreme Court's ruling in Mills v. Maryland (1988). The U.S. Supreme Court reversed the decision (in part) and remanded it. Pointing to its opinion in Teague v. Lane (1989) and the fact that Mills was decided after Banks's conviction, the Court reasoned that the appeals court did not consider whether Mills could be "retroactively" applied. The Third Circuit Court - reviewing its ruling - did not change its original opinion. It found that "Mills did not announce a new rule of constitutional law for retroactivity purposes" and that Banks's death sentence was unconstitutional.


[Beard v. Banks (2004) — Rehnquist Court (1994-2005) — Conclusion]
Ruling yes on the first question, the Court did not need to reach the second question. In a 5-to-4 decision written by Justice Clarence Thomas, the Court found that the rule announced in Mills - that sentencing schemes could not prevent jurors from considering mitigating evidence that had not been accepted unanimously when deciding whether to apply the death penalty - was a new rule, because it was not compelled by previous Court decisions. As a new rule, it could only be applied retroactively if it was a "watershed rule[] of criminal procedure implicating the fundamental fairness and accuracy of the criminal proceeding." Finding that it was not a watershed rule, the Court found that it could not be applied retroactively and that Beards' conviction was therefore constitutional.


[Tennessee Student Assistance Corporation v. Hood (2004) — Rehnquist Court (1994-2005) — Facts]
Pamela Hood had an outstanding debt to the Tennessee Student Assistance Corporation, a loan-granting institution established by the state, when she filed for bankruptcy. The state objected to her request that the debt be forgiven ("discharged" in the terms of bankruptcy law) by the federal bankruptcy court, arguing that to discharge the debt would violate the state's sovereign immunity (that is, its right not to be sued). Hood countered that the Federal Rules of Bankruptcy Procedure allow student loan debts to be discharged if the bankruptcy filer can demonstrate that they will suffer "undue hardship" if the debt is not forgiven, and that this congressional permission is a constitutional waiver of state sovereign immunity because it falls under the power granted to Congress by the Bankruptcy Clause (Article I, Section 8 of the U.S. Constitution).
The bankruptcy court sided with Hood, finding that Congress had acted constitutionally in waiving the states' sovereign immunity. The Sixth Circuit Bankruptcy Appellate Panel affirmed, as did a normal panel of the Sixth Circuit.


[Tennessee Student Assistance Corporation v. Hood (2004) — Rehnquist Court (1994-2005) — Conclusion]
In a per curiam (unsigned) opinion, the Court declined to reach the question of whether the Bankruptcy Clause gives Congress the power to waive a state's sovereign immunity. Instead, the Court ruled that discharging a debt owed to a state in a bankruptcy procedure is different from a suit and therefore not barred by sovereign immunity. "A bankruptcy court is able to provide the debtor a fresh start in this manner ... because the court's jurisdiction is premised on the debtor and his estate, and not on the creditors," wrote the Court. That is, the discharge of debt by a bankruptcy court is not a personal suit against a state (which would violate sovereign immunity) but instead merely a modification of a debtor's estate that incidentally affects a state. As such, it is permissible even without Congressional waiver of sovereign immunity.


[Till et ux. v. SCS Credit Corp. (2004) — Rehnquist Court (1994-2005) — Facts]
Lee Till owed $4,000 in payments on his truck when he filed for Chapter 13 bankruptcy. Under the Bankruptcy Code, a Chapter 13 debtor must promise each creditor future payments "not less than the [claim's] allowed amount." When a repayment plan includes a series of payments (installments), as Till's did, the installments must equal the "total present value" of the amount owed. Till proposed that he make monthly payments on the truck to SCS Credit with a 9.5 percent yearly interest rate, which was slightly higher than the average loan rate to make up for the increased risk that Till would fail to make a payment (because he had already declared bankruptcy once). SCS, however, argued that it was entitled to 21 percent interest because that was how much it would have made if it had foreclosed on the loan, taken the truck, sold it, and reinvested the proceeds. SCS argued that this 21 percent plan was necessary to ensure that the payments were equal to the "total present value" or "not less than the [claim's] allowed amount." The bankruptcy court ruled for Till. The district court reversed, imposing SCS's 21 percent rate. A divided Seventh Circuit Court of Appeals panel modified that approach slightly, ruling that the 21 percent rate was probably correct but that the parties could introduce evidence that a higher or lower rate should apply.


[Till et ux. v. SCS Credit Corp. (2004) — Rehnquist Court (1994-2005) — Conclusion]
In a decision that had no majority opinion, four justices held that the proper rate was the 9.5 percent one arrived at by modifying the average national loan rate to make up for the increased risk of non-payment. While this would not give the creditors the same amount of money that they might have gotten had they seized the collateral for the loan, it nevertheless met the statutory requirement that the repayments equal the "total present value." Justice Clarence Thomas, in a separate opinion that provided the fifth vote needed for judgment, found that the 9.5 percent rate was acceptable, but that it could be even lower because the Bankruptcy Code did not require the judge to accommodate for the risk of non-payment.


[Jones v. R. R. Donnelley & Sons Company (2004) — Rehnquist Court (1994-2005) — Facts]
In November of 1996, Edith Jones and several other African Americans filed a class action lawsuit in federal district court against R.R. Donnelley and Sons, a commercial printing company. They claimed they had suffered racial discrimination in violation of section 1981 of United States Code (U.S.C.), which had no specified statute of limitations. Donnelley and Sons, however, argued that the section was bound by a two-year statute of limitations established by Illinois for all personal injury claims. The suit fell outside that statute of limitations, and the company argued that it should therefore be dismissed.
Jones, however, argued that a separate section of U.S.C. extended the statute of limitations to four years for any civil suit brought under an act of Congress passed after 1990. Because the 1991 Civil Rights Act had broadened the definition of section 1981, she argued, the four-year statute of limitations should apply to that section and the suit should therefore not be thrown out. Donnelley and Sons countered that the 1991 Civil Rights Act had merely amended the section, not created a new law, and that the four-year statute of limitations therefore did not apply.
A federal district court sided with Jones. A Seventh Circuit Court of Appeals panel unanimously reversed.


[Jones v. R. R. Donnelley & Sons Company (2004) — Rehnquist Court (1994-2005) — Conclusion]
It also applies to amendments of previously existing laws. Writing for a unanimous Court, Justice John Paul Stevens stated "[a]n amendment to an existing statute is no less an 'Act of Congress' than a new, stand-alone statute." The four-year statute of limitations therefore applies to any act or amendment to an act passed by Congress after 1990.


[Verizon Communications, Inc. v. Law Offices of Curtis V. Trinco, LLP (2004) — Rehnquist Court (1994-2005) — Facts]
Curtis Trinko was an AT&T customer but received service on lines owned by Verizon, which AT&T was permitted to use for a fee under the anti-monopoly 1996 Telecommunications Act. Trinko claimed that Verizon discriminated against AT&T customers by providing them worse service than it provided to its own customers. He claimed that this violated both the Telecommunications Act and the Sherman Anti-Trust Act of 1890, which prohibits monopolies from aggressively defending their monopoly position in the market. A federal district court ruled that Trinko had no grounds to sue because he was not a direct customer of Verizon. A 2nd Circuit Court of Appeals panel, however, reinstated the charges leveled under the Sherman Act.


[Verizon Communications, Inc. v. Law Offices of Curtis V. Trinco, LLP (2004) — Rehnquist Court (1994-2005) — Conclusion]
No. In a unanimous opinion delivered by Justice Antonin Scalia, the Court held that the complaint alleging breach of Verizon's Telecommunication Act duties to share its network with competitors did not state a claim under the Sherman Act. The Court reasoned that the 1996 act did not alter antitrust law or add new claims and that Verizon did not violate preexisting antitrust standards. The justices declined to add a new claim by making an exception to the rule that businesses need not aid competitors.


[Hamdi v. Rumsfeld (2004) — Rehnquist Court (1994-2005) — Facts]
In the fall of 2001, Yaser Hamdi, an American citizen, was detained by the United States military in Afghanistan. He was accused of fighting for the Taliban against the U.S., declared an "enemy combatant," and was held in Guantanamo Bay. Upon learning he was an American citizen, he was transferred to a military prison in Virginia. Hamdi’s father, Esam Fouad Hamdi, filed a petition for a writ of habeas corpus naming himself as Hamdi’s “next friend,” in an attempt to have Hamdi’s detention declared unconstitutional. The district court granted Hamdi’s petition, and appointed the Federal Public Defender for the Eastern District of Virginia, Frank Dunham, Jr., as counsel for the petitioners. He argued that the government had violated Hamdi's Fifth Amendment right to Due Process by holding him indefinitely and not giving him access to an attorney or a trial. The government countered that the Executive Branch had the right, during wartime, to declare people who fight against the United States "enemy combatants" and thus restrict their access to the court system.
The district court refused to answer the question of whether the declaration of "enemy combatant" was sufficient to justify his detention without review of materials and criteria used in making the determination. It ordered the government to produce these materials for a review by the court. Not wanting to produce these materials, the government appealed. The Fourth Circuit Court of Appeals panel reversed, finding that the separation of powers required federal courts to practice restraint during wartime because "the executive and legislative branches are organized to supervise the conduct of overseas conflict in a way that the judiciary simply is not." The panel therefore found that it should defer to the Executive Branch's "enemy combatant" determination.


[Hamdi v. Rumsfeld (2004) — Rehnquist Court (1994-2005) — Conclusion]
Yes and no. In an opinion backed by a four-justice plurality and partly joined by two additional justices, Justice Sandra Day O'Connor wrote that although Congress authorized Hamdi's detention, Fifth Amendment due process guarantees give a citizen held in the United States as an enemy combatant the right to contest that detention before a neutral decisionmaker. The plurality rejected the government's argument that the separation-of-powers prevents the judiciary from hearing Hamdi's challenge. Justice David H. Souter, joined by Justice Ruth Bader Ginsburg, concurred with the plurality that Hamdi had the right to challenge in court his status as an enemy combatant. Souter and Ginsburg, however, disagreed with the plurality's view that Congress authorized Hamdi's detention. Justice Antonin Scalia issued a dissent joined by Justice John Paul Stevens. Justice Clarence Thomas dissented separately.


[Securities and Exchange Commission v. Edwards (2004) — Rehnquist Court (1994-2005) — Facts]
Charles Edwards founded a company that sold pay telephones and then leased them back from the purchasers for a fixed monthly fee. After Edwards filed for bankruptcy, the Securities and Exchange Commission (SEC) sued him for selling securities (considering the telephones to be investments on the part of the purchasers and therefore securities) in violation of the registration and anti-fraud provisions of the federal securities laws.
A federal district court froze Edwards' assets in a preliminary injunction. The 11th Circuit Court of Appeals overruled the district court's injunction for lack of jurisdiction. The SEC, the court reasoned, failed to show that Edwards' selling pay telephones was an "investment contract" under federal securities laws. In defining "investment contract," the court used the Supreme Court's ruling in SEC v. W.J. Howey Co. (1946), that a financial interest is an "investment contract" if it involves (1) an investment of money, (2) in a common enterprise, (3) with the expectation of profits to be derived solely from the efforts of others. The 11th Circuit ruled that the SEC could not meet the test's third part because the purchasers received a fixed fee that was guaranteed by contract and therefore not dependant on Edwards' success.


[Securities and Exchange Commission v. Edwards (2004) — Rehnquist Court (1994-2005) — Conclusion]
Yes. In a unanimous opinion delivered by Justice Sandra Day O'Connor, the Court held that an investment scheme promising a fixed rate of return can be an "investment contract" and thus a "security" subject to federal securities laws. The test the Court uses for determining whether a scheme is an "investment contract" is "whether the scheme involves an investment of money in a common enterprise with profits to come solely from the efforts of others." Because the test does not distinguish between promises of fixed returns and promises of variable returns, the scheme at issue here can be defined as an "investment contract."


[Aetna Health, Inc. v. Davila (2004) — Rehnquist Court (1994-2005) — Facts]
Juan Davila sued his HMO in state court because it had refused to provide certain procedures, and the refusal led to certain injuries. He brought the suit under a Texas law that requires HMOs "to exercise ordinary care" for their patients. The HMO asked that the case be moved to federal court, arguing that the case should be governed under the Employee Retirement Income Security Act of 1974 (ERISA) rather than the Texas law, because ERISA is a federal law the takes precedence over any state laws dealing with the same subject matter. Davila objected, arguing that the case did not fall under ERISA and should be heard in state court. The federal district court sided with the HMO, finding that ERISA prohibits individuals from filing state suits against HMOs when they refuse to pay for a particular treatment. A Fifth Circuit Court of Appeals panel reversed.


[Aetna Health, Inc. v. Davila (2004) — Rehnquist Court (1994-2005) — Conclusion]
Yes. In a unanimous opinion written by Justice Clarence Thomas, the Court held that Congress intended ERISA to provide a uniform system for regulating retirement schemes and benefits. If a state law conflicts with ERISA, therefore, ERISA must be used in its place. Justice Thomas wrote, "[A]ny state-law cause of action that duplicates, supplements or supplants the ERISA civil enforcement remedy conflicts with the clear congressional intent to make the ERISA remedy exclusive and is therefore preempted."


[Baldwin v. Reese (2004) — Rehnquist Court (1994-2005) — Facts]
A state trial court sentenced Reese to 33 years in prison. An appellate court lowered the sentence to 24 years. In another appeal to a state appellate court, Reese argued his federal Sixth Amendment right to effective counsel was violated at trial and on appeal. The appellate court refused to reverse Reese's sentence. Reese appealed to the state supreme court and failed.
Reese appealed to a U.S. District Court. Ruling against Reese, the Court held that Reese did clearly say to the state supreme court his claims were federal. Federal law requires state prisoners to "fairly present" federal constitutional claims in each state court before appealing to federal courts. A federal appellate court reversed, ruling that the state supreme court had had the opportunity to read the state appellate court decision - had the court done this, it would have understood Reese's claims were federal.


[Baldwin v. Reese (2004) — Rehnquist Court (1994-2005) — Conclusion]
Yes. In an 8-1 opinion delivered by Justice Stephen Breyer, the Court held that Reese did not "fairly present" his Sixth Amendment ineffective counsel claim to state courts. Federal law thus barred Reese from turning to federal courts. The state court could have understood Reese's claims were federal if the court had read the lower court opinion. However, a state prisoner does not "fairly present" a federal claim to a state court if that court must read beyond what the prisoner files. There is no federal requirement that courts read lower court opinions.


[South Florida Water Management District v. Miccosukee Tribe of Indians (2004) — Rehnquist Court (1994-2005) — Facts]
The Miccosukee Tribe of Indians and the Friends of the Everglades sued the South Florida Water Management District under the Clean Water Act (CWA) in federal district court. The suit alleged that the water district violated the Clean Water Act by releasing pollutants from a pump system without a discharge elimination system permit. The Clean Water Act prohibits the "addition of any pollutant... from any point source" without a specific permit. The water district defended its action by claiming that it was not actually adding pollutants to the water, but merely transporting polluted water from one body of water to another, less polluted, body.
The district court ruled against the water district and found that it had violated the CWA by using the pump. The 11th Circuit Court of Appeals affirmed on this point, "conclud[ing] that the release of water caused by the... pump station's operation constitutes an addition of pollutants from a point source."


[South Florida Water Management District v. Miccosukee Tribe of Indians (2004) — Rehnquist Court (1994-2005) — Conclusion]
In an opinion delivered by Justice Sandra Day O'Connor, the Court sent the case back to the district court to consider whether the water conservation area and the canal used to transport the water are distinct. If the district court decides the two are not distinct, then the water district will not need a permit under the Clean Water Act. The Court rejected the water district's argument that the act covers a point source only when pollutants originate from that source, not when pollutants originating elsewhere pass through the point source. A point source need only convey the pollutant to navigable waters. The Court was unanimous in sending the case back to district court. Justice Antonin Scalia dissented from part of the Court's reasoning.


[F. Hoffman-LaRoche, Ltd. v. Empagran S.A. (2004) — Rehnquist Court (1994-2005) — Facts]
Under the Foreign Trade Antitrust Improvements Act of 1982 (FTAIA), the Sherman Act (which regulates monopolies and attempts to unfairly raise prices) does not apply to foreign commerce unless that commerce significantly harms domestic commerce, American imports, or American exporters. In this case, several companies that purchase and resell vitamins sued several vitamin manufacturers for illegal attempts to raise prices, both within the United States and in foreign countries. The manufacturers asked the district judge to dismiss several of the vitamin purchasers from the case because they only did business in other countries and, the manufacturers argued, could therefore not bring claims under the Sherman Act. The purchasers countered that the foreign price-fixing attempts were linked to the domestic attempts and could therefore be heard under the exception to the FTAIA. The district court sided with the manufacturers. On appeal, a D.C. Circuit Court of Appeals panel reversed, finding that the price fixing schemes were independent of each other but that Congress' intent had been to prevent price-fixing both at home and abroad, and that even the foreign claims could therefore be brought under the exception to the FTAIA.


[F. Hoffman-LaRoche, Ltd. v. Empagran S.A. (2004) — Rehnquist Court (1994-2005) — Conclusion]
No. The Court unanimously ruled that Congress' intent in passing the FTAIA was to prevent American courts from interfering in foreign commerce. Congress made an exception for foreign commerce that affected domestic commerce, but the exception should not be read as a general prohibition against price-fixing in all parts of the world. In the majority opinion (Justices Clarence Thomas and Antonin Scalia filed a separate opinion concurring in judgment), Justice Stephen G. Breyer wrote, "Why should American law supplant, for example, Canada's or Great Britain's or Japan's own determination about how best to protect (their own) customers from anticompetitive conduct engaged in" by their own companies?


[Olympic Airways v. Husain (2004) — Rehnquist Court (1994-2005) — Facts]
Abid Hanson was allergic to second-hand smoke. On an Olympic Airways flight, he and his wife, Rubina Husain, sat in non-smoking seats. However, because the seats were close to the smoking section, Mrs. Husain requested she and her husband be moved. Her request was denied twice, even after the smoke began bothering Hanson. Hanson died during the flight. Husain filed suit in California federal district court. She sought damages under Article 17 of the Warsaw Convention, which allows damages recovery for international air travelers for accidents on airplanes. The district court agreed that Hanson's death was an "accident" as defined by the convention and awarded Husain $1.4 million. The 9th Circuit Court of Appeals affirmed.


[Olympic Airways v. Husain (2004) — Rehnquist Court (1994-2005) — Conclusion]
Yes. Justice Clarence Thomas delivered the Court's 6-2 opinion that the events on the airplane were an "accident" under the Warsaw Convention's Article 17. The Court cited its 1985 decision in Air France v. Saks, in which it decided any "injury is the product of a chain of causes" and that an accident occurs when "some link in the chain was an unusual or unexpected event external to the passenger." The Court rejected Olympic Airways' argument that only the cigarette smoke was relevant and that no "accident" took place because the flight attended simply did not act. The flight attendant's refusal three times to reseat Husain was a "link in the chain" of causes leading to his death and the attendant's rejection of an explicit request for assistance was an "event."


[Yarborough v. Alvarado (2004) — Rehnquist Court (1994-2005) — Facts]
Police interviewed Michael Alvarado, 17, without his parents at a police station about his involvement in a crime. Police neither arrested nor Mirandized Alvarado. During the interview, Alvarado confessed involvement. Based, in part, on these statements, Alvarado was convicted of second-degree murder and attempted robbery. After failed appeals in the California courts, Alvarado unsuccessfully sought a writ of habeas corpus in federal district court in California. The Ninth Circuit Court of Appeals reversed. Recognizing the "in custody" standard to be whether a reasonable person would feel free to end interrogation, the appeals court held that a juvenile is more likely to feel he is in custody. Because Alvarado was "in custody," the Fifth Amendment required that his rights under Miranda v. Arizona (1966) be read to him.


[Yarborough v. Alvarado (2004) — Rehnquist Court (1994-2005) — Conclusion]
No. In a 5-to-4 decision written by Justice Anthony Kennedy, the Court ruled that the purpose of the Court's Miranda decision was to provide an objective rule readily understandable by police officers: when interrogating a suspect who is "in custody," an officer must first read the suspect his Miranda rights. Determining whether a suspect is actually in custody has always been based on objective criterion like whether he had been brought to the police station by police or had come of his own accord. Requiring officers to consider individual characteristics of a suspect when determining whether he is "in custody," such as the suspect's age or previous history with law enforcement, would make the test a subjective one that would be more difficult for officers to understand and abide by. Justice Kennedy wrote that the Miranda decision "states an objective rule designed to give clear guidance to the police, while consideration of a suspect's individual characteristics - including his age - could be viewed as creating a subjective inquiry."


[Norton v. Southern Utah Wilderness Alliance (2004) — Rehnquist Court (1994-2005) — Facts]
The federal Bureau of Land Management (BLM) designated 2.5 million acres of land in Utah as "Wilderness Study Areas" under the Federal Land Policy and Management Act of 1976 (FLPMA). Under the Act, the BLM is required to manage this land "so as not to impair the suitability of such areas for preservation as wilderness."
The Southern Utah Wilderness Alliance (SUWA) and several other environmentalist groups brought suit in federal district court under section 706 (1) of the Administrative Procedure Act (APA), which allows federal courts to compel government action when an agency has failed to meet its legal duties. SUWA claimed that the BLM had failed to take a "hard look," as required by the National Environmental Policy Act of 1969, at the effects of off-road vehicles on the Wilderness Study Areas. It also claimed that the permitted off-road vehicle use was in fact damaging the study areas in violation of the agency's FLPMA obligations.
The district court dismissed the case, holding that SUWA's charge that the bureau had failed to adequately protect the study areas was not specific enough for the court to hear under the Administrative Procedure Act. On appeal, a divided panel of the 10th Circuit Court of Appeals reversed the decision. It held that the bureau's discretion was limited to deciding how to implement the act, not if to implement it, and that SUWA could therefore bring suit to force it at least to take a "hard look" at the effects of the off-road vehicle policy.


[Norton v. Southern Utah Wilderness Alliance (2004) — Rehnquist Court (1994-2005) — Conclusion]
Yes, but only to a limited extent. In a unanimous opinion written by Justice Antonin Scalia, the Court ruled that the APA only allows courts to examine government agencies' failures to meet specific statutory requirements. A general complaint based on policy differences - like SUWA's view that the off- road vehicles made the Wilderness Study Areas unsuitable for preservation as wilderness - could not be heard under the APA. Justice Scalia wrote, "If courts were empowered to enter general orders compelling compliance with broad statutory mandates ... it would ultimately become the task of the supervising court, rather than the agency, to work out compliance with the broad statutory mandate, injecting the judge into day-to-day agency management."


[Rumsfeld v. Padilla (2004) — Rehnquist Court (1994-2005) — Facts]
Jose Padilla, an American citizen, was arrested in Chicago's O'Hare International Airport after returning from Pakistan in 2002. He was initially detained as a material witness in the government's investigation of the al Qaeda terrorist network, but was later declared an "enemy combatant" by the Department of Defense, meaning that he could be held in prison indefinitely without access to an attorney or to the courts. The FBI claimed that he was returning to the United States to carry out acts of terrorism.
Donna Newman, who had represented him while he was being held as a material witness, filed a petition for habeas corpus on his behalf. The U.S. District Court for the Southern District of New York ruled that Newman had standing to file the petition despite the fact that Padilla had been moved to a military brig in South Carolina. However, the court also found that the Department of Defense, under the President's constitutional powers as Commander in Chief and the statutory authorization provided by Congress's Authorization for Use of Military Force, had the power to detain Padilla as an enemy combatant. The district judge rejected Newman's argument that the detention was prohibited by the federal Non-Detention Act, which states that no "citizen shall be imprisoned or otherwise detained by the United States except pursuant to an Act of Congress."
On appeal, a divided Second Circuit Court of Appeals panel reversed the district court's "enemy combatant" ruling. The panel found that the Authorization for Use of Military force did not meet the requirement of the Non-Detention Act and that the President could not, therefore, declare American citizens captured outside a combat zone as enemy combatants.


[Rumsfeld v. Padilla (2004) — Rehnquist Court (1994-2005) — Conclusion]
The Court did not reach a decision on the merits in this case. Instead, in 5-to-4 opinion written by Chief Justice William H. Rehnquist, the Court found that the case had been improperly filed. Under federal law, a petition for a writ of habeas corpus can only be filed against the person directly responsible for a prisoner's confinement or, put another way, the person with the power to bring the prisoner to court. In most cases this person is the warden of the petitioner's prison; in this case, it was the commander of the military brig in which Padilla was held. Because Padilla's attorney had listed Secretary of Defense Donald Rumsfeld as the defendent, instead of the brig commander, and because the suit was filed in New York instead of in South Carolina, where the commander lived and worked, the Court found that the case would have to be re-filed in a federal district court in South Carolina.
Justices Stevens, Souter, Ginsberg and Breyer dissented, finding that an exception should be made to the jurisdictional rule because the government had moved Padilla to South Carolina without giving his attorney notice to file the habeas writ.


[Missouri v. Seibert (2004) — Rehnquist Court (1994-2005) — Facts]
Patrice Seibert was convicted of second degree murder for the death of 17 -year-old Donald Rector, who died in a fire set in the mobile home where he lived with Seibert. Several days after the fire, Seibert was interrogated by a police officer. The officer initially withheld her Miranda warnings, hoping to get a confession from her first. Once she had confessed, the officer took a short break from questioning, then read her her Miranda rights and resumed questioning her after she waived those rights. He prompted her to restate the confession that she had made earlier. Based on this second, Mirandized confession, Seibert was convicted.
She appealed, charging that the officer's intentional use of an un-Mirandized interrogation to get the initial confession made the later confession, though it occurred after she had waived her Miranda rights, inadmissable. The prosecution cited Oregon v. Elstad to argue that an initial, un-Mirandized confession did not make a defendant incapable of voluntarily waiving her Miranda rights and confessing later.
The Supreme Court of Missouri agreed with Seibert, overturning the conviction.


[Missouri v. Seibert (2004) — Rehnquist Court (1994-2005) — Conclusion]
No. In a decision with no majority, a four-justice plurality found that the post-Miranda confession is only admissible - even if the two-stage interview was unintentional, as it was in Elstad - if the Miranda warning and accompanying break are sufficient to give the suspect the reasonable belief that she has the right not to speak with the police. Justice Anthony Kennedy, in a concurring opinion that provided the fifth vote, found that evaluating the warning and accompanying break was only necessary if the police used the two-stage interrogation intentionally. Justice Kennedy wrote, "The admissibility of postwarning statements should continue to be governed by Elstad's principles unless the deliberate two-step strategy is employed. Then, the postwarning statements must be excluded unless curative measures are taken before they were made."


[Scarborough v. Principi (2004) — Rehnquist Court (1994-2005) — Facts]
Randall Scarborough won a case against the Department of Veterans Affairs. He then applied for attorney's fees to the U.S. Veterans' Court under the federal Equal Access to Justice Act (EAJA). Under the EAJA, the government must pay attorney's fees to anyone who wins against the federal government in litigation unless the government can show that its position was "substantially justified." However, Scarborough's attorney submitted an incomplete application, neglecting to assert that the government's position was not substantially justified. Though he amended and resubmitted it, he did so after the 30-day filing deadline. The Veterans' Court dismissed the application for "lack of subject matter jurisdiction" - that is, because it was not filed in its complete form within the 30-day deadline. The Court of Appeals for the Federal Circuit affirmed.


[Scarborough v. Principi (2004) — Rehnquist Court (1994-2005) — Conclusion]
Yes. In a 7-to-2 opinion written by Justice Ruth Bader Ginsburg, the Court held that the statement on the application that the government's position had not been "substantially justified" was merely procedural. There was no need to prove the assertion - the applicant merely had to make the claim to shift the burden of proof to the government. Because the government was not harmed by the initial omission of the statement - filing the claim made it obvious that the applicant thought the government's position was not substantially justified, even without the specific statement - Scarborough should be able to amend his application even after the 30-day filing period had passed.


