[Unknown Act > Facts]
Reginald Shepard pled guilty to violating the federal statute prohibiting a felon from possessing a gun. The government argued Shepard's sentence should be enhanced under the Armed Career Criminal Act (ACCA). The act added at least a 15-year sentence for any felon with three or more "violent felony" convictions who then possessed a gun. The government argued at least five of the 11 breaking and entering convictions on Shepard's record were violent felonies. The ACCA listed "burglary" as a violent felony and in Taylor v. U.S.(1990) the U.S. Supreme Court said the act meant "generic burglary" of a "building or other structure." However the Massachusetts burglary law Shepard pled guilty to breaking gave burglary a nongeneric definition - including entry into non-structures like cars. Shepard argued he had not pled guilty to generic robbery. The federal district court refused to sentence Shepard under the ACCA. The First Circuit Court of Appeals reversed and said the district court must consider evidence that showed it was obvious to Shepard that he pled guilty to generic robbery. The district court refused. The First Circuit reversed and sentenced Shepard under the ACCA.


[Unknown Act > Conclusion]
No. In a 5-3 opinion delivered by Justice David H. Souter, the Court held that while a guilty plea could qualify as a predicate offense under the ACCA, courts may only look to the following when determining if that plea admitted to generic burglary: the terms of the charging document, the terms of a plea agreement, or a judicial record in which the defendant confirmed the factual basis for the plea (such as conversation between defendant and judge).


[Unknown Act > Facts]
In Ohio state court proceedings, Stumpf pled guilty in to aggravated murder committed in an armed robbery. That robbery had left Mr. Stout wounded and Mrs. Stout dead. While Stumpf admitted to shooting Mr. Stout, he insisted his accomplice Wesley had shot Mrs. Stout. A three-judge panel ruled Stumpf the principal offender in Mrs. Stout's murder and sentenced him to death. Following this, in Wesley's trial, the state presented evidence that Wesley had admitted to shooting Mrs. Stout. After Wesley's trial, Stumpf moved to withdraw his plea or reverse his death sentence, arguing that the evidence presented by the prosecution in Wesley's trial was inconsistent with what it had presented in his own. This, Stumpf argued, cast doubt on his conviction and sentence. Stumpf's motion was unscucessful in Ohio courts. A federal district court denied Stumpf habeas relief, but the Sixth Circuit reversed.


[Unknown Act > Conclusion]
Yes and possibly not. In a unanimous opinion delivered by Justice Sandra Day O'Connor, the Court held that Stumpf's plea was knowing and therefore valid, because his attorneys at the plea hearing had represented that they had explained the elements to Stumpf, who then confirmed this. The Court articulated the broad rule that constitutional requirements were satisfied when a defendant's competent counsel explained to him the charge's nature and the crime's elements. As for the prosecution's use of inconsistent theories in Stumpf's and Wesley's trials, the Court held that Stumpf's sentence may have been invalid, depending on the relationship between the prosecutor's conduct and Stumpf's death sentence.. The Court sent the question of that relationship back to the Sixth Circuit.


[Unknown Act > Facts]
Federal district courts convicted David Whitfield and Haywood Hall of conspiracy to commit money laundering. They appealed and argued the federal money laundering law required the jury to have found proof of an "overt act" furthering the conspiracy. The 11th Circuit Court of Appeals rejected this argument, reasoning that the law lacked any language requiring proof of an overt act. Other federal appeals courts had ruled the law did require an overt act.


[Unknown Act > Conclusion]
No. Justice Sandra Day O'Connor delivered the Court's unanimous ruling that because the federal money laundering law's text did not expressly make committing an overt act an element of the conspiracy offense, the government did not need to prove such an act.


[Unknown Act > Facts]
Christopher Simmons was sentenced to death in 1993, when he was only 17. A series of appeals to state and federal courts lasted until 2002, but each appeal was rejected. Then, in 2002, the Missouri Supreme Court stayed Simmon's execution while the U.S. Supreme Court decided Atkins v. Virginia, a case that dealt with the execution of the mentally disabled. After the U.S. Supreme Court ruled that executing the mentally disabled (or "mentally retarded" in the vernacular of the day) violated the Eighth and 14th Amendment prohibitions on cruel and unusual punishment because a majority of Americans found it cruel and unusual, the Missouri Supreme Court decided to reconsider Simmons' case.
Using the reasoning from the Atkins case, the Missouri court decided, 6-to-3, that the U.S. Supreme Court's 1989 decision in Stanford v. Kentucky, which held that executing minors was not unconstitutional, was no longer valid. The opinion in Stanford v. Kentucky had relied on a finding that a majority of Americans did not consider the execution of minors to be cruel and unusual. The Missouri court, citing numerous laws passed since 1989 that limited the scope of the death penalty, held that national opinion had changed. Finding that a majority of Americans were now opposed to the execution of minors, the court held that such executions were now unconstitutional.
On appeal to the U.S. Supreme Court, the government argued that allowing a state court to overturn a Supreme Court decision by looking at "evolving standards" would be dangerous, because state courts could just as easily decide that executions prohibited by the Supreme Court (such as the execution of the mentally ill in Atkins v. Virginia) were now permissible due to a change in the beliefs of the American people.


[Unknown Act > Conclusion]
Yes. In a 5-4 opinion delivered by Justice Anthony Kennedy, the Court ruled that standards of decency have evolved so that executing minors is "cruel and unusual punishment" prohibited by the Eighth Amendment. The majority cited a consensus against the juvenile death penalty among state legislatures, and its own determination that the death penalty is a disproportionate punishment for minors. Finally the Court pointed to "overwhelming" international opinion against the juvenile death penalty. Chief Justice William Rehnquist and Justices Antonin Scalia, Sandra Day O'Connor, and Clarence Thomas all dissented.


[Unknown Act > Facts]
Federal law made gun possession illegal for any person "convicted in any court" for crimes punishable by more than a year in prison. A Japanese court convicted Gary Sherwood Small for crimes punishable by a prison term longer than one year. Years later a U.S. District Court convicted Small, because of his prior conviction, of illegally possessing a gun. Small appealed and argued the term "convicted in any court" did not include convictions in foreign courts. The Third Circuit Court of Appeals ruled against Small.


[Unknown Act > Conclusion]
No. In a 5-3 opinion delivered by Justice Stephen Breyer, the Court held that the federal law's phrase, "convicted in any court," encompassed only domestic, not foreign, convictions. The majority reasoned that in determining the scope of the phrase, it was appropriate to assume Congress had domestic concerns in mind. Moreover, the statute's overall language suggested no intent to reach beyond domestic convictions.


[Unknown Act > Facts]
Tony Alford was driving when Washington state police, concerned Alford was impersonating a police officer, pulled him over. During a search of Alford's car, police found a tape recorder recording the traffic stop. The police arrested Alford and said he had made an illegal recording of a private conversation - a violation, they said, of the state's Privacy Act. A state court judge dismissed charges against Alford, ruling - as another state court already had - that the Privacy Act did not apply to public police work.
Alford then sued the officers in federal district court, alleging his arrest violated the Fourth Amendment right to be free from unreasonable seizure. The district court ruled for the officers.
The Ninth Circuit Court of Appeals reversed and ruled the officers violated Alford's Fourth Amendment rights. The facts and law were so clearly established that no reasonable officer could believe Alford violated the Privacy Act. Therefore the officers lacked probable cause for the arrest and were not protected by qualified immunity. The court rejected the officers' argument that the arrest was constitutional because there was probable cause Alford committed the crime of impersonating a police officer. That was not the reason police gave during the arrest. The Ninth Circuit said there was only one instance when an arrest for a reason the police did not articulate was constitutional: if that reason was closely related to the stated reason for the arrest. Impersonating a police officer was not closely related to violating the state Privacy Act. Other circuit courts disagreed with the Ninth Circuit's "closely related offense doctrine."


[Unknown Act > Conclusion]
No. In a unanimous opinion delivered by Justice Antonin Scalia, the Court held that police had probable cause to arrest Alford for impersonating a police officer, despite the fact that this was not closely related to the offense police identified during the arrest. A warrantless arrest by a police officer is reasonable under the Fourth Amendment if, given the facts known to the officer, there is probable cause to believe a crime has been or is being committed. The offense establishing probable cause need not be closely related to the offense the arresting officer identifies at the time of arrest. An arresting officer's state of mind, except for facts he knows, is irrelevant to probable cause.


[Unknown Act > Facts]
A Florida court convicted Joe Elton Nixon of murder and sentenced him to death. During the trial Nixon's lawyer told the jury Nixon was guilty. Nixon appealed and argued he received ineffective counsel in violation of the Sixth Amendment. Nixon said he did not agree to the lawyer's strategy. After several appeals the Florida Supreme Court granted Nixon a new trial. The court said Nixon's lawyer's comments were essentially a guilty plea and that because Nixon did not explicitly agree to the strategy, the lawyer was "per se ineffective."


[Unknown Act > Conclusion]
In a unanimous 8-0 decision, the Court ruled that Nixon's lawyer's strategy - pursued without Nixon's express approval - did not automatically qualify the lawyer as ineffective. The Court reversed the ruling of the Florida Supreme Court, faulting that court for inappropriately applying presumptions of prejudice and deficient performance. The opinion by Justice Ruth Bader Ginsburg held that "When counsel informs the defendant of the strategy counsel believes to be in the defendant's best interest and the defendant is unresponsive, counsel's strategic choice is not impeded by any blanket rule demanding the defendant's explicit consent." Nixon's lawyer would have needed Nixon's consent for a formal guilty plea, but the Court ruled that the tactic of effectively conceding guilt in order to concentrate on the sentencing phase of the trial was legitimate as long as the defendant was informed of the strategy. Chief Justice William H. Rehnquist took no part in the decision of the case.


