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Betts v. Brady

https://api.oyez.org/cases/1940-1955/316us455

837

1940-1955

Smith Betts

Patrick J. Brady, Warden

<p>Betts was indicted for robbery in Maryland. He was unable to afford counsel and requested one be appointed for him. The judge in the case denied the request, and Betts subsequently pled not guilty. He was convicted of robbery, which he eventually appealed to the Supreme Court. He argued he was wrongfully denied his right to counsel.</p>

majority opinion

affirmed

Criminal Procedure

Wickard v. Filburn

https://api.oyez.org/cases/1940-1955/317us111

59

1940-1955

Claude R. Wickard, Secretary of Agriculture et al.

Roscoe C. Filburn

<p>Filburn was a small farmer in Ohio who harvested nearly 12 acres of wheat above his allotment under the Agricultural Adjustment Act of 1938. Filburn was penalized under the Act. He argued that the extra wheat that he had produced in violation of the law had been used for his own use and thus had no effect on interstate commerce, since it never had been on the market. In his view, this meant that he had not violated the law because the additional wheat was not subject to regulation under the Commerce Clause. </p>

majority opinion

reversed

West Virginia State Board of Education v. Barnette

https://api.oyez.org/cases/1940-1955/319us624

591

1940-1955

West Virginia State Board of Education

Walter Barnette

<p>In 1942, the West Virginia Board of Education required public schools to include salutes to the flag by teachers and students as a mandatory part of school activities. The children in a family of Jehovah's Witnesses refused to perform the salute and were sent home from school for non-compliance. They were also threatened with reform schools used for criminally active children, and their parents faced prosecutions for causing juvenile delinquency.</p>

majority opinion

affirmed

Yakus v. United States

https://api.oyez.org/cases/1940-1955/321us414

374

1940-1955

Albert Yakus

United States

<p>In 1942, Congress enacted the Emergency Price Control Act to control commodity prices and prevent inflation during wartime. This case is the consolidation of two cases in which the defendants were tried and convicted in district court on several counts of selling wholesale cuts of beef at prices above the maximum prices set by the Revised Maximum Price Regulation under the Act. During the trial, the district court overruled all motions regarding the validity of the Regulation and the Act, including questions of whether the Act deprived the defendants of their Fifth Amendment rights to due process. The U.S. Court of Appeals for the First Circuit affirmed the convictions.</p>

Korematsu v. United States

https://api.oyez.org/cases/1940-1955/323us214

22

1940-1955

Fred Toyosaburo Korematsu

United States

<p>In response to the Japanese attack on Pearl Harbor during World War II, the U.S. government decided to require Japanese-Americans to move into relocation camps as a matter of national security. President Franklin Roosevelt signed Executive Order 9066 in February 1942, two months after Pearl Harbor. A Japanese-American man living in San Leandro, Fred Korematsu, chose to stay at his residence rather than obey the order to relocate. Korematsu was arrested and convicted of violating the order. He responded by arguing that Executive Order 9066 violated the Fifth Amendment. The Ninth Circuit affirmed Korematsu's conviction.</p>

majority opinion

affirmed

Everson v. Board of Education of the Township of Ewing

https://api.oyez.org/cases/1940-1955/330us1

52

1940-1955

Arch R. Everson

Board of Education of the Township of Ewing

<p>A New Jersey law authorized reimbursement by local school boards of the costs of transportation to and from schools, including private schools. 96% of the private schools who benefitted from this law were parochial Catholic schools. Arch R. Everson, a taxpayer in Ewing Township, filed a lawsuit alleging that this indirect aid to religion violated both the New Jersey state constitution and the First Amendment. After losing in state courts, Everson appealed to the U.S. Supreme Court on purely federal constitutional grounds.</p>

majority opinion

affirmed

Shelley v. Kraemer

https://api.oyez.org/cases/1940-1955/334us1

72

1940-1955

J. D. Shelley and Ethel Lee Shelley et al.

Louis Kraemer and Fern Kraemer

<p>In 1911, a St. Louis, Missouri neighborhood enacted a racially restrictive covenant designed to prevent African-Americans and Asian-Americans from living in the area. In 1945, an African-American family (the Shelleys) moved into the neighborhood. Louis Kraemer brought suit to enforce the covenant and prevent the Shelleys from moving into their house. A similar lawsuit arose in Detroit, Michigan. Both state supreme courts enforced the covenants because they were private rather than state action. The Supreme Court consolidated the cases on appeal. </p>

majority opinion

reversed

Illinois ex rel. McCollum v. Board of Ed. of School Dist. No. 71, Champaign County

https://api.oyez.org/cases/1940-1955/333us203

90

1940-1955

Illinois ex rel. Vashti McCollum

Board of Ed. of School Dist. No. 71, Champaign County, Illinois

<p>The case tested the principle of "released time", where public schools set aside class time for religious instruction. The Champaign County Board of Education authorized a program in which outside religious teachers hired by private third parties provided weekly religious instruction in public schools. The classes were not mandatory. McCollum, an atheist, complained that her son was ostracized for not attending the classes. McCollum eventually sued the school board in 1945, arguing that the religious instruction in the public schools violated the Establishment Clause of the First Amendment and the Equal Protection Clause of the Fourteenth Amendment. </p>

majority opinion

reversed

Wolf v. Colorado

https://api.oyez.org/cases/1940-1955/338us25

17

1940-1955

Julius A. Wolf

Colorado

<p>Julius A. Wolf, Charles H. Fulton, and Betty Fulton were charged with conspiracy to perform an abortion. At trial, Wolf objected to evidence material and admissible as to his co-defendants would be inadmissible if he were tried separately. The Colorado Supreme Court upheld all three convictions in which evidence was admitted that would have been inadmissible in a prosecution for violation of a federal law in a federal court.</p>

majority opinion

affirmed

Sweatt v. Painter

https://api.oyez.org/cases/1940-1955/339us629

44

1940-1955

Heman Marion Sweatt

Theophilis Shickel Painter

<p>In 1946, Heman Marion Sweatt, a black man, applied for admission to the University of Texas Law School. State law restricted access to the university to whites, and Sweatt's application was automatically rejected because of his race. When Sweatt asked the state courts to order his admission, the university attempted to provide separate but equal facilities for black law students.</p>

majority opinion

reversed/remanded

Dennis v. United States

https://api.oyez.org/cases/1940-1955/341us494

336

1940-1955

Eugene Dennis, John B. Williamson, Jacob Stachel, et al.