[Grupo Dataflux v. Atlas Global Group, L.P. (2004) — Rehnquist Court (1994-2005) — Facts]
Atlas Global Group was a limited partnership company created under Texas law. They filed a suit in federal court against Grupo Dataflux, a Mexican corporation. The suit dealt with a state law, but Atlas filed the case in federal court because, it claimed, the court had "diversity jurisdiction" (when a case involves citizens of two different states, or an American citizen and a foreign citizen, it is heard in federal court). However, at the time the case was filed, two of Atlas's partners were Mexican citizens (they left the partnership before the trial began). After the case was decided, but before the judgment was announced, Grupo Dataflux filed a motion to dismiss the case because the court did not have diversity jurisdiction. The judge granted the motion, finding that Atlas was a Mexican "citizen" at the time of filing because of the citizenship of its partners, and that the federal courts therefore did not have jurisdiction. On appeal, Atlas argued that even if the necessary diversity had not been present at the time of filing, it was present before the trial began and the court should therefore ignore the error under an exception for cases that have already been decided. A Fifth Circuit Court of Appeals panel agreed, reversing the decision.


[Grupo Dataflux v. Atlas Global Group, L.P. (2004) — Rehnquist Court (1994-2005) — Conclusion]
No. In a 5-to-4 decision written by Justice Antonin Scalia, the Court ruled that allowing diversity jurisdiction to change after a case is filed would create uncertainty and expensive litigation that dealt with jurisdiction rather than the merits of the case. "Uncertainty regarding the question of jurisdiction is particularly undesirable, and collateral litigation on the point particularly wasteful," wrote Justice Scalia. "The stability provided by our time tested rule (of requiring diversity at the time of filing) weighs heavily against the approval of any new deviation."


[Muhammad v. Close (2004) — Rehnquist Court (1994-2005) — Facts]
Prison officials sentenced Muhammad, a state prisoner, to seven days of special detention and 30 days of restricted privileges for insolence toward Close, a prison guard. Muhammad filed suit with a magistrate judge under section 1983 of the Civil Rights Act of 1871, seeking $10,000 in damages. Muhammad alleged Close had charged him with threatening behavior in retaliation for other proceedings against Close. Muhammad did not challenge his insolence conviction or punishment. The magistrate judge ruled that Muhammad lacked evidence proving Close acted in retaliation. The U.S. District Court agreed.
The U.S. Court of Appeals affirmed the ruling for a different reason, citing the U.S. Supreme Court decision Heck v. Humphrey (1994). In Heck the Court held that when a prisoner seeks damages in a case that questions his sentence, the prisoner must first have successfully challenged the sentence itself or the conviction itself. The Court of Appeals held that because Muhammad's damages case questioned his sentence, he must first successfully appeal the sentence itself. Going further the Court of Appeals held that Heck applies to all challenges to prison disciplinary proceedings.


[Muhammad v. Close (2004) — Rehnquist Court (1994-2005) — Conclusion]
No. In a unanimous per curiam opinion, the Court ruled that prisoners - whose suits do not question their sentences - do not need to successfully challenge those sentences before challenging prison disciplinary proceedings. The Court rejected the argument that Heck necessarily requires successful sentence appeals before any challenges can be made to prison disciplinary proceedings. Muhammad's suit sought damages for prison disciplinary proceedings but in no way challenged his sentence.


[Rasul v. Bush (2004) — Rehnquist Court (1994-2005) — Facts]
Two Australians and 12 Kuwaitis were captured by the American military in Pakistan or Afghanistan during the United States' War on Terror. The captives were transported to the American military base in Guantanamo Bay, Cuba. When their families learned of the arrests, they filed suit in federal district court seeking a writ of habeas corpus that would declare the detention unconstitutional. They claimed that the government's decision to deny the men access to attorneys and to hold them indefinitely without access to a court violated the Fifth Amendment's Due Process Clause. The government countered that the federal courts had no jurisdiction to hear the case because the prisoners were not American citizens and were being held in territory over which the United States did not have sovereignty (the Guantanamo Bay base was leased from Cuba indefinitely in 1903, and Cuba retains "ultimate sovereignty").
The district court agreed with the government, dismissing the case because it found that it did not have jurisdiction. The US Court of Appeals for the District of Columbia affirmed the district court's decision.


[Rasul v. Bush (2004) — Rehnquist Court (1994-2005) — Conclusion]
Yes. In a 6-3 opinion written by Justice John Paul Stevens, the Court found that the degree of control exercised by the United States over the Guantanamo Bay base was sufficient to trigger the application of habeas corpus rights. Stevens, using a list of precedents stretching back to mid-17th Century English Common Law cases, found that the right to habeas corpus can be exercised in "all ... dominions under the sovereign's control." Because the United States exercised "complete jurisdiction and control" over the base, the fact that ultimate sovereignty remained with Cuba was irrelevant. Further, Stevens wrote that the right to habeas corpus is not dependent on citizenship status. The detainees were therefore free to bring suit challenging their detention as unconstitutional.


[Kontrick v. Ryan (2004) — Rehnquist Court (1994-2005) — Facts]
Andrew Kontrick filed for bankruptcy after he and his partner, Robert Ryan, dissolved their plastic surgery practice. Ryan notified the court that Kontrick owed him money before the 60-day filing deadline set by Bankruptcy Rule 4004. More than three months later (after the deadline for filing had passed) Ryan filed an amended complaint charging that Kontrick was diverting paychecks into his wife's account so that he wouldn't have to pay Ryan. Ryan's attorneys claimed that they were not making a new claim - the diversion had been alluded to in other court documents - but that they were merely refocusing the judge's attention. Furthermore, they argued that the deadline for filing could be - and had been - waived by the judge. Kontrick's attorneys, on the other hand, argued that the amended complaint was a new filing and that the deadlines for filing could not be waived. The bankruptcy court ruled for Ryan. The district court and a Seventh Circuit Court of Appeals panel both affirmed, holding that the deadline was subject to waiver.


[Kontrick v. Ryan (2004) — Rehnquist Court (1994-2005) — Conclusion]
No. In a unanimous opinion delivered by Justice Ruth Bader Ginsburg, the Court held that Kontrick lost the right to invoke Rule 4004's time limitation because he did so after the bankruptcy court reached the merits of Ryan's objection. The Court rejected Kontrick's claim that Rule 4004 is "jurisdictional" and that it trumps other considerations whenever raised in proceedings.


[Maryland v. Pringle (2003) — Rehnquist Court (1994-2005) — Facts]
A police officer stopped a car for speeding, searched the car, and seized money from the glove compartment and cocaine from behind the back-seat armrest. The officer arrested the car's three occupants after they denied ownership of the drugs and money. A state court sentenced Pringle, the front-seat passenger, for possessing and intending to distribute cocaine after he signed a written confession. The state appellate court reversed the conviction, holding that the mere finding of cocaine in the back armrest when Pringle was in the front-seat of a car being driven by its owner was insufficient to establish probable cause for arrest for possession.


[Maryland v. Pringle (2003) — Rehnquist Court (1994-2005) — Conclusion]
No. In a unanimous opinion delivered by Chief Justice William Rehnquist, the Court ruled that because the officer had probable cause to arrest Pringle, the arrest did not violate the Fourth Amendment. The Court reasoned that "a reasonable officer could conclude that there was probable cause to believe that Pringle committed the crime of possession of cocaine."


[Johnson v. California (2004) — Rehnquist Court (1994-2005) — Facts]
Jay Shawn Johnson, on trial in California for murder, objected to the district attorney's use of peremptory challenges to eliminate all three black prospective jurors. Johnson argued the eliminations were based on race. The judge denied Johnson's motions and held that Johnson had failed to show a "strong likelihood" that the dismissals were race-based. The judge relied on People v. Wheeler, the 1978 case in which the California Supreme Court ruled that to establish a prima facie case of racial bias in peremptory challenges, the objector had to show "strong likelihood" that the challenges were race- based. The jury found Johnson guilty of second-degree murder.
Johnson appealed and argued that the "strong likelihood" standard in Wheeler was at odds with the 'reasonable inference" standard the U.S. Supreme Court set in Batson v. Kentucky (1986). The appeals court agreed and reversed Johnson's conviction. The California Supreme Court reversed and ruled that the two standards were the same.


[Johnson v. California (2004) — Rehnquist Court (1994-2005) — Conclusion]
In a per curiam opinion, the Court ruled it lacked jurisdiction and dismissed the case.


[Alaska Dept. of Environmental Conserv. v. EPA (2004) — Rehnquist Court (1994-2005) — Facts]
Under the Clean Air Act, state agencies must determine the best way to prevent air pollution in areas that have met national clean air standards. In part, they must require that polluting companies use the "best available control technology" to limit pollution whenever they construct new facilities. In 1998, Teck Cominco Alaska, a mining company, requested a permit to build an additional generator at one of its mines. The Alaska Department of Environmental Conservation (ADEC) issued the permit, which called for Cominco to use "Low NOx" technology on all its generators, not just the new one. The Environmental Protection Agency (EPA), however, stepped in, arguing that a better technology was available. ADEC appealed the EPA's decision to the Ninth Circuit Court of Appeals, arguing that the EPA did not have the right to interfere with the state agency's decision. The Ninth Circuit sided with the EPA.


[Alaska Dept. of Environmental Conserv. v. EPA (2004) — Rehnquist Court (1994-2005) — Conclusion]
Yes. In a 5-4 opinion delivered by Justice Ruth Bader Ginsburg, the Court held that the Clean Air Act authorized the EPA to bar the construction of the polluting facility in Alaska. Though Alaska determined the facility's use of "Low NOx" met the act's requirement that facilities use "best available control technology," the EPA was reasonable to reject this claim. Justice Anthony Kennedy delivered a dissent joined by Justices Clarence Thomas, Antonin Scalia and Chief Justice William Rehnquist.


[Engine Manufacturers' Association v. South Coast Air Quality Management District (2004) — Rehnquist Court (1994-2005) — Facts]
The Engine Manufacturers Association (EMA) sued the South Coast Air Quality Management District (SCAQMD) - established under the California Health and Safety Code - in federal district court. The EMA alleged that the Clean Air Act (CAA) preempted SCAQMD's "fleet rules" - rules that required new commercial vehicles to meet specific emissions standards - and that the rules were therefore illegal. The EMA pointed to section 209 of the act, which prohibits states from enforcing "any standard relating to the control of emissions from new motor vehicles." Reasoning that the regulations affected the standards at which engines could be sold, not the standards to which they must be manufactured, and finding that Congress's purpose was to protect manufactures from "having to build engines in compliance with a multiplicity of standards," the district court ruled that the CAA did not preempt California's fleet rules. The Ninth Circuit Court of Appeals affirmed.


[Engine Manufacturers' Association v. South Coast Air Quality Management District (2004) — Rehnquist Court (1994-2005) — Conclusion]
Probably. In an 8-to-1 opinion written by Justice Antonin Scalia, the Court ruled that distinguishing between rules governing the standards to which engines must be made and the standards at which they may be sold was unreasonable. Justice Scalia wrote, "A command ... that certain purchasers may buy only vehicles with particular emission characteristics is as much an 'attempt to enforce' a 'standard' as a command ... that a certain percentage of a manufacturer's sales volume must consist of such vehicles." Justice Scalia reserved judgment on the specific regulations at issue in the case, however, sending the case back to the district court for further proceedings consistent with the holding that regulating the standards engines must meet to be sold is no different from regulating the standards at which they must be manufactured.


[Hibbs v. Winn (2004) — Rehnquist Court (1994-2005) — Facts]
Several Arizona residents challenged in federal district court an Arizona statute that allows tax credits for money spent toward parochial schools. They alleged that the statute violates the religious establishment clause of the U.S. Constitution's First Amendment.
The district court dismissed the case and ruled that it lacked jurisdiction for two reasons: First, the federal Tax Injunction Act (TIA) prohibits federal district courts from ruling on the "assessment, levy or collection of any tax under state law where a plain, speedy and efficient remedy may be had in the courts of such state." And second, the court pointed to the comity doctrine - that is, the deference that federal courts should generally give to state tax laws. The Ninth Circuit Court of Appeals reversed, ruling that neither the TIA nor comity place the case outside federal jurisdiction. The court reasoned that the TIA was inapplicable because invalidating a tax credit would not harm Arizona's ability to raise revenue.


[Hibbs v. Winn (2004) — Rehnquist Court (1994-2005) — Conclusion]
No. In a 5-to-4 decision written by Justice Ruth Bader Ginsburg, the Court held that the intention of the Tax Injunction Act (TIA) was to prevent taxpayers from trying to avoid their state taxes through federal litigation. TIA was not intended, however, to prevent all federal interference with state taxation. Justice Ginsburg wrote, "Third-party suits not seeking to stop the collection of a tax imposed on plaintiffs were outside Congress' purview. ... Nowhere does the [legislative] history announce a sweeping congressional direction to prevent federal-court interference with all aspects of state tax administration." (emphasis original) Establishment clause challenges to state tax exemptions for religious eduction could therefore be challenged without violating TIA.


[Household Credit Services, Inc. v. Pfennig (2004) — Rehnquist Court (1994-2005) — Facts]
Sharon Pfennig went over her $2000 credit limit. The company that issued Pfennig her credit card, Household Credit Services, Inc., charged her a fee of $29 for each month that her balance remained over $2000. This fee was listed in the "Purchases" category on her monthly statement rather than as a "finance charge." Under the Truth in Lending Act (TILA), any charges "incident to the extension of credit" must be listed separately as "finance charges."
Household Credit Services chose not to list the over-limit fee as a "finance charge," however, based on the Federal Reserve Board's definition of the term, which explicitly excludes "charges ... for exceeding a credit limit." Pfenning countered that the Board's definition was an unreasonable interpretation of TILA's plain language and should therefore be disregarded.
The district court sided with Household Credit Services, finding that the the Federal Reserve Board had properly exercised its authority under TILA to define the term, that the definition was a reasonable interpretation of TILA, and that the credit company was therefore justified in relying on its definition. The Sixth Circuit Court of Appeals reversed.


[Household Credit Services, Inc. v. Pfennig (2004) — Rehnquist Court (1994-2005) — Conclusion]
Yes. In a unanimous decision written by Justice Clarence Thomas, the Court found that the Board's definition of "finance charge" was reasonable under the language of TILA. Because neither side challenged the authority of the Board to interpret the act (Pfennig just challenged its end result as unreasonable), under Chevron USA Inc. v. Natural Resources Defense Council, 467 U.S. 837, the Court would have to find that the Board's regulation was clearly contrary to the unambiguous intent of Congress in order to overturn it. Finding that Congress's intent with respect to over-limit fees was ambiguous, Justice Thomas wrote that the regulation was entitled to deference and the credit company's reliance on it could therefore not be punished.


[United States v. Galletti (2004) — Rehnquist Court (1994-2005) — Facts]
Abel Galletti and his wife, along with another couple, the Briguglios, formed a business partnership. The partnership underpaid its federal employment taxes, and the IRS assessed the unpaid taxes against the partnership (meaning the partnership would be forced to pay the taxes). According to the Internal Revenue Code, if a tax debt is assessed within three years after the return was filed, the government has 10 additional years to collected the money.
More than three years later, the Gallettis and the Briguglios separately filed for bankruptcy. The IRS made a claim in bankruptcy court against the two couples for the taxes assessed against the partnership. The couples objected, arguing that because the partners themselves had not been separately assessed, the statute of limitations had not been extended to the partners.
The bankruptcy court ruled against the IRS, holding that the IRS must assess tax claims against individual partners, not just the partnership, in order to later collect on those claims from the individuals. The district court and a Ninth Circuit Court of Appeals panel both affirmed the decision.


[United States v. Galletti (2004) — Rehnquist Court (1994-2005) — Conclusion]
No. In a unanimous opinion delivered by Justice Clarence Thomas, the Court held that the IRS' assessment against the partnership was sufficient to extend the statute of limitations by 10 years to collect the money from the partners themselves. The Internal Revenue Code does not require the government to make separate assessments of a single debt against people or entities secondarily liable in order to extend the statute of limitations. The statute of limitations extension is attached to the debt - without reference to the entities who owe the debt.


[United States v. Banks (2003) — Rehnquist Court (1994-2005) — Facts]
On July 15, 1998 police officers, with a warrant, knocked on the door of suspected drug dealer Lashawn Banks. They waited between 15 and 20 seconds, and when Banks did not come to the door they smashed it open with a battering ram. Banks was arrested but, before his trial, he filed a motion to suppress the evidence found in his apartment because, he claimed, the forced entry had been unlawful. When the request was denied, he pled guilty, but eventually attempted to retract his guilty plea on the advice of a new attorney. The new attorney, Randall Roske, argued that the search was unconstitutional because officers did not wait long enough before breaking down the door, and had no evidence that waiting longer would have had negative consequences. A Ninth Circuit Court of Appeals agreed, ruling the search unconstitutional and suppressing the evidence found during it.


[United States v. Banks (2003) — Rehnquist Court (1994-2005) — Conclusion]
The Court unanimously held that 15 to 20 seconds was a reasonable period for police to wait before entering by force when they were investigating drug charges because waiting any longer was likely to result in the destruction of evidence. Justice David Souter, writing for the court, stated that "while we agree... that this call is a close one, we think that after 15 to 20 seconds without a response, police could fairly suspect that cocaine would be gone if they were reticent any longer."


[National Archives and Records Administration v. Favish (2004) — Rehnquist Court (1994-2005) — Facts]
Vincent Foster, a high-ranking White House lawyer involved in the investigation of possible fraud by the Clinton family in the Whitewater real estate venture, was found dead in a Virginia park. Two government investigations subsequently found that the death had been a suicide. Allan Favish questioned the findings of the government investigations, claiming that they were part of a government cover-up of murder. Under the Freedom of Information Act, Favish requested access to 150 photos of Foster's body in the park and during the autopsy. He later reduced his request to 129 photos.
The government initially denied him access to all the photos, but eventually gave him access to 118 of them. It withheld the rest, arguing that the privacy interest of Foster's family members in relation to Foster's death trumped the public interest served by providing Favish access to the photos. The government stated that the photos were very graphic and that releasing them would upset the family. Favish countered by arguing that the family did not have a relevant privacy interest; the only person whose privacy interests would be violated by the release of the photos was Foster, Favish argued, and Foster's death had rendered him incapable of exercising that interest.
After a series of appeals in which a Ninth Circuit panel held that the Foster family's right to privacy was relevant to the case but that the district court must look at the specific photos in order to weigh the privacy rights against Favish's right to access government information, the Ninth Circuit eventually decided that Favish should be given access to all but four of the photos. The government, joined by the Foster family, appealed the decision to the Supreme Court.


[National Archives and Records Administration v. Favish (2004) — Rehnquist Court (1994-2005) — Conclusion]
Yes. In a unanimous opinion delivered by Justice Anthony Kennedy, the Court held that the Foster family's interest in privacy outweighed the public interest in seeing pictures from Vincent Foster's death scene. The public interest could only trump privacy interests if Favish could present evidence that the government might have acted improperly. Favish failed to do so. The Court acknowledged that citizens seeking access to documents under the Freedom of Information Act normally need not explain why they seek the information. The act, however, exempts from disclosure records that would present an unwarranted invasion of privacy. In ruling that the act protected the privacy of the Foster family, the Court rejected Favish's argument that the act only protected Vincent Foster's privacy (an interest that Favish argued died with Foster).


[Thornton v. United States (2004) — Rehnquist Court (1994-2005) — Facts]
Marcus Thornton was stopped after getting out of his vehicle by a police officer who had noticed that the license plate on Thornton's Lincoln Town Car belonged to a Chevy two-door car. During his conversation with Thornton, the officer asked if he could search him. During the search he found two bags of drugs. The officer arrested Thornton, then searched his vehicle (which Thornton had already exited by the time the police officer spoke with him, though the officer had seen him exit it). In the vehicle the officer found a gun.
Thornton was convicted of drug and firearms offenses. On appeal, he moved to have the gun dismissed as evidence because, he claimed, it had been found as the result of an unconstitutional search. He argued that the officer had contacted him after he had left the vehicle and that the search therefore did not fall within the "search incident to arrest" exception to the Fourth Amendment warrant requirement (the exception allows police to search the person being arrested and the area "within his immediate control").
A Fourth Circuit Court of Appeals panel rejected his argument, holding that requiring officers to signal their intent to arrest a person before he exited his vehicle would be dangerous because it would give him a chance to get any weapons in the vehicle or to use the vehicle to get away or run over the officers.


[Thornton v. United States (2004) — Rehnquist Court (1994-2005) — Conclusion]
Yes. In a 7-to-2 decision, the Court ruled that forcing officers to decide whether a suspect had noticed them before exiting the car (with the understanding that only if he had could the car be searched) would be too subjective and leave officers uncertain of whether they could perform searches. Further, it found that weapons or contraband inside a vehicle could still be easily accessed by someone who had just exited it, providing the same reason for searching the vehicle that was present in cases where suspects were arrested while still inside it (that is, the possibility that illegal material would be destroyed or officers attacked with concealed weapons). Chief Justice Rehnquist, in the majority opinion, wrote, "Once an officer determines there is probable cause to make an arrest, it is reasonable to allow officers to ensure their safety and to preserve evidence by searching the entire passenger compartment."


[Vieth v. Jubelirer (2004) — Rehnquist Court (1994-2005) — Facts]
After the 2000 census reduced the size of the Pennsylvania Congressional delegation by two members, the Republican-controlled state legislature passed a redistricting plan that clearly benefitted Republican candidates. Several members of the Democratic party sued in federal court, claiming that the plan was unconstitutional because it violated the one-person, one-vote principle of Article I, Section 2 of Constitution, the Equal Protection clause, the Privileges and Immunities clause, and the freedom of association.
The district court dismissed all but the Article I, Section 2 claim. It held that the voters bringing the suit had not proved that they would be denied representation, only that they would be represented by Republican officials. Because the plaintiffs (those bringing the suit) were not denied the right to vote, to be placed on the ballot box, to associate as a party, or to express their political opinions, their political discrimination claims failed.
However, the court found the act unconstitutional because it created districts with different numbers of voters, thereby violating the one-person, one-vote principle. Because the plaintiffs had shown that it was possible to create districts with smaller differences, and because the defendants had failed to justify the disparities resulting under their plan, it was therefore unconstitutional.


[Vieth v. Jubelirer (2004) — Rehnquist Court (1994-2005) — Conclusion]
In a split decision that had no majority opinion, the Court decided not to intervene in this case because no appropriate judicial solution could be found. Justice Antonin Scalia, for a four-member plurality, wrote that the Court should declare all claims related to political (but not racial) gerrymandering nonjusticiable, meaning that courts could not hear them. Because no court had been able to find an appropriate remedy to political gerrymandering claims in the 18 years since the Court decided Davis v. Bandemer, 478 U.S. 109, which had held that such a remedy had not been found yet but might exist, Scalia wrote that it was time to recognize that the solution simply did not exist.
Justice Anthony Kennedy, however, wrote in his concurring opinion (which provided the deciding fifth vote for the judgment) that the Court should rule narrowly in this case that no appropriate judicial solution could be found, but not give up on finding one eventually.


[BedRoc Limited, LLC v. United States (2004) — Rehnquist Court (1994-2005) — Facts]
BedRoc Ltd. and Western Elite, Inc., own property in Nevada patented under the federal Pittman Act (1919). (The act was repealed in 1964.) The act authorized the issuance of patents to desert lands in Nevada to individuals who successfully developed underground water resources. However, the act specified that patents reserve to the United States "all the coal and other valuable minerals" in the patented lands. When the previous owner of BedRoc and Western Elite's land extracted and sold commercially valuable sand and gravel from the lands without a federal mineral contract, the Bureau of Land Management (BLM) gave notification that the mining was illegal under federal law. The owner lost an appeal to the Interior Board of Land Appeals (IBLA). Once BedRoc and Western Elite owned the land, they filed suit in U.S. district court, arguing that the Pittman Act's "valuable minerals" provision did not include valuable sand and gravel. The district court rejected the companies' argument and sided with the United States. The Ninth Circuit Court of Appeals affirmed.


[BedRoc Limited, LLC v. United States (2004) — Rehnquist Court (1994-2005) — Conclusion]
No. In an plurality opinion written by Chief Justice William Rehnquist and joined by three other Justices, the Court ruled that because sand and gravel were not commercially valuable in 1919 when the Pittman Act was passed, they were not "valuable minerals" covered under the Act. Although the Court had interpreted "minerals" expansively in the past, the Court held that the adjective "valuable" limited the term sufficiently to exclude sand and gravel. The Court emphasized that since the plain text of the statute was clear, there was no need to delve into the legislative history of the Act. Justice Thomas, joined by Justice Breyer, wrote a separate concurring opinion in which he agreed that sand and gravel were not "valuable minerals" under the Act, but disputed the plurality's reliance on the word "valuable." Justice Stevens, joined by Justices Souter and Ginsburg, dissented. The dissent argued that the legislative history of the Pittman Act indicated that "valuable minerals" should be interpreted broadly to include sand and gravel.


[Blakely v. Washington (2004) — Rehnquist Court (1994-2005) — Facts]
Blakely pleaded guilty to the kidnapping of his estranged wife and the facts admitted in his plea supported a maximum sentence of 53 months. Washington state law allows a judge to impose a sentence above the standard range if he finds "substantial and compelling reasons" for doing so that were not computed into the standard range sentence. The judge in this case imposed an "exceptional" sentence of 90 months after determining Blakely had acted with "deliberate cruelty."
Blakely appealed, arguing that this sentencing procedure deprived him of his federal Sixth Amendment right to have a jury determine beyond a reasonable doubt all facts legally essential to his sentence. A state appellate court affirmed the sentence and the state supreme court denied review.


[Blakely v. Washington (2004) — Rehnquist Court (1994-2005) — Conclusion]
In a 5-4 decision delivered by Justice Antonin Scalia, the Court held that an exceptional sentence increase based on the judge's determination that Blakely had acted with "deliberate cruelty" violated Blakely's Sixth Amendment right to trial by jury. Citing its decision in Apprendi v. New Jersey, the Court ruled that facts increasing the penalty for a crime beyond the prescribed statutory maximum must be submitted to a jury and proved beyond a reasonable doubt. Dissents by Justice Sandra Day O'Connor, Anthony Kennedy and Justice Stephen Breyer argued the ruling will diminish legislatures' ability to set uniform sentencing guidelines.


[Nixon v. Missouri Municipal League (2004) — Rehnquist Court (1994-2005) — Facts]
The Telecommunications Act of 1996 allowed federal preemption of state and local regulations "prohibiting the ability of any entity" to provide telecommunications services. Based on this act, a group of local governments in Missouri (the Missouri Municipal League) asked the Federal Communications Commission (FCC) to nullify a state law that prevented municipalities from providing telecommunications services. Missouri argued that municipal governments were not separate entities but merely subsections of the state government and that the state could therefore restrict their authority. The FCC agreed with the state, refusing to nullify the law.
The Municipal League appealed, and an Eighth Circuit Court of Appeals panel reversed the decision. The panel held the words "any entity" were intentionally broad and that a proper understanding of them would include municipal governments. The state could therefore not regulate attempts by municipalities to provide telecommunications services. The FCC, along with the state of Missouri and Southwestern Bell Telephone Company, appealed the decision to the Supreme Court.


[Nixon v. Missouri Municipal League (2004) — Rehnquist Court (1994-2005) — Conclusion]
Yes. In an 8-1 opinion delivered by Justice David Souter, the Court held that the act allows states to prevent municipalities from providing telecommunications services. The act only allows federal preemption of state and local efforts to prevent "any private entity" from providing telecommunications services. The Court concluded it would be "unlikely" and "strange" if Congress intended to free municipal governments from state regulations because municipal governments rely on state governments for authority to regulate.


[Iowa v. Tovar (2004) — Rehnquist Court (1994-2005) — Facts]
Felipe E. Tovar was charged with drunk-driving in Iowa three times in four years. Tovar pleaded guilty both times and waived his right to an attorney the first time. The third time, because Iowa law increases sentencing for successive drunk-driving, Tovar faced up to five years in prison. Tovar argued that his first conviction was an invalid waiver of his 6th Amendment right to counsel and should not increase his third sentence. The waiver was invalid, Tovar argued, because the judge did not warn him of the consequences of entering a guilty plea without an attorney. The Iowa district court rejected Tovar's argument and sentenced him to 30 days in jail. The court of appeals affirmed. The Iowa Supreme Court reversed.


[Iowa v. Tovar (2004) — Rehnquist Court (1994-2005) — Conclusion]
In a unanimous opinion delivered by Justice Ruth Bader Ginsburg, the Court held that Tovar's Sixth Amendment right to counsel was not violated. In a case like Tovar's, the Sixth Amendment requires the judge to inform the accused of the charges against him, of his right to counsel regarding his plea, and of the range of punishments he faces if he pleads guilty. The Court decided Tovar's trial court judge satisfied these requirements and that Tovar's waiver of his right to counsel was "knowing, voluntary, and intelligent."


[Ashcroft v. American Civil Liberties Union (2004) — Rehnquist Court (1994-2005) — Facts]
Congress passed the Child Online Protection Act (COPA) to prevent minors from accessing pornography online. The American Civil Liberties Union (ACLU) and online publishers sued in federal court to prevent enforcement of the act, arguing that it violated the Free Speech clause of the First Amendment. The District Court agreed. On appeal, a Third Circuit Court of Appeals panel affirmed, holding that because the act used "community standards" to decide which material was harmful to minors, it would prohibit material that was felt offensive in the most "puritanical" communities from being displayed in more "tolerant" ones.
On appeal, the Supreme Court ruled that the "community standards" provision alone did not make the act unconstitutional and sent the case back to the Third Circuit for further evaluation.
The Third Circuit again prohibited implementation of the act, holding that it was likely to fail the "strict scrutiny" test because it was not narrowly tailored - that is, it prevented online publishers from publishing some material that adults had a right to access - and because it did not use the least restrictive means possible to protect children (the court found that blocking software installed on home computers by parents would do as good a job without preventing free speech). For similar reasons, the panel found that the act was unconstitutionally "overbroad" - that is, it applied to too much protected material.


[Ashcroft v. American Civil Liberties Union (2004) — Rehnquist Court (1994-2005) — Conclusion]
Yes. In an interesting 5-to-4 vote, with Justices Kennedy, Stevens, Souter, Thomas and Ginsburg on one side and Chief Justice Rehnquist and Justices Scalia, Breyer and O'Connor on the other, the Court found that Congress had not yet met its burden to show that the COPA requirements were more effective than other methods of preventing minors. Justice Anthony Kennedy, in the majority opinion, wrote that the district court's injunction "was not an abuse of discretion, because on this record there are a number of plausible, less restrictive alternatives to the statute." The majority also emphasized that barring the statute's enforcement during the trial would be less harmful than allowing it, because allowing it would be likely to prevent online publishers from publishing certain material.


[General Dynamics Land Systems Inc. v. Cline (2004) — Rehnquist Court (1994-2005) — Facts]
General Dynamics Land Systems renegotiated its union contract to provide full health care benefits only to retirees who were more than 50 years old by a July 1, 1997, deadline. Union member Dennis Cline fell two years short of 50 at the time of the deadline and was excluded permanently from receiving health benefits.
Cline - along with 196 other 40-to 49-year-old employees - filed suit against General Dynamics under the Age Discrimination in Employment Act of 1967 (ADEA). ADEA protects workers over 40 from age discrimination. Since the contract excluded workers between the ages of 40 and 49, Cline alleged that providing benefits only to retirees 50 and up was illegal age discrimination.
A U.S. district court in Ohio rejected Cline's claims. The court ruled that the ADEA does not recognize claims for "reverse discrimination" or preferential treatment for older people within the same over-40 class. Cline appealed and the U.S. Court of Appeals for the Sixth Circuit reversed. The court ruled that General Dynamics was guilty of plain age discrimination, since the ADEA protects all persons over 40 from age discrimination by their employers.


[General Dynamics Land Systems Inc. v. Cline (2004) — Rehnquist Court (1994-2005) — Conclusion]
No. Justice David H. Souter delivered the Court's 6-3 opinion that the Age Discrimination in Employment Act's "text, structure, purpose, history, and relationship to other federal statutes show that the statute does not mean to stop an employer from favoring an older employee over a younger one." The Court cited a long-held understanding of the "ADEA as a remedy for unfair preference based on relative youth, leaving complaints of the relatively young outside the statutory concern." The Court also noted the findings section of the act included no evidence of younger workers being discriminated against in favor of older workers. Further "[i]f Congress had been worrying about protection the younger against the older, it would not likely have ignored everyone under 40."


[Dretke v. Haley (2004) — Rehnquist Court (1994-2005) — Facts]
Haley was convicted in Texas state courts of a felony theft and sentenced as a habitual felony offender (extending his sentence). After a failed appeal to the Texas appellate court, Haley filed a state habeas application in the trial court, arguing that his past crimes did not qualify him as a habitual offender and that his attorney had provided ineffective counsel when he failed to object to the extended sentence. The court dismissed his claims on procedural grounds, because he had not raised the issue during his trial and therefore could not raise it in the habeas petition. The Texas Court of Criminal Appeals denied his habeas application based on the trial court's findings.
Haley then filed for habeas corpus relief in federal district court. Pointing to the procedural-default doctrine, Texas argued that Haley's claim was procedurally barred from federal habeas review. Under the procedural-default doctrine, federal courts cannot grant habeas relief if the last state court rejected the appeal for procedural violations of state law; the only exception is if the petitioner is actually innocent.
The district court held that Haley showed he was "actually innocent" of earlier violations on which his sentence enhancement was based. The court ruled that Haley's sentence was therefore improperly extended. It never reached his ineffective assistance of counsel claim, having already found grounds for overturning the extended sentence. The U.S. Fifth Circuit Court of Appeals affirmed, rejecting Texas's argument that the actual-innocence exception applies only to cases involving capital offenses.


[Dretke v. Haley (2004) — Rehnquist Court (1994-2005) — Conclusion]
The Court declined to answer the question presented, ruling instead that the district court should have first considered the ineffective assistance of counsel claim before reaching the question of whether the "actual innocence" exception applies to non-capital cases. Justice Sandra Day O'Connor, for a seven-member majority, wrote that the ineffective assistance of counsel claim would accomplish the same thing - the reduction of the sentence - without burdening the state with the need to prove the existence of all prior convictions beyond a reasonable doubt.


[United States v. Dominguez Benitez (2004) — Rehnquist Court (1994-2005) — Facts]
Carlos Dominguez Benitez confessed to selling drugs to an informant. He made a plea agreement with the government in which he would plead guilty to conspiracy to sell drugs, which normally carried a 10-year minimum sentence. However, the government agreed to ask the judge to reduce the sentence below that minimum. The plea agreement also said that, if the judge did not agree to the government's request to lower the sentence, Dominguez could not withdraw his guilty plea. During discussions of the plea, the judge failed to mention the fact that it prohibited him from withdrawing his plea (the written statement, which did contain the fact, was read to him at another time). When the judge ruled that he could not lower the sentence, Dominguez appealed. He argued that the judge's failure to tell him that he would be unable to withdraw his appeal was a "plain error" under Federal Rule of Criminal Procedure 52 and therefore required reversal. The prosecutors countered that, in order to show that the judge had made a "plain error" Dominguez would need to show not just that he had made a mistake but also that it was reasonably likely that, without the error, Dominguez would not have pled guilty. A Ninth Circuit Court of Appeals rejected that argument, siding with Dominguez to reverse the decision.


[United States v. Dominguez Benitez (2004) — Rehnquist Court (1994-2005) — Conclusion]
Yes. In a unanimous decision, the Court ruled that the judge's error most likely had no effect on Dominguez's decision to plead guilty, because he had already confessed to the crime and had little chance of winning at trial. Under Rule 52, a plain error is an "error that affects substantial rights." Because the error did not harm Dominguez - he would likely have pled guilty anyway - it was not a reversible plain error. Justice David H. Souter, writing for 8 members of the Court (Justice Antonin Scalia wrote a separate opinion concurring in judgment), wrote, "The point of the question is not to second-guess a defendant's actual decision... The point, rather, is to enquire whether the omitted warning would have made the difference required by the standard of reasonable probability; it is hard to see here how the warning could have had an effect on Dominguez's assessment of his strategic position."


[Nelson v. Campbell (2004) — Rehnquist Court (1994-2005) — Facts]
David Nelson was sentenced to death for murder and scheduled for execution in 1997. A series of appeals and habeas petitions in federal court delayed the execution until 2002, when an 11th Circuit Court of Appeals panel unanimously rejected a claim dealing with the alleged violation of his Sixth Amendment right to an attorney. After the final appeal was rejected, Nelson was rescheduled for execution on October 9, 2003.
Nelson filed petition in federal district court alleging that the method of execution proposed by Alabama violated his Eighth Amendment protection against cruel and unusual punishment. Alabama had notified Nelson that, because of damage done to his veins by previous intravenous drug abuse, the execution procedure might require corrections officers to cut through muscles and fat in his arm to get access to a vein that could carry the toxins. He claimed that this was an inhumane method of execution and should therefore be barred. Further, he argued that the petition was not an appeal of his conviction or sentence (appeals of both were prohibited by U.S. Code Title 28, Section 2254, a federal law designed to limit the number of habeas corpus appeals by death row inmates) but rather a freestanding lawsuit challenging the constitutionality of the proposed execution procedure. Alabama countered that Nelson's appeal was intended only to prolong his life through procedural delays, exactly what the federal law was designed to prevent, and should therefore be thrown out.
The federal district court agreed with Alabama, holding that Nelson's appeal dealt not just with the procedure but with the sentence itself. It was therefore functionally equivalent to a habeas corpus petition, which was barred by Section 2254. A divided 11th Circuit Court of Appeals panel affirmed the decision. After the 11th Circuit declined to rehear the case as a whole (en banc), the U.S. Supreme Court issued a stay of execution and then accepted the case for appeal.


[Nelson v. Campbell (2004) — Rehnquist Court (1994-2005) — Conclusion]
No. In an opinion by Justice Sandra Day O'Connor, the Court ruled unanimously that Nelson's suit dealt only with the proposed method of execution, not with his conviction or sentence, and was therefore different from a habeas corpus appeal. Nelson had a right to challenge the necessity of the procedure for his execution using the same legal approach he would have used to challenge the conditions of his prison. However, the Court declined to rule on whether the execution would be constitutional if the district court found that cutting through was indeed necessary, leaving that question for a case in which necessity had already been determined.


[United States Postal Service v. Flamingo Industries (USA), Limited (2004) — Rehnquist Court (1994-2005) — Facts]
When the U.S. Postal Service ended its mail-sack contract with Flamingo Industries, Flamingo sued in U.S. district court. Flamingo claimed the Postal Service declared a "fake emergency in the supply of mail sacks" so it could give no-bid contracts to cheaper foreign manufacturers without allowing U.S. companies to compete for them. Flamingo claimed this violated federal antitrust laws (among other charges). The district court dismissed the antitrust claim reasoning that the federal government is protected by sovereign immunity. The Ninth Circuit Court of Appeals reversed on the antitrust immunity count. It ruled that the 1970 Postal Reorganization Act waived the Postal Service's sovereign immunity and that it could be sued under federal antitrust laws as a "person."


[United States Postal Service v. Flamingo Industries (USA), Limited (2004) — Rehnquist Court (1994-2005) — Conclusion]
No. In a unanimous opinion delivered by Justice Anthony Kennedy, the Court held that the U.S. Postal Service cannot be sued under antitrust laws. The Court acknowledged the Postal Reorganization Act may waive the Postal Service's immunity from suit. However, federal antitrust laws (the Sherman Act, for example) do not allow the federal government - of which the Postal Service is a part - to be sued.


[Schriro v. Summerlin (2004) — Rehnquist Court (1994-2005) — Facts]
Warren Summerlin killed a loan collector with a hatchet in 1982 and was subsequently convicted of murder. He was sentenced to death by a state trial judge because of the heinous nature of the crime and his previous criminal history. He appealed the sentence, arguing that his attorney's romantic relationship with the prosecutor and the trial judge's proven use of marijuana had prevented him from receiving a fair trial, but the Arizona state courts rejected his appeals.
In June 2002, however, the U.S. Supreme Court issued its decision in Ring v. Arizona. The decision found that the Sixth Amendment right to jury trial meant that only juries, not judges, could sentence someone to death. The Ring decision gave Summerlin new hope. He appealed his conviction, arguing that the decision changed the substance of the law rather than just the procedure used to apply it, and that it should therefore be applied retroactively. The state countered that the change dealt only with who did the actual sentencing, not with the burden of proof, and was therefore only procedural. Because procedural changes are not applied retroactively under the Supreme Court's 1989 decision in Teague v. Lane, the state argued that Summerlin's sentence should be upheld. A divided Ninth Circuit Court of Appeals disagreed, siding instead with Summerlin and ordering the state to reopen his trial for re-sentencing.


[Schriro v. Summerlin (2004) — Rehnquist Court (1994-2005) — Conclusion]
No. In a 5-to-4 decision written by Justice Antonin Scalia, the Court held that the changed announced in Ring v. Arizona was merely procedural and therefore not retroactively applicable. Justice Scalia wrote, "[W]e give retroactive effect to only a small set of 'watershed rules of criminal procedure implementing the fundamental fairness and accuracy of the criminal proceeding.' That a new procedural rule is 'fundamental' in some abstract sense is not enough; the rule must be one 'without which the likelihood of an accurate conviction is seriously diminished." (Italics Scalia's, citation omitted). Because the Court could not confidently say that fact-finding by a judge rather than a jury seriously diminished accuracy, it could not apply its Ring ruling retroactively.


[Sosa v. Alvarez-Machain (2004) — Rehnquist Court (1994-2005) — Facts]
A U.S. Drug Enforcement Agency (DEA) special agent was kidnapped and murdered by a Mexican drug cartel in 1985. After an investigation, the DEA concluded that Humberto Alvarez-Machain had participated in the murder. A warrant for his arrest was issued by a federal district court. The DEA, however, was unable to convince Mexico to extradite Alvarez-Machain, so they hired several Mexican nationals to capture him and bring him back to the United States. His subsequent trial went all the way to the Supreme Court, which found that the government could try a person who had been forcibly abducted, but that the abduction itself might violate international and provide grounds for a civil suit. When the case went back to the district court for trial, Alvarez-Machain was found not guilty for lack of evidence.
Alvarez-Machain then filed a group of civil suits in federal court against the United States and the Mexican nationals who had captured him under the Federal Tort Claims Act (FTCA), which allows the federal government to be sued on tort claims, and the Alien Tort Statute (ATS), which permits suits against foreign citizens in American courts. The government argued that the FTCA applied only to claims arising from actions that took place in the United States and therefore did not cover Alvarez-Machain's case because the arrest took place in Mexico. Further, the government and the Mexican nationals argued that the ATS gave federal courts jurisdiction to hear tort claims against foreign citizens, but did not allow private individuals to bring those suits.
The federal district court disagreed with the government's contention that the FCTA claim did not apply, finding that plan to capture Alvarez-Machain was developed on U.S. soil and therefore covered. However, the court then ruled that the DEA had acted lawfully when they arrested Alvarez-Machain and was therefore not liable. On the ATS claims, the court rejected the argument that private individuals could not bring suit under the Act. The court found that Jose Francisco Sosa, one of the Mexican nationals who kidnapped Alvarez- Machain, had violated international law and was therefore liable under the ATS.
On appeal, the Ninth Circuit Court of Appeals overturned the district court's FTCA decision, ruling that the DEA could not authorize a citizen's arrest of Alvarez-Machain in another country and was therefore liable. The appeals court did, however, affirm the lower court's finding on the ATS claim, upholding the judgment against Sosa.


[Sosa v. Alvarez-Machain (2004) — Rehnquist Court (1994-2005) — Conclusion]
No and No. On the Alien Tort Statute claim, the Court unanimously ruled that the ATS did not create a separate ground of suit for violations of the law of nations. Instead, it was intended only to give courts jurisdiction over traditional law of nations cases - those involving ambassadors, for example, or piracy. Because Alvarez-Machain's claim did not fall into one of these traditional categories, it was not permitted by the ATS. On the FTCA claim, the Court ruled that the arrest had taken place outside the United States and therefore was exempted from the Act. It rejected Alvarez-Machain's argument that the exemption should not apply because the arrest had been planned in the United States.


[Doe v. Chao (2004) — Rehnquist Court (1994-2005) — Facts]
Seven coal miners sued the Department of Labor, claiming that the department had violated the federal Privacy Act and the right to privacy found in the federal Constitution by releasing their social security numbers (SSNs). The Privacy Act stated that any "person entitled to recovery" in a suit against the government for a violation of privacy would be awarded "actual damages sustained by the individual... but in no case... [would the damages awarded be] less than the sum of $1000" and attorney fees.
The miners argued that all they needed to prove in order to receive the $1000 minimum award was that the government had violated their privacy by releasing their SSNs; they did not need to prove that they had suffered actual damages. They maintained that the inclusion of "actual damages" in the act was only intended to limit the size of judgments awarded against the government, not to require proof of actual damage. The government argued that the act required the miners to prove that they had been harmed by the government's violation of their privacy.
The district court ruled in favor of the government. A divided Fourth Circuit Court of Appeals panel affirmed.


[Doe v. Chao (2004) — Rehnquist Court (1994-2005) — Conclusion]
Yes. Justice David Hackett Souter delivered the Court's 6-3 opinion that the Privacy Act requires plaintiffs prove actual damages to qualify for the minimum statutory award of $1000. The Court reasoned that "a straightforward textual analysis" of the Privacy Act shows that the statute guarantees the $1000 minimum for victims of willful Privacy Act violations only in relation to "actual damages sustained." Individuals subjected to an adverse effect - like the miners in this case - have "injury enough to open the courthouse door, but without more" have "no cause of action for damages under the Privacy Act."


[Raymond B. Yates, M. D., P. C. Profit Sharing Plan v. Hendon (2004) — Rehnquist Court (1994-2005) — Facts]
Raymond Yates owned a corporation with a profit sharing/pension plan. Yates borrowed money from the plan at a set interest. After he had repaid the loan to his profit sharing/pension plan, Yates' creditors filed an involuntary bankruptcy petition against him. They asked the bankruptcy court to set aside the repayment (interest included) and give it to the creditors.
Yates argued that under the Employee Retirement Income Security Act (ERISA), the interest from the profit sharing/pension plan could not be seized (except for loans to participants). The bankruptcy court disagreed and granted Yates' creditors' requests. The court reasoned that as the sole owner of the business, Yates was an employer under ERISA, not a "participant." The plan's prohibition on interest seizure therefore did not apply. A federal district court and a Sixth Circuit Court of Appeals panel both affirmed.


[Raymond B. Yates, M. D., P. C. Profit Sharing Plan v. Hendon (2004) — Rehnquist Court (1994-2005) — Conclusion]
Yes. Justice Ruth Bader Ginsburg delivered the Court's unanimous opinion holding that a business owner, such as Yates, qualifies as a "participant" in an ERISA pension plan. The Court reasoned that this was the intent of Congress and that the act's text verifies this. In a business in which an ERISA plan covers employees, the employer can essentially qualify as an employee and receive the plan's protections. In light of this, the Court sent Yates' bankruptcy issues to a lower court for resolution.