[Unknown Act > Facts]
The American Civil Liberties Union (ACLU) sued three Kentucky counties in federal district court for displaying framed copies of the Ten Commandments in courthouses and public schools. The ACLU argued the displays violated the First Amendment's establishment clause, which prohibits the government from passing laws "respecting an establishment of religion." The district court and the Sixth Circuit Court of Appeals ruled the displays violated the establishment clause.


[Unknown Act > Conclusion]
Yes and yes. In a 5-4 opinion delivered by Justice David Souter, the majority held that the displays violated the establishment clause because their purpose had been to advance religion. In the case of each of the displays, the Court held, an observer would have concluded that the government was endorsing religion. The first display for presenting the Ten Commandments in isolation; the second for showing the Commandments along with other religious passages; the third for presenting the Commandments in a presentation of the "Foundations of American Law," an exhibit in which the county reached "for any way to keep a religious document on the walls of courthouses."


[Unknown Act > Facts]
The Religious Land Use and Institutionalized Persons Act (2000, RLUIPA) prohibited government from imposing a substantial burden on prisoners' religious exercise, unless the burden furthered a "compelling government interest." Prisoners in Ohio alleged in federal district court that prison officials violated RLUIPA by failing to accomodate the inmates' exercise of their "nonmainstream" religions. The prison officials argued that the act improperly advanced religion and thus violated the First Amendment's establishment clause (which prohibited government from making laws "respecting an establishment of religion"). The district court rejected that argument and ruled for the inmates. The Sixth Circuit Court of Appeals reversed.


[Unknown Act > Conclusion]
No. In a unanimous opinion delivered by Justice Ruth Bader Ginsburg, the Court held that, on its face, RLUIPA made an accommodation allowed by the First Amendment. The Court reasoned that the law was an effort to alleviate the "government-created burden" on religious exercise that prisoners faced. Nor did section three discriminate between mainstream and non-mainstream religions. The Court did point out that constitutional problems could arise if RLUIPA were enforced improperly and religious prisoners received favored treatment, or if religious exercise and security concerns were not properly balanced.


[Unknown Act > Facts]
A California court sentenced William Payton to death for murder and attempted murder. Payton appealed and alleged the jury, when imposing the death penalty, did not consider the potentially mitigating evidence of his post-crime religious conversion. California's death penalty statute required jurors to weigh 11 factors when imposing a death penalty. The first 10 factors were specific to the crime and the eleventh factor was a "catch-all factor" that allowed the judge or jury to consider any other circumstance the defendant presented in mitigation of a death sentence. Payton alleged the judge's jury instructions effectively prevented the jury from considering his post-crime religious conversion. The California Supreme Court ruled there was nothing wrong with the judge's jury instructions. A federal district court and the Ninth Circuit Court of Appeals agreed with Payton and reversed the death sentence. The Ninth Circuit said the California Supreme Court's application of U.S. Supreme Court precedent was objectively unreasonable. According to the Ninth Circuit, the clearly established precedent required juries to consider mitigating post-crime evidence when considering a death sentence.


[Unknown Act > Conclusion]
No. In a 5-3 opinion delivered by Justice Anthony Kennedy, the Court held that the California Supreme Court was not unreasonable to decline to distinguish between pre-crime and postcrime mitigating evidence. The California Supreme Court reasonably read the relevant precedent, Boyde v. California (1990), as establishing that the catch-all factor's text was broad enough to accommodate Payton's post-crime religious conversion.


[Unknown Act > Facts]
A Pennsylvania court convicted Ronald Rompilla of murder. During the sentencing phase, the prosecution presented to the jury Rompilla's previous rape and assault conviction, as an aggravating factor to justify the death sentence. The jury sentenced Rompilla to death and the state supreme court affirmed. Rompilla's new lawyers filed an additional appeal, arguing that Rompilla's trial counsel had been ineffective for failing to present mitigating evidence about his various personal problems. The state courts found that Rompilla's counsel had sufficiently investigated mitigation possibilities. After Rompilla filed a federal habeas petition, a district court reversed the sentence and ruled the state supreme court had unreasonably applied the U.S. Supreme Court's 1984 decision in Strickland v. Washington. Had the state court followed that case, the district court ruled, the court would have found Rompilla's trial counsel ineffective for failing to investigate obvious signs of Rompilla's troubled childhood, mental illness and alcoholism. The Third Circuit reversed.


[Unknown Act > Conclusion]
Yes. In a 5-4 opinion delivered by Justice David H. Souter, the Court held that Rompilla's trial counsel was ineffective for failing to make reasonable efforts to examine the file on Rompilla's prior conviction for rape and assault. Moreover, counsel had known the prosecution would probably present the prior conviction to the jury during sentencing. In that file counsel would have found mitigating evidence about Rompilla's troubled childhood and mental health.


[Unknown Act > Facts]
Title II of the Communications Act of 1934, which was amended in 1996, subjected providers of "telecommunications service" to mandatory common- carrier regulation. The FCC concluded that this did not include broadband cable companies. The Ninth Circuit reversed and cited its own previous opinion that had held that cable modem service was a "telecommunications service."


[Unknown Act > Conclusion]
Yes. In a 6-3 opinion delivered by Justice Clarence Thomas, the Court held that the FCC lawfully construed the Communications Act to not define cable broadband providers as "telecommunications services." The Court held that the Ninth Circuit should have followed the Supreme Court's 1984 decision in Chevron v. Natural Resources Defense Council. That decision required federal courts to defer to an agency's construction of a statute, if that statute was within the agency's jurisdiction to administer and the agency's interpretation was reasonable, even if it differed from the court's own interpretation. In this case, the Court held that the FCC's construction was reasonable.


[Unknown Act > Facts]
The Indian Self-Determination and Education Assistance Act (ISDA) allows tribes to administer health care programs previously run by the federal government. Tribes can opt to do this by entering into contracts with the Secretary of Health and Human Services, who is obligated to fund tribe-run health services as if they were still federally run. The Secretary must also fund "contract support costs" associated with carrying out the contract. However, ISDA requires the federal government to fund contract support costs only to the extent money is available. ISDA also does not require the federal government to reduce funding for some tribe programs to make funds available for other tribes. In two separate cases tribes claimed the federal government under-funded contract support costs. The Secretary argued the Omnibus Consolidated and Emergency Appropriations Act made it clear the government lacked the funds to pay the full contract support costs. In one case a federal appellate court ruled that the federal government did not adequately fund contract support costs and that funds were available. In another case a federal appellate court ruled for the federal government.


[Unknown Act > Conclusion]
Yes. In an 8-0 opinion delivered by Justice Stephen Breyer, the Court held that the government was legally bound to pay the contract support costs. Only in a "special" instance could the government break its promise to pay the costs. In this case, the government had access to sufficient unrestricted funds appropriated by Congress. Moreover, nothing in the act's language suggested it was non-binding.


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


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


[Unknown Act > Facts]
A Minnesota state court convicted Somalian refugee Keyse Jama of assault. As a result the Immigration and Naturalization Service (INS) argued in immigration court that Jama should be deported to Somalia. The court agreed and an immigration appeals court also agreed. Jama then appealed to a federal district court and argued the part of the U.S. Code dealing with deporting an alien to his country of birth required that country to first accept the alien. Because Somalia lacked a functioning central government, this was impossible. The district court ruled for Jama. A federal appellate court reversed and said Jama and the district court misinterpreted the law.


[Unknown Act > Conclusion]
Yes. Federal immigration law permitted an alien to be removed to a country without the advance consent of that country's government. Of the four removal options federal immigration law listed, an acceptance requirement appeared in only one clause: "...he shall be removed to another country whose government will accept him." That clause only applied after the attorney general attempted the prior deportation option. The grammatical "rule of the last antecedent," prevented "another" from applying to the earlier options. Nor did the law's structure impose an acceptance requirement. Moreover, contrary to Jama's argument, the acceptance requirement was hardly settled judicial interpretation.


[Unknown Act > Facts]
Integra Lifesciences sued Merck for supplying an Integra patented compound to other drug companies for use in preclinical research. In response, Merck claimed its actions were allowed under the federal law that said it was not an act of patent infringement to use or import a patented invention into the United States, if the invention was used only in ways related to the development and submission of information under a federal drug law (such as the law governing submission of data to the FDA). The district court ruled against Merck and awarded Integra damages. The Federal Circuit affirmed the judgment but ordered a modification of damages.


[Unknown Act > Conclusion]
Yes. Justice Antonin Scalia delivered the Court's unanimous opinion that federal law allowed the use of patented compounds in preclinical studies, as long as there was a reasonable basis to believe the compound could be the subject of an FDA submission. The Court reasoned that federal law provided "a wide berth for the use of patented drugs in activities related to the federal regulatiory process" and that "this necessarily included preclinical studies." Because federal law required only a "reasonable relation" to FDA submission, information gathered on the patented invention (a compound in this case) did not necessarily need to be submitted to the FDA to be exempt from patent protection.


[Unknown Act > Facts]
A 1994 amendment to the Michigan constitution said criminal defendants who pled guilty had no right to appeal and could appeal only with the permission of a state appellate court. Michigan then enacted a law that said in most cases judges could not appoint appellate lawyers for indigent defendants who pled guilty. Two criminal attorneys and three indigent defendants who were denied appointed appellate lawyers filed a single suit alleging the state law violated the 14th Amendment's due process and equal protection clauses. The district court ruled that the indigents had standing to sue and that the lawyers who sued with them had the right to sue as third-party representatives of the rights of indigents. A federal appellate court agreed the statute was unconstitutional, but based this only on the lawyers' claims. The court said the U.S. Supreme Court's 1971 decision in Younger v. Harris required it to abstain from hearing the indigents' claims because the indigents were involved in related proceedings in state court.