United States

<p>In 1948, eleven Communist Party leaders were convicted of advocating the violent overthrow of the US government and for the violation of several points of the Smith Act. The Act made it unlawful to knowingly conspire to teach and advocate the overthrow or destruction of the United States government. The party members who had been petitioning for socialist reforms claimed that the Act violated their First Amendment rights. Party leaders were found guilty and lower courts upheld the conviction.</p>

plurality opinion

affirmed

Youngstown Sheet & Tube Company v. Sawyer

https://api.oyez.org/cases/1940-1955/343us579

744

1940-1955

Youngstown Sheet & Tube Company

Charles Sawyer, Secretary of Commerce

<p>In April of 1952, during the Korean War, President Truman issued an executive order directing Secretary of Commerce Charles Sawyer to seize and operate most of the nation's steel mills. This was done in order to avert the expected effects of a strike by the United Steelworkers of America.</p>

majority opinion

affirmed

Hernandez v. Texas

https://api.oyez.org/cases/1940-1955/347us475

406

1940-1955

Pete Hernandez

Texas

<p>Pete Hernandez, an agricultural worker, was indicted for the murder of Joe Espinoza by an all-Anglo (white) grand jury in Jackson County, Texas. Claiming that Mexican-Americans were barred from the jury commission that selected juries, and from petit juries, Hernandez' attorneys tried to quash the indictment. Moreover, Hernandez tried to quash the petit jury panel called for service, because persons of Mexican descent were excluded from jury service in this case. A Mexican-American had not served on a jury in Jackson County in over 25 years and thus, Hernandez claimed that Mexican ancestry citizens were discriminated against as a special class in Jackson County. The trial court denied the motions. Hernandez was found guilty of murder and sentenced by the all-Anglo jury to life in prison. In affirming, the Texas Court of Criminal Appeals found that "Mexicans are...members of and within the classification of the white race as distinguished from members of the Negro Race" and rejected the petitioners' argument that they were a "special class" under the meaning of the Fourteenth Amendment. Further, the court pointed out that "so far as we are advised, no member of the Mexican nationality" challenged this classification as white or Caucasian.</p>

majority opinion

reversed

Brown v. Board of Education of Topeka (1)

https://api.oyez.org/cases/1940-1955/347us483

1

1940-1955

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

Board of Education of Topeka, Shawnee County, Kansas, et al.

<p>This case was the consolidation of cases arising in Kansas, South Carolina, Virginia, Delaware, and Washington D.C. relating to the segregation of public schools on the basis of race. In each of the cases, African American students had been denied admittance to certain public schools based on laws allowing public education to be segregated by race. They argued that such segregation violated the Equal Protection Clause of the Fourteenth Amendment. The plaintiffs were denied relief in the lower courts based on <em>Plessy v. Ferguson</em>, which held that racially segregated public facilities were legal so long as the facilities for blacks and whites were equal. (This was known as the “separate but equal” doctrine.) </p>

majority opinion

none

Bolling v. Sharpe

https://api.oyez.org/cases/1940-1955/347us497

8

1940-1955

Spotswood Thomas Bolling et al.

C. Melvin Sharpe et al.

<p>The D.C. Board of Education denied a petition by a group of parents in Anacostia to racially integrate John Phillip Sousa Junior High School. The following year, in 1950, the parents sought admission to the all-white school for 11 African-American children. When the request was again denied by the Board, a Howard University law professor brought a lawsuit. The claim was dismissed by the trial court.</p>

majority opinion

reversed

Gayle v. Browder

https://api.oyez.org/cases/1956/342

342

1956

W. A. Gayle, Mayor of Montgomery

Aurelia Browder

<p>While the Rev. Martin Luther King, Jr. led a boycott of the racially segregated bus system in Montgomery Alabama, the Legal Defense Fund of the NAACP challenged racial segregation on the bus system in the federal courts. This case arose in federal court as a violation of Reconstruction-era civil rights statutes and as a violation of the Equal Protection clause of the Fourteenth Amendment. A three-judge district court held that state enforcement of the segregated but privately owned bus system in Montgomery violated the Equal Protection Clause. The city appealed directly to the Supreme Court.</p>

per curiam

affirmed

Thornburgh v. Abbott

https://api.oyez.org/cases/1988/87-1344

87-1344

1988

Richard L. Thornburgh

Jack Abbott, et al.

<p>Jack Abbott and other prisoners were denied access to publications that Richard Thornburgh, the U.S. Attorney General at the time, and the Federal Bureau of Prisons (FBP) deemed to be detrimental to penological interests. FBP regulations allow publications that may pose a threat to the security and discipline of prisons or that promote criminal activity to be rejected. Material cannot be rejected based on its political, philosophical, or distasteful nature, and prison officials have the burden of showing why the restriction was necessary and how the denied material was detrimental to penological interests. Abbott and others sued and argued that the restriction on certain publications violated their First Amendment rights. The district court held that prisons had a right to deny access to certain publications and that prison wardens must be given broad discretion in their duties to maintain the security of the prison, but their discretion must not limit the prisoners’ First Amendment right more than what is necessary to protect the government’s penological interests. The U.S. Court of Appeals for the District of Columbia Circuit reversed and held that the prison officials had the burden of showing how the denied material is detrimental to penological interests.</p>

majority opinion

vacated/remanded

Taylor v. United States

https://api.oyez.org/cases/2015/14-6166

14-6166

2015

David Anthony Taylor

United States

<p>David Anthony Taylor was a member of the “Southwest Goonz,” a group of robbers based in Roanoke, Virginia, that focused on robbing drug dealers, who typically have drug proceeds in their home and are reluctant to report crime. Taylor was indicted on two counts of robbery under the Hobbs Act, which prohibits actual or attempted robbery or extortion affecting interstate or foreign commerce. At Taylor’s second trial, after his first resulted in a hung jury, the government moved to prevent Taylor from offering evidence that robbing a drug dealer who grows marijuana outside of state lines does not affect interstate commerce and therefore cannot violate the Hobbs Act. The district court granted the government’s motion, and Taylor was subsequently convicted of both counts under the Hobbs Act. Taylor moved to set aside the verdict on the grounds that the government did not present sufficient evidence that his actions affected interstate commerce. The district court denied Taylor’s motion, and the U.S. Court of Appeals for the Fourth Circuit affirmed the conviction.</p>

majority opinion

affirmed

Criminal Procedure

RJR Nabisco v. The European Community

https://api.oyez.org/cases/2015/15-138

15-138

2015

RJR Nabisco, Inc., et al.

The European Community, et al.

<p>The European Community and 26 of its member states sued RJR Nabisco (RJR) and alleged that RJR directed, managed, and controlled a global money-laundering enterprise in violation of the Racketeer Influenced and Corrupt Organizations (RICO) statute. The European Community claimed that Colombian and Russian criminal organizations imported illegal drugs into European countries, where they produced revenue in euros that was then laundered back into the currency of the criminal organizations’ home countries while the euros were sold to cigarette importers at a discounted rate to purchase RJR’s cigarettes. The lawsuit alleged that RJR controlled this operation and in the course of executing it committed various violations of the RICO statute as well as violations of New York state law. The defendants moved to dismiss, and the district court granted the motion based on the presumption the U.S. statutes did not apply extraterritorially absent express Congressional intent. The U.S. Court of Appeals for the Second Circuit reversed and held that claims under the RICO statute can apply extraterritorially when the RICO claim is a violation of a predicate statute that Congress clearly intended to apply extraterritorially.</p>

majority opinion

reversed/remanded

Economic Activity

Wittman v. Personhuballah

https://api.oyez.org/cases/2015/14-1504

14-1504

2015

Robert J. Wittman, et al.

Gloria Personhuballah, et al.

<p>In 2012, the Virginia State Legislature adopted a redistricting plan that altered the composition of the Third Congressional District, which was already majority African-American, and increased the percentage of African-American voters in the district. Pursuant to Section 5 of the Voting Rights Act, the plan was submitted to the Department of Justice for preclearance, which was granted. On October 2, 2013, plaintiffs sued the defendants in their official capacities and argued that Virginia’s Third Congressional District was racially gerrymandered in violation of the Equal Protection Clause of the Fourteenth Amendment. The district court ruled that the districting plan was unconstitutional because its use of race as a factor was not sufficiently narrowly tailored to serve a compelling government interest.</p> <p>The defendant Commonwealth of Virginia did not appeal; instead, ten members of Congress, who had intervened in the case at the trial level, appealed to the U.S. Supreme Court, which remanded the case for reconsideration in light of its decision in <em>Alabama Legislative Black Caucus v. Alabama</em>. In that case, the Court held that the Voting Rights Act does not require a legislature to maintain a particular minority number percentage in creating a districting plan, but rather it requires that the legislature maintain a minority’s ability to elect a candidate of choice. In considering whether a districting plan is unconstitutional, courts must examine whether racial considerations predominated over nonracial ones in determining which voters to place in which district. On remand, the district court again determined that the Third Congressional District was unconstitutional because racial considerations predominated in creating the plan.</p>

dismissal - other

none

Judicial Power

MHN Government Services, Inc., and Managed Health Network, Inc. v. Zaborowski, et al.

https://api.oyez.org/cases/2015/14-1458

14-1458

2015

MHN Government Services Inc., and Managed Health Network, Inc.

Thomas Zaborowki, et al.

<p>MHN Government Services (MHN) hired the plaintiffs, a group of professionally licensed counselors, to provide counseling to military service members and their families across the United States and overseas. The plaintiffs sued MHN for unpaid overtime under the Fair Labor Standards Act and claimed they were improperly identified as “consultants” for MHN and not full-time employees, which resulted in the denial of overtime compensation. MHN filed a motion to compel arbitration because the plaintiffs’ employment contract with MHN included a clause requiring arbitration and denying the right to “jury or court trial.” The district court denied the motion because it held that the arbitration provision was unconscionable, and under California law, unconscionable contracts are unenforceable. The district court held that the provision was unconscionable due to its placement near the bottom of the employment contract with no effort to highlight or draw attention to the provision, the fact that MHN is a major corporation whose bargaining power and finances put it in a superior position to the plaintiffs during arbitration, and the fact that the arbitration provision of the employment contract allowed for limited discovery. The U.S. Court of Appeals for the Ninth Circuit affirmed the lower court’s decision.</p>

dismissal - moot

none

Molina-Martinez v. United States

https://api.oyez.org/cases/2015/14-8913

14-8913

2015

Saul Molina-Martinez

United States

<p>Saul Molina-Martinez pleaded guilty to being in the United States illegally following deportation proceedings that stemmed from his felony convictions. The district court accordingly sentenced Molina-Martinez to 77 months in prison, pursuant to the sentencing range established in the U.S. Sentencing Guidelines for his criminal history category. Under the Sentencing Guidelines, prior sentences are counted as a single sentence if they were imposed on the same day unless the offenses in question were separated by an intervening arrest. Molina-Martinez’s prior offenses were not separated by an intervening arrest, so when his probation officer calculated his criminal history points and concluded that they placed him in category VI, he erred; Molina-Martinez should properly have been placed in category V, which carries a lower sentencing range of 70-87 months. Molina-Martinez appealed his sentence on the grounds that the district court erred in sentencing him based on the incorrect criminal history category. The U.S. Court of Appeals for the Fifth Circuit held that, despite the error in calculation, Molina-Martinez failed to show that the error affected his substantial rights and therefore affirmed his conviction and sentence.</p>

majority opinion

reversed/remanded

Criminal Procedure

Utah v. Strieff

https://api.oyez.org/cases/2015/14-1373

14-1373

2015

Utah

Edward Joseph Strieff

<p>Utah Detective Douglas Fackrell received an anonymous tip about drug sales in a South Salt Lake residence, so he surveyed the area over a short period of time and speculated there was drug activity taking place. Fackrell saw Edward Joseph Strieff, Jr. leaving the residence and stopped him for questioning. During the stop, Fackrell discovered Strieff had an outstanding warrant and arrested him. During the lawful search after his arrest, Fackrell found methamphetamine and a drug pipe on Strieff’s person. The district court ruled that, although Fackrell did not have enough evidence to conduct an investigatory stop, the methamphetamine and drug paraphernalia obtained during the lawful search incident to arrest justified the admission of that evidence for trial. The Utah Court of Appeals affirmed the district court’s ruling, but the Utah Supreme Court reversed and held that the evidence should have been suppressed because the warrant that was the basis for the arrest was discovered during an unlawful investigatory stop.</p>

majority opinion

reversed

Criminal Procedure

Duncan v. Owens

https://api.oyez.org/cases/2015/14-1516

14-1516

2015

Stephen Duncan

Lawrence Owens

<p>Ramon Nelson was riding his bike when he suffered a lethal blow to the back of his head with a baseball bat. After two eyewitnesses identified Lawrence Owens from an array of photos and then a lineup, he was tried and convicted for Nelson’s death. Because Nelson was carrying cocaine and crack cocaine potentially for distribution, the judge at Owens’ bench trial ruled that Owens was probably also a drug dealer and was trying to “knock [Nelson] off.” Owens was found guilty of first-degree murder and sentenced to 25 years in prison.</p> <p>Owens filed a petition for a writ of habeas corpus on the grounds that his constitutional right to due process was violated during the trial. He argued that the eyewitness identification should have been inadmissible based on unreliability and that the judge impermissibly inferred a motive when a motive was not an element of the offense. The district court denied the writ of habeas corpus, and Owens appealed. The U.S. Court of Appeals for the Seventh Circuit reversed the denial and held that the trial judge’s inference about Owens’s motive violated his right to have his guilt adjudicated solely based on the evidence presented at trial.</p>

per curiam

none

Judicial Power

Americold Realty Trust v. Conagra Foods, Inc., et al.

https://api.oyez.org/cases/2015/14-1382

14-1382

2015

Americold Realty Trust

Conagra Foods, Inc., et al.

<p>The plaintiffs, food distributors including Conagra Foods Inc. and Kraft Foodservice, sued Americold Logistics LLC and Americold Realty Trust (Americold) in state court for a breach of contract stemming from a dispute regarding liability for a warehouse fire. Americold sought to remove the case to federal court based on diversity jurisdiction because of the diversity of the trust’s board. No party challenged the propriety of the removal, and the district court addressed the case solely on its merits. Both parties moved for summary judgment, and the district court found in favor of the defendant.</p> <p>On appeal, the U.S. Court of Appeals of the Tenth Circuit raised the issue of potentially improper removal and asked the parties to submit briefs addressing the issue. The appellate court held that Americold did not meet its burden to demonstrate that diversity jurisdiction was appropriate because the inquiry must extend to the trust’s beneficiaries (who are its shareholders), not just the trustees.</p>

majority opinion

affirmed

Judicial Power

Bank Markazi v. Peterson

https://api.oyez.org/cases/2015/14-770

14-770

2015

Bank Markazi

Deborah Peterson, et al.

<p>Deborah Peterson and a group of other plaintiffs were seeking to obtain judgments for injury or wrongful death during acts of terrorism by Iran. The Iran Central Bank (Bank Markazi) owned nearly $2 billion worth of bonds that were held in an account in New York City. Based on the Uniform Commercial Code, these assets were not considered assets of Bank Markazi, and therefore could not be attached by the plaintiffs and were immune from attachment under the Foreign Sovereign Immunities Act.</p> <p>While this case was pending, Congress passed the Iran Threat Reduction and Syria Human Rights Act of 2012, Section 8772 of which stated, “[T]he financial assets that are identified in and the subject of proceedings in the United States District for the Southern District of New York in Peterson et al. v. Islamic Republic of Iran et al., shall be subject to execution…in order to satisfy any judgment to the extent of any compensatory damages awarded against Iran for damages for personal injury or death caused by an act of [terrorism].” The plaintiffs moved for summary judgment based on Section 8772. Bank Markazi argued that Section 8772 violated the United States’ separation of powers because the law was solely directed at this specific case. The district court granted summary judgment for plaintiffs and ordered the turnover of the assets. The U.S. Court of Appeals for the Second Circuit affirmed.</p>

majority opinion

affirmed

Economic Activity

Nebraska v. Parker

https://api.oyez.org/cases/2015/14-1406

14-1406

2015

State of Nebraska, et al.

Mitch Parker, et al.

<p>Omaha Tribal members attempted to enforce liquor licenses and taxes on local venders and clubs selling alcoholic beverages in Pender, Nebraska. The plaintiffs, the owners of clubs and venues that sold alcoholic beverages in Pender, Nebraska, joined by the state of Nebraska, sued for injunctive relief and argued that they are not located on federally-recognized Indian reservation land and therefore were not under the jurisdiction of the Omaha Tribe. The plaintiffs and defendants cross-filed for summary judgment, and the trial court found in favor of the defendants. The trial court held that Pender, Nebraska, was under the jurisdiction of tribal law because the U.S. Senate’s passage of an 1882 Act that allowed the Omaha tribe to sell allotments of its tribal land did not diminish the tribal boundaries of jurisdiction. The U.S. Court of Appeals for the Eighth Circuit affirmed the lower court’s decision.</p>

majority opinion

affirmed

Civil Rights

Maryland v. Kulbicki

https://api.oyez.org/cases/2015/14-848

14-848

2015

Maryland

James Kulbicki

<p>In 1993, James Kulbicki fatally shot his 22-year-old mistress the weekend before a scheduled hearing on unpaid child support in an ongoing paternity suit between the two. At Kulbicki’s trial, the prosecution presented evidence that the bullet removed from the victim’s brain and the bullet taken from Kulbicki’s gun were a close enough match that they likely came from the same package. After being presented with this ballistics evidence, as well as other physical evidence and witness testimony, the jury convicted Kulbicki of first-degree murder.</p> <p>Kulbicki filed a petition for post-conviction relief in state court in which he argued that he received ineffective assistance of counsel because his attorneys failed to question the legitimacy of the ballistics evidence. Kulbicki’s petition was denied at the trial level, but the Maryland Court of Appeals reversed and vacated Kulbicki’s conviction.</p>

per curiam

reversed

Criminal Procedure

Sturgeon v. Frost

https://api.oyez.org/cases/2015/14-1209

14-1209

2015

John Sturgeon

Bert Frost

<p>John Sturgeon regularly hunted on the Yukon-Charley River National Preserve (Yukon-Charley), which is part of the National Park Service (NPS), in Alaska. Sturgeon used a hovercraft to hunt. During one of his hunting trips, he was approached by three NPS enforcement employees and told that NPS regulations prohibited the operation of hovercrafts within all national parks, and therefore he was prohibited from using his hovercraft within the Yukon-Charley boundaries. Sturgeon insisted that the NPS did not have jurisdiction in the area because it was a state-owned river and subsequently sued Bert Frost, the director of the NPS for Alaska. Sturgeon claimed the NPS violated Alaska National Interest Lands Conservation Act of 1980 (ANILCA) as applied to his use of hovercrafts on state-owned lands and waters because ANILCA limited the applicability of NPS regulations on land that is not federally owned.</p>

majority opinion

vacated/remanded

Economic Activity

Heffernan v. City of Paterson

https://api.oyez.org/cases/2015/14-1280

14-1280

2015

Jeffrey Heffernan

City of Paterson

<p>Jeffrey Heffernan was a police officer for the City of Paterson, New Jersey. A fellow police officer observed Heffernan picking up a campaign sign for the mayoral candidate running against the incumbent. When a supervisor confronted him, Heffernan claimed that he was not politically involved, could not vote in the city of Paterson, and was picking up the sign on behalf of his mother. Heffernan was demoted to a walking post because his actions were considered to be “overt involvement in political activities.” Heffernan sued the city of Paterson and claimed that the city had violated his First Amendment rights to freedom of speech and association. The city filed a motion for summary judgment and argued that, since Heffernan had not actually engaged in constitutionally protected speech, the City’s actions had not violated his First Amendment rights. The district court granted the city’s motion for summary judgment because there was no evidence Heffernan associated himself with the political candidate at issue. Heffernan admitted himself that he was not associated with the candidate, and therefore there is no evidence of a violation of his right to freedom of association. The U.S. Court of Appeals for the Third Circuit affirmed.</p>

majority opinion

reversed/remanded

First Amendment

Williams v. Pennsylvania

https://api.oyez.org/cases/2015/15-5040

15-5040

2015

Terrance Williams

Pennsylvania

<p>Terrance Williams was convicted and sentenced to death for the robbery and murder of Amos Norwood. The Supreme Court affirmed Williams’ conviction and sentence, and he filed three petitions under the Post-Conviction Relief Act, all of which were denied and the denials affirmed by the Pennsylvania Supreme Court. Williams also petitioned for federal habeas relief, which was denied. On his fourth petition for relief under the Post-Conviction Relief Act, the state court determined that Williams had sufficiently demonstrated that there was governmental interference in his trial and granted the relief. The Pennsylvania Supreme Court reversed the lower court’s decision and lifted the stay of execution.</p> <p>The Chief Justice of the Pennsylvania Supreme Court at that point was Ronald Castille, who had been the District Attorney for Philadelphia throughout Williams’ trial, sentencing, and appeal, and who had personally authorized his office to seek the death penalty in this case. Prior to having his case heard by the Pennsylvania Supreme Court, Williams moved to have Chief Justice Castille recuse himself from this case. Chief Justice Castille refused to do so and ultimately joined the opinion that reversed the lower court’s grant of habeas relief and lifted the stay of execution.</p>

majority opinion

vacated/remanded

Due Process

Hughes v. Talen Energy Marketing, LLC

https://api.oyez.org/cases/2015/14-614

14-614

2015

W. Kevin Hughes, Chairman, Maryland Public Service Commission, et al.

Talen Energy Marketing, LLC, fka PPL EnergyPlus, LLC, et al.

<p>The Federal Power Act (FPA) was passed in 1935 to regulate interstate electricity sales. The FPA vested the Federal Energy Regulatory Commission (FERC) with authority over the transmission of electrical energy in interstate commerce and the wholesale of electric energy in interstate commerce. To this end, FERC has created regional transmission organizations, such as PJM Interconnection, LLC, (PJM) which regulates a large regional market that includes Maryland and the District of Columbia. Maryland became concerned that FERC actions were failing to adequately incentivize the construction of new plants, so the Maryland Public Service Commission began soliciting proposals for the construction of a new plant and instituted a Generation Order to regulate how the company that won the bid would interact with the rest of the energy market. Commercial Power Ventures Maryland, LLC, (CPV) won the bid. PPL EnergyPlus, LLC, (PPL) and other existing power plants sued and argued that the Generation Order unconstitutionally interfered with the PJM-regulated market. The district court held that the Generation Order was preempted by the federal regulation of the energy markets pursuant to the Supremacy Clause. The U.S. Court of Appeals for the Fourth Circuit affirmed. This case was consolidated with CPV’s suit against PPL and the other existing power plants.</p>

majority opinion

affirmed

Federalism

Fowler v. North Carolina

https://api.oyez.org/cases/1975/73-7031

73-7031

1975

Jesse Thurman Fowler

North Carolina

<p>A jury found Fowler guilty of murder in the first degree. The trial judge imposed the mandatory sentence of death in the state's gas chamber. Fowler appealed his conviction and sentence. Both were affirmed. Fowler then attacked the mandatory imposition of his sentence. The U.S. Supreme Court granted certioriari.</p>

memorandum

reversed/remanded

Puerto Rico v. Sanchez Valle

https://api.oyez.org/cases/2015/15-108

15-108

2015

Commonwealth of Puerto Rico

Luis M. Sanchez Valle, et al.

<p>In 2008, Luis M. Sanchez Valle was charged in federal for illegally trafficking in weapons and ammunition in interstate commerce and, on substantially the same facts, was charged with several violations of the Puerto Rico Weapons Act. After Sanchez Valle was convicted in federal court, he filed a motion to dismiss the claims under Puerto Rican law and argued that the constitutional protection against double jeopardy meant that he could not be prosecuted in Puerto Rico for the same offenses for which the federal court had already convicted him. The prosecution argued that, pursuant to the precedent the Supreme Court of Puerto Rico established in <em>Puerto Rico v. Castro García</em>, the United States and the Commonwealth of Puerto Rico derive their authority from different sources and therefore can punish substantially the same offenses without implicating the constitutional protections against double jeopardy.</p> <p>The trial court dismissed the charges against Sanchez Valle and held that he could not be indicted twice for the same offenses by the same sovereign entity, and because Puerto Rico and the United States both derive their authority from the United States Constitution, they are the same sovereign entity. The Court of Appeals consolidated this case with several others presenting the same question and held that, under current law, a person could punished for the same offenses in both federal and Puerto Rican court without implicating the protection against double jeopardy. The Supreme Court of Puerto Rico reversed and held that the U.S. Supreme Court precedent regarding double jeopardy was binding on the Supreme Court of Puerto Rico, and therefore the <em>Puerto Rico v. Castro García</em> precedent was incorrect and the Puerto Rican charges against Sanchez Valle should be dismissed.</p>

majority opinion

affirmed

Criminal Procedure

Voisine v. United States

https://api.oyez.org/cases/2015/14-10154

14-10154

2015

Stephen Voisine, et al.

United States

<p>In 2003 and 2005, Stephen Voisine was convicted of assaulting a woman (with whom he was in a domestic relationship) under a Maine state statute that establishes that a person is guilty of assault if that person “knowingly, intentionally, or recklessly causes bodily injury or offensive physical contact to another person.” A violation of that statute is misdemeanor domestic violence assault if the victim is a family or household member. In 2009, Voisine was arrested on the federal misdemeanor charge of killing a bald eagle. During the course of the investigation, police recovered a rifle from Voisine and, because of his earlier misdemeanor assault convictions, arrested and charged Voisine with violating a federal statute that makes it a crime for a person convicted of misdemeanor domestic violence to possess a firearm.</p> <p>William Armstrong III was convicted of assaulting his wife in violation of Maine’s misdemeanor domestic violence assault statutes in 2002 and 2008. In 2010, police searched the Armstrong residence for drugs and drug paraphernalia and discovered ammunition which was later linked to guns Armstrong had transported to a friend’s house. Armstrong was also charged with violating the federal statute that makes it a crime for a person convicted of misdemeanor domestic violence to possess a firearm.</p> <p>Voisine and Armstrong moved to dismiss the charges against them and argued that Maine’s misdemeanor domestic violence assault statutes do not constitute misdemeanor domestic violence under the federal statute because “recklessness” is sufficient for conviction under the Maine statute, but not the federal one. The district court denied the motions, and the U.S. Court of Appeals for the First Circuit affirmed. The defendants petitioned for a writ of certiorari from the U.S. Supreme Court, which remanded the case in light of that Court’s decision in <em>United States v. Castleman</em>, which held that offensive touching satisfied the “physical force” requirement of the federal statute. On remand, the appellate court again held that Maine’s statute constituted misdemeanor domestic violence under the federal statute.</p>

majority opinion

affirmed

Criminal Procedure

Franchise Tax Board of California v. Hyatt

https://api.oyez.org/cases/2015/14-1175

14-1175

2015

Franchise Tax Board of California

Gilbert P. Hyatt

<p>Throughout the 1990s, inventor Gilbert P. Hyatt was involved in litigation with the Franchise Tax Board of California (FTB) based on the FTB’s audits of his 1991 and 1992 tax returns. The FTB claimed that Hyatt had falsified his tax forms by manufacturing a move to Nevada that did not occur until later and therefore failing to file state taxes for time that he was actually living in California. Hyatt protested that the FTB acted in bad faith and eventually sued the FTB in Nevada alleging negligence along with several intentional torts and seeking damages. Before the case went to trial, the FTB argued that it should be immune from the lawsuit based on California law that granted it sovereign immunity. The case eventually went before the U.S. Supreme Court, which held that Nevada courts were not bound to grant the FTB full immunity.</p> <p>At trial, the jury found in favor of Hyatt and awarded him over $300 million in damages. The parties cross-appealed to the Supreme Court of Nevada, which held that the FTB is not immune from the suit because in Nevada governmental entities are not immune from claims for intentional torts. However, because Nevada law does not allow punitive damages against governmental entities, the punitive damage award in this case should be reversed.</p> <p> </p>

opinion of the court

affirmed

Economic Activity

Nichols v. United States

https://api.oyez.org/cases/2015/15-5238

15-5238

2015

Lester Ray Nichols

United States

<p>In 2003, Lester Nichols was charged with intent to engage in sex with a minor. In 2006, the Sexual Offender Registration and Notification Act (SORNA) was passed, and the Attorney General issued a rule in 2007 that SORNA applied retroactively to convicted sex offenders. Under this rule, Nichols was required to register with SORNA and update his residency. In 2012, Nichols flew from Kansas to the Philippines without updating his location pursuant to SORNA. Authorities in the Philippines took Nichols into custody and returned him to the United States where he was charged with noncompliance with SORNA regulations regarding updating his residency. Nichols filed a motion to dismiss and argued that the Philippines are outside U.S. jurisdiction, so he was not required to update his location. The trial court dismissed his motion, and Nichols plead guilty. He then appealed to the U.S. Court of Appeals for the Tenth Circuit, which affirmed his conviction.</p>

majority opinion

reversed

Criminal Procedure

Mullenix v. Luna

https://api.oyez.org/cases/2015/14-1143

14-1143

2015

Chadrin Lee Mullenix

Beatrice Luna, individually and as representative of the estate of Israel Leija, Jr., et al.

<p>On March 23, 2010, a police officer approached Israel Leija, Jr. at a drive-in restaurant with a warrant for his arrest. Leija proceeded to lead the police on a high-speed chase on the interstate while periodically calling the police dispatcher, saying that he had a gun and threatening to shoot the officers chasing him. The officers continued their pursuit, and other officers deployed spike strips. Trooper Chadrin Lee Mullenix, upon learning that other spike strips were set up, decided to pursue the alternate tactic of shooting at Leija’s car in order to stop it. Although he had not received training on this maneuver, he informed one of the officers in pursuit of his plan and radioed his supervisor for permission. Before receiving a response, Mullenix got in position on an overpass. Witnesses testified that Mullenix could hear his supervisor respond to say that he should “stand by” and “see if the spikes work first.” When Leija’s car approached, Mullenix fired six shots. The car struck the spike strips, hit the median, and rolled several times. It was later determined that Leija died as a result of Mullenix’ shots, four of which struck his body and none of which struck the car’s radiator, hood, or engine block.</p> <p>The respondents sued Mullenix under 42 U.S.C. §1983 and argued that Mullenix had violated Leija’s Fourth Amendment rights by using excessive force against him. Mullenix moved for summary judgment and argued that he was entitled to qualified immunity. The district court denied the motion and held that there were genuine questions of fact regarding whether Mullenix acted as a reasonable officer would have under similar circumstances. The U.S. Court of Appeals for the Fifth Circuit affirmed and subsequently denied Mullenix’s petition for a rehearing.</p>

per curiam

reversed

Criminal Procedure

Halo Electronics v. Pulse Electronics Inc.

https://api.oyez.org/cases/2015/14-1513

14-1513

2015

Halo Electronics

Pulse Electronics Inc., et al.

<p>Halo Electronics, Inc. (Halo) and Pulse Electronics, Inc. (Pulse) are both suppliers of electronic components. Halo owns three patents regarding surface mount electronic packages; Pulse designs and sells surface mount electronic packages and does its manufacturing in Asia. In 2002, Halo unsuccessfully attempted to license their patents to Pulse. In 2007, Halo sued Pulse for patent infringement. The district court held that Pulse infringed on Halo’s patents with products shipped into the United States, had induced others to infringe on products delivered outside of the U.S. but ultimately imported into the U.S. as finished products, and found that it was highly probable that Pulse’s infringement was willful. The court later found that Pulse’s infringement was not willful. The U.S. Court of Appeals for the Federal Circuit affirmed and held that there was no “willful infringement.” In determining that there was no willful infringement, the appellate court applied a rigid two-part test established in <em>In re Seagate</em> that required that willfulness be proven on both an objective and subjective basis. In this case, the appellate court held that the objective prong was not met. This two-part test is similar to one the Supreme Court struck down last term in <em>Octane Fitness, LLc v. ICON Health &amp; Fitness</em>, which dealt with a test for awarding attorneys fees.</p> <p>In the consolidated case, Stryker Corporation (Stryker) sued Zimmer, Inc. (Zimmer) over patent infringement of medical equipment. Stryker and Zimmer are both competitors in the market for pulsed lavage devices, which deliver pressurized irrigation for certain medical procedures in orthopedic medicine. Stryker holds three patents for pulsed lavage devices that it claimed Zimmer had infringed. The district court found Zimmer liable for patent infringement. The jury awarded Stryker treble damages as allowed under 35 U.S.C. § 284 on the grounds that Zimmer intentionally violated Stryker’s patents. Zimmer appealed to the U.S. Court of Appeals for the Federal Circuit, which requires that the patent-holder prove the infringement was willful to be eligible for treble damages. Therefore, the appellate court overturned the award for treble damages on the grounds that Zimmer did not intentionally violate Stryker’s patents.</p>

majority opinion

vacated/remanded

Economic Activity

Zubik v. Burwell

https://api.oyez.org/cases/2015/14-1418

14-1418

2015

David A. Zubik, et al.

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

<p>In 2010, Congress passed the Affordable Care Act (ACA), which requires group health plans and health insurance issuers offering health plans to provide preventative care and screenings for women pursuant to the guidelines established by the Department of Health and Human Services (HHS). These guidelines include “approved contraceptive methods, sterilization procedures, and patient education and counseling for all women with reproductive capacity.” The regulations include an exemption from contraceptive coverage for the group health plan of a religious employer. The exemption does not mean that such services are not covered, but that they are not covered through a cost-sharing mechanism.</p> <p>The petitioners are religious organizations that argue that the contraceptive coverage mandate of the ACA violates the Religious Freedom Restoration Act (RFRA), which Congress enacted in 1993, because the mandate requires these organizations to “facilitate” the provision of insurance coverage for contraceptive services that they oppose on religious grounds. In several separate cases, the relevant district courts issued injunctions against the government, and the relevant Courts of Appeals reversed. The appellate courts held that the religious organizations were unable to show that the contraceptive mandate substantially burdened the exercise of their religious freedom.</p>

majority opinion

vacated/remanded

First Amendment

Husky Electronics v. Ritz

https://api.oyez.org/cases/2015/15-145

15-145

2015

Husky International Electronics, Inc.

Daniel Lee Ritz, Jr.

<p>Husky International Electronics, Inc. (Husky) sold and delivered electronic equipment to Chrysalis Manufacturing Corp. (Chrysalis), headed by Daniel Ritz. Chrysalis owed Husky $163,999.38 in purchases between 2003 and 2007. In 2007, Ritz started transferring funds from Chrysalis to various other ventures in which he owned stock. In 2009 Husky sued Ritz for payment of his outstanding debt, and Ritz then filed for Chapter 7 bankruptcy. In 2011, Husky filed a complaint against the discharge of Ritz’s debt and argued that Ritz had fraudulently moved funds from Chrysalis to other accounts in order to file for bankruptcy. The bankruptcy court found that Ritz had not fraudulently filed for bankruptcy and that it could not “pierce the veil” to go after Ritz’s personal finances for the debt Chrysalis owed.</p> <p>Husky appealed to the district court, which affirmed the bankruptcy court’s determination and found that Ritz had not committed “actual fraud” by false representation and that Husky had not proven that Ritz acted “maliciously and willfully.” The United States Appeals Court for the Fifth Circuit affirmed the lower court’s decision to discharge Ritz’s debt.</p>

majority opinion

reversed/remanded

Economic Activity

Whole Woman’s Health v. Hellerstedt

https://api.oyez.org/cases/2015/15-274

15-274

2015

Whole Woman’s Health, et al.

John Hellerstedt, Commissioner, Texas Department of State Health Services, et al.

<p>In 2013, the Texas Legislature passed House Bill 2 (H.B. 2), which contained several provisions related to abortions. One such provision required that any physician performing an abortion have admitting privileges at a hospital within 30 miles of where the abortion was performed, and another provision required that all abortion clinics comply with standards for ambulatory surgical centers. The petitioners are a group of abortion providers who sued the State of Texas seeking to invalidate those provisions in H.B. 2 as they relate to facilities in McAllen and El Paso. The petitioners argued that H.B. 2 denied equal protection, unlawfully delegated lawmaking authority, and constituted arbitrary and unreasonable state action. The district court dismissed the equal protection, unlawful delegation, and arbitrary and unreasonable state action claims and granted declaratory and injunctive relief against the enforcement of the two contested provisions of H.B. 2. The U.S. Court of Appeals for the Fifth Circuit affirmed the district court’s dismissal of the equal protection, unlawful delegation, and arbitrary and unreasonable state action claims and partially reversed the injunctions because the plaintiffs failed to show that they placed a substantial burden in the path of a woman seeking an abortion.</p>

majority opinion

reversed/remanded

Privacy

Simmons v. Himmelreich

https://api.oyez.org/cases/2015/15-109

15-109

2015

Jermaine Simmons et al.

Walter J. Himmelreich

<p>Walter Himmelreich is a federal prisoner at the Federal Correctional Institution in Danbury, Connecticut. In 2008, he was attacked by another prisoner. Himmelreich filed a complaint against multiple defendants alleging many causes of action, including a claim that his First Amendment rights were violated when he was placed in administrative detention after filing a claim under the Federal Torts Claims Act (FTCA) and a claim that his Eighth Amendment rights were violated when the prison officials failed to protect him from being assaulted by another inmate. The district court dismissed his case for failure to state a claim. On appeal, the U.S. Court of Appeals for the Sixth Circuit vacated the decision and remanded the case for reconsideration of the First and Eighth Amendment claims.</p> <p>On remand, the district court granted summary judgment for the defendants by holding that Himmelreich had failed to exhaust his administrative remedies on the claims and that the prison officials were subject to the discretionary exception to the FTCA, which triggered the judgment bar of the FTCA, 28 U.S.C. §2676, that prohibits “any action by the same claimant, by reason of the same subject matter, against the employee of the government whose act of omission gave rise to the claim.” The appellate court again vacated and remanded the lower court’s judgment. It held that Himmelreich’s failure to exhaust his administrative remedies should be excused because he had been intimidated and threatened by prison officials to not pursue a grievance process against them. The appellate court also found that the dismissal of Himmelreich’s claim based on discretionary exception to the FTCA as applied by the district court does not necessarily trigger a judgment bar of 28 U.S.C §2676.</p>

majority opinion

affirmed

Economic Activity

Betterman v. Montana

https://api.oyez.org/cases/2015/14-1457

14-1457

2015

Brandon Thomas Betterman

State of Montana

<p>Brandon Thomas Betterman failed to appear in court on December 8, 2011, on charges of partner or family member assault, and a warrant was issued for his arrest. On February 9, 2012, Betterman turned himself in and stated that he knew he was supposed to appear in court but claimed he had neither money nor transportation to get to the courthouse that day. He was convicted on March 15, 2012, and sentenced to five years. On April 19, 2012, he pled guilty to the charges of jumping bail. His sentence hearing did not occur until January 17, 2013, when he filed a motion to dismiss on the grounds that he was denied a speedy and fair trial due to the amount of time that had lapsed between his guilty plea and sentencing hearing. On April 29, 2013, his motion was denied, and on June 27, 2013, Betterman was sentenced to seven years for his bail-jumping charge. The Supreme Court of Montana held that the delay between Betterman’s plea and sentencing was unacceptably long but had not violated his rights to fair and speedy trial.</p>

majority opinion

affirmed

Criminal Procedure

Puerto Rico v. Franklin California Tax-Free Trust

https://api.oyez.org/cases/2015/15-233

15-233

2015

Commonwealth of Puerto Rico, et al.

Franklin California Tax-Free Trust, et al.

<p>Unlike states, the Commonwealth of Puerto Rico may not authorize its municipalities, including utilities, to declare bankruptcy and seek relief under Chapter 9 of the U.S. Bankruptcy Code. In June 2014, Puerto Rico enacted the Puerto Rico Public Corporation Debt Enforcement and Recovery Act (Recovery Act), which expressly provided different protections for creditors than Chapter 9 of the U.S. Bankruptcy Code.</p> <p>The plaintiffs in this case are a group of investors who collectively hold nearly two billion dollars in bonds issued by one of Puerto Rico’s public utilities, the Puerto Rico Electric Power Authority (PREPA), which could potentially file for bankruptcy under the Recovery Act. The plaintiffs sued Puerto Rico in district court and argued that Chapter 9 of the U.S. Bankruptcy Code, which prohibits state municipal debt restructuring laws from binding creditors without their consent, preempts the Recovery Act. The district court found in favor of the plaintiffs and enjoined the enforcement of the Recovery Act. The U.S. Court of Appeals for the First Circuit affirmed.</p>

majority opinion

affirmed

Economic Activity

Ross v. Blake

https://api.oyez.org/cases/2015/15-339

15-339

2015

Michael Ross

Shaidon Blake

<p>On June 21, 2007, Lieutenants Michael Ross and James Madigan were escorting Shaidon Blake from his cell when Madigan shoved Blake several times. The incident escalated to Madigan punching Blake in the face several times with a key ring wrapped around his fingers while Ross held him. Blake was then taken to the medical unit and later diagnosed with nerve damage. Blake reported the incident to senior corrections officers, and the Internal Investigative Unit of the Maryland Department of Public Safety and Correctional Services conducted an investigation and issued a formal report. The formal report determined that Madigan had used excessive force against Blake and that Blake was not at fault in any way. Blake subsequently sued Ross and Madigan in addition to two supervisors and three government entities under 42 U.S.C. § 1983 and argued that they violated his constitutional rights by using excessive force.</p> <p>Nearly two years after Blake initially filed the suit, Ross filed an amended answer to the complaint that alleged that Blake had failed to exhaust his administrative remedies as the Prison Litigation Reform Act (PLRA) required. Ross also moved for summary judgment based on the same argument, and the district court granted the motion. The U.S. Court of Appeals for the Fourth Circuit reversed and held that the “special circumstances” exception to the PLRA’s exhaustion requirement was met in this case. Because the internal investigation provided the correction officials time and opportunity to address the complaints internally and Blake reasonably believed that he had exhausted his administrative remedies by participating in an internal investigation, the requirements for the “special circumstances” exception to the PLRA were met.</p>

majority opinion

vacated/remanded

Civil Rights

Universal Health Services, Inc. v. Escobar

https://api.oyez.org/cases/2015/15-7

15-7

2015

Universal Health Services, Inc.

United States and Massachusetts, ex rel. Julio Escobar and Carmen Correa

<p>Universal Health Services, Inc. (UHS) owns and operates Arbour Counseling Services (Arbour), a mental health services provider in Lawrence, Massachusetts. Arbour participates in the state Medicaid program, MassHealth, and the state has promulgated regulations for such “satellite” facilities.</p> <p>Julio Escobar and Carmen Correa are the parents of Yarushka Rivera, a teenager with behavioral issues who began seeing a counselor at Arbour. These counselors were not licensed, and Escobar and Correa became concerned that they were not being properly supervised as the regulations of satellite facilities required. Rivera was eventually diagnosed with bipolar disorder and prescribed a medicine by a “doctor” who was later discovered to be a nurse under the supervision of a non-board-certified psychiatrist. Rivera soon had an adverse reaction to the medicine and called Arbour for guidance but was unable to speak with anyone. A few days later, she had a seizure and was hospitalized. A few months later, she suffered a fatal seizure.</p> <p>Escobar and Correa filed complaints with several state agencies and eventually sued UHS under both the federal and state False Claims Acts. The district court dismissed the complaint and held that the plaintiffs did not sufficiently plead the elements of falsity that claims under the False Claims Act require. The U.S. Court of Appeals reversed and held that the plaintiffs had sufficiently pled the elements of falsity by applying an “implied certification” test, which states that falsity has been sufficiently pled when there is evidence that the defendant did not comply with a condition of payment.</p>

majority opinion

vacated/remanded

Economic Activity

Sheriff v. Gillie

https://api.oyez.org/cases/2015/15-338

15-338

2015

Mark J. Sheriff, et al.

Pamela Gillie, et al.

<p>In 1977, Congress enacted the Federal Debt Collection Practices Act (FDCPA) in an effort to combat abusive debt collection practices, which were particularly problematic with third party or independent debt collectors, who are unlikely to have contact with the consumer and therefore have little incentive to act fairly. One of the issues that the FDCPA addressed was independent debt collectors representing themselves as government officials. