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Henderson v. United States

https://api.oyez.org/cases/2014/13-1487

13-1487

2014

Tony Henderson

United States

<p>Tony Henderson was a former United States Border Patrol Agent who was charged with, among other crimes, distribution of marijuana. On June 9, 2006, two days after he was arrested, Henderson voluntarily turned 19 firearms over to the Federal Bureau of Investigation (FBI), which he argued was for "safekeeping as a condition of the bond." He later pled guilty to his narcotics charges.</p> <p>In 2008 and 2009, Henderson requested that the FBI return his firearms so that he could transfer them to a purported buyer, but the FBI refused to do so. Henderson then moved the district court to allow him to transfer the firearms to the 2009 buyer or his wife. The magistrate judge recommended denial of the motion because Henderson was a convicted felon, and the district court adopted the recommendation. Henderson appealed and argued that, because he had not been given notice that his guilty plea would disqualify him from firearm ownership, he is entitled to relief. The U.S. Court of Appeals for the Eleventh Circuit affirmed the decision of the lower court.</p>

majority opinion

vacated/remanded

Criminal Procedure

Williams-Yulee v. The Florida Bar

https://api.oyez.org/cases/2014/13-1499

13-1499

2014

Lanell Williams-Yulee

The Florida Bar

<p>During her candidacy for County Court Judge in Hillsborough County, Florida, Lanell Williams-Yulee personally solicited campaign contributions. She stated that she served as the "community Public Defender" – although her title was "assistant public defender" – and inaccurately stated in the media that there was no incumbent in the judicial race for which she was running.</p> <p>The Florida Bar filed a complaint against Williams-Yulee and alleged that her actions during the campaign violated the rules regulating The Florida Bar. A referee was appointed who suggested that Williams-Yulee receive a public reprimand. Williams-Yulee appealed the referee's finding, and the Supreme Court of Florida held that Williams-Yulee violated bar rules for directly soliciting funds for her judicial campaign. Williams-Yulee appealed and claimed that The Florida Bar rule prohibiting a candidate from personal solicitation of funds violated the First Amendment protection of freedom of speech.</p>

majority opinion

affirmed

First Amendment

Oneok, Inc. et al. v. Learjet, Inc. et al.

https://api.oyez.org/cases/2014/13-271

13-271

2014

Oneok, Inc. et al.

Learjet, Inc. et al.

<p>Learjet, Inc. and other retail buyers of natural gas (Learjet) sued Oneok, Inc. and other energy trading companies (Oneok) for artificially increasing energy prices during the 2000–2002 energy crisis in violation of several states' antitrust laws. Learjet claimed that Oneok reported false data and engaged in "wash sales," which are prearranged sales in which traders execute a trade on an electronic trading platform, and then immediately offset that trade by executing an equal and opposite trade. Oneok moved to dismiss Learjet's claims and argued that the claims were pre-empted by the federal Natural Gas Act (NGA). The Natural Gas Act regulates interstate, wholesale natural gas trade, but it does not apply to retail sales of natural gas. The district court granted Oneok's motion to dismiss and held that Learjet's claims were pre-empted by the NGA because Oneok's actions affected wholesale prices as well as retail prices. The U.S. Court of Appeals for the Ninth Circuit reversed and held that, because Learjet suffered harm in retail transactions, which the NGA does not regulate, Learjet's claims were not pre-empted.</p>

majority opinion

affirmed

Federalism

Brumfield v. Cain

https://api.oyez.org/cases/2014/13-1433

13-1433

2014

Kevan Brumfield

Burl Cain

<p>In 1995, Kevan Brumfield was convicted of the murder of a Louisiana police officer and sentenced to death. After the Supreme Court decided <em> Atkins v. Virginia </em> in 2002, which held the execution of mentally retarded criminals violated the Eighth Amendment's prohibition of cruel and unusual punishment, Brumfield filed for post-conviction relief on the basis that he was mentally retarded. Brumfield also requested funds to help develop his <em>Atkins</em> claim. The Louisiana state court found that Brumfield was not entitled to an <em>Atkins</em> hearing because Brumfield did not present enough evidence to establish he was mentally impaired. The Louisiana Supreme Court denied his appeal without explanation.</p> <p>Brumfield next filed a petition for a writ of habeas corpus in federal court and argued that the state courts had erred in failing to give him a full <em>Atkins</em> hearing. He also requested funding to enable him to fully present his claims, which was granted. A federal magistrate found that, while the state court had correctly ruled that Brumfield's initial evidence regarding his mental retardation was not adequate for the court to have granted <em>Atkins</em> relief, the additional funds enabled Brumfield to establish a prima facie case of mental retardation. The federal magistrate subsequently recommended that the district court admit Brumfield's new evidence when determining his habeas claim; the district court did so and ruled in favor of Brumfield by forbidding Louisiana from executing him. The U.S. Court of Appeals for the Fifth Circuit reversed and held that the state court's ruling on Brumfield's <em>Atkins</em> claim constituted a decision on the merits, so the Antiterrorism and Effective Death Penalty Act prevented the district court from reviewing the decision unless the state court's decision was contrary to clearly established federal law or based on an unreasonable determination of the facts. Because the state denied Brumfield additional funds to develop his case due to his failure to establish a prima facie case of mental retardation, the decision was not a violation of Brumfield's constitutional due process rights nor based on an unreasonable determination of the facts.</p>

majority opinion

vacated/remanded

Criminal Procedure

Integrity Staffing Solutions, Inc. v. Busk

https://api.oyez.org/cases/2014/13-433

13-433

2014

Integrity Staffing Solutions, Inc.

Jesse Busk, et al.

<p>Jesse Busk and Laurie Castro were former employees of Integrity Staffing Solutions, Inc. (Integrity), a company that provides warehouse space and staffing to clients such as Amazon.com. Busk and Laurie both worked in warehouses in Nevada filling orders placed by Amazon.com customers. At the end of each day, all the workers were required to pass through a security clearance checkpoint where they had to remove their keys, wallets, and belts, pass through a metal detector, and submit to being searched. The whole process could take up to 25 minutes. Similarly, up to ten minutes of the workers' 30-minute lunch period was consumed by security clearance and transition time. In 2010, Busk and Castro sued Integrity and argued that these practices violated the Fair Labor Standards Act (FLSA) as well as Nevada state labor laws.</p> <p>The district court granted Integrity's motion to dismiss and held that time spent clearing security was non-compensable under the FLSA and that the shortened meal periods were not relevant to the FLSA because the plaintiffs did not argue that they performed work-related duties during their lunch periods. The U.S. Court of Appeals for the Ninth Circuit affirmed in part and reversed in part. While the Court of Appeals agreed that the shortened lunch periods were not relevant to the FLSA, the Court of Appeals held that the district court should have assessed the plaintiffs claims that the security clearances were "integral and indispensable" to their work in order to determine if that time was compensable.</p>

majority opinion

reversed

Unions

B&B Hardware Inc. v. Hargis Industries Inc.

https://api.oyez.org/cases/2014/13-352

13-352

2014

B&B Hardware Inc.

Hargis Industries Inc.

<p>B&amp;B Hardware (B&amp;B) sells a fastener product in the aerospace industry under the trademark "Sealtight," which it registered in 1993. Hargis Industries (Hargis) sells self-drilling screws under the mark "Sealtite" in the construction industry. After Hargis applied to register its mark in 1996, B&amp;B opposed the application and sued Hargis for infringement. The Trademark Trial and Appeal Board (TTAB) eventually determined that there was a likelihood of confusion between the two marks and denied Hargis' application. On appeal, the district court held that, because the TTAB is not an Article III court, it need not give deference to the TTAB decision and refused to admit the decision into evidence. A jury then found in favor of Hargis. The U.S. Court of Appeals for the Eighth Circuit affirmed and held that, since the Eighth Circuit uses a slightly different likelihood of confusion test from the TTAB, the TTAB did not decide the same likelihood of confusion issues presented to the district court.</p>

majority opinion

reversed/remanded

Economic Activity

Omnicare, Inc. v. Laborers District Council Construction Industry Pension Fund

https://api.oyez.org/cases/2014/13-435

13-435

2014

Omnicare, Inc. et al.

Indiana State District Council of Laborers and Hod Carriers Pension and Welfare Fund, et al.

<p>Plaintiffs were investors who bought Omnicare securities in a December 15, 2005 public offering. At the same time, Omnicare offered 12.8 million shares of common stock and made related filing with the Securities and Exchange Commission. These filings were incorporated into a Registration Statement. The plaintiffs sold all the securities by January 31, 2006. Plaintiffs brought suit under §11 of the Securities Act of 1993 claiming Omnicare materially misled or omitted material information on the registration statement because they were engaged in illegal activities that included kickback arrangements with pharmaceutical manufacturers and submitting false claims to Medicare and Medicaid. Plaintiffs further allege that Omnicare failed to comply with Generally Accepted Accounting Principles (GAAP), which resulted in a substantial overstatement of the company's revenue affecting the 2005 public offering.</p> <p>The original suit filed in the district court had multiple claims from which this case arose, but all were dismissed in favor of Omnicare. The claims were dismissed because the plaintiffs failed to plead that the defendants had knowledge of wrongdoing when they materially falsified information on the registration statement. The United States Court of Appeals for the Sixth Circuit affirmed the dismissals except one filed under §11 for materially misleading or omitting material information because that claim was filed under a strict liability statute which did not require pleading to knowledge of wrongdoing. The Court held that plaintiffs had met their burden for making a prima facie case under §11 and remanded the case to district court.</p>

majority opinion

vacated/remanded

Economic Activity

Reed et al. v. Town of Gilbert, Arizona et al.

https://api.oyez.org/cases/2014/13-502

13-502

2014

Clyde Reed, et al.

Town of Gilbert, Arizona, et al.

<p>Clyde Reed, pastor of Good News Community Church (Good News), rented space at an elementary school in Gilbert, Arizona, and placed about 17 signs in the area announcing the time and location of Good News' services. Gilbert has an ordinance (Sign Code) that restricts the size, number, duration, and location of certain types of signs, including temporary directional ones, to prevent improper signage. After Good News received an advisory notice from Gilbert that it violated the Sign Code, Good News sued Gilbert and claimed that the Sign Code violated the Free Speech Clause of the First Amendment and the Equal Protection Clause of the Fourteenth Amendment.</p> <p>The district court found that the Sign Code was constitutional since it was content-neutral and was reasonable in light of the government interests. The U.S. Court of Appeals for the Ninth Circuit affirmed and held that, even though an official would have to read a sign to determine what provisions of the Sign Code applied, the restrictions were not based on the content of the signs, and the Sign Code left open other channels of communication.</p>

majority opinion

reversed/remanded

First Amendment

Warger v. Shauers

https://api.oyez.org/cases/2014/13-517

13-517

2014

Gregory P. Warger

Randy D. Shauers

<p>In 2006, Gregory Warger was involved in an automobile collision with another car driven by Randy Shauers. Warger filed suit against Shauers for damages resulting from the crash, and Shauers filed a counter-suit. After an initial mistrial, a jury found for Shauers. Warger appealed on the basis that, following the verdict, Warger's attorney had been contacted by a jury member who expressed concern that the jury foreperson had improperly gained the sympathy of the other jurors by informing them all that her daughter had been in a similar type of automobile accident and that the verdict would have had a negative impact on her life had she been found responsible. Warger claimed that the foreperson's alleged misconduct should result in a new trial because it was improper outside influence, which tainted the jury's verdict, and because it was evidence that the foreperson had lied during jury selection.</p> <p>The district court ruled that the concerned jury member's statement was inadmissible based on Federal Rule of Evidence 606(b), which bars the testimony of a juror concerning any statements made during the jury's deliberations for purposes determining the validity of a verdict, with an exception for testimony regarding whether an improper outside influence was used to persuade any juror. Specifically, the court ruled that the past life experiences of the foreperson did not constitute improper outside influence. While 606(b) does not explicitly bar juror testimony for the purposes of proving dishonesty by a potential juror during jury selection, in this case the evidence was barred by 606(b) because it was based on statements the foreperson made during the jury's deliberations. The U.S. Court of Appeals for the Eighth Circuit affirmed.</p>

majority opinion

affirmed

Criminal Procedure

North Carolina Board of Dental Examiners v. Federal Trade Commission

https://api.oyez.org/cases/2014/13-534

13-534

2014

North Carolina Board of Dental Examiners

Federal Trade Commission

<p>The North Carolina State Board of Dental Examiners (Board) is a statutorily created agency that regulates the practice of dentistry. It is composed of six dentists⎯who are elected by other dentists in North Carolina⎯one dental hygienist, and one consumer member. The Board may bring an action in the North Carolina Superior Court to enjoin the conduct of any individual the Board suspects of engaging in the unlawful practice of dentistry.</p> <p>In 2003, non-dentists began offering teeth-whitening services to consumers in mall kiosks and salons across the state. After dentists complained, the Board sent 47 cease and desist letters to 29 non-dentist teeth-whiteners. The non-dentists ceased offering the service, and manufacturers and distributors of over-the-counter teeth-whitening products exited the North Carolina market.</p> <p>The Federal Trade Commission (FTC) subsequently charged the Board with violating the Federal Trade Act by excluding the non-dentists. An Administrative Law Judge found that the Board had engaged in unfair competition and enjoined the Board from issuing any more cease and desist letters; the FTC upheld that ruling on appeal. The Board petitioned the U.S. Court of Appeals for the Fourth Circuit to review the FTC decision and argued that, as a state agency, it was exempt from federal antitrust laws. The Court of Appeals declined to review the case and held that, when a state agency is operated by market participants who are elected by other market participants, the agency is a private actor and subject to federal antitrust laws.</p>

majority opinion

affirmed

Economic Activity

Comptroller of the Treasury of Maryland v. Wynne

https://api.oyez.org/cases/2014/13-485

13-485

2014

Maryland State Comptroller of Treasury

Brian Wynne et ux.