[Unknown Act > Conclusion]
In a 6-3 opinion delivered by Chief Justice William H. Rehnquist, the Court held that the attorneys lacked third-party standing to sue on behalf of the Michigan indigent defendants. The attorneys did not have close relationships with the indigent defendants, nor was there a hindrance to these defendants' ability to advance their own constitutional rights against the Michigan scheme. In addition, under Younger, the indigents should have only turned to the federal courts after pursuing their claims in state court.


[Unknown Act > Facts]
A Mississippi court convicted Marlon Howell of capital murder - murder committed during a felony - and sentenced him to death. Howell appealed and argued the trial court was wrong to deny the jury the option of finding Howell guilty of the lesser offenses of non-capital murder or manslaughter, for which the death penalty would not have been an option. The Mississippi Supreme Court ruled against Howell and said there was no evidence to support lesser charges.


[Unknown Act > Conclusion]
In a unanimous per curiam opinion, the Court dismissed the case because Howell had not first raised his federal constitutional claims in state court.


[Unknown Act > Facts]
The federal government deemed Daniel Benitez and Sergio Martinez inadmissible immigrants and detained them until they could be returned to Cuba.
Benitez and Martinez argued that because deportation to Cuba was unforeseeable, they could not be detained longer than the 90 days allowed by federal law. They pointed to the U.S. Supreme Court's 2001 decision in Zadvydas v. Davis that said the government can detain beyond 90 days immigrants who were admitted to the United States, but only so long as necessary to deport them. Immigrants must be released if deportation is unforeseeable, the Court said.
While separate district courts agreed deportation to Cuba was unforeseeable, the Ninth Circuit and 11th Circuits disagreed over whether Zadvydas applied to inadmissible immigrants.
The U.S. Supreme Court consolidated the two cases.


[Unknown Act > Conclusion]
Yes. In a 7-2 decision delivered by Justice Antonin Scalia, the Court said the requirement that immigrants be detained no longer than reasonably necessary for deportation applied to both admissible and inadmissible immigrants. Because readmission to Cuba was unforeseeable, the detentions of Martinez and Benitez were unreasonable. The Court refused to give the same immigration statute different interpretations based on immigrants' characteristics.


[Unknown Act > Facts]
Alaska and the United States disputed ownership of two areas of submerged lands - enclaves under the Alexander Archipelago, which are more than three miles from the coast of Alaska or any island, and lands beneath the inland waters of Glacier Bay. Alaska claimed the archipelago waters under the Submerged Lands Act, which entitled states to submerged lands three miles seaward of their coastline and to land beneath inland navigable waters. The dispute over the submerged lands under Glacier Bay centered on the United States' claim that, at the time Alaska gained statehood, those lands were intended for a national monument. A Special Master appointed to deal with the conflict, recommended to the U.S. Supreme Court that the Court side with the United States with respect to both areas. Alaska appealed that decision.


[Unknown Act > Conclusion]
In an opinion delivered by Justice Anthony Kennedy, the Court unanimously concluded that the Alexander Archipelago waters were not inland waters and thus belonged to the federal government. The Court reasoned that the archipelago waters were neither historic inland waters nor inland waters under the juridical bay theory (the theory would work only if the islands formed a peninsula from the mainland that divided the archipelago's waters in two). Kennedy also delivered the Court's 6-3 opinion holding that the underlying waters of Glacier Bay National Park belong to the federal government. The majority wrote that, at the time Alaska gained statehood, the government intended those lands to be part of a national monument.
On January 23, 2006, the Court issued its final decree. On the issues of Alexander Archipelago and Glacier Bay, the Court declared: "judgment is granted to the United States, and the State of Alaska shall take nothing." Alaska's additional motion for judgment on the submerged lands within the Tongass National Forest was dismissed as moot (meaning "previously settled"), because the federal government had already disclaimed any interest in the lands. The newly appointed Chief Justice John Roberts took no part in the case.


[Unknown Act > Facts]
Miller-El alleged the prosecution in his capital murder trial violated the 14th Amendment's equal protection clause by excluding 10 of 11 blacks from the jury. The jury convicted Miller-El and he was sentenced to death. State courts rejected Miller-El's appeals and ruled Miller-El failed to meet the requirements for proving jury-selection discrimination outlined by the U.S. Supreme Court in Batson v. Kentucky (1986). Miller-El then appealed to a federal district court. The district court rejected Miller-El's appeal and ruled the court must defer to the state courts' acceptance of prosecutors' race-neutral justifications for striking potential jurors. The Fifth Circuit Court of Appeals affirmed and ruled a federal court could only grant an appeal if the applicant made a substantial showing of the denial of a constitutional right.
Miller-El appealed to the U.S. Supreme Court and in Miller-El v. Cockrell (2003) the Court ruled the Fifth Circuit should have accepted Miller- El's appeal to review the district court's ruling. The Supreme Court said an appeal should have been granted if the petitioner could demonstrate reasonable jurists could disagree with the district court's decision. The Court said the district court did not give full consideration to the substantial evidence Miller-El presented. The Fifth Circuit reconsidered Miller-El's appeal and ruled Miller-El failed to show clear and convincing evidence that the state court was wrong to find no purposeful discrimination.


[Unknown Act > Conclusion]
Yes and yes. In a 6-3 opinion delivered by Justice David Souter, the Court held that Miller-El deserved to win his appeal because the jury selection in his case violated the Fourteenth Amendment's equal protection clause. The Court began by noting that the prosecutors used peremptory strikes to exclude 91 percent of the eligible black prospective jurors, "a disparity unlikely to have been produced by happenstance." After comparing two eliminated black prospective jurors with similar white jurors who were not eliminated, the Court concluded that the "selection process was replete with evidence that prosecutors were selecting and rejecting potential jurors because of race." The Court further concluded that Texas' jury selection manual, both in this case and generally, tended to allow prosecutors to read disparate questions to prospective jurors depending on whether they were black or white.


[Unknown Act > Facts]
Ohio state prisoners Rogerico Johnson and William Dwight Dotson separately alleged their parole proceedings violated due process. Each sued the Ohio prison system under a section of the U.S. Code - section 1983 - which allows prisoners to challenge conditions of confinement. The district courts dismissed the prisoners' claims. The courts ruled their claims challenging parole decisions actually challenged their sentences and that the U.S. Supreme Court's decision in Heck v. Humphrey (1994) barred prisoners from using section 1983 to do this. The prisoners could make their claims only under the section of the U.S. Code that allows prisoners to petition for habeas corpus. A federal appellate court reversed the district courts' decisions.


[Unknown Act > Conclusion]
Yes and No. In an 8-1 decision, the Court affirmed the appellate court and ruled that prisoners could use Section 1983 to challenge a state's parole procedures. The majority opinion by Justice Stephen Breyer held that though prisoners cannot use Section 1983 to directly challenge their sentences, they can bring suit under the Section when a successful suit "would not necessarily spell immediate or speedier release for the prisoner." Though a successful constitutional challenge to Ohio's parole procedures might make it more likely that the prisoners would be released from prison sooner, the Court called the connection "too tenuous" for the prisoners' suit to be considered a challenge of the sentences themselves. The Court ruled that since the prisoners sought only new parole hearings, not reduced sentences, a favorable ruling would not necessarily imply the invalidity of their sentences. Justice Anthony Kennedy wrote a lone dissent arguing that challenges to parole proceedings can only be brought by a petition for habeas corpus.


[Unknown Act > Facts]
Sheila White was the only woman working in the Maintenance of Way Department of the Burlington Northern Santa Fe Railroad's Tennessee Yard. After she complained of harassment by her supervisor, White was moved from duties as a forklift operator to less desirable duties as a track laborer, though her job classification remained the same. She was also suspended for 37 days without pay, but was eventually reinstated and given full back pay.
White filed suit in federal court, where a jury rejected her claims of sex discrimination but awarded her damages of $43,000 after finding that she had been retaliated against for her complaints, in violation of Title VII of the Civil Rights Act of 1964. On appeal, Burlington Northern argued that White had not suffered "adverse employment action," and therefore could not bring the suit, because she had not been fired, demoted, denied a promotion, or denied wages. The Sixth Circuit Court of Appeals disagreed, finding that the suspension without pay - even if back pay was eventually awarded - was an "adverse employment action," as was the change of responsibilities within the same job category.


[Unknown Act > Conclusion]
Yes. The Supreme Court unanimously agreed that White suffered retaliatory discrimination when she was reassigned to less desirable duties and suspended without pay. Though the duties were within the same classification and the pay was eventually reinstated, the action was nevertheless sufficiently harsh to constitute retaliatory discrimination. In a decision authored by Justice Stephen Breyer and joined by Chief Justice Roberts and six other justices, the Court held that in order to prevail on a claim of retaliatory discrimination, "a plaintiff must show that a reasonable employee would have found the challenged action materially adverse, which in this context means it well might have dissuaded a reasonable worker from making or supporting a charge of discrimination." (internal citations omitted) Justice Samuel Alito wrote separately, agreeing with the result but arguing that the test adopted by the other members of the Court would eventually prove problematic.


[Unknown Act > Facts]
S.D. Warren Company (Warren) operates several hydroelectric dams in Maine. Under Section 401 of the federal Clean Water Act, companies must obtain state approval of "any activity" "which may result in any discharge into the [Nation's] navigable waters." When Warren sought to renew the federal licenses for its dams, the Federal Energy Regulatory Commission (FERC) required that it first get approval from the Maine Board of Environmental Protection because, FERC ruled, the dams resulted in a "discharge." Warren disagreed, arguing that the water which moved through the hydroelectric dams was not actually a "discharge" because it was water from the same river which had just been temporarily re-routed. After Warren's administrative appeals and state court suit (which went to the Maine Supreme Judicial Court) failed, it appealed the case to the U.S. Supreme Court.