<p>Brian Wynne and his wife are Howard County, Maryland residents who own stock in Maxim Healthcare Services, Inc. (Maxim), a company that provides health care services nationally. Maxim's income is "passed through" to its owners, and the owners are then taxed individually. In 2006, Maxim filed income tax returns in 39 states and allocated a share of taxes paid to each shareholder. The Wynnes claimed the share of Maxim's income taxes that they paid as a credit against their Maryland individual income tax, which includes Maryland state taxes and Howard County taxes. The Comptroller of Maryland determined that the Wynnes had incorrectly calculated their county tax credit by including the taxes they had paid to other states and issued an assessment for the remaining tax owed. The Wynnes appealed to the Hearings and Appeals Section of the Comptroller's Office, which noted that the wrong county tax rate had been applied initially and revised the assessment, but nonetheless affirmed that the tax credit was limited to Maryland state taxes and not applicable to Howard County taxes.</p> <p>The Wynnes appealed to the Maryland Tax Court and argued that the limitation violated the dormant Commerce Clause of the Constitution. The Tax Court rejected the Wynnes' argument and affirmed the revised assessment. The Wynnes then appealed to the Maryland Circuit Court for Howard County. The Circuit Court reversed the Tax Court's decision and held that the county tax without a credit violated the dormant Commerce Clause. The Comptroller appealed to the Maryland Court of Appeals and argued that the Commerce Clause was not implicated by the county tax. The Maryland Court of Appeals affirmed the Circuit Court by finding that the county tax implicates the dormant Commerce Clause because it affects the interstate market for capital and business investment and the overlapping power to tax income from such sources. The Maryland Court of Appeals held that the county tax without a credit violated the Commerce Clause because the county tax is not fairly apportioned, since taxpayers who earn income from interstate activities would be taxed at higher rates than taxpayers who earn income exclusively in Maryland while the tax covers income earned wholly outside of Maryland. The Maryland Court of Appeals also held that the county tax is discriminatory against interstate commerce since it favors businesses that do business primarily in Maryland.</p>

majority opinion

affirmed

Economic Activity

Tibble v. Edison International

https://api.oyez.org/cases/2014/13-550

13-550

2014

Glenn Tibble, et al.

Edison International, et al.

<p>Edison International is a holding company for electric utilities and energy interests. Since 1999, Edison International and its related benefits and investment committees (collectively, Edison) have offered retail-class mutual funds as part of its 401(k) employee benefits plan, even though otherwise identical institutional-class funds that charged lower fees were available. Those mutual funds also give a portion of the fees collected back to plan service providers, including Edison's, which thereby reduces Edison's administrative costs.</p> <p>In 2007, Glenn Tibble and other Edison employees (Employees) sued under the Employee Retirement Income Security Act of 1974 (ERISA), which requires fiduciaries of an employee benefit plan to administer the plan prudently for the exclusive benefit of the participants. The Employees argued that the continued inclusion of the higher-cost funds in the benefit plan was a "continuing violation" of ERISA. Edison argued that ERISA's statute of repose, which bars claims filed more than six years after the date of the last action which constituted a part of the violation, prevented Employees' claim. The district court granted summary judgment for Edison and held that there was no "continuing violation" theory under ERISA. The court stated that the act of designating an investment for inclusion started the six-year period, and since Edison had not made any misstatements or actively concealed any breach following the initial inclusion, the six-year period had passed. The U.S. Court of Appeals for the Ninth Circuit affirmed.</p>

majority opinion

vacated/remanded

Economic Activity

Heien v. North Carolina

https://api.oyez.org/cases/2014/13-604

13-604

2014

Nicholas B. Heien

State of North Carolina

<p>On April 29, 2010, Sergeant Darisse of the Surry County Sheriff's Department observed Maynor Javier Vasquez driving north on I-77 with a broken brake light. When Darisse pulled over the vehicle, he noticed another man, Nicholas Heien, lying under a blanket in the backseat. Darisse spoke with the two men, felt that their stories did not match up, and was concerned that Heien had not gotten up from the back seat. Darisse asked for permission to search the vehicle. Heien agreed, and Darisse found a bag containing 54.2 grams of cocaine in the car.</p> <p>A grand jury indicted Heien for two counts of trafficking cocaine. Heien filed a motion to suppress the evidence discovered during the search of his vehicle, and the trial court denied the motion. The North Carolina Court of Appeals reversed the trial court and held that the traffic stop was not objectively reasonable because North Carolina law only required one working brake light. The North Carolina Supreme Court reversed and held that when an officer's mistake of the law is reasonable, it may give rise to the "reasonable suspicion" required for a traffic stop of a vehicle under the Fourth Amendment. That North Carolina Supreme Court sent the case back to the state Court of Appeals.</p> <p>The North Carolina Court of Appeals found no error in the trial court's judgment. A dissenting judge, however, stated that the North Carolina Supreme Court's ruling created "fundamental unfairness" because it held citizens to the traditional rule that "ignorance of the law is no excuse" while allowing police to be ignorant of the law. Based on this dissent, Heien again appealed to the North Carolina Supreme Court which rejected Heien's appeal.</p>

majority opinion

affirmed

Criminal Procedure

Alabama Department of Revenue v. CSX Transportation, Inc.

https://api.oyez.org/cases/2014/13-553

13-553

2014

Alabama Department of Revenue, et al.

CSX Transportation, Inc.

<p>Alabama imposes a 4% sales tax on the gross receipts of retail businesses and a 4% use tax on storage, use, or consumption of tangible personal property. Accordingly, rail carriers that purchase diesel fuel within the state are subject to a 4% sales tax. However, motor and water carriers that purchase fuel in Alabama pay an excise tax of $0.19 per gallon.</p> <p>In 2008, CSX Transportation, Inc. (CSX) sued the Alabama Department of Revenue for violating the Railroad Revitalization and Regulatory Reform Act of 1974 (4-R Act), which targeted local and state taxation schemes that discriminated against rail carriers. CSX argued that the sales tax was discriminatory because it required the rail carriers to pay more than their competitors for purchasing diesel fuel in the state. The district court dismissed the case and U.S. Court of Appeals for the Eleventh Circuit affirmed the dismissal by citing precedent that held that a railroad could not challenge its competitors' exemptions from a sales tax as discriminatory under the 4-R Act. The Supreme Court granted certiorari, overturned the ruling, and remanded the case. On remand, the district court conducted a bench trial and issued an order holding that the state's sales tax does not discriminate against rail carriers for the purposes of the 4-R Act, because the amount that motor carriers paid was roughly equal to that paid by rail carriers. The Court of Appeals reversed the lower court's decision and held that the tax is discriminatory because the state had not offered sufficient justification for exempting CSX's competitors from the sales tax.</p>

majority opinion

reversed/remanded

Economic Activity

Public Employees' Retirement System v. IndyMac MBS, Inc.

https://api.oyez.org/cases/2013/13-640

13-640

2013

Public Employees' Retirement System of Mississippi, et al.

IndyMac MBS, Inc., et al.

<p>IndyMac MBS, Inc. (IndyMac MBS) is an issuer of mortgage-backed securities that issued securities known as mortgage pass-through certificates. The Police and Fire Retirement System of the City of Detroit and the Wyoming Retirement System filed two separate class action suits on behalf of asserted members of the class who had purchased some of the certificates. The suits claimed that IndyMac MBS had made fraudulent misrepresentations and omissions regarding the sale of the certificates. The district court consolidated these suits and dismissed the claims for lack of standing.</p> <p>Despite the fact that the three-year statute of limitation set out in the Securities Act of 1933 had expired, several putative class members sought to intervene and revive the claims. They argued that the rule established in <em>American Pipe &amp; Construction Co. v. Utah</em>, which allowed the commencement of a class action to suspend the statute of limitations as it relates to members of the class, applied in this case. They also argued that Rule 15(c) of the Federal Rules of Civil Procedure allowed them to "relate back" their claims to the original class action suit. The district court denied the motions to intervene, and the U.S. Court of Appeals for the Second Circuit affirmed.</p>

dismissal - improvidently granted

none

Zivotofsky v. Kerry

https://api.oyez.org/cases/2014/13-628

13-628

2014

M. B. Z., By His Parents and Guardians, Ari Z. Zivotofsky, et ux.

John Kerry, Secretary of State

<p>In 2002, Manachem Zivotofsky was born in Jerusalem to parents who are United States citizens. Manachem's parents requested that the U.S. State Department record his place of birth on his passport as "Israel," in accordance with Section 214(d) of the Foreign Relations Authorization Act of 2003 (Act). The State Department refused and instead issued Manachem a passport that listed "Jerusalem" as his place of birth. His parents sued the Secretary of State on his behalf and sought the enforcement of Section 214(d). The district court dismissed the case on the grounds that it presented a non-justiciable political question. The U.S. Supreme Court, in <em>Zivotofsky v. Clinton</em>, reversed that holding and remanded the case. On remand, the district court held that Section 214(d) "impermissibly intereferes" with the President's exclusive power to recognize foreign states. The U.S. Court of Appeals for the District of Columbia Circuit affirmed and held that the section goes beyond the scope of Congress's passport power to affect United States foreign policy, which is a realm the Constitution reserves for the executive branch.</p>

majority opinion

affirmed

Miscellaneous

Holt v. Hobbs

https://api.oyez.org/cases/2014/13-6827

13-6827

2014

Gregory Houston Holt

Ray Hobbs, Director, Arkansas Department of Corrections, et al.

<p>Gregory Holt (also known as Abdul Maalik Muhammad) was an inmate of the Arkansas Department of Corrections and a practicing Salafi Muslim. He sought an injunction and temporary relief from the enforcement of the Arkansas Department of Corrections' grooming policy, which allowed trimmed mustaches and quarter-inch beards for diagnosed dermatological problems but otherwise no facial hair. Holt argued that growing a beard was a necessary part of the practice of his religion, that the grooming policy significantly burdened his ability to do so, and that the grooming policy was therefore a violation of the Religious Land Use and Institutionalized Persons Act (RLUIPA). Holt was willing to limit his beard to a length of one-half inch as a form of compromise with the policy.</p> <p>The district court granted temporary relief but then dismissed the complaint upon being presented with evidence of the other ways in which Holt was allowed to practice his religion and the extent to which the grooming policy was necessary to maintain prison security. The U.S. Court of Appeals for the Eighth Circuit affirmed.</p>

majority opinion

reversed/remanded

First Amendment

Jesinoski v. Countrywide Home Loans, Inc.

https://api.oyez.org/cases/2014/13-684

13-684

2014

Larry D. Jesinoski, et ux.

Countrywide Home Loans, Inc., et al.

<p>On February 23, 2007, Larry and Cheryle Jesinoski refinanced their Eagan, Minnesota, home by borrowing $611,000 from Countrywide Home Loans, Inc. The Jesinoskis received a Truth in Lending Act (TILA) disclosure and a Notice of the Right to Cancel, which gave them until midnight on February 27, 2007, to rescind the loan. The Jesinoskis did not exercise their right to cancel the loan, and they used the money to pay off several consumer debts. On February 23, 2010, the Jesinoskis attempted to rescind the loan and argued that they did not receive sufficient copies of the TILA disclosure and the Notice of the Right to Cancel. After the request to rescind the loan was denied, the Jesinoskis sued Countrywide Home Loans for failure to rescind their loan on February 24, 2011.</p> <p>Countrywide Home Loans sought a judgment on the pleadings and argued that the Jesinoskis did not file their suit within the three-year time period allowed by TILA. The Jesinoskis argued that, because they attempted to rescind the loan within the three-year time period, their suit fulfills that requirement and should be allowed to proceed. The district court found in favor of Countrywide Home Loans; the U.S. Court of Appeals for the Eighth Circuit affirmed.</p>

majority opinion

reversed/remanded

Economic Activity

Johnson v. United States

https://api.oyez.org/cases/2014/13-7120

13-7120

2014

Samuel Johnson

United States

<p>In 2010, the Federal Bureau of Investigation (FBI) began investigating Samuel Johnson based on his involvement in an organization called the National Social Movement. Later in 2010, Johnson left that group to found the Aryan Liberation Movement. In November of that year, Johnson told an undercover FBI agent that he manufactured napalm, silencers, and other explosives for the Aryan Liberation Movement in addition to possessing an AK-47 rifle, several semi-automatic weapons, and a large cache of ammunition. In April 2012, Johnson was arrested at a meeting with his probation officer and admitted to possessing some of the previously mentioned weapons.</p> <p>A grand jury charged Johnson with six counts of firearm possession, three of which relied on his classification as an "armed career criminal." This classification was based on the fact that he had three prior felony convictions that the district court designated as "violent felonies"—attempted simple robbery, simple robbery, and possession of a short-barreled shotgun. Pursuant to the Armed Career Criminal Act (ACCA), Johnson was then subject to a mandatory minimum sentence of 15 years. Johnson argued that the convictions in question should not be considered violent felonies and that the ACCA was unconstitutionally vague. The district court held that the felony convictions in question were in fact violent felonies and that Johnson was an armed career criminal for the purposes of the mandatory minimum sentence required by the ACCA. The U.S. Court of Appeals for the Eighth Circuit affirmed.</p>

majority opinion

reversed

Due Process

Jennings v. Stephens

https://api.oyez.org/cases/2014/13-7211

13-7211

2014

Robert Mitchell Jennings

William Stephens, Director of the Texas Department of Criminal Justice, Correctional Institutions Division

<p>On July 19, 1988, Houston Police Officer Elston Howard was in the midst of arresting the clerk of an adult bookstore when Robert Mitchell Jennings entered the store intending to rob it. Jennings shot Officer Howard four times and then proceeded to rob the store. The trial court jury subsequently convicted Jennings of capital murder. In the sentencing phase of the trial, the prosecution presented evidence of Jennings' long criminal history as an aggravating factor. The defense called the jail chaplain to testify to his opinion that Jennings was not "incorrigible," and the defense did not present any further evidence of mitigating factors.</p> <p>In 1996, Jennings filed a state habeas petition and argued that he had received ineffective assistance of counsel at the punishment phase because his attorneys had failed to contact his family to provide evidence of a disadvantaged background and had failed to find and present a 1978 psychological report that suggested that Jennings had a "mild organic brain dysfunction." The state court held that Jennings' attorneys had conducted a sufficient investigation into his background, and that their decision not to introduce this testimony and evidence was a reasonable trial strategy. The state court recommended that the Texas Court of Criminal Appeals deny the request for habeas relief, and the Texas Court of Criminal Appeals acted accordingly.</p> <p>In 2009, Jennings filed a federal habeas petition with the district court. The district court granted the petition and held that Jennings had received ineffective assistance of counsel because his attorneys failed to present evidence of his disadvantaged background and possible mental incapacities. The U.S. Court of Appeals for the Fifth Circuit reversed and held that Jennings' counsel's decision not to pursue these avenues of argument was a legitimate trial strategy. The Court of Appeals also held that a federal habeas petitioner must file a certificate of appealability in order to respond to arguments concerning the state's appeal.</p>

majority opinion

reversed/remanded

Criminal Procedure

Dart Cherokee Basin Operating Company LLC v. Owens

https://api.oyez.org/cases/2014/13-719

13-719

2014

Dart Cherokee Operating Company, LLC, et al.

Brandon W. Owens

<p>On October 30, 2012, Brandon W. Owens filed a class action petition in state court that alleged that Dart Cherokee Basin Operating Company and Cherokee Basin Pipeline underpaid the members on the class on royalties they were owed from wells. The petition alleged that this underpayment constituted a breach of contract and sought damages without specifying an amount.</p> <p>On December 5, 2012, the defendants removed the case from state court to federal district court and cited that federal jurisdiction existed under the Class Action Fairness Act of 2005 (CAFA). CAFA requires that three elements be established for a class action case to fall under federal jurisdiction: at least one plaintiff and one defendant must be citizens of different states, the class must consist of at least 100 members, and the amount in controversy must exceed $5 million. The defendants in this case claimed that they met the requirements for removal to federal court under CAFA because the amount in controversy exceeded $8 million, but did not include specific evidence in the notice of removal. The federal district court held that defendants had not provided evidence that the amount in controversy exceeded $5 million in the notice of removal and therefore remanded the case back to state court.</p> <p>The U.S. Court of Appeals for the Tenth Circuit held that the district court should not have remanded the case because requiring the party requesting the removal to produce evidence that the amount in controversy exceeds $5 million creates an evidentiary burden. The Court of Appeals held that that such evidence is wholly unnecessary unless the removal is contested. A party requesting that a case be removed to federal court need only allege that the grounds for removal exist and need only prove those allegations if they are contested.</p>

majority opinion

vacated/remanded

Judicial Power

Kimble v. Marvel

https://api.oyez.org/cases/2014/13-720

13-720

2014

Stephen Kimble, et al.

Marvel Enterprises, Inc.

<p>In 1990, Stephen Kimble obtained a patent for a Spider-Man toy that was set to expire in May 2010. Kimble claimed that he discussed the idea with the president of Marvel Enterprises Inc., and that he would be compensated for use of his ideas. Although no agreement was reached, Marvel produced a toy that was similar to Kimble's design. In 1997, Kimble sued for patent infringement, and the parties settled in 2001, with Marvel agreeing to purchase the patent and pay royalties to the petitioner without an expiration date. The case was subsequently dismissed. In 2006, Marvel entered a licensing agreement with Hasbro Inc. that gave it the right to produce the toy. Disagreements arose between Kimble and Marvel concerning the royalty payments, and Kimble claimed that the original patent would be infringed if royalties were not paid. Kimble sued Marvel in Arizona state court, and the case was then removed to the federal district court.</p> <p>The magistrate judge determined that settlement agreement was a "hybrid" agreement, in which patent and non-patent rights were inseparable, and that the Supreme Court decision in <em>Brulotte v. Thys Co.</em> applied. In that case, the Court ruled that, when patents are sold in return for a royalty payment, the purchaser was not obligated to continue these payments beyond the expiration date of the patents because doing so would over-compensate the seller of the patent and improperly extend the patent monopoly beyond the intended time limit. On recommendation of the magistrate, the district court granted summary judgment in favor of Marvel and ruled that the settlement agreement transferred patent rights, but that it was unclear if non-patent rights were transferred. Kimble appealed and argued that the settlement agreement transferred both patent and non-patent rights and that, while royalty payments ended for the patent, they did not end for the toy itself. The U.S. Court of Appeals for the Ninth Circuit affirmed the decision of the district court.</p>

majority opinion

affirmed

Economic Activity

Yates v. United States

https://api.oyez.org/cases/2014/13-7451

13-7451

2014

John L. Yates

United States

<p>On August 17, 2007, John L. Yates and his crew prepared his fishing vessel for a commercial fishing trip into federal waters in the Gulf of Mexico. On August 23, 2007, Officer John Jones, a field officer with the Florida Fish and Wildlife Conservation Commission who was empowered to enforce federal fisheries laws, boarded the vessel and noticed red grouper fish that appeared to be smaller than the requisite 20 inches. Officer Jones measured the grouper that appeared smaller and found a total of 72 fish that measured under 20 inches. Officer Jones placed these fish in wooden crates, issued Yates a citation, and informed Yates that the National Marine Fisheries Service would seize these fish upon the vessel's return to port. Contrary to Officer Jones' directions, Yates instructed his crew to throw the fish in question overboard and replace them with larger fish. When the vessel returned to port and the fish were measured on August 27, Officer Jones suspected that Yates had disposed of the fish he had measured.</p> <p>Yates was charged with destruction and falsification of evidence. At trial he argued that the fish thrown overboard were not actually undersized because Officer Jones had measured the fish with their mouths closed, which shortens the length of fish. The district court found Yates guilty of disposing of undersized fish and therefore in violation of a statute that makes it a crime to destroy or conceal "a tangible object with the intent to impede, obstruct, or influence" a governmental investigation. The U.S. Court of Appeals for the Eleventh Circuit affirmed.</p>

majority opinion

reversed/remanded

Criminal Procedure

Teva Pharmaceuticals USA, Inc. v. Sandoz, Inc.

https://api.oyez.org/cases/2014/13-854

13-854

2014

Teva Pharmaceuticals USA, Inc.

Sandoz, Inc., et al.

<p>Sandoz, Inc., (Sandoz) and Mylan Pharmaceuticals, Inc. (Mylan) submitted Abbreviated New Drug Applications (ANDAs) to the Food and Drug Administration (FDA) to produce and market generic versions of Copaxone, a drug used to treat Multiple Sclerosis. Teva Pharmaceuticals USA, Inc., the manufacturer of the original drug, sued Sandoz and Mylan and used two different types of claims that are based on different ways to use molecular weight to distinguish between polymer samples. The district court did not distinguish between the different methods of using molecular weight and held that the claims were not indefinite as Sandoz and Mylan argued. After a bench trial, the district court held that the Sandoz and Mylan products infringed on Teva's patent.</p> <p>The U.S. Court of Appeals for the Federal Circuit held that the district court did not error in holding that the patents were infringed, but that some of the claims had not been effectively shown to be definite.</p>

majority opinion

vacated/remanded

Economic Activity

Alabama Legislative Black Caucus v. Alabama

https://api.oyez.org/cases/2014/13-895

13-895

2014

Alabama Democratic Conference, et al.

Alabama, et al.

<p>The Voting Rights Act of 1965 focuses on preserving the equal representation of voters in different legislative voting districts. In 2012, the Alabama legislature redrew Alabama’s electoral districts with the goal of creating districts with a population deviation of only 1%, as opposed to the 5% courts traditionally allow when evaluating redistricting efforts. Alabama also tried to maintain the existing percentage of minority voters in each electoral district. Petitioners sued in district court and argued that Alabama’s redistricting violated the Voting Rights Act and amounted to racial gerrymandering that had negative impacts on the equal representation of racial minorities in multiple electoral districts. The district court held that the petitioners had failed to prove that Alabama used race as a “dominant and controlling” factor in redrawing its electoral districts and also that Alabama’s goal of maintaining the minority population percentages in existing districts was “narrowly tailored” to a compelling state interest. The Supreme Court noted probable jurisdiction to address the district court’s application of existing legal principles.</p>

majority opinion

vacated/remanded

Civil Rights

Department of Homeland Security v. MacLean

https://api.oyez.org/cases/2014/13-894

13-894

2014

Department of Homeland Security

Robert J. MacLean

<p>In July 2003, the Transportation Security Administration (TSA) learned of a potential plot to hijack US planes and briefed the Federal Air Marshals accordingly. Not long after that briefing, the TSA notified the Marshals that all missions on flights from Las Vegas would be cancelled until August. Federal Air Marshal Robert J. MacLean became concerned that the TSA was not appropriately responding to the threat and creating a danger to the flying public, so he contacted an MSNBC reporter about the situation in an attempt to create a public controversy. MSNBC published an article, and several members of Congress joined in criticizing the decision to cancel the missions. That decision was then rescinded. In 2004, MacLean appeared disguised on NBC Night News, and some TSA employees recognized his voice. During the course of the investigation that followed, MacLean revealed his role in the 2003 MSNBC article. This contact was deemed to be an unauthorized disclosure of sensitive security information, and MacLean was removed from his position.</p> <p>MacLean challenged the determination that he disclosed sensitive security information before the U.S. Court of Appeals for the Ninth Circuit. MacLean argued that the information about the cancellation of missions was not classified at the time he received it and could not be retroactively classified. The Court of Appeals held that the TSA had simply applied regulations already in force in 2003 to determine that information should fall under that classification. MacLean also challenged his removal before the Merit Systems Protection Board (Board) and argued that his actions were protected under the Whistleblower Protection Act (WPA). The Board determined that MacLean's actions did not fall under the WPA because they were explicitly prohibited by law. The U.S. Court of Appeals for the Federal Circuit reversed the Board's ruling and held that MacLean's actions were not explicitly prohibited by law under the WPA.</p>

majority opinion

affirmed

First Amendment

Lopez v. Smith

https://api.oyez.org/cases/2014/13-946

13-946

2014

Raul Lopez, Warden

Marvin Vernis Smith

<p>On December 15, 2005, Minnie Smith was found dead in the home she shared with her husband, Marvin Smith. Smith was charged with first-degree murder for the death of his wife. At the end of the trial, the prosecution asked for and received an aiding-and-abetting instruction, which would allow the jury to convict Smith even if they found that he had not delivered the fatal blow. The jury convicted Smith but did not specify which theory of guilt they adopted. The California Court of Appeal affirmed the conviction and rejected Smith's argument that he had not been given adequate notice of the possibility of the aiding-and-abetting instruction. The California Supreme Court denied Smith's petition for review.</p> <p>Smith filed a petition for habeas relief. The Magistrate Judge recommended granting the relief, and the district court agreed. The U.S. Court of Appeals for the Ninth Circuit affirmed and held that Smith should have been aware that the aiding-and-abetting instruction was possible because under California law aiding and abetting the crime is part of the same substantive offense as the commission of the crime itself. However, the appellate court held that Smith's Sixth Amendment right had been violated because the prosecution had tried the case on a single theory before adding the second instruction at the very end of the trial. In reaching this decision, the appellate court relied on its own precedent, which it claimed faithfully applied Supreme Court precedent.</p>

per curiam

reversed/remanded

Criminal Procedure

Commil USA, LLC v. Cisco Systems, Inc.

https://api.oyez.org/cases/2014/13-896

13-896

2014

Commil USA, LLC

Cisco Systems, Inc.

<p>Commil USA, LLC (Commil) holds a patent on a method to implement short-range wireless networks. Commil sued Cisco Systems, Inc. (Cisco) and alleged that Cisco performed the patented method and induced its customers to infringe by performing the patented method. Cisco argued that Commil's patent was invalid for indefiniteness, non-enablement, and lack of written description. The district court found for Commil and awarded more than $70 million in damages. Cisco appealed and argued that the trial court erroneously instructed the jury that the standard for inducement was negligence and precluded the submission of evidence of Cisco's good-faith belief that Commil's patent was invalid. The U.S. Court of Appeals for the Federal Circuit reversed and held that the standard for induced infringement is actual knowledge or willful blindness, and therefore that a good-faith belief of patent invalidity was a defense to claims of induced infringement.</p>

majority opinion

vacated/remanded

Economic Activity

Whitfield v. United States

https://api.oyez.org/cases/2014/13-9026

13-9026

2014

Larry Whitfield

United States

<p>On September 26, 2008, Larry Whitfield and Quanterrious McCoy attempted to rob the Fort Financial Credit Union in Gastonia, North Carolina. After their robbery attempt was foiled by the bank's security system, the two fled. McCoy was later found hiding under a van, while Whitfield entered the Parnell residence and attempted to contact a getaway vehicle. Mary Parnell was subsequently pronounced dead of a heart attack. Whitfield was arrested nearby and signed a confession admitting to breaking into several homes as well as the attempted bank robbery.</p> <p>A grand jury indicted McCoy and Whitfield on several counts relating to the failed robbery, but only Whitfield was indicted for forcing someone to accompany him and killing that person while trying to avoid being apprehended for the commission of a crime. Whitfield moved to dismiss this charge and argued that it was unconstitutionally vague and that the prosecution was required to prove that he intentionally caused Parnell's death. The district court denied the motion. Prior to the jury's deliberations, the district court instructed the jury that, in order to find Whitfield guilty of the additional charge, it only needed to find that his actions were the proximate cause of Parnell's death, and it did not include a minimum limit on the degree of accompaniment necessary. Whitfield objected to the instruction and the court overruled the objection. Whitfield was found guilty, but on the additional charge he was found guilty of forcing Parnell to accompany him, not of killing her. The U.S. Court of Appeals for the Fourth Circuit vacated Whitfield's conviction and remanded the case for rehearing on the issue of whether or not the district court constructively amended the indictment in its jury instructions. On remand, the district court again found Whitfield guilty and the Court of Appeals affirmed.</p>

majority opinion

affirmed

Criminal Procedure

T-Mobile South, LLC v. City of Roswell, Georgia

https://api.oyez.org/cases/2014/13-975

13-975

2014

T-Mobile South, LLC

City of Roswell, Georgia

<p>Telecommunications service provider T-mobile South, LLC (T-mobile) submitted an application to construct a 108–foot cell tower resembling a man-made tree (monopine) in Roswell, Georgia. The location of the site, though planned inside a vacant lot, would be in an area zoned for single-family residences within a well-established residential neighborhood. Following an outpouring of public opposition to the tower, Roswell's Planning and Zoning Division recommended that the Mayor and city council, who ultimately approve applications after a public hearing, impose certain conditions before approving the application. Specifically, the Planning and Zoning Division recommended that T-Mobile should relocate the site to another part of the property, erect a fence around the tower, and plant pine trees to shield it from residential owners' view. At the public hearing, city council members voted to deny the application.</p> <p>Two days later, Roswell sent T-Mobile a letter notifying the company that the application was denied and referred the company to the minutes of the public hearing. T-Mobile sued Roswell and claimed that the city had not provided substantial evidence that would support a denial of the application. T-Mobile also alleged that, by prohibiting T-Mobile from building the structure, Roswell violated the Telecommunications Act of 1996 (TCA). The district court did not rule on the substantial evidence question and instead held that Roswell had not met the "in writing" component of the TCA, which required the government to state the reason(s) for denying an application. The district court ordered Roswell to grant the permit, and Roswell appealed. The U.S. Court of Appeals for the Eleventh Circuit held that Roswell had met the "in writing" requirement by issuing a written denial and referring to the minutes of the hearing for the reasoning.</p>

majority opinion

reversed/remanded

Economic Activity

Elonis v. United States

https://api.oyez.org/cases/2014/13-983

13-983

2014

Anthony Elonis

United States

<p>Anthony Elonis was convicted under 18 U. S. C. §875(c), which criminalizes the transmission of threats in interstate commerce, for posting threats to injure his coworkers, his wife, the police, a kindergarten class, and a Federal Bureau of Investigation agent on Facebook. The district court instructed the jury that a "true threat," which falls outside the scope of First Amendment speech protections, requires an objective intent to threaten. Elonis appealed and argued that "true threats" require a subjective intent to threaten. The U.S. Court of Appeals for the Third Circuit affirmed Elonis' conviction and held that a subjective intent standard would fail to protect individuals from the fear of violence which the "true threat" exception was created to prevent.</p>

majority opinion

reversed/remanded

Criminal Procedure

Wellness International Network v. Sharif

https://api.oyez.org/cases/2014/13-935

13-935

2014

Wellness International Network, Ltd., et al.

Richard Sharif

<p>Richard Sharif and others entered into distributorship contracts with Wellness International Network (WIN) for the sale of health and wellness products. Sharif and others later sued WIN and claimed that WIN was running a pyramid scheme. The district court granted summary judgment for WIN and awarded $655,596.13 in attorney's fees as a sanction against Sharif and his co-plaintiffs for ignoring some of WIN's discovery requests. WIN attempted to discover Sharif's assets, but Sharif ignored all attempts until he was held in civil contempt for discovery violations and arrested. In 2009, Sharif filed for Chapter 7 bankruptcy. WIN filed an adversary proceeding in bankruptcy court and claimed that Sharif had continuously concealed property and information pertaining to his assets. The bankruptcy court found in favor of WIN and ordered Sharif to pay WIN's attorney's fees along with other sanctions.</p> <p>Sharif appealed to federal district court, but before he filed his first brief, the U.S. Supreme Court decided <em>Stern v. Marshall</em>, which held that a bankruptcy court lacked the authority to enter a final judgment on a state-law counterclaim against a creditor. Sharif subsequently attempted to advance an argument based on <em>Stern</em>, but the district court did not allow it. Instead, the district court held that such an objection can be waived and that Sharif's failure to bring up to argument earlier constituted an implied waiver. The U.S. Court of Appeals for the Seventh Circuit affirmed in part and vacated in part. The Court of Appeals held that an objection based on <em>Stern</em> cannot be waived and that the bankruptcy court only had the authority to enter a final judgment on some of WIN's claims.</p>

majority opinion

reversed/remanded

Judicial Power

Rodriguez v. United States

https://api.oyez.org/cases/2014/13-9972

13-9972

2014

Dennys Rodriguez

United States

<p>On March 27, 2012, a Nebraska K-9 police officer pulled over a vehicle driven by Dennys Rodriguez after his vehicle veered onto the shoulder of the highway. The officer issued a written warning and then asked if he could walk the K-9 dog around Rodriguez's vehicle. Rodriguez refused, but the officer instructed him to exit the vehicle and then walked the dog around the vehicle. The dog alerted to the presence of drugs, and a large bag of methamphetamine was found.</p> <p>Rodriguez moved to suppress the evidence found in the search, claiming the dog search violated his Fourth Amendment right to be free from unreasonable seizures. The district court denied the motion. On appeal, the United States Court of Appeals for the Eighth Circuit affirmed, holding the search was constitutional because the brief delay before employing the dog did not unreasonably prolong the otherwise lawful stop.</p>

majority opinion

vacated/remanded

Criminal Procedure

Baker Botts, LLP v. ASARCO, LLC

https://api.oyez.org/cases/2014/14-103

14-103

2014

Baker Botts, LLP

ASARCO, LLC

<p>Baker Botts, LLP, along with Jordan, Hyden, Womber, Culbreth &amp; Holzer, PC, was awarded about $120 million in fees for representing Asarco, LLC in its Chapter 11 bankruptcy case, from which Asarco had emerged in 2009 with a reorganization plan that would pay its creditors in full. Baker Botts then filed for a final fee request, which Asarco contested. The bankruptcy court awarded Baker Botts more than $117 million to cover the fees in addition to $5 million for expenses incurred defending the fee claims. The district court affirmed. The U.S. Court of Appeals for the Fifth Circuit held that the Bankruptcy Code did not allow the firms to recover $5 million spent defending the fee request against Asarco's opposition.</p>

majority opinion

affirmed

Attorneys

King v. Burwell

https://api.oyez.org/cases/2014/14-114

14-114

2014

David King, et al.

Sylvia Mathews Burwell, Secretary of Health and Human Services, et al.

<p>In 2010, Congress passed the Affordable Care Act (ACA) to increase the number of Americans covered by health insurance and decrease the cost of health care. The ACA required each state to establish an "exchange" through which people could purchase health care coverage, and if a state elected not to do so, the federal government would establish one through the Secretary of Health and Human Services. The ACA also required people to obtain the minimum essential coverage or pay a tax penalty unless they fell within an unaffordability exemption for low-income individuals. To limit the number of people that would fall into such an exemption, the ACA provided for tax credits that are calculated based on the health plan in which an individual enrolls through the exchange. Although the legislative language of the ACA pertaining to the tax credits only referred to the exchanges established by the states, the Internal Revenue Service (IRS) created a regulation that made the tax credits available to those enrolled in plans through federal as well as state exchanges.</p> <p>Virginia declined to establish a state-run exchange and has one operated by the federal government. The plaintiffs are a group of Virginia residents who, without the tax credits, would fall under the unaffordability exception and be exempt from having to purchase health insurance. They sued and argued that the IRS regulation exceeded the agency's statutory authority, is arbitrary and capricious, and is contrary to the law in violation of the Administrative Procedure Act. The district court granted the defendants' motion to dismiss, and the U.S. Court of Appeals for the Fourth Circuit affirmed.</p>

majority opinion

affirmed

Federal Taxation

Walker v. Texas Division, Sons of Confederate Veterans, Inc.

https://api.oyez.org/cases/2014/14-144

14-144

2014

John Walker, III, et al.

Texas Division, Sons of Confederate Veterans, Inc., et al.

<p>In August 2009, the Texas division of the Sons of Confederate Veterans (Texas SCV), a non-profit organization that works to preserve the memory and reputation of soldiers who fought for the confederacy in the Civil War, applied to have a new specialty license plate issued by the Texas Department of Motor Vehicles (TDMV). The proposed license plate had two confederate flags on it: one in the organization's logo, and one faintly making up the background of the plate. The TDMV had a policy stating that it "may refuse to create a new specialty license plate if the design might be offensive to any member of the public." The board in charge of approving new specialty plates received multiple negative comments from the public regarding this plate and ultimately voted to deny Texas SCV's application.</p> <p>Texas SCV sued in federal district court claiming their First and Fourteenth Amendment rights were violated. The TDMV argued that the Free Speech Clause did not apply in this case because license plates are a form of government speech; therefore, they were within their rights to choose which messages and views they wanted to express on the plates. The district court disagreed and held that the plates were private, non-governmental speech, and that the TDMV's denial was a reasonable, content-based restriction of speech in a non-public forum. The United States Court of Appeals for the Fifth Circuit reversed and held that TDMV's denial was a form of viewpoint discrimination that "discriminated against Texas SCV's view that the Confederate flag is a symbol of sacrifice, independence, and Southern heritage."</p>

majority opinion

reversed

First Amendment

Bullard v. Blue Hills Bank, fka Hyde Park Savings

https://api.oyez.org/cases/2014/14-116

14-116

2014

Louis B. Bullard

Blue Hills Bank, fka Hyde Park Savings Bank

<p>Louis Bullard borrowed $387,000 from Hyde Park Savings to buy his property in Massachusetts. In December 2010, he filed for Chapter 13 of the Bankruptcy Code and proposed a plan in which he offered to pay the bank back the value of the property in a loan that was secured by the actual property and then put the rest of the home loan into a pool with other debts that would be paid at a different rate. The bankruptcy court rejected this plan because it believed this hybrid plan was inconsistent with certain provisions of the Bankruptcy Code. The bankruptcy appellate panel agreed but stated the order was appealable because Bullard could simply propose another plan. Bullard petitioned for an appeal but the bankruptcy appellate panel denied the petition because the petitioner had already filed his notice of appeal to the U.S. Court of Appeals for the First Circuit. The First Circuit held that it did not have jurisdiction, as courts of appeals only have jurisdiction over "final decisions, judgments, orders and decrees."</p>

majority opinion

affirmed

Judicial Power

Bank of America v. Caulkett

https://api.oyez.org/cases/2014/13-1421

13-1421

2014

Bank of America, N.A.

David B. Caulkett

<p>David Caulkett’s property was subject to two mortgage liens when he filed for bankruptcy. Because the debt owed on the first mortgage exceeded the value of the property, the second mortgage, which Bank of America held, was considered “underwater.” When Caulkett filed for bankruptcy, he moved the bankruptcy court to void Bank of America’s lien on the second mortgage and argued that Section 506(d) of the Bankruptcy Code allowed a debtor filing for bankruptcy to void a second mortgage when the debt owed on the first mortgage exceeded the value of the collateral property. The bankruptcy court granted the motion, and both the district court and the U.S. Court of Appeals for the Eleventh Circuit affirmed.</p> <p>This case was consolidated with a similar case, <em>Bank of America v. Toledo-Cardona</em>, which had substantially the same facts and an identical procedural history.</p>

majority opinion

Economic Activity

Armstrong v. Exceptional Child Center, Inc.

https://api.oyez.org/cases/2014/14-15

14-15

2014

Richard Armstrong, et al.

Exceptional Child Center, Inc., et al.

<p>The federal Medicaid Act requires that state Medicaid plans contain procedures to ensure that reimbursement rates for healthcare providers "are consistent with efficiency, economy, and quality of care and are sufficient to enlist enough providers" to meet the need for care and services in the geographic area. Ninth Circuit precedent also requires that reimbursement rates bear a reasonable relationship to Medicaid provider costs, and where rates do not "substantially reimburse providers their costs," a state cannot justify its rates with "purely budgetary reasons." Richard Armstrong, the Director of Idaho's Department of Health and Welfare, and others (the Directors) conducted provider cost studies and recommended increasing reimbursement rates but ultimately did not increase rates for budgetary reasons.</p> <p>A group of Idaho Medicaid providers (the Providers) sued the Directors and claimed that, based on the new cost information, the Department's failure to raise rates was not consistent with the Ninth Circuit's requirements. The Directors argued that the Supremacy Clause of the federal Constitution does not give providers a private right of action and that the existing rates were consistent with the Medicaid Act's requirements of efficiency, economy, and quality of care. The district court granted the Providers' motion for summary judgment and held that the failure to increase rates led to a failure to substantially reimburse providers. The U.S. Court of Appeals for the Ninth Circuit affirmed.</p>

majority opinion

reversed

Judicial Power

Reyes Mata v. Lynch

https://api.oyez.org/cases/2014/14-185

14-185

2014

Noel Reyes Mata

Loretta Lynch, Attorney General of the United States

<p>Noel Reyes Mata, a citizen of Mexico, was convicted of assaulting a woman he was dating; he was deported in 2010. His appeal to the Board of Immigration Appeals (BIA) was dismissed after his attorney failed to file an appellate brief. Mata subsequently moved to reopen his case based on ineffective assistance of counsel, but the BIA denied Mata's motion as untimely because it was filed well after the 90 days allowed. Mata appealed the BIA's denial of his motion to the U.S. Court of Appeals for the Fifth Circuit and argued that the BIA should not have enforced the filing period limitation because his attorney's failure to file a brief deprived him of his due process rights. The appellate court held that such a motion was subject to the complete discretion of the BIA, and thus the appellate court lacked the jurisdiction to review the decision.</p>

majority opinion

reversed/remanded

Judicial Power

Carroll v. Carman

https://api.oyez.org/cases/2014/14-212

14-212

2014

Jeremy Carroll

Andrew Carman, et ux.

<p>On July 3, 2009, the Pennsylvania State Police Department received a report that Michael Zita had stolen a car and two handguns and then likely fled to the Carman residence. Officers Jeremy Carroll and Brian Roberts went to the Carman residence to investigate and noticed that a small structure in the rear of the property had a light on a door open, so they approached and announced their presence. When no one responded, the officers continued to approach the house via a back door that the officers believed looked like a customary entrance. The residents confronted the officers, but eventually identified themselves as the Carmans and allowed the officers to search their house. The officers did not find Zita, and the Carmans were not charged with a crime.</p> <p>The Carmans later sued Officer Carroll in district court and argued that he had unlawfully entered their property in violation of the warrant requirement of the Fourth Amendment. Carroll argued that his entry was legal under the "knock and talk" exception to the warrant requirement, which allows officers to knock on someone's door as long as the officers are standing on the parts of the person's property on which the general public is allowed. The Carmans argued that exception did not apply in this case because a normal visitor would have used the front door. The jury found in favor of Carroll, and the U.S. Court of Appeals for the Third Circuit reversed because the "knock and talk" exception requires that the police begin their interaction at the front door. The appellate court also held that Carroll was not entitled to qualified immunity because his actions violated clearly established law.</p>

per curiam

reversed/remanded

Civil Rights

McFadden v. United States

https://api.oyez.org/cases/2014/14-378

14-378

2014

Stephen D. McFadden

United States

<p>Stephen McFadden sold overstocked products on the Internet to augment his income. In 2011, McFadden noticed that a lot of businesses where he lived were selling a product known as "bath salts," an aromatherapy product that emits a stimulating vapor when burned. After confirming that bath salts were not illegal, McFadden began selling them like his other products. He continued to sell them until he learned they had been placed on the list of substances that the Controlled Substances Act (CSA) prohibited.</p> <p>The government prosecuted McFadden under the Controlled Substances Analogue Enforcement Act of 1986, which allows substances not listed as "controlled" to be treated as illegal if the analogue has effects and a chemical make-up that are "substantially similar" to those listed in the CSA. At trial, McFadden argued that the state needed to prove that he was aware, or actively resisted finding out, that the bath salts were substantially similar to a controlled substance and constituted an analogue. Instead, the district court held that the state only needed to prove that the petitioner knew "the products were intended for human consumption." The U.S. Court of Appeals for the Fourth Circuit affirmed.</p>

majority opinion

vacated/remanded

Criminal Procedure

Horne v. Department of Agriculture

https://api.oyez.org/cases/2014/14-275

14-275

2014

Marvin D. Horne

U.S. Department of Agriculture

<p>In 1949 the U.S. Department of Agriculture implemented the Marketing Order Regulating the Handling of Raisins Produced from Grapes Grown in California (Marketing Order). The Marketing Order authorized the federal government to reserve a percentage of the yearly California raisin crop to stabilize the supply, and thus the price, of California raisins. Under the Marketing Order, farmers are entitled to a share of the proceeds acquired when, or if, the government sells the reserved raisins. Marvin Horne, a farmer and raisin producer, attempted to skirt the Marketing Order by processing his own raisins, which he claimed exempted his raisins from the Marketing Order's reserve requirement. The Department of Agriculture claimed Horne's raisins were still subject to the Market Order, and following administrative proceedings, Horne was fined nearly $700,000.</p> <p>Horne sued the Department of Agriculture and claimed that the Marketing Order violated his Fifth Amendment rights against uncompensated takings. The district court found in favor of the Department of Agriculture. The U.S. Court of Appeals for the Ninth Circuit held that it lacked standing to address Horne's claim, because Fifth Amendment takings claims are within the jurisdiction of the Court of Federal Claims. The United States Supreme Court held that the appellate court did have jurisdiction and remanded the case. On remand, the appellate court found for the Department of Agriculture by holding that the reserve requirement did not act as a <em>per se</em> taking because Horne's raisins constituted personal property rather than real property. The appellate court also held that the Marketing Order did not constitute a taking because there was a sufficient nexus, and rough proportionality, between the reserve requirement and the specific interest the government seeks to protect, which in this case is the government's interest in stabilizing raisin prices.</p>

majority opinion

reversed

Due Process

Toca v. Louisiana

https://api.oyez.org/cases/2014/14-6381

14-6381

2014

George Toca

State of Louisiana

<p>In the 1980s, George Toca was arrested and sentenced to life in prison without the possibility of parole, probation, or suspension of his sentence for accidentally shooting his friend while the two of them committed a robbery. At the time of the robbery, George was 17 years old and was considered a juvenile. In 2012, the Supreme Court held in <em>Miller v. Alabama</em> that sentencing a juvenile to life in prison without the possibility of parole was a violation of the Eighth Amendment's protection against cruel and unusual punishment. In light of the <em>Miller</em> case, Toca applied for a Motion to Correct an Illegal Sentence, which the district court approved by holding that the <em>Miller</em> decision applied retroactively to cases like Toca's. The Supreme Court of Louisiana overturned that decision by denying Toca's motion and holding that the <em>Miller</em> rule does not apply retroactively because it is not a substantive rule, nor does it correct any substantive issues of fairness or accuracy in the criminal proceedings. The Supreme Court of Louisiana also held that the <em>Miller</em> rule is simply a new rule of criminal procedure and does not apply retroactively.</p>

dismissal - rule 46

none

Harris v. Viegelahn

https://api.oyez.org/cases/2014/14-400

14-400

2014

Charles E. Harris, III

Mary K. Viegelahn

<p>In February 2010, Charles Harris filed for bankruptcy under Chapter 13 of the Bankruptcy Code. The approved plan instructed Harris to make monthly payments to the trustee Mary Viegelahn for sixty months, as well as monthly payments directly to Chase, which held his mortgage. After the mortgage and secured creditors debts were paid off, the payments would go to Harris' unsecured creditors. In October 2010, Chase moved to lift the automatic stay of Harris' home for his failure to make the mortgage payments, and Harris moved out of his house when the stay was lifted in November 2010. At that point, Viegelahn held the portion of the monthly payments intended to go to Chase. After Harris voluntarily converted his bankruptcy case to Chapter 7, Viegelahn distributed those funds to Harris' creditors. Harris sued for that money and argued that Viegelahn had no authority to disburse funds after conversion of the case. The bankruptcy court issued an order compelling the return of the funds and the district court affirmed. However, the U.S. Court of Appeals for the Fifth Circuit reversed and held that the undistributed payments that the Chapter 13 trustee holds at the time of the case's conversion to Chapter 7 must be distributed to creditors pursuant to the Chapter 13 plan.</p>

majority opinion

reversed/remanded

Economic Activity

Michigan v. Environmental Protection Agency

https://api.oyez.org/cases/2014/14-46

14-46

2014

Michigan, et al.

Environmental Protection Agency, et al.

<p>The 1990 amendments to the Clean Air Act require that the Environmental Protection Agency (EPA) regulate electric utility steam generating units (EGUs) if it finds that such regulation was "appropriate and necessary" after conducting a utility study. In December 2000, the EPA issued a notice that such regulation was necessary based on the results of the utility study, which showed that the mercury emissions from EGUs were a threat to public health. In 2005, the EPA reversed its findings and determined that it was not "appropriate and necessary" to regulate coal-and oil-fired EGUs. States and other groups petitioned for review, and the U.S. Court of Appeals for the District of Columbia Circuit held that the EPA's attempt to reverse its findings was unlawful because it could not remove pollutant sources from the regulation list once they were on it. In 2012, the EPA confirmed that EGU regulation was necessary and promulgated emission standards. State, industry, and labor groups petitioned the appellate court for review of the EPA's interpretation of the "appropriate and necessary" requirement with respect to these regulations. The appellate court denied the petition.</p>

majority opinion

reversed/remanded

Economic Activity

Christeson v. Roper

https://api.oyez.org/cases/2014/14-6873

14-6873

2014

Mark A. Christeson

Don Roper, Warden

<p>In 1999, a jury convicted Mark Christeson of capital murder for invading the home of a mother and her two children, raping the mother, and then cutting their throats and pushing them into the pond. The jury sentenced Christeson to death. In 2004, the Supreme Court of Missouri affirmed the conviction, which meant that Christeson's federal habeas petition was due on April 10, 2005. Nine months before the deadline, the Court appointed attorneys Phil Horwitz and Eric Butts to represent Christeson. Horwitz and Butts failed to meet with Christeson until six weeks after the petition was due, and they filed the petition 117 days late. The federal district court dismissed the petition as untimely. Seven years later, Horwitz and Butts contacted attorneys Jennifer Merrigan and Joseph Perkovich to discuss Christeson's case. Merrigan and Perkovich discovered Christeson's only chance would be to reopen the final judgment on the grounds that the statute of limitation should not have been enforced in this case. Horwitz and Butts, knowing this would ruin their reputations, refused to let outside counsel access their files. Merrigan and Perkovich moved for substitution of counsel, which the district court denied because they were from out of state and because Horwitz and Butts had not abandoned their client. The U.S. Court of Appeals for the Eighth Circuit affirmed.</p>

per curiam

reversed/remanded

Civil Rights

Obergefell v. Hodges

https://api.oyez.org/cases/2014/14-556

14-556

2014

James Obergefell, et al.

Richard Hodges, Director of the Ohio Department of Health, et al.

<p>Groups of same-sex couples sued their relevant state agencies in Ohio, Michigan, Kentucky, and Tennessee to challenge the constitutionality of those states' bans on same-sex marriage or refusal to recognize legal same-sex marriages that occurred in jurisdictions that provided for such marriages. The plaintiffs in each case argued that the states' statutes violated the Equal Protection Clause and Due Process Clause of the Fourteenth Amendment, and one group of plaintiffs also brought claims under the Civil Rights Act. In all the cases, the trial court found in favor of the plaintiffs. The U.S. Court of Appeals for the Sixth Circuit reversed and held that the states' bans on same-sex marriage and refusal to recognize marriages performed in other states did not violate the couples' Fourteenth Amendment rights to equal protection and due process.</p>

majority opinion

reversed

Due Process

Kingsley v. Hendrickson

https://api.oyez.org/cases/2014/14-6368

14-6368

2014

Michael B. Kingsley

Stan Hendrickson

<p>In May 2010, Michael Kingsley, who was being held as a pretrial detainee in Monroe County Jail, was ordered to take down a piece of paper covering the light above his cell bed but refused to do so. After Sergeant Stan Hendrickson ordered Kingsley to take down the paper several times and each time was met with refusal, Lieutenant Robert Conroy, the jail administrator, ordered the jail staff to take down the paper and transfer Kingsley to another cell. During the transfer, Kingsley refused to act as ordered, so the officers pulled him to his feet in such a manner that his feet hit the bedframe, which caused pain and made him unable to walk or stand. In the new cell, when Kingsley resisted the officers' attempts to remove the handcuffs, Hendrickson put his knee in Kingsley's back and Kingsley yelled at him. Kingsley also claimed that Hendrickson smashed his head into the concrete bunk. After further verbal exchange, another officer applied a taser to Kingsley's back.</p> <p>Kingsley sued Hendrickson and other jail staff members and claimed that their actions violated his due process rights under the Fourteenth Amendment. The jury found the defendants not guilty. Kingsley appealed and argued that the jury was wrongly instructed on the standards for judging excessive force and intent. The U.S. Court of Appeals for the Seventh Circuit reversed.</p>

majority opinion

vacated/remanded

Civil Rights

Glebe v. Frost

https://api.oyez.org/cases/2014/14-95

14-95

2014

Patrick Glebe, Superintendent of the Stafford Creek Corrections Center

Joshua James Frost

<p>Over the course of eleven days in April 2003, Joshua James Frost and two associates committed a series of armed robberies in the state of Washington. Frost was charged with robbery and related offenses. During closing arguments, Frost's lawyer expressed his desire to argue both that the prosecution did not meet their burden and that Frost acted under duress. The trial judge made the defense choose between the two alternative defenses, and the defense chose duress. The jury convicted Frost of multiple counts.</p> <p>The Washington Supreme Court held that the trial court's restriction of the closing argument violated Frost's rights to due process and assistance of counsel. However, that decision constituted trial error, which makes the mistake reviewable, rather than structural error, which would require automatic reversal. Upon such review, the Washington Supreme Court held that there was sufficient evidence to convict Frost and upheld the conviction.</p> <p>Frost filed a petition for a writ of habeas of corpus that the district court denied, and a panel of the U.S. Court of Appeals for the Ninth Circuit affirmed the dismissal. Upon rehearing en banc, the appellate court reversed and directed the district court to grant the petition because the Washington Supreme Court unreasonably applied clearly established law by failing to classify the trial court's restriction of the defense's closing argument as structural error.</p>

per curiam

reversed/remanded

Woods v. Donald

https://api.oyez.org/cases/2014/14-618

14-618

2014

Jeffrey Woods, Warden

Cory Donald

<p>Cory Donald, Seante Liggins, Rashad Moore, Dewayne Saine, and Fawzi Zaya decided to rob Mohammed Makki, a local drug dealer. During the course of the robbery, several shots were fired and Makki was later discovered dead. Liggins and Zaya pled guilty, and Donald was tried with Moore and Saine for one count of first-degree felony murder and two counts of armed robbery. When the government sought to admit evidence of phone communication among the defendants on the day in question, Donald’s lawyer indicated that evidence did not affect his client, so the judge allowed testimony to proceed when Donald’s lawyer was not in the courtroom. The jury convicted Donald on all three counts. He appealed and argued that his lawyer’s absence from the courtroom during the phone call testimony denied him his Sixth Amendment right to effective assistance of counsel. The Michigan Court of Appeals rejected the claim and the Michigan Supreme Court denied review.</p> <p>Donald moved for federal habeas relief, which the district court granted, and the U.S. Court of Appeals for the Sixth Circuit affirmed by holding that the Michigan Court of Appeals did not properly apply the precedent established by the Supreme Court’s decision in <em>United States v. Cronic</em>. In that case, the Court held that courts may presume a defendant’s Sixth Amendment rights have been violated when he is denied the assistance of counsel at a critical stage in his trial, which the appellate court found happened in this case.</p>

per curiam

reversed/remanded

Civil Rights

Glossip v. Gross

https://api.oyez.org/cases/2014/14-7955

14-7955

2014

Richard E. Glossip, et al.

Kevin J. Gross, et al.

<p>On April 29, 2014, Oklahoma executed Clayton Lockett using a three-drug lethal injection procedure. The procedure went poorly; Lockett awoke after the injection of the drugs that were supposed to render him unconscious and did not die until about 40 minutes later. Oklahoma suspended all subsequent executions until the incident could be investigated and subsequently adopted a new protocol that placed a higher emphasis on making sure the injection was done properly. The new protocol also allowed for four alternative drug combinations, one of which used midazolam as the initial drug, as did the protocol used in the Lockett execution.</p> <p>Charles Warner and 20 other death row inmates sued various state officials and argued that the use of midazolam as the initial drug in the execution protocol violated the Eighth Amendment's prohibition against cruel and unusual punishment. Warner and three other plaintiffs also moved for a preliminary injunction to prevent Oklahoma from moving forward with their executions. A federal district court denied the injunction and held that the plaintiffs had not provided sufficient evidence that they would prevail on the merits of their claims and that they had failed to identify a "known and available" alternative to the drug in question. The U.S. Court of Appeals for the Tenth Circuit affirmed.</p> <p>On January 15, 2015, the Supreme Court declined to grant the petition for a writ of certiorari, and Charles Warner was subsequently executed. Richard E. Glossip and the other two death row inmates petitioned the Court again.</p>

majority opinion

affirmed

Criminal Procedure

Equal Employment Opportunity Commission v. Abercrombie & Fitch Stores, Inc.

https://api.oyez.org/cases/2014/14-86

14-86

2014

Equal Employment Opportunity Commission

Abercrombie & Fitch Stores, Inc.

<p>Abercrombie &amp; Fitch Stores, Inc. (Abercrombie) is a national chain of clothing stores that requires its employees to comply with a "Look Policy" that reflects the store's style and forbids black clothing and caps, though the meaning of the term cap is not defined in the policy. If a question arises about the Look Policy during the interview or an applicant requests a deviation, the interviewer is instructed to contact the corporate Human Resources department, which will determine whether or not an accommodation will be granted.</p> <p>In 2008, Samantha Elauf, a practicing Muslim, applied for a position at an Abercrombie store. She wore a headscarf, or hijab, every day, and did so in her interview. Elauf did not mention her headscarf during her interview and did not indicate that she would need an accommodation from the Look Policy. Her interviewer likewise did not mention the headscarf, though she contacted her district manager, who told her to lower Elauf's rating on the appearance section of the application, which lowered her overall score and prevented her from being hired.</p> <p>The Equal Employment Opportunity Commission (EEOC) sued Abercrombie on Elauf's behalf and claimed that the company had violated Title VII of the Civil Rights Act of 1964 by refusing to hire Elauf because of her headscarf. Abercrombie argued that Elauf had a duty to inform the interviewer that she required an accommodation from the Look Policy and that the headscarf was not the expression of a sincerely held religious belief. The district court granted summary judgment for the EEOC. The U.S. Court of Appeals for the Tenth Circuit reversed and held that summary judgment should have been granted in favor of Abercrombie because there is no genuine issue of fact that Elauf did not notify her interviewer that she had a conflict with the Look Policy.</p>

majority opinion

reversed/remanded

Civil Rights

Grady v. North Carolina

https://api.oyez.org/cases/2014/14-593

14-593

2014

Torrey Dale Grady

North Carolina

<p>Between 1997 and 2006, Torrey Grady was convicted of two sexual offenses. After being released for the second time, a trial court civilly committed Grady to take part in North Carolina’s satellite-based monitoring program for the duration of his life. The program required participants to wear a GPS monitoring bracelet so that authorities can make sure that participants are complying with prescriptive schedule and location requirements. Grady challenged the constitutionality of the program and argued that the constant tracking amounted to an unreasonable search that was prohibited under the Fourth Amendment. Both the trial court and the North Carolina Court of Appeals held that wearing a GPS monitor did not amount to a search.</p>

per curiam

vacated/remanded

Criminal Procedure

Montgomery v. Louisiana

https://api.oyez.org/cases/2015/14-280

14-280

2015

Henry Montgomery

Louisiana

<p>In 1963, Henry Montgomery was found guilty and received the death penalty for the murder of Charles Hunt, which Montgomery committed less than two weeks after he turned 17. He appealed to the Louisiana Supreme Court, and his conviction was overturned because of community prejudice. At his new trial, Montgomery was again convicted, but he was sentenced to life without parole.</p> <p>In 2012, the U.S. Supreme Court decided <em>Miller v. Alabama</em>, in which the Court held that mandatory sentencing schemes requiring children convicted of homicide to be sentenced to life imprisonment without parole violate the Eighth Amendment. In light of that decision, Montgomery filed a motion in state district court to correct what he argued was now an illegal sentence. The trial court denied Montgomery’s motion, and the Louisiana Supreme Court denied Montgomery’s application by holding that the decision in <em>Miller</em> does not apply retroactively.</p>

majority opinion

reversed/remanded

Criminal Procedure

Hurst v. Florida

https://api.oyez.org/cases/2015/14-7505

14-7505

2015

Timothy Lee Hurst

Florida

<p>Timothy Lee Hurst was charged and convicted of first-degree murder for killing his co-worker, Cynthia Harrison, during a robbery of the Popeye’s restaurant where they both worked. He was sentenced to death and appealed. On appeal, Hurst was granted a new sentencing trial because the Supreme Court of Florida found that his counsel should have investigated and presented evidence of Hurst’s borderline intelligence and possible organic brain damage. At his new sentencing trial, Hurst was prevented from presenting mental retardation evidence as an absolute bar to the imposition of the death penalty, though he was allowed to present it as mitigating evidence. The jury again sentenced Hurst to the death penalty by a vote of seven to five, and the Supreme Court of Florida affirmed.</p> <p>In 2002, the Supreme Court decided the case <em>Ring v. Arizona</em>, in which the Court held that the Sixth Amendment required that the presence of aggravating factors, which Arizona’s death penalty sentencing scheme viewed as essentially elements of a larger offense, be determined by the jury. The Supreme Court of Florida had previously held that the decision in <em>Ring v. Arizona</em> did not apply to Florida’s death penalty sentencing scheme generally and specifically did not require that a jury’s recommendation of the death penalty be unanimous or that a jury determine the factual issue of a defendant’s potential mental retardation.</p>

majority opinion

reversed/remanded

Criminal Procedure

Thompson v. Coastal Oil Co.

https://api.oyez.org/cases/1956/1

1

1956

William Thompson

Coastal Oil Co.

<p>William Thompson suffered a head injury aboard the SS. Rosina Marron after an attack by a fellow crewmember. After several months of recuperation, Thompson signed an agreement releasing Costal Oil Company from liability in exchange for $4000. Later, Thompson discovered the damage from his injury was much more extensive than originally thought. Thomson sued to recover damages from his injury. The district court upheld the release, noting that Thompson adamantly refused to consult an attorney, although he had many opportunities to do so, and freely entered into the agreement. The U.S. Court of Appeals for the Third Circuit reversed.</p>

per curiam

reversed

Economic Activity

Montanile v. Board of Trustees of the National Elevator Industrial Health Benefit Plan

https://api.oyez.org/cases/2015/14-723

14-723

2015

Robert Montanile

Board of Trustees of the National Elevator Industrial Health Benefit Plan

<p>In late 2008, Robert Montanile was involved in a car accident that resulted in significant injuries. Montanile was covered by an employee welfare benefit plan administered by the Board of Trustees of the National Elevator Industrial Health Benefit Plan (Plan). After Montanile’s accident, the Plan dispersed over $120,000 to cover Montanile’s medical expenses. Montanile later sued the driver of the other car involved in the accident, eventually obtaining a $500,000 settlement. Per its terms, the Plan then requested that Montanile reimburse the initial $120,000 disbursement. When Montanile and the Plan were unable to reach an agreement, the Plan sued Montanile.</p> <p>The Plan is governed by the Employee Retirement Income Security Act of 1974 (ERISA), which allows plan administrators to recover overpayment from a beneficiary when the recovery would constitute “appropriate equitable relief”. The trial court held that the terms of the Plan required Montanile to repay the initial $120,000, and that this repayment was appropriate equitable relief in part because the Plan was able to identify a source of funds within Montanile’s possession—the $500,000 settlement. Montanile appealed and claimed that the repayment would not be equitable relief because the settlement had been spent or disbursed to other parties. The U.S. Court of Appeals for the Eleventh Circuit held that, because the Plan had a right to reimbursement, the Plan’s lien against Montanile’s $500,000 settlement attached before Montanile spent or disbursed the funds. Therefore, Montanile could not evade the repayment by claiming the settlement funds had been spent or disbursed.</p>

majority opinion

reversed/remanded

Economic Activity

Pennsylvania v. Nelson

https://api.oyez.org/cases/1955/10

10

1955

Pennsylvania

Nelson

<p>Nelson, a member of the Communist Party, was convicted of violating the Pennsylvania Sedition Act. This Act was implemented prior to Congress's adoption of the Smith Act of 1940 (amended in 1948) which prohibited the same conduct as Pennsylvania's law.</p>

majority opinion

affirmed

First Amendment

DIRECTV, Inc. v. Imburgia

https://api.oyez.org/cases/2015/14-462

14-462

2015

DIRECTV, Inc.

Amy Imburgia, et al.

<p>On September 7, 2008, Amy Imburgia filed a class action lawsuit against DIRECTV, Inc. (DIRECTV), and argued that DIRECTV had improperly charged early termination fees to its customers. In 2011, the U.S. Supreme Court decided <em>AT&amp;T Mobility LLC v. Concepcion</em>, in which the Court held that the Federal Arbitration Act preempted California precedent that had previously held that, in certain circumstances, arbitration clauses in customer agreements were unenforceable. Less than one month after that decision, DIRECTV moved to stay or dismiss the plaintiffs’ case and compel arbitration, which DIRECTV argued it had not done previously because it thought the arbitration clause in its customer agreement was void under California precedent. The trial court denied the motion and the California Court of Appeal for the Second District affirmed by holding that the language of the customer agreement subjected the arbitration clause to state law.</p>

majority opinion

reversed/remanded

Economic Activity

Kansas v. Carr

https://api.oyez.org/cases/2015/14-449

14-449

2015

Kansas

Jonathan and Reginald Carr

<p>In December 2000, brothers Jonathan and Reginald Carr committed a series of crimes in Wichita, Kansas, known as “The Wichita Massacre,” which included assault, robbery, rape, and the murder of five people. The Carrs were prosecuted jointly. They moved to sever their cases and argued that being tried jointly would be prejudicial because they intended to mount antagonistic defenses and introduce evidence that would be admissible or non-prejudicial only in separate trials. The trial judge denied the motion, and the Carrs were later jointly convicted on numerous counts and sentenced to death. The jury instructions at the sentencing trial did not state that mitigating circumstances need not be proven beyond a reasonable doubt.</p> <p>On appeal, the Carrs argued that their Eighth Amendment rights to individualized sentencing were violated both by the trial judge’s refusal to sever their cases and the failure to affirmatively instruct the jury that mitigating circumstances need not be proven beyond a reasonable doubt. The Kansas Supreme Court agreed and reversed the death sentences by holding that the trial judge failed to do the necessary analysis and carefully consider the severance issue. The court also held that the jurors may have been prevented from giving meaningful effect to mitigating evidence because they were not instructed that mitigating circumstances need not be proven beyond a reasonable doubt.</p> <p>In the consolidated case, <em>Kansas v. Gleason</em>, Gleason was convicted of capital murder for the killings of several people in connection with a robbery. He was also convicted of pre-meditated murder, aggravated kidnapping, aggravated robbery, and criminal possession of a firearm. The jury sentenced Gleason to death for the capital murder charge and a consecutive sentence of life in prison without the possibility of parole for 50 years for the other charges. Gleason appealed his convictions, and the Kansas Supreme Court vacated his conviction of life imprisonment because it was multiplicitous with his death sentence and vacated his death sentence because the jury was not properly instructed on how to consider mitigating circumstances.</p>

majority opinion

reversed/remanded

Criminal Procedure

McConnell v. Federal Election Commission

https://api.oyez.org/cases/2003/02-1674

02-1674

2003

Mitch McConnell, U.S. Senator

Federal Election Commission

<p>In early 2002, a many years-long effort by Senators John McCain and Russell Feingold to reform the way that money is raised for--and spent during-- political campaigns culminated in the passage of the Bipartisan Campaign Reform Act of 2002 (the so-called McCain-Feingold bill sometimes referred to as BCRA). Its key provisions were a) a ban on unrestricted ("soft money") donations made directly to political parties (often by corporations, unions, or wealthy individuals) and on the solicitation of those donations by elected officials; b) limits on the advertising that unions, corporations, and non-profit organizations can engage in up to 60 days prior to an election; and c) restrictions on political parties' use of their funds for advertising on behalf of candidates (in the form of "issue ads" or "coordinated expenditures").</p> <p>The campaign finance reform bill contained an unusual provision providing for an early federal trial and a direct appeal to the Supreme Court of the United States, by-passing the typical federal judicial process. In May a special three-judge panel struck down portions of the Campaign Finance Reform Act's ban on soft-money donations but upheld some of the Act's restrictions on the kind of advertising that parties can engage in. The ruling was stayed until the Supreme Court could hear and decide the resulting appeals.</p>

majority opinion

reversed

First Amendment

Slochower v. Board of Higher Education of New York City

https://api.oyez.org/cases/1955/23

23

1955

Harry Slochower

Board of Higher Education of New York City

<p>New York City municipal charter provision §903 required discharge of any municipal employee who invokes the Fifth Amendment protection against self-incrimination in a legally authorized inquiry into that employee’s official conduct. Harry Slochower, a tenured professor at Brooklyn College, invoked this privilege in a congressional committee investigation into his past Communist Party membership. Despite his tenured status, which required notice and a hearing before termination, the city terminated him immediately. The state trial court dismissed a motion to review the discharge and the Court of Appeals of New York affirmed.</p>

majority opinion

reversed/remanded

First Amendment

Cole v. Young

https://api.oyez.org/cases/1955/442

442

1955

Cole

Young

<p>The Food and Drug Administration ("FDA") fired Kendrick Cole when it determined that his employment was not "clearly consistent with the interests of national security." Mr. Cole was a food and drug inspector and a "preference-eligible veteran," but was charged with having "a close association with individuals reliably reported to be Communists." Mr. Cole appealed his discharge to the Civil Service Commission, which denied his appeal, finding that the Veterans' Preference Act did not afford Mr. Cole a right of appeal under the circumstances. Mr. Cole brought an action seeking declaratory judgment in the District of Columbia federal district court alleging that his discharge was invalid and that the Civil Service Commission improperly denied his appeal. The district court dismissed the case and the U.S. Court of Appeals for the District of Columbia affirmed.</p>

majority opinion

reversed/remanded

First Amendment

Reid v. Covert

https://api.oyez.org/cases/1955/701

701

1955

Curtis Reid, Superintendent of the District of Columbia Jail

Claris Covert

<p>Mrs. Covert killed her husband on an airbase in England. Pursuant to a “status-of-forces” executive agreement with England, she was tried and convicted by US court-martial without a jury trial under the Uniform Code of Military Justice (UCMJ). She petitioned a writ of habeas corpus on the grounds that the conviction violated her Fifth &amp; Sixth Amendment rights to be tried by a jury after indictment by a grand jury.</p>

majority opinion

affirmed

Civil Rights

Griffin v. Illinois

https://api.oyez.org/cases/1955/95

95

1955

Judson Griffin and James Crenshaw

Illinois

<p>Judson Griffin and James Crenshaw were indicted for armed robbery in Cook County, Illinois. Following their conviction, in preparation for filling for an appeal, Griffin and Crenshaw requested a transcript of their trial proceedings without cost, on the basis that they could not afford the standard fee for the transcript. The lower court dismissed the petition without hearing evidence.</p>

plurality opinion

vacated/remanded

Civil Rights

Brown v. Board of Education of Topeka (2)

https://api.oyez.org/cases/1940-1955/349us294

1

1940-1955

Oliver Brown, Mrs. Richard Lawton, Mrs. Sadie Emmanuel et al.

Board of Education of Topeka

<p>After its decision in <em>Brown v. Board of Education of Topeka</em> (<em>Brown I</em>), which declared racial discrimination in public education unconstitutional, the Court convened to issue the directives which would help to implement its newly announced constitutional principle. The cases stemmed from many different regions of the United States with distinctive conditions and problems. </p>

majority opinion

reversed/remanded

Williamson v. Lee Optical of Oklahoma, Inc.

https://api.oyez.org/cases/1940-1955/348us483

184

1940-1955

Williamson

Lee Optical of Oklahoma, Inc.

<p>An Oklahoma law prohibited persons who were not licensed optometrists or ophthalmologists to fit lenses for eyeglasses. Non-licensed individuals were also prohibited from duplicating optical instruments without written prescriptions from licensed ophthalmologists. The Lee Optical Company challenged the law.</p>

majority opinion

reversed in-part

Kingsley Books, Inc. v. Brown

https://api.oyez.org/cases/1956/107

107

1956

Kingsley Books, Inc. et al.

Peter Campbell Brown

<p>New York state law authorized the legal counsel for a municipality to seek an injunction against and the destruction of material deemed by the courts to be obscene. Peter Campbell Brown, Corporation Counsel for the City of New York, sought such an injunction against several bookstores. The process of review that followed was a civil, rather than criminal procedure, and the courts ultimately granted the injunction and sought to destroy the obscene material.</p>

majority opinion

affirmed

First Amendment

Butler v. Michigan

https://api.oyez.org/cases/1956/16

16

1956

Butler

Michigan

<p>John H. Griffin’s book &lt;i&gt;The Devil Rides Outside&lt;/i&gt; traces the spiritual development of an unnamed American musician as he vacillates between choosing a life in a Benedictine monastery and the lustfulness of the outside world. When Alfred Butler, the Detroit district sales manager of Pocket Books, sold a copy of the book to a police officer, he was arrested and charged with violating a Michigan obscenity statute. At trial, the judge held that the book contained obscene language that could lead to the corruption of minors and that the passages in question lacked redeeming literary value. Butler was convicted and fined $100. Butler appealed and argued that the statute violated his right to free speech under the First and Fourteenth Amendments. The Supreme Court of Michigan denied Butler’s application for leave to appeal.</p>

majority opinion

reversed

First Amendment

Deen v. Gulf, Colorado & Santa Fe Railway Co.

https://api.oyez.org/cases/1956/199

199

1956

Earl R. Deen

Gulf, Colorado & Santa Fe Railway Company

<p><em>Not Available.</em></p>

per curiam

reversed/remanded

Economic Activity

Jencks v. United States

https://api.oyez.org/cases/1956/23

23

1956

Clinton D. Jencks

United States

<p>Clinton Jencks, a union leader, was charged with falsely filing an Affidavit of Non-Communist Union Officer with the National Labor Relations Board. Two undercover informants for the Federal Bureau of Investigation (FBI) testified against Jencks, and reported that he had been seen at Communist Party events and working with Communist Party members. The evidence provided against Jencks was entirely circumstantial, and the prosecution's evidence rested largely on the testimonies and reports of the undercover informants. Jencks requested the testimony of the informants to review their credibility and admissibility in court. The trial court denied his request without stating the reasons, and Jencks was found guilty on two counts of communist activity and sentenced to five years imprisonment for each offense. Jencks appealed the lower court's decision on the grounds that the informants' reports should have been provided for review to determine their use in the trial and on the grounds that the jury was improperly instructed on the definitions of political party membership. The U.S. Court of Appeals for the Fifth Circuit affirmed the decision of the lower court.</p>

majority opinion

reversed

Criminal Procedure

Leiter Minerals, Inc., v. United States

https://api.oyez.org/cases/1956/26

26

1956

Leiter Minerals, Inc.,

United States, The California Company, Allen L. Lobrano

<p>In December 1938, Thomas Leiter conveyed approximately 8,711 acres of land in Plaquemines Parish, Louisiana to the United States. The deed contained a mineral reservation under which Leiter retained the right to mine and remove all valuable minerals until April 1, 1945. The deed allowed for the extension of this reservation for an additional five years so long as operations were conducted profitably during the previous five years for an average of fifty days a year. If at the end of the original term or an additional extended term the operation had not carried on for fifty days a year, Leiter’s right to mine would terminate, and complete title would become vested in the United States. No mineral operations were conducted on the land in question during the original term.</p> <p>On March 1, 1949, the United States conveyed the operating rights under lease to Frank J. and Albert Lobrano, who then conveyed those rights to The California Company. The California Company drilled and completed eighty wells, producing $3,500,000 in royalties for the United States. Leiter Minerals, Inc. then filed an action in state court against Allen L. Lobrano and The California Company based on a Louisiana law allegedly making a reservation of mineral rights to the United States “imprescriptible”. The United States was not a party to the suit. Leiter Minerals claimed that it was the fee simple owner of all the oil, gas and mineral rights in or on the land acquired by the United States from Thomas Leiter.</p> <p>The United States then brought an action in district court; it sought to quiet Leiter Minerals’ title and rights and to enjoin Leiter Minerals from further asserting any claims in state court. The United States argued in part that irreparable injury in the form of lost royalties would result from any dispossession to its lessees. The district court granted the injunction, holding that the action could only be tried in federal court because the United States was not a party to the state court action.</p>

majority opinion

affirmed

Judicial Power

Watkins v. United States

https://api.oyez.org/cases/1956/261

261

1956

John Watkins

United States

<p>In 1954, John Watkins, a labor organizer, was called upon to testify in hearings conducted by the House Committee on Un-American Activities. Watkins agreed to describe his alleged connections with the Communist Party and to identify current members of the Party. Watkins refused to give information concerning individuals who had left the Communist Party. Watkins argued that such questions were beyond the authority of the Committee.</p>

majority opinion

reversed/remanded

First Amendment

Herdman v. Pennsylvania Railroad Company

https://api.oyez.org/cases/1956/46

46

1956

Virgil Herdman

Pennsylvania Railroad Company

<p>On February 1, 1951, Virgil Herdman, a train conductor, was in charge of a freight train traveling from Indiana to Ohio. While passing through Dayton, Ohio, the train braked abruptly to avoid hitting a car stopped on a railroad crossing. Herdman fell and was injured as the train came to a stop.</p> <p>Herdman sued the railroad company for negligence and claimed that the company was responsible for his fall under the doctrine of <i>res ipsa loquitur</i>. Courts typically apply this doctrine when negligence can be inferred, without actual direct evidence, from the very nature of the accident. The United States District Court for the Southern District of Ohio ruled in favor of the railroad on the basis that Herdman did not provide enough facts to support his negligence claim, even under the <i>res ipsa loquitur</i> doctrine. Herdman appealed and the United States Court of Appeals for the Sixth Circuit affirmed the lower court’s decision.</p>

majority opinion

affirmed

Economic Activity

Lambert v. California

https://api.oyez.org/cases/1956/47

47

1956

Lambert

California

<p>Under Los Angeles Municipal Code Section 52.39, no convicted felon could stay in the city for more than five days without registering. Lambert, a convicted felon, stayed in Los Angeles for seven years without registering and was convicted of violating the ordinance. On appeal, she argued that due process under the Fourteenth Amendment required the ordinance to include some mental state element, and she was not aware of it. </p>

majority opinion

reversed

Economic Activity

National Labor Relations Board v. Lion Oil Company

https://api.oyez.org/cases/1956/4

4

1956

National Labor Relations Board

Lion Oil Company, Monsanto Chemical Company

<p>Beginning on October 23, 1950, Lion Oil Company and Oil Workers International Union CIO entered into a collective bargaining agreement providing in detail the wages, hours and conditions for employees of the company. The agreement provided the means to amend its terms: Either party must notify the other in writing of its desire to amend the agreement, after which the company and the union should attempt to agree on the desired amendments. If no agreement was reached within sixty days, either party may terminate the agreement.</p> <p>On August 24, 1951, the union transmitted a letter to the company notifying the company of its desire to modify the agreement. Representatives of the company and the union first met on August 29, 1951 to discuss the proposed amendments. The two groups held 37 more meetings between that date and April 30, 1952, but no agreement was reached. On April 30, employees of the company went on strike, demanding wage increases and other benefits. Neither the company nor the union notified the other that it intended to terminate the contract. On June 21, 1952, the union offered to return all striking employees to work unconditionally, but the company refused this offer.</p> <p>The company distributed a letter to the union explaining that there would be no reinstatement of workers unless the employees agreed to work for a period of at least one year without work stoppage. After June 21, the company interviewed individual employees and rehired only those who assured the company that they would continue to work daily throughout the strike. On August 3, 1952, a new agreement was executed between the company and the union; employees were reinstated the next day.</p> <p>The National Labor Relations Act (NLRA) provided that where there is a collective bargaining contract, employees may not go on strike until sixty days after either party provides written notice of its intent to terminate or modify the contract or until the contract expires, whichever occurs later. Employees who go on strike before this point lose the protection of the NLRA.</p> <p>During the negotiations for the new agreement, the union filed a charge of unfair labor practices against the company with the National Labor Relations Board, based on the company’s response to the employees’ offer to return to work. The five member Board held in a split decision that the company was guilty of unfair labor practices under the NLRA, rejecting the company’s defense that the strikers lost the protection of the act because the contract was still in effect. The company appealed to the United States Court of Appeals for the Eighth Circuit, which set aside the Board’s ruling. The Eighth Circuit held that a strike would violate the terms of the contract until the contract expired or was cancelled in the manner provided for in the NLRA. As the contract had not expired when the employees went on strike, those employees violated the terms of the NLRA and lost its protection.</p> <p>While the case was pending in the Supreme Court, Lion Oil Company was merged into Monsanto Chemical Company. By order of the Court, Monsanto was made a party in the case.</p>

majority opinion

reversed/remanded

Unions

Rowoldt v. Perfetto

https://api.oyez.org/cases/1957/5

5

1957

Charles Rowoldt

J.D. Perfetto

<p>Charles Rowoldt, a German citizen living in the United States, received an order of deportation under the Internal Security Act of 1950 because of his membership in the Communist Party. Rowoldt admitted to joining the Party for about a year and working at a Communist bookstore. However, he contended that he should not be deported because he joined the Party to "fight for his daily needs" and get "something to eat and something to crawl into." The Internal Security Act contained an exception for those who joined the Party to obtain food, employment, or other necessities of living. Rowolt also indicated that he was not aware that anyone in the Party supported violent overthrow of the government. Rowoldt sought a writ of habeas corpus from the District Court for the District of Minnesota, but his writ was denied because there was enough evidence to support his membership in the Party. The Court of Appeals for the Eighth Circuit affirmed the District Court's judgment.</p>

majority opinion

reversed

First Amendment

United States v. Howard

https://api.oyez.org/cases/1956/52

52

1956

United States

Ludenia Howard, trading as Stokes Fish Company

<p>Federal criminal information was filed in district court against Ludenia Howard, representing Stokes Fish Company, for violating the Federal Black Bass Act. The Act forbids any person to transport black bass or other fish across state lines if doing so is prohibited by the laws of the state. In Florida, such issues are governed by the regulations of the Florida Game and Fresh Water Fish Commission. The district court held that the regulations were not “laws” of Florida under the meaning of the Black Bass Act and quashed the information. The United States appealed directly to the Supreme Court.</p>

majority opinion

reversed/remanded

Economic Activity

Mallory v. United States

https://api.oyez.org/cases/1956/521

521

1956

Mallory

United States

<p>Andrew Mallory was arrested by federal officers on charges of rape. Upon arresting Mallory, the officers questioned him until he confessed roughly seven hours later. After the confession, the police officers sought to reach a United States Commissioner for the purpose of arraigning Mallory.</p>

majority opinion

reversed/remanded

Criminal Procedure

Fikes v. Alabama

https://api.oyez.org/cases/1956/53

53

1956

William Earl Fikes

Alabama

<p>On April 24, 1953 in Selma, Alabama, an intruder broke into the apartment of the daughter of the city mayor. The daughter and the intruder struggled through several rooms until she was able to seize his knife, and he fled. The assailant had a towel over his head, so the victim could not identify the defendant during the trial. The police apprehended William Earl Fikes on the basis of a call from a private citizen and held him “on an open charge of investigation.” The police questioned Fikes for hours, placed him in jail, and limited his access to anyone familiar. After nearly a week of this treatment, Fikes confessed in the form of answers to the interrogator’s leading questions. Five days later, Fikes confessed under questioning a second time. When these confessions were admitted into the trial as evidence, Fikes did not testify regarding the events surrounding his interrogation because the judge had ruled he would be subjected to unlimited cross-examination. The jury convicted Fikes and sentenced him to death. The Supreme Court of Alabama affirmed.</p>

majority opinion

reversed/remanded

Criminal Procedure

Carroll v. United States

https://api.oyez.org/cases/1956/571

571

1956

Leon F. Carroll, Daniel J. Stewart

United States

<p>Police arrested Leon Carroll and Daniel Stewart on warrants for violating local lottery laws and conspiring to run a lottery. Each filed a pre-trial motion to suppress evidence found at the time of arrest. The district court granted the motions, citing a lack of probable cause. The U.S. Court of Appeals for the District of Columbia Circuit reversed, holding that the order for suppression of evidence was appealable.</p>

majority opinion

reversed/remanded

Criminal Procedure

Leedom v. International Union of Mine, Mill & Smelter Workers

https://api.oyez.org/cases/1956/57

57

1956

Boyd Leedom et al. Members of the National Labor Relations Board

International Union of Mine, Mill & Smelter Workers

<p>The National Labor Relations Act (NLRA) required union officers to file non-communist affidavits to gain the protections of the National Labor Relations Board (NLRB). The NLRA also made filing a false affidavit a crime. The NLRB found that an officer of the International Union of Mine, Mill &amp; Smelt workers had filed a false affidavit. The NLRB issued a decompliance order ceasing all protections. The union sued to enjoin the order. The district court denied relief, but the U.S. Court of Appeals for the District of Columbia Circuit reversed.</p>

majority opinion

affirmed

Judicial Power

Roviaro v. United States

https://api.oyez.org/cases/1956/58

58

1956

Roviaro

United States

<p>On August 12, 1954, agents of the Federal Bureau of Narcotics ("FBN") and the Chicago Police Department met twice with Albert Roviaro near the intersection of 75th Street and Prairie Avenue in Chicago. According to Agent Norris Durham of the FBN, after the second meeting, Detective Byson of the Chicago police climbed into the trunk of a Cadillac sedan owned and driven by "John Doe," an informant for the government. The trunk was propped open slightly to preserve Byson's line of sight. John Doe drove the car to 74th Street and St. Lawrence Avenue, where Alberto Roviaro got out of a Pontiac sedan. Roviaro entered the Cadillac sedan and took a seat next to the driver, John Doe.</p> <p>Durham followed the Cadillac, which took a circuitous rote to Champlain Avenue and 74th Street. He observed Roviaro leave the Cadillac and walk to a nearby tree, where he picked up a small package. Byson confirmed this from his vantage point in the Cadillac's trunk. Roviaro then walked to the car's open right front door and motioned as if he was leaving the package inside. A chemist working for the United States later identified the package's contents as heroin.</p> <p>The government charged Roviaro with trafficking heroin, in violation of the Narcotic Drugs Import and Export Act. He was convicted, and the district court denied his motion for a new trial. The U.S. Court of Appeals, Seventh Circuit, affirmed the ruling. Judge Walter Lindley, writing for a unanimous court, held that because John Doe was not a participant in Roviaro's actual possession of heroin, Roviaro is not entitled to full disclosure of his identity.</p>

majority opinion

reversed/remanded

Criminal Procedure

Roth v. United States

https://api.oyez.org/cases/1956/582

582

1956

Roth

United States

<p>Roth operated a book-selling business in New York and was convicted of mailing obscene circulars and an obscene book in violation of a federal obscenity statute. Roth's case was combined with <em>Alberts v. California</em>, in which a California obscenity law was challenged by Alberts after his similar conviction for selling lewd and obscene books in addition to composing and publishing obscene advertisements for his products.</p>

majority opinion

affirmed

First Amendment

Yates v. United States

https://api.oyez.org/cases/1956/6

6

1956

Oleta O'Connor Yates

United States

<p>Fourteen leaders of the Communist Party in the state of California were tried and convicted under the Smith Act. That Act prohibited willfully and knowingly conspiring to teach and advocate the overthrow of the government by force. This case was decided in conjunction with <em>Richmond v. United States</em> and <em>Schneiderman v. United States</em>.</p>

majority opinion

reversed/remanded

First Amendment

Trop v. Dulles

https://api.oyez.org/cases/1956/70

70

1956

Albert L. Trop

John Foster Dulles, Secretary of State

<p>In 1944, United States Army private Albert Trop escaped from a military stockade at Casablanca, Morocco, following his confinement for a disciplinary violation. A day later, Trop willingly surrendered to an army truck headed back to Casablanca. Despite testifying that he "decided to return to the stockade" when he was picked up, a general court martial convicted Trop of desertion and sentenced him to three years at hard labor, loss of all pay and allowances, and a dishonorable discharge. In 1952, Trop applied for a passport. His application was rejected under Section 401(g) of the amended 1940 Nationality Act, on the ground that he lost his citizenship due to his conviction and dishonorable discharge for wartime desertion. After failing to obtain a declaratory judgment that he was a US citizen, from both a district and the Second Circuit Court of Appeals, Trop appealed to the Supreme Court, which granted certiorari.</p>

majority opinion

reversed

United States v. Shotwell Manufacturing Company

https://api.oyez.org/cases/1957/1

1

1957

United States

Shotwell Manufacturing Company, et al.

<p>Shotwell Manufacturing, along with several employees, was convicted of evading income taxes. The U.S. Court of Appeals for the Seventh Circuit reversed the conviction because the district court had denied Shotwell’s motion to suppress evidence of certain disclosures. Shotwell allegedly made these disclosures in good faith, thinking they would shield them from liability. After the government petitioned for certiorari, they moved to remand the case to the district court in light of new evidence. If true, this new evidence could prove Shotwell lied while testifying about making the disclosures in good faith.</p>

majority opinion

vacated/remanded

Criminal Procedure

Chicago, Milwaukee, St. Paul & Pacific Railroad Company v. Illinois

https://api.oyez.org/cases/1957/12

12

1957

Chicago, Milwaukee, St. Paul & Pacific Railroad Company

State of Illinois, Illinois Commerce Commission, and Milwaukee Road Commuters' Association

<p>The Interstate Commerce Commission (ICC) passed an order making intrastate passenger fares for the Milwaukee Road’s Chicago suburban commuter line higher than the fares the state commission had authorized. The state of Illinois, the Illinois Commerce Commission, and the Milwaukee Road Commuters’ Association sued the ICC in district court and sought to enjoin the enforcement of the order. The district court held that the ICC had failed to show that the fares authorized by the state commission caused undue, unreasonable, or unjust discrimination against interstate commerce, and therefore the order was not justified. The ICC appealed the case directly to the Supreme Court.</p>

majority opinion

affirmed

Economic Activity

Cicenia v. Lagay

https://api.oyez.org/cases/1957/177

177

1957

Cicenia

Lagay

<p>During police interrogation for a murder, Cicenia and his counsel repeatedly requested to see one another but they were refused their requests. By the time Cicenia saw his attorney, he had made and signed a written confession to the murder. Cicenia moved the state trial court for an order requiring the state to produce his written confession. The trial court denied the motion and the state supreme court affirmed the decision. Cicenia commenced a federal habeas corpus proceeding and the lower court discharged the writ, holding that Cicenia had failed to establish the involuntariness of his confession and that the state's refusal to permit petitioner to communicate with counsel during the inquiry did not deprive him of due process. The appellate court affirmed and the Supreme Court granted certiorari.</p>

majority opinion

affirmed

Criminal Procedure

Crooker v. California

https://api.oyez.org/cases/1957/178

178

1957

John Russell Crooker, Jr.

California

<p>On July 5, 1955, John Russell Crooker was arrested for the murder of his boss with whom he had been having an illicit relationship. For the next fourteen hours, Crooker was sporadically questioned and interrogated in his home and in the West Los Angeles Police Station; he repeatedly asked to meet with an attorney and was told that he could call only after the investigation was over. After fourteen hours of detainment and periodic interrogation, Crooker wrote a full confession to the murder. The next morning, Crooker was asked to orally repeat his confession, but he refused and again asked to speak with an attorney. Crooker was permitted to call his attorney at that point, and from then forward, he was represented by his counsel.</p> <p>At trial, Crooker argued that his confession was obtained in violation of his Fourteenth Amendment right to due process because his confession was coerced by state authorities, and even if it was given voluntarily, he was denied the right to counsel. The issue of whether Crooker’s confession was voluntary was presented to the jury, which resolved the question against Crooker and convicted him. The Supreme Court of California affirmed.</p>

majority opinion

affirmed

Criminal Procedure

Cooper v. Aaron

https://api.oyez.org/cases/1957/1_misc

1 MISC

1957

William G. Cooper et al., Members of the Board of Directors of the Little Rock, Arkansas, Independent School District, et al.

John Aaron, et al.

<p>The Governor and the Legislature of Arkansas openly resisted the Supreme Court's decision in <em>Brown v. Board of Education</em>. On February 20, 1958, five months after the integration crisis involving the Little Rock Nine, members of the school board (along with the Superintendent of Schools) filed suit in the United States District Court for the Eastern District of Arkansas, urging suspension of its plan of desegregation. The relief the plaintiffs requested was for the African American children to be returned to segregated schools and for the implementation of the desegregation plan to be postponed for two and a half years. The district court granted the school board's request, but the United States Court of Appeals for the Eighth Circuit reversed.</p>

per curiam

affirmed

International Union, United Automobile, Aircraft and Agricultural Implement Workers of America (UAW-CIO) v. Russell

https://api.oyez.org/cases/1957/21

21

1957

International Union, United Automobile, Aircraft and Agricultural Implement Workers of America (UAW-CIO)

Paul S. Russell

<p>On July 18, 1951 the International Automobile Union called a strike against Wolverine Tube, Inc., a subsidiary of the Calumet and Hecla Consolidated Copper Company, located in Decatur, AL. As a result of this strike, Mr. Paul Russell, a non-union employee at the plant, was prevented from working when members of the picket line made violent threats against him and physically blocked the only entrance into the plant. The strike lasted until August 22, 1951.</p> <p>Russell sued the union in Alabama state court, claiming that the union unlawfully invaded his right to engage in a lawful occupation free from unlawful interference. The Union argued that the Labor Management Act of 1947 removed jurisdiction from the state court to the National Labor Relations Board (NLRB). When the trial court decided for the union, Russell appealed. The Supreme Court of Alabama reversed the lower court’s decision and remanded the case for trial.</p> <p>At trial, a jury returned a $10,000.00 verdict for Russell. The union appealed, arguing that the jury verdict was excessive and reiterating its argument that the state court had no jurisdiction to hear this case. The Supreme Court of Alabama affirmed the trial court’s decision.</p>

majority opinion

affirmed

Federalism

Romero v. International Terminal Operating Company

https://api.oyez.org/cases/1958/3

3

1958

Francisco Romero

International Terminal Operating Company Compania Trasatlantica, also known as Spanish Line, Garcia & Diaz, Inc., and Quin Lumber Co., Inc.

<p>While the Spanish ship S.S. Guadalupe was docked in Hoboken, NJ, a cable struck Francisco Romero and seriously him. He sued for negligence under the Jones act and maritime law. The Jones Act provides jurisdiction for claims under the Constitution and treaties of the U.S. for persons of diverse citizenship. Both Romero and his employer were aliens, so there was no diversity of citizenship. Also, the maritime laws did not arise from the Constitution or treaties of the U.S.. The district court dismissed all claims for lack of jurisdiction. The district court also held that Romero could receive adequate remedies under Spanish law. The U.S. Court of Appeals for the Second Circuit affirmed.</p>

majority opinion

vacated/remanded

First Unitarian Church for Los Angeles v. County of Los Angeles

https://api.oyez.org/cases/1957/382

382

1957

First Unitarian Church for Los Angeles

County of Los Angeles et al.

<p>These are two consolidated cases concerning property tax exemption under the California Constitution and California Revenue and Taxation Code (CRTC) for real property and buildings used solely for religious worship. The California Constitution requires denial of tax exemption to any person or organization who advocates the overthrow of the U.S. Government or the State of California by violent or unlawful means. To enforce this, a provision of the CRTC requires those applying for tax exemption to sign an oath declaring that they do not engage in that prohibited activity.</p> <p>In both cases, the Los Angeles assessor denied tax exemption because the churches refused to agree to the oath. The churches paid their taxes under protest and sued the County of Los Angeles for a refund. The churches argued that requiring them to agree to the oath violated the U.S. Constitution. In 382, the trial court upheld the oath and the Supreme Court of California affirmed. In 385, the court upheld the oath under the U.S. Constitution, but held that it violated the California Constitution because it excluded householders from the requirement. The Supreme Court of California reversed.</p>

majority opinion

reversed/remanded

First Amendment

Staub v. City of Baxley

https://api.oyez.org/cases/1957/48

48

1957

Rose Staub

City of Baxley

<p>Rose Staub was convicted and fined for attempting to organize a branch of the International Ladies’ Garment Workers Union at Hazlehurst Manufacturing Company. She violated an ordinance in the neighboring town of Baxley, where many of the Manufacturing Co. workers lived. That ordinance required anyone soliciting members for a union to apply for a permit from the mayor and city council. The mayor and city council had unlimited discretion to grant or deny the permits for any reason. Staub argued that the ordinance violated her constitutional right to free speech. The Court of Appeals of Georgia affirmed the conviction, but did not consider the constitutional question because Staub did not attempt to comply with the ordinance. The Supreme Court of Georgia denied certiorari.</p>

majority opinion

reversed

First Amendment

Kent v. Dulles

https://api.oyez.org/cases/1957/481

481

1957

Kent

Dulles

<p>Rockwell Kent applied for and was refused a passport to visit England. In addition to informing him that his application refusal rested on his Communist Party affiliations, the Passport Office Director told Kent that in order for a passport to be issued a hearing would be necessary. The Director instructed Kent to submit an affidavit as to whether he was a current or past Communist. Upon the advice of counsel, Kent refused to sign the affidavit but did participate in a hearing at which he was once more asked to sign an affidavit concerning his Communist affiliations. When he refused the affidavit, the Passport Department advised Kent that no further action would be taken on his passport request until he satisfied the affidavit requirement. On appeal from consecutive adverse rulings in both district and appellate court, the Supreme Court granted Kent certiorari.</p>

majority opinion

reversed

First Amendment

Wiener v. United States

https://api.oyez.org/cases/1957/52

52

1957

Wiener

United States

<p>By the War Claims Act of 1948, Congress established the War Claims Commission for the purpose of adjudicating claims for compensating internees, prisoners of war, and religious organizations. Wiener was confirmed as a member of the Commission by President Truman in 1950. In 1953, when President Eisenhower requested Wiener's resignation, Wiener refused. Eisenhower subsequently appointed a substitute to Wiener's post. The Commission was abolished in 1954, and Wiener brought a claim to recover his salary from the time of his removal to the last day of the Commission's existence.</p>

majority opinion

reversed

Economic Activity

Byrd v. Blue Ridge Rural Electric Cooperative, Inc.

https://api.oyez.org/cases/1957/57

57

1957

Byrd

Blue Ridge Rural Electric Cooperative, Inc.

<p>Byrd, a resident of North Carolina, was employed by a subcontractor of Blue Ridge Electric, a South Carolina company. When he was hurt during his work on power lines, Byrd sued Blue Ridge for negligence in a federal court, based on diversity jurisdiction. Blue Ridge defended against his claim based on a South Carolina law providing that employees of sub-contractors should be considered employees of contractors for which the sub-contractor provided work. South Carolina law further provided that the immunity defense needed to be determined by a judge rather than a jury. Byrd contended that his Seventh Amendment right to a jury trial should trump that provision of the state law. </p>

majority opinion

reversed/remanded

Economic Activity

American Trucking Associations, Inc. v. United States

https://api.oyez.org/cases/1957/6

6

1957

American Trucking Associations, Inc.

United States

<p>In 1938, the Interstate Commerce Commission authorized Rock Island Motor Transit, a subsidiary of the Chicago, Rock Island and Pacific Railroad, to purchase the property and rights of the White Line Motor Freight Company between Silvis, Illinois and Omaha, Nebraska. The certificate limited motor operations to service to or from points on the Rock Island Railroad, subject to any restrictions the commission might impose under the Interstate Commerce Act to insure that the service was auxiliary or supplementary to train service. The Act authorized consolidation, merger, acquisition, or lease of common carriers if the commission deemed it to be “consistent with the public interest.” In a separate section, Congress directed the commission not to certify a railroad corporation seeking to operate motor carriers unless it also found that the railroad would use motor vehicle service to public advantage in its operations and would not unduly restrain competition.</p> <p>In 1944, Rock Island purchased the Frederickson Lines, covering routes between Atlantic, Iowa and Omaha, Nebraska. Rock Island filed for permission to provide motor service to points along the Frederickson Lines. The commission granted Rock Island permission, but placed five conditions on motor service for both the White and Frederickson routes. Rock Island challenged the conditions in district court and won, but on appeal, the Supreme Court upheld the commission’s power to impose the conditions.</p> <p>Rock Island then filed for permission to provide unrestricted motor service to points along the White and Frederickson lines. In 1954, the application was substantially granted. American Trucking Associations, Inc., nine other motor carriers, a group of railway trade unions, and several other organizations intervened, arguing that 1) the commission was required to limit motor service by a rail-owned motor carrier to auxiliary or supplementary service, and 2) the evidence was not sufficient to support the commission’s certification order. The district court upheld the certificate as granted.</p>

majority opinion

affirmed

Economic Activity