[Unknown Act > Conclusion]
Yes. In a unanimous decision, the Supreme Court held that the term "discharge" in section 401 had historically been given a broad meaning by FERC, the Environmental Protection Agency, and even the Supreme Court. Justice David Souter, in the Opinion of the Court, wrote that "[w]hen it applies to water, 'discharge' commonly means a 'flowing or issuing out.' ... In fact, this understanding of the word was accepted by all Members of the Court sitting in our only other case focused on Section 401 of the Clean Water Act." The discharge from hydroelectric dams fit this definition perfectly, and Section 401 therefore mandated state approval.


[Unknown Act > Facts]
As part of Ohio's economic development plan, DaimlerChrysler agreed to expand its operations in Toledo in exchange for tax exemptions and tax credits worth roughly $280 million. Charlotte Cuno and others challenged the deal, however, arguing that Ohio had violated the Commerce Clause of the U.S. Constitution by offering the tax incentives. A federal district court disagreed, ruling for DaimlerChrysler, but on appeal a panel of the Sixth Circuit Court of Appeals reversed. The panel found that the tax incentives coerced businesses to expand in Ohio at the expense of other states, and were therefore unconstitutional manipulations of interstate commerce.


[Unknown Act > Conclusion]
The Supreme Court did not reach the central question presented, finding instead that Cuno and the other plaintiffs did not have standing to bring the suit. Chief Justice John Roberts, for the unanimous Court, wrote that simply alleging standing based on their status as taxpayers in Ohio and Michigan did not give them a sufficiently strong interest in the case. The citizens from Ohio could not definitively show that the tax incentives had decreased the amount of money available to the state treasury (and thus increased their tax burden or decreased the services available to them) because the point of the incentive was to increase long-term tax revenue. The citizens from Michigan, meanwhile, could not show that any tax revenue increase in Michigan that could have resulted from DaimlerChrysler expanding there instead of in Ohio would have actually benefited them directly, because it might have been used for programs that they did not benefit from. Without any clear injury, they had no standing to sue.


[Unknown Act > Facts]
Clarence Hill was sentenced to death in Florida, which ordinarily uses a three-drug combination for executions. Hill claimed that this particular form of lethal injection was unnecessarily and gratuitously painful, and that it therefore violated the Eighth Amendment's prohibition on cruel and unusual punishment. However, Hill had previously filed for a federal writ of habeas corpus challenging his conviction, and the federal district court ruled that his new challenge was the practical equivalent of a second habeas corpus appeal. Successive habeas corpus appeals are not allowed under 28 U.S.C. 2244, and so the district court rejected Hill's petition. The Eleventh Circuit Court of Appeals affirmed the decision.


[Unknown Act > Conclusion]
No. In a unanimous decision authored by Justice Anthony Kennedy, the Supreme Court held that challenging the form of execution was fundamentally different from challenging the lawfulness of a conviction or sentence, the traditional purposes of a habeas corpus appeal. This finding was supported by the fact that Hill conceded other forms of execution would be constitutional, and that Florida state law does not require the particular form of execution at issue in this case. "Under these circumstances," Justice Kennedy wrote, "a grant of injunctive relief could not be seen as barring the execution of Hill's sentence."


[Unknown Act > Facts]
In two separate cases, employees sued Barber Foods and IBP in federal district court. The employees alleged the companies violated the Fair Labor Standards Act by not paying them for time spent walking to the worksite after putting on required equipment. The district court and later the First Circuit ruled against the Barber employees. A separate district court ruled IBP must compensate its employees for the disputed time. The Ninth Circuit agreed. The U.S. Supreme Court consolidated the cases.


[Unknown Act > Conclusion]
Yes. Justice John Paul Stevens, for a unanimous Court, wrote that putting on required safety equipment qualified as a "principal activity" under the FLSA. The workday began when employees started that activity and therefore included the subsequent time spent walking to the worksite. The time spent waiting to put on safety equipment before that, however, was not included in the workday because it was a "preliminary" activity under the Portal-to-Portal Act.


[Unknown Act > Facts]
John Cardegna signed a contract for a loan from Buckeye Check Cashing. The contract contained a clause in which Cardegna agreed to resolve any controversies over the loan through arbitration. Cardegna later sued Buckeye, claiming that the conditions for the loan stipulated by the contract were illegal. Buckeye filed a motion in Florida district court to have the case resolved by arbitration, as required by the contract. Cardegna countered that the contract as a whole was illegal and that the arbitration clause was therefore not enforceable. The court agreed and ruled for Cardegna.
On appeal, the state appeals court reversed, holding that the Federal Arbirtration Act, as interpreted by the U.S. Supreme Court, allows arbitration clauses to be enforced even if they are part of otherwise invalid contracts. The appeals court relied on the U.S. Supreme Court's decision in Prima Paint Corporation v. Flood & Conklin Manufacturing Company. The Florida Supreme Court disagreed with the appeals court's use of Prima Paint, however, because the contract in that case had been merely voidable, while the contract in Cardegna's case was actually illegal. The Florida Supreme Court therefore reversed, ruling in favor of Cardegna.


[Unknown Act > Conclusion]
No. The 7-1 majority (Justice Samuel Alito not participating) ruled that challenges to the legality of a contract as a whole must be argued before the arbitrator rather than a court. The opinion by Justice Antonin Scalia explained that "unless the challenge is to the arbitration clause itself, the issue of the contract's validity is considered by the arbitrator in the first instance." The Court held that the Florida Supreme Court had been wrong to rely on a distinction between void and merely voidable contracts, because the word "contract" in the Federal Arbitration Act includes contracts later found to be void. Justice Clarence Thomas dissented due to his long-held view that the FAA does not apply in state courts.


[Unknown Act > Facts]
In 1998, Texaco and Shell Oil agreed to stop competing for the U.S. oil market. The two companies formed a joint venture, Equilon Enterprises, which would manage the refining and marketing of gasoline in the western United States. The joint venture was charged with setting prices for Texaco and Shell gasoline, which would be sold under the original brand names. When Equilon set the same price for both brands, Dagher and other service station owners sued under Section 1 of the Sherman Antitrust Act, alleging that Equilon was engaging in illegal price-fixing. The dispute turned on whether Equilon's actions fell under the Sherman Act's per se rule against price-fixing, under which all such instances of price-fixing by joint ventures would be illegal without regard to the specific harm caused in any particular case. The District Court granted summary judgment for Texaco, holding that the per se rule did not apply to the price-setting engaged in by Equilon. The District Judge reasoned that all enterprises, including joint ventures, must eventually set prices for their products. Therefore Equilon was merely engaged in a normal business practice, not the type of unreasonable, anticompetitive price-fixing that would run afoul of the Supreme Court's non-literal interpretation of the Sherman Act. The Ninth Circuit Court of Appeals reversed, ruling that Equilon's actions constituted price-fixing under the Sherman Act's per se rule and therefore could not be legal.


[Unknown Act > Conclusion]
No. In an 8-0 decision (Justice Alito not participating), the Court ruled that the per se rule against price-fixing should not be applied to price-setting by joint ventures. The opinion by Justice Clarence Thomas held that "though Equilon's pricing policy may be price fixing in a literal sense, it is not price fixing in the antitrust sense." The Court distinguished 'horizontal' price-fixing schemes between competitors, which are per se illegal, from the "internal pricing decisions of a legitimate joint venture," which are not.


[Unknown Act > Facts]
Shadi Dabit, formerly a stockbroker at Merrill Lynch, brought a class action suit against his former employer alleging that the company had defrauded brokers by deceptively inflating stock prices, causing the brokers to hold onto stocks they would otherwise have sold. Dabit's class action was filed in the U.S. District Court based on federal diversity jurisdiction, but was based on Oklahoma state law.
In response to perceived abuses of the class-action vehicle in securities litigation, Congress had passed the Private Securities Litigation Reform Act of 1995, which placed restrictions on federal securities fraud class actions. When plaintiffs began avoiding the law by bringing the suits in state courts instead of federal courts, Congress passed the Securities Litigation Uniform Standards Act of 1998 (SLUSA), which pre-empts federal class action securities fraud claims brought under state law that allege misrepresentation "in connection with the purchase or sale of a covered security."
Merrill Lynch argued that Dabit's suit was pre-empted by SLUSA and therefore could not be brought under state law. Dabit countered that the suit alleged misrepresentation concerning only the holding of stocks, and therefore was beyond the scope of SLUSA. The District Court for the Southern District of New York ruled for Merrill Lynch, finding the language of SLUSA broad enough to include suits such as Dabit's. The Second Circuit Court of Appeals reversed, holding that suits by holders of stocks are distinct from suits by sellers and purchasers and that SLUSA was meant to pre-empt only the latter.


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


[Unknown Act > Facts]
U.S. Customs Service agents investigating a child pornography website raided Susan and Richard Hallock's residence and seized several computers. The Hallocks were cleared of any guilt, but the computers were damaged beyond repair. Susan Hallock originally sued the government under the Federal Tort Claims Act (FTCA), which waives the government's sovereign immunity in certain cases. The District Court dismissed that case for lack of jurisdiction, because the FTCA's waiver has an exception for claims arising from the detention of goods by customs. Hallock then sued Will and the other customs agents as individuals. The agents made a motion for dismissal under a provision of the FTCA that bars suits where a judgment on the claim has already been entered. The District Court denied the motion, accepting Hallock's argument that the dismissal for lack of jurisdiction did not constitute a final judgment. Although the trial had not yet concluded, the Second Circuit Court of Appeals granted the agents' appeal of the District Court's ruling on the motion and affirmed the District Court, ruling that since Hallock had not properly brought a claim in the original suit, no judgment had been entered. The Circuit Court ruled that it had jurisdiction to hear the appeal under the collateral order doctrine, under which some decisions of lower courts other than final judgments can be appealed. The Supreme Court granted certiorari on the question of the motion to dismiss, but instructed the parties to argue the question of the Circuit Court's authority to hear the appeal.


[Unknown Act > Conclusion]
Unanswered, and no. In a unanimous opinion, the Court ruled that the Circuit Court had no jurisdiction to hear an appeal under the collateral order doctrine. Writing for the Court, Justice David Souter stressed the narrow scope of the doctrine. The Court reiterated that only orders that cannot be "effectively" reviewed after a final judgment can be appealed before the close of the trial. Essential to this determination is the importance of the interest at stake. In this case, the Court ruled that the agents' interest in appealing the District Court's order had no "greater importance than the typical defense of claim preclusion" and it therefore warranted "no immediate appeal of right as a collateral order."


[Unknown Act > Facts]
Schmidt, a South Carolina citizen, sued Wachovia Bank in a South Carolina state court for fraudulently inducing him to participate in an illegal tax shelter. Wachovia is a national bank with its main office in North Carolina and branch offices in several other states, including South Carolina. Under federal diversity jurisdiction, federal courts can hear cases in which the parties are citizens of different states. Wachovia filed a petition in Federal District Court, seeking to compel arbitration of the dispute. After the petition was denied on the merits, Wachovia appealed to the Fourth Circuit Court of Appeals, which dismissed the case for lack of jurisdiction. Under 28 U.S.C. Section 1348, national banks are "deemed citizens of the States in which they are respectively located." The Circuit Court interpreted "located" to mean any state where the bank has a branch location. Noting that the statute uses both "located" and "established" to refer to the presence of a bank, the Circuit Court determined that a national bank is "established" in the state where its main office is located, and "located" in every state where it has a branch office. Therefore, under the Fourth Circuit's reasoning, Wachovia was "located" in, and a citizen of, South Carolina (as well as several other states with branch offices). Since both parties, Schmidt and Wachovia, had South Carolina citizenship, the Circuit Court dismissed the case for lack of diversity jurisdiction.


[Unknown Act > Conclusion]
No. In an 8-0 decision authored by Justice Ruth Bader Ginsburg, the Court ruled that a national bank is "located" in, and therefore a "citizen" of, only the state in which its main office is located. Looking to the history of Congress's diversity jurisdiction statutes, the Court concluded that the word "located" need not be interpreted to mean any state where a bank has a physical presence. Furthermore, the Court ruled that the Fourth Circuit had erred in drawing a distinction between the words "located" and "established": "the Congress may well have comprehended the words 'located' and 'established,' as used in [Section] 1348, as synonymous terms." Justice Thomas took no part in the decision of the case.


[Unknown Act > Facts]
MercExchange patented a design for an online marketplace in which a single company provides the trustworthy framework within which buyers and sellers can negotiate for goods. After negotiations with eBay and Half.com to license the patent failed, MercExchange brought suit in federal district court alleging patent violation under the Patent Act. The jury sided with MercExchange, ruling that its patent had been violated, but the district court judge refused to issue a permanent injunction. The injunction would have forced eBay and Half.com to stop using the contested framework, but the judge applied the traditional four-part test to determine whether an injunction was necessary and found that it was not. That decision was reversed, however, by the U.S. Circuit Court of Appeals for the Federal Circuit, which applied a "general rule that courts will issue permanent injunctions against patent infringements absent exceptional circumstances."


[Unknown Act > Conclusion]
No. Justice Clarence Thomas, writing for a unanimous Court, held that the appeals court's general rule was an unwarranted departure from the traditional four-part test applied to determine whether an injunction is necessary. That test requires the plaintiff to prove (1) that it has suffered an irreparable injury; (2) that the law does not provide other adequate ways to compensate it; (3) that considering the balance of hardships between the plaintiff and defendant, an injunction is warranted; and (4) that the public interest would not be harmed by a permanent injunction. The Court found no reason to make decisions on injunctions under the Patent Act different from other decisions on injunctions, and so the appeals court's general rule was rejected and the decision reversed.


[Unknown Act > Facts]
Jennifer Arbaugh, a waitress at the Moonlight Cafe in Louisiana, sued her employer, the Y&H Corporation, for sexual harassment under Title VII of the Civil Rights Act. The federal district court jury ruled for Arbaugh. Filing a motion to dismiss, Y&H claimed it did not qualify as an employer under Title VII, because it did not employ 15 or more employees for 20 or more calendar weeks during the relevant time period. The district court then reversed the jury judgment, holding that the number of employees determines a court's subject matter jurisdiction in a Title VII suit. The Fifth Circuit affirmed.


[Unknown Act > Conclusion]
The Court held that the number-of-employees requirement is an element of the merits of a Title VII claim, not a jurisdictional limitation. The 8-0 opinion (Justice Alito not participating) by Justice Ruth Bader Ginsburg reversed the Circuit Court, noting the "unfair[ness]" and "waste of judicial resources" that could result from a jurisdictional interpretation of the number-of-employees requirement as well as the lack of any specific jurisdictional language that would require such an interpretation. The Court relied on a "readily administrable bright line" rule that statutory limitations should be treated as non-jurisdictional unless specified as jurisdictional by Congress.


[Unknown Act > Facts]
In 2003, the Supreme Court ruled that abortion protesters do not commit extortion in violation the Hobbs Act and the Racketeer Influenced and Corrupt Organizations Act (RICO) when they blockade abortion clinics, because they do not "obtain" property, as required by the Act. The Court concluded that "Without an underlying RICO violation, the injunction [on the protesters] issued by the District Court must necessarily be vacated." The Seventh Circuit Court of Appeals declined to vacate the injunction, however, finding that the Court had only ruled on the 117 counts of extortion, and not on four additional counts of violence unrelated to extortion. The National Organization for Women (NOW) argued that acts of physical violence are sufficient to establish a violation of the Hobbs Act. Scheidler countered that the four counts of "violence-only" were irrelevant to the Hobbs Act, which he said requires that violence be used for robbery or extortion. Scheidler petitioned the Supreme Court to decide whether the Circuit Court had acted properly, and the Court granted certiorari. (Consolidated with No. 04-1352, Operation Rescue v. NOW.)


[Unknown Act > Conclusion]
No. In an 8-0 decision (Justice Alito not participating), the Court ruled that "physical violence unrelated to robbery or extortion falls outside the scope of the Hobbs Act." Writing for the unanimous Court, Justice Stephen Breyer cited statutory language, legislative history, and case law in support of the decision. He wrote, "The language of the statute makes the more restrictive reading the more natural one." Although Congress had revised the Act in 1948, making it less clear, the Court ruled that Congress did not intend for the revisions to "create a freestanding physical violence offense in the Hobbs Act."


[Unknown Act > Facts]
Barbara Dolan tripped over mail left on her porch by a mailman, injuring herself. She sued the Postal Service under the Federal Tort Claims Act (FTCA), arguing that her injuries were due to the mailman's negligence. The government, claiming that its sovereign immunity had not been waived in this particular case, moved to have the case dismissed. The FTCA, while waiving federal sovereign immunity for most incidents that could arise under it, has an exception for the "negligent transmission of letters or postal matter." Dolan argued that this exception referred only to mail that was lost or damaged by the Postal Service, not to people injured by the placement of the mail, but the district court disagreed. The case was dismissed, and the dismissal was affirmed by the Third Circuit Court of Appeals.


[Unknown Act > Conclusion]
No. In a 7-1 decision authored by Justice Anthony Kennedy (Justice Alito not participating), the Court ruled that the "negligent transmission" exception was inapplicable to Dolan's case, and therefore sovereign immunity had been waived and her case could proceed. The Court accepted Dolan's argument that the exception was only meant to encompass cases of late, missing, or incorrectly delivered mail. To rule otherwise, the Court found, would be to ignore the context of the exception and risk subverting the main purpose of the statute. Justice Thomas wrote a dissent arguing that cases arising out of ambiguity in sovereign immunity waivers should be resolved in the Government's favor.


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


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


[Unknown Act > Facts]
Cuauhtemoc Gonzalez-Lopez hired Joseph Low, an attorney, to represent him in a federal criminal trial. The district court judge refused to allow Low to represent Gonzalez-Lopez, however, because the judge ruled that Low had violated a court rule in a previous case. Gonzalez-Lopez was subsequently convicted. On appeal, he argued that his Sixth Amendment right to paid counsel of his own choosing had been violated and that the conviction should therefore be overturned. The Eighth Circuit agreed, holding that the trial judge had misinterpreted the court rule and that Low's conduct had been acceptable under a proper understanding of the rule. The decision to not allow him to represent Gonzalez-Lopez was therefore wrong, and resulted in a violation of Gonzalez- Lopez's Sixth Amendment rights significant enough to warrant overturning the conviction.


[Unknown Act > Conclusion]
Yes. In a 5-to-4 decision authored by Justice Antonin Scalia, the Supreme Court held that a denial of the Sixth Amendment right to paid counsel of one's own choosing is "structural" error. Unlike some other kinds of errors in which a defendant must also prove that the result would likely have been different had his rights not been violated, structural errors must result in automatic reversal of the conviction. "[T]he erroneous denial of counsel bears directly on the 'framework within which the trial proceeds,'" Justice Scalia wrote. "It is impossible to know what different choices the rejected counsel would have made, and then to quantify the impact of those different choices on the outcome of the proceedings. ... Harmless error analysis in such a context would be a speculative inquiry into what might have occurred in an alternate universe."


[Unknown Act > Facts]
A police officer stopped and searched Samson on the street in San Bruno, California. The officer had no warrant and later admitted he had stopped Samson only because he knew him to be on parole. The officer found that Samson was in possession of methamphetamines. Samson was arrested and charged with drug possession in state court. At trial Samson argued the drugs were inadmissible as evidence, because the search had violated his Fourth Amendment rights. The trial court denied the motion and the state supreme court declined to hear the case.


[Unknown Act > Conclusion]
No. In a 6-to-3 decision authored by Justice Clarence Thomas, the Supreme Court held that Samson "did not have an expectation of privacy that society would recognize as legitimate." Parole allows convicted criminals out of prison before their sentence is completed. An inmate who chooses to complete his sentence outside of direct physical custody, however, remains in the Department of Correction's legal custody until the conclusion of his sentence, and therefore has significantly reduced privacy rights. In this case, Samson had also been required, as a condition of his parole, to sign an agreement that he would be "subject to search or seizure by a parole officer or other peace officer..., with or without a search warrant and with or without cause." This written consent to suspicionless searches, along with his already reduced privacy interests as a parolee, combined to make the search constitutional. Justices Stevens, Souter and Breyer dissented, arguing that parolees have an expectation of privacy greater than that of prisoners, which was violated by the search at issue in this case.
Learn more about the Roberts Court and the Fourth Amendment in Shifting Scales, a nonpartisan Oyez resource.


[Unknown Act > Facts]
Salim Ahmed Hamdan, Osama bin Laden's former chauffeur, was captured by Afghan forces and imprisoned by the U.S. military in Guantanamo Bay. He filed a petition for a writ of habeas corpus in federal district court to challenge his detention. Before the district court ruled on the petition, he received a hearing from a military tribunal, which designated him an enemy combatant.
A few months later, the district court granted Hamdan's habeas petition, ruling that he must first be given a hearing to determine whether he was a prisoner of war under the Geneva Convention before he could be tried by a military commission. The Circuit Court of Appeals for the District of Columbia reversed the decision, however, finding that the Geneva Convention could not be enforced in federal court and that the establishment of military tribunals had been authorized by Congress and was therefore not unconstitutional.


[Unknown Act > Conclusion]
Yes and no. The Supreme Court, in a 5-to-3 decision authored by Justice John Paul Stevens, held that neither an act of Congress nor the inherent powers of the Executive laid out in the Constitution expressly authorized the sort of military commission at issue in this case. Absent that express authorization, the commission had to comply with the ordinary laws of the United States and the laws of war. The Geneva Convention, as a part of the ordinary laws of war, could therefore be enforced by the Supreme Court, along with the statutory Uniform Code of Military Justice. Hamdan's exclusion from certain parts of his trial deemed classified by the military commission violated both of these, and the trial was therefore illegal. Justices Scalia, Thomas, and Alito dissented. Chief Justice John Roberts, who participated in the case while serving on the DC Circuit Court of Appeals, did not take part in the decision.


[Unknown Act > Facts]
When ConAgra, Swift-Eckrich's parent company, attempted to enforce its patent for a process for browning precooked meats, Unitherm claimed that the patent was invalid because Unitherm's president had invented the process six years before. Unitherm sued, alleging that ConAgra had violated the Sherman Antitrust Act by attempting to enforce a patent obtained by fraud. Pursuant to Rule 50(a) of the Federal Rules of Civil Procedure, ConAgra moved for judgment as a matter of law, asking the Disrict Court to dismiss the case based on insufficiency of evidence. The court denied the motion and sent the case to the jury, which returned a verdict for Unitherm. ConAgra appealed to the Circuit Court of Appeals for the Federal Circuit, again arguing that the evidence was insufficent to prove an antitrust violation. However, ConAgra did not renew the motion for judgment as a matter of law after the verdict, pursuant to Rule 50(b), or move for a new trial, pursuant to Rule 59. Normally, parties must file the Rule 50(b) motion after an unfavorable verdict in order to obtain judgment as a matter of law on appeal. Unitherm argued that since ConAgra had failed to renew its motion under Rule 50(b), the Court of Appeals could not consider the insufficiency-of-evidence claim. ConAgra took the position that renewal of the motion is optional. The Federal Circuit considered itself bound to apply the precedent of the relevant regional Circuit Court (the Tenth), under which Rule 50(b) is indeed optional, in contrast to the precedents of the other Circuit Courts. The Federal Circuit found the evidence insufficient to support the jury's verdict, so it reversed the District Court and ordered a new trial. Unitherm appealed to the Supreme Court, which agreed to consider the procedural dispute.


[Unknown Act > Conclusion]
No. In a 7-2 decision authored by Justice Clarence Thomas, the Court ruled that a party must renew its motion for judgment under Rule 50(b) if the motion is to be the basis for an appeal. The District Court's denial of the initial Rule 50(a) motion could not itself form the basis of an appeal, because the denial was within the District Court's discretion. "The only error here," Justice Thomas noted, "was counsel's failure to file a postverdict motion pursuant to Rule 50(b)." Justice John Paul Stevens wrote a dissent, joined by Justice Kennedy, arguing that in exceptional cases courts of appeals can consider substantive issues even when procedural oversights by appellants would normally preclude them.


[Unknown Act > Facts]
Keshia Dixon was arrested for illegally purchasing firearms. At her trial, Dixon raised a duress defense, claiming that her boyfriend abused her and that she feared he would harm or kill her or her daughters if she did not buy the firearms. Upon being convicted, Dixon appealed to the Fifth Circuit Court of Appeals, arguing that she should not bear the evidentiary burden of proving her duress claim. The Circuit Court rejected Dixon's argument, noting that the circuit's previous cases had clearly established that the duress defense requires the defendant to prove duress by a preponderance of evidence. This ruling conflicted with a ruling on a similar case in the Sixth Circuit Court of Appeals. Dixon appealed to the Supreme Court, which agreed to consider the narrow question of the burden of proof.


[Unknown Act > Conclusion]
The burden of proof is on the defendant. In a 7-to-2 decision authored by Justice John Paul Stevens, the Supreme Court held that the government meets its evidentiary burden when it proves beyond a reasonable doubt that the defendant acted "knowingly" and "willfully." Dixon had argued that duress would make it impossible for a defendant to act "willfully" (and that the government therefore had to prove she did not act under duress in order to prove she acted willfully). The Court rejected that argument, however, because under Bryan v. United States, 524 U.S. 184, acting "willfully" means simply that a defendant "acted with knowledge that his conduct was unlawful."


[Unknown Act > Facts]
A jury found Randy Lee Guzek guilty of capital murder and sentenced him to death. On appeal, the Oregon Supreme Court overturned the death sentence. Guzek was sentenced to death again, and the Oregon Supreme Court again threw out the death sentence. When Guzek was sentenced to death a third time, the Oregon Supreme Court again overturned his sentence and also considered his complaint that he had not been allowed to present testimony about his alibi at the sentencing phase of the trial. Oregon law requires that evidence of innocence, such as an alibi, be presented during the trial, not during the sentencing hearing. The Oregon Supreme Court accepted Guzek's argument that he had a constitutional right under the Eighth and Fourteenth Amendments to introduce the alibi testimony at his sentencing proceeding. Oregon appealed to the Supreme Court, arguing that it was reasonable to restrict the introduction of evidence of innocence to the guilt phase of the trial.


[Unknown Act > Conclusion]
No. In an 8-0 decision (Justice Alito not participating), the Supreme Court reversed the Oregon Supreme Court. Justice Stephen Breyer wrote for the Court: "We can find nothing in the Eighth or Fourteenth Amendments that provides a capital defendant a right to introduce new evidence of this kind at sentencing." States are free "to set reasonable limits upon the evidence a defendant can submit, and to control the manner in which it is submitted." This can include excluding the introduction of evidence of innocence from the sentencing phase.


[Unknown Act > Facts]
In 2002 the U.S. began withholding a portion of Lockhart's Social Security payments to offset his debt on federally reinsured student loans that were more than 10 years overdue. Lockhart sued, arguing the offset was barred by the 10-year statute of limitations of the Debt Collection Act (1982). The district court dismissed Lockhart's suit, and the Ninth Circuit affirmed.


[Unknown Act > Conclusion]
Yes. In a unanimous opinion delivered by Justice Sandra Day O'Connor, the Court held that the Debt Collection Improvement Act made Social Security benefits subject to offset and that the Higher Education Technical Amendments removed the 10-year limit that would otherwise bar the offset.


[Unknown Act > Facts]
The Prairie Band Potawatomi Nation, a sovereign Indian tribe, raises revenue with a tax on the gasoline sold at an on-reservation gas station. The Nation purchases the gas from non-Indian, off-reservation distributors. Kansas imposed a tax on distributors of motor fuels, which the distributors pass on to the gas stations they sell to. The Nation sued Wagnon, the Secretary of the Kansas Department of Revenue, seeking to avoid the tax. The Nation argued that the state's tax interfered with the tribe's sovereignty, and therefore was not allowed by federal law. Wagnon claimed that since the tax was on off-reservation suppliers, the Nation's sovereignty was unaffected. The District Court accepted that argument and ruled for Wagnon. The Tenth Circuit Court of Appeals reversed, applying the interest-balancing test prescribed by White Mountain Apache Tribe v. Bracker. The Circuit Court found that the tribe's interests in economic development, tribal self-sufficiency, and strong tribal government out-weighed Kansas's interest in raising revenue.


[Unknown Act > Conclusion]
No. In a 7-2 decision authored by Justice Clarence Thomas, the Court ruled that the White Mountain Apache v. Bracker balancing test applies only where "a State asserts authority over the conduct of non-Indians engaging in activity on the reservation." The Court ruled for Wagnon and upheld the tax, agreeing with the District Court that the balancing test should not apply to taxes on off-reservation distributors. Justice Thomas wrote that keeping the scope of the test narrow would maintain the traditional concept of tribal sovereignty, establish a "bright-line standard" in Indian tax-immunity, and still respect tribal authority over on-reservation activities. Justice Ginsburg wrote a dissent, which Justice Kennedy joined.


[Unknown Act > Facts]
Terry Whitman works as an air traffic assistant for the Federal Aviation Administration (which is part of the Department of Transportation). Federal law requires that FAA employees who perform "safety-sensitive functions" submit to random drug tests. Whitman brought suit in federal district court, claiming that the FAA was testing him for substance abuse three times more often than other people holding similar positions. The disproportionate testing, he argued, violated his "First Amendment right to privacy" as well as his statutory rights, because the testing was not truly random.
The district court dismissed the suit, finding that the Civil Service Reform Act requires complaint's like Whitman's to be decided through the arbitration procedures set forth in the collective bargaining agreement between the FAA and the National Association of Government Employees. The Ninth Circuit Court of Appeals affirmed.


[Unknown Act > Conclusion]
No. In an anonymous 8-0 opinion, the Court reversed the Circuit Court of Appeals. The Court explained that while the Civil Service Reform Act does not itself enable federal courts to hear civil suits, neither does it remove the jurisdiction over civil suits that federal courts have under other statutes. The Justices declined to rule on whether the District Court should have taken Whitman's case, because lower courts had not determined exactly "where Whitman's claims fit within the statutory scheme." The Court sent the case back to the Court of Appeals with instructions to rule on this question. (Justice Alito took no part in the decision of this case.)


[Unknown Act > Facts]
In 1997 Vermont passed a campaign finance law, Act 64, which imposed strict limits both on expenditures by candidates for office during the election cycle and on the contributions of individuals, political groups, and parties. Neil Randall, a state legislator, sued Vermont Attorney General William Sorrell, arguing that the limits were unconstitutional infringements on First Amendment freedom of speech. In Randall's view, the Supreme Court had declared all expenditure limits unconstitutional in Buckley v. Valeo, and Act 64's contribution limits were unconstitutionally low. Sorrell countered that Buckley was outmoded because that Court had not considered one of Vermont's justifications, namely that expenditure limits prevent candidates from spending too much time trying to raise money. Sorrell also argued that Vermont's interests in combating corruption and ensuring fair elections justified the contribution limits. The District Court struck down the expenditure limits, but upheld most of the contribution limits. Only the limits on contributions by political parties - under which national, state, and local parties together could give only $400 to a statewide candidate - were unconstitutionally low. Both parties appealed the ruling to the Second Circuit Court of Appeals. The Circuit Court reversed, ruling that all of Vermont's contribution limits were constitutional. The Second Circuit also found that the expenditure limits would be constitutional as long as they were "narrowly tailored" to the state's interests.


[Unknown Act > Conclusion]
Yes and yes. The Court reversed the Circuit Court and invalidated Vermont's Act 64 by a 6-3 vote. The opinion by Justice Stephen Breyer held that the Court should let stand the Buckley decision and its invalidation of expenditure limits. Vermont's argument that such limits prevent candidates from spending too much time fund-raising was deemed irrelevant because it was "perfectly obvious" and would not have changed the result in Buckley. The Court affirmed that some limits on political contributions are constitutional, but perceived "danger signs" indicating that Vermont's exceptionally low limits could prevent candidates from campaigning effectively. Applying a 5-part test, the Court held that Vermont's contribution limits were "disproportionate to the public purposes they were enacted to advance." Justice Souter wrote a dissent, joined by Justices Ginsburg and Stevens, in which he argued that the contribution limits should be upheld and the expenditure limits should be referred to the lower courts for a determination of whether they were the "least restrictive means" of accomplishing Vermont's goals. Justice Stevens wrote a separate dissent arguing that Buckley should be overruled as it pertains to expenditure limits.


[Unknown Act > Facts]
Under West Virginia law, employers are required to either participate in a state-run workers' compensation fund or demonstrate that they are financially capable of covering any workers' compensation claims that may arise. Howard Delivery service, a West Virginia freight carrier, chose to fulfill its obligation by purchasing insurance from Zurich American Insurance Company. In January of 2002, however, the company cancelled its policy (still owing thousands of dollars in unpaid premiums) and filed for bankruptcy.
Zurich filed for special status as a creditor, arguing that the money owed to them consisted of "contributions to an employee benefit plan arising from services rendered," and that under Chapter 11 of the Bankruptcy Code they should therefore be given priority in recovering the premiums. The bankruptcy court rejected Zurich's claims, however, finding that the provision did not apply to the workers compensation insurance premiums because they were not wage-substitute-type benefits for which the company could bargain (because Howard was required by law to have some form of insurance). A federal district court affirmed the decision, but a divided panel of the Fourth Circuit Court of Appeals reversed, holding that contributions to an employee benefit plan did not need to be voluntary to meet the Chapter 11 definition.


[Unknown Act > Conclusion]
No. In a 6-to-3 decision authored by Justice Ruth Bader Ginsburg, the Supreme Court held that the workers' compensation insurance was different from the sort of employee benefit programs for which creditors could be given priority under Chapter 11. The programs for which preferred status was authorized were those whose main beneficiaries were the employees, and which could be offered as an alternative to wage increases. The workers' compensation insurance mandated in this case, however, benefited the employer as much as the employees (because it protected them from liability) and were legally required, not given as part of employment negotiations. Justice Ginsburg wrote that, though the question was a close one, "we are guided in reaching our decision by the equal distribution objective underlying the Bankruptcy Code, and the corollary principle that provisions allowing preferences must be tightly construed."


[Unknown Act > Facts]
Mr. and Mrs. Sereboff held a health insurance policy with Mid Atlantic Medical Services that was governed by the Employee Retirement Income Security Act of 1974 (ERISA). If a beneficiary is injured, Mid Atlantic pays for all covered medical expenses. However, the plan also has a provision that requires the beneficiaries to reimburse Mid Atlantic when an injury has been caused by a third party and the beneficiary receives compensation from that third party. In this case, the Sereboffs were injured in an automobile accident caused by a third party. After they settled their suit against that third party, Mid Atlantic filed suit in federal district court under section 502(a)(3) of ERISA to recover the money it had spent on medical expenses. 502(a)(3) provides that a health insurer may bring suit "to obtain ... appropriate equitable relief ... to enforce ... the terms of the plan." The Sereboff's objected, arguing that the sort of reimbursement provision at issue in this case was not "equitable" because the Sereboffs had not had the funds in their possession when they agreed to the plan. Both the district court and the Fourth Circuit Court of Appeals disagreed, siding with Mid Atlantic.


[Unknown Act > Conclusion]
Yes. Chief Justice John Roberts, for a unanimous Supreme Court, pointed to Barnes v. Alexander, 232 U.S. 117 (1914), in deciding this case. In Barnes, an attorney's promise to pay two other attorneys a portion of the money he collected from a case that had yet to be decided was held legally binding. Roberts wrote that equity had once required a contract to specify an existing fund from which money would be paid (which could not have happened in this case), but that after Barnes this was no longer the case. Roberts wrote that "the most (the Sereboffs) can muster ... are several state cases predating Barnes and a single decision that rests .. on the simple conclusion that a contractual provision purporting to secure an equitable lien did not properly do so.."


[Unknown Act > Facts]
Ideal Steel Supply Corporation filed a civil suit against its competitor, National Steel Supply, Inc. in federal court. Ideal alleged that National had failed to charge sales tax for cash purchases, giving it a competitive (but fraudulent) advantage. Under the Racketeer Influenced and Corrupt Organizations Act, "[a]ny person injured in his business or property" by racketeering activity may bring a civil suit. Ideal argued that it had been injured through lost sales because of National's illegal lower prices, and therefore had standing to sue.
The federal district court disagreed, dismissing the suit because Ideal had not had any direct encounters with National or relied on their fraudulent tax records. A Second Circuit Court of Appeals panel reversed the decision, however, finding that a company can sue under RICO when its competitor uses racketeering to gain an advantage.


[Unknown Act > Conclusion]
No. Eight members of the Supreme Court agreed that Ideal did not have standing to bring the suit because the relationship between its injuries and the fraudulent conduct of National was too remote. Justice Anthony Kennedy, writing for a seven-member majority, wrote that "[w]hen a court evaluates a RICO claim for proximate causation, the central question it must ask is whether the alleged violation led directly to the plaintiff's injuries. In the instance case, the answer is no." Justice Stephen Breyer wrote separately to say that the decisive factor in this case was not just the indirectness of the injury but also the fact that legitimate business practices (the lowering of prices) had actually caused it, even though those practices were made possible by the fraud. The ninth member - Justice Clarence Thomas - wrote that while he disagreed with the other justices' concern about directness, he too would have ruled in National's favor because the case had nothing to do with organized crime, RICO's original target.


[Unknown Act > Facts]
The Bipartisan Campaign Reform Act of 2002 (BCRA) prohibits corporate funds from being used for certain political advertisements in the 60-day period prior to an election. Wisconsin Right to Life (WRTL) ran a series of television advertisements encouraging viewers to contact two U.S. Senators and tell them to oppose judicial filibusters. WRTL anticipated that the ads would probably run afoul of BCRA and sued the Federal Election Commission (FEC), seeking an order barring the FEC from enforcing BCRA against the ads. WRTL's suit alleged that BCRA is unconstitutional as it applies to the ads, which it claimed are "grassroots lobbying advertisements" unrelated to electoral campaigning. The FEC argued that the Supreme Court in McConnell v. Federal Election Commission (2003) had ruled out all "as-applied" challenges to BCRA. The U.S. District Court for D.C. agreed and denied WRTL's motion.


[Unknown Act > Conclusion]
Yes. The unanimous per curiam opinion reversed the District Court's judgment, allowing WRTL to proceed with its as-applied challenge. The opinion explained that the District Court had misinterpreted a footnote in McConnell that seemed to foreclose such challenges. The Justices instructed the lower court to consider the larger question of whether the BCRA is constitutional as applied to WRTL's ads.


[Unknown Act > Facts]
A group of current and former employees of Mohawk Industries brought suit against Mohawk in federal district court under the Racketeer Influenced and Corrupt Organizations Act (RICO). They claimed that Mohawk had conspired with third-party employment recruiters to bring illegal immigrants into Georgia to work for the company, and that the resulting competition for jobs hurt the legal workers. Mohawk asked the court to dismiss the case because, it argued, the plaintiffs had not shown that there were two distinct entities involved in the illegal activity as required under RICO. The only parties involved were the Mohawk corporation and the third-party recruiters, which were acting as its "agents." Mohawk argued that, because the recruiters were working on behalf of the corporation rather than in cooperation with (but distinct from) it, they should not be considered separate entities. The Eleventh Circuit Court of Appeals disagreed, ruling that the recruiters and the corporation were distinct and that RICO could therefore apply.


[Unknown Act > Conclusion]
Not answered. In a per curiam opinion, the Supreme Court dismissed the case as improvidently granted. They sent it back to the Eleventh Circuit to be considered in light of Anza v. Ideal Steel Corporation, another RICO case decided while Mohawk was pending before the Court.


[Unknown Act > Facts]
Richard Ceballos, an employee of the Los Angeles District Attorney's office, found that a sheriff misrepresented facts in a search warrant affidavit. Ceballos notified the attorneys prosecuting the case stemming from that arrest and all agreed that the affidavit was questionable, but the D.A.'s office refused to dismiss the case. Ceballos then told the defense he believed the affidavit contained false statements, and defense counsel subpoenaed him to testify. Seeking damages in federal district court, Ceballos alleged that D.A.s in the office retaliated against him for his cooperation with the defense, which he argued was protected by the First Amendment. The district court ruled that the district attorneys were protected by qualified immunity, but the Ninth Circuit reversed and ruled for Ceballos, holding that qualified immunity was not available to the defendants because Ceballos had been engaged in speech that addressed matters of public concern and was thus protected by the First Amendment.


[Unknown Act > Conclusion]
In a 5-to-4 decision authored by Justice Anthony Kennedy, the Supreme Court held that speech by a public official is only protected if it is engaged in as a private citizen, not if it is expressed as part of the official's public duties. Ceballos's employers were justified in taking action against him based on his testimony and cooperation with the defense, therefore, because it happened as part of his official duties. "The fact that his duties sometimes required him to speak or write," Justice Kennedy wrote, "does not mean his supervisors were prohibited from evaluating his performance." Justices Stevens, Souter, Ginsburg and Breyer dissented.


[Unknown Act > Facts]
In 1994 Oregon enacted the Death with Dignity Act, the first state law authorizing physicians to prescribe lethal doses of controlled substances to terminally ill patients. Attorney General John Ashcroft declared in 2001 that physician-assisted suicide violated the Controlled Substances Act of 1970 (CSA). Ashcroft threatened to revoke the medical licenses of physicians who took part in the practice. Oregon sued Ashcroft in federal district court. That court and, later the Ninth Circuit, held Ashcroft''s directive illegal. The courts held that the CSA did not authorize the attorney general to regulate physician-assisted suicide, which was the sort of medical matter historically entrusted to the states.


[Unknown Act > Conclusion]
No. In a 6-3 opinion delivered by Justice Anthony Kennedy, the Court held that Congress intended the CSA to prevent doctors only from engaging in illicit drug dealing, not to define general standards of state medical practice. Moreover, the CSA did not authorize Attorney General John Ashcroft to declare a medical practice authorized under state law to be illegitimate.


[Unknown Act > Facts]
The parents of Brian Schaffer, a disabled child, sued their public school district under the Individuals with Disabilities Education Act (IDEA). Schaffer's parents claimed the Individualized Education Program that the school system devised for their son, and which IDEA required for each disabled student, was inadequate. The district court ruled for the Schaffers, but the Fourth Circuit reversed, holding that the lower court incorrectly assigned the burden of proof to the school system. Because IDEA was silent on whether the parents or the school system bear the burden of proof, the Fourth Circuit held, the general rule that the party initiating the suit bears that burden should be applied.


[Unknown Act > Conclusion]
In a 6 to 2 ruling, the Supreme Court held that the party bringing the suit bears the burden of proof, whether that party is the parents or the school system. In the majority opinion, Justice Sandra Day O'Connor wrote that "absent some reason to believe that Congress intended otherwise, ... we will conclude that the burden of persuasion lies where it usually falls, upon the party seeking relief."


[Unknown Act > Facts]
John Rapanos sought to fill in three wetland areas on his property in order to build a shopping center. Rapanos ignored warnings from the Michigan Department of Environmental Quality that the area was protected wetlands under the Clean Water Act (CWA). The CWA allows the government to regulate the discharge of any pollutant (including dirt or sand) into "navigable waters," which the Act defines as "the waters of the United States." Under regulations issued by the Army Corps of Engineers (Corps), wetlands are covered by the CWA as long as they are adjacent to traditionally navigable waters or tributaries of such waters. After Rapanos also ignored cease-and-desist orders from the U.S. Environmental Protection Agency, the government brought a civil suit against him. Rapanos argued before the District Court that the CWA gives the government jurisdiction to regulate only traditionally navigable waters. The government countered that Rapanos's lands were covered by the CWA as "adjacent wetlands" under the Corps's interpretation of the Act; the sites drained into man-made drains which eventually emptied into navigable rivers and lakes. The District Court rejected Rapanos's argument and upheld the Corps's regulations including the wetlands as "waters of the United States." The Sixth Circuit Court of Appeals affirmed, holding that the "hydrological connection" of the wetlands to the navigable waters qualifies them as "waters of the United States" under the Act.
The Carabells sought to fill in a wetland on their property in order to build a condominium, but were denied a permit because the wetland was protected under the Clean Water Act (CWA). The CWA allows the government to regulate the discharge of any pollutant (including dirt or sand) into "navigable waters," which the Act defines as "the waters of the United States." Under regulations issued by the Army Corps of Engineers (Corps), wetlands are covered by the CWA as long as they are adjacent to traditionally navigable waters or tributaries of such waters. Carabell's site is separated from a nearby ditch by a 4-foot-wide berm (earthen barrier), but the Corps's regulations specify that the wetland is nevertheless adjacent to the waterway. The ditch empties into another ditch, which in turn empties into a creek and ultimately into Lake St. Clair, a navigable water. After exhausting administrative appeals, Carabell sued in District Court. Carabell argued that the government lacked jurisdiction under the CWA to regulate the relatively isolated wetland as part of the "waters of the United States." The District Court disagreed, and upheld the Corps's expansive interpretation of the CWA. On appeal, the Sixth Circuit Court of Appeals also ruled for the Corps, holding that as long as wetlands are "adjacent" to tributaries of traditionally navigable waters and share a "significant nexus" with such waters, the wetlands qualify as "waters of the United States" for purposes of the CWA.


[Unknown Act > Conclusion]
Unanswered. The closely-divided Court split 4-1-4, with Justice Anthony Kennedy providing the crucial fifth vote to reject the Sixth Circuit's decision.
Justice Antonin Scalia wrote the plurality opinion, which was joined by three other Justices. The plurality rejected the argument that only actually-navigable waters can be regulated by the Clean Water Act, but also held that the word "navigable" in the Act cannot be divested of all meaning. The plurality held that the definitional term "waters of the United States" can only refer to "relatively permanent, standing or flowing bodies of water," not "occasional," "intermittent," or "ephemeral" flows. Furthermore, A mere "hydrological connection" is not sufficient to qualify a wetland as covered by the CWA; it must have a "continuous surface connection" with a "water of the United States" that makes it "difficult to determine where the 'water' ends and the 'wetland' begins."
Justice Kennedy wrote a separate concurring opinion, which disagreed with much of the plurality's reasoning. In Justice Kennedy's view, wetlands need not have a continuous surface connection to a continuously flowing body of water to be covered under the CWA, but mere adjacency to a tributary of a navigable water is not sufficient. Instead, Wetlands that are not adjacent to a traditionally navigable water must have a "significant nexus" with a one. This requirement is satisfied if the wetland has a significant effect on the water quality of navigable waters. Justice Kennedy suggested that Rapanos's wetlands may be covered under the CWA if more evidence of a significant nexus were presented.
Justice Stevens wrote a dissent, which was joined by Justices Souter, Ginsburg, and Breyer. The dissent argued that the Corps's regulations should be upheld as a reasonable interpretation of the Act. The inclusion of all wetlands adjacent to tributaries of navigable waters was most consistent with the CWA's purpose of eliminating pollution in the nation's waters.
Though the Court failed to obtain a majority on most of the legal issues presented by the case, the plurality and Justice Kennedy agreed to send the case back to the Sixth Circuit for a new decision based on a different analysis.


[Unknown Act > Facts]
Following his arrest for murder, Leeander Blake invoked his right to speak with a lawyer. Before Blake's attorney arrived, however, an officer and a detective approached Blake to give him a copy of the charges against him. The statement of the charges included "DEATH" as a possible penalty, although Blake was 17 years old and therefore too young to face the death penalty. The officer said to Blake "I bet you want to talk now, huh!" The detective then said "No, he doesn't want to talk to us. He already asked for a lawyer. We cannot talk to him now." A half hour later Blake decided to speak to the police without his lawyer, and he proceeded to make incriminating statements about the murder. At trial, Blake argued that the incriminating statements were the product of an illegal interrogation, and therefore inadmissible. (Under Edwards v. Arizona, police must cease interrogating a suspect after he requests an attorney, unless the suspect waives his previous request.) A county circuit court agreed with Blake, and ruled the statement inadmissible. On appeal, Maryland argued that Blake's interaction with the officer and the detective did not constitute an interrogation, because the officer's statement was a mere rhetorical question, and in any case was quickly corrected by the detective. An intermediate state appeals court agreed and allowed the statement to be admitted as evidence. However, the Maryland Court of Appeals reversed that decision, holding that the detective's correction did not reduce the severity of the officer's inappropriate statement. Since the officer's statement was ruled an illegal interrogation in violation of Blake's Miranda rights, the incriminating statement could not be used as evidence at trial.


[Unknown Act > Conclusion]
Unanswered. Shortly after oral argument, the Court dismissed the case. The anonymous Per Curiam opinion stated simply: "The writ of certiorari is dismissed as improvidently granted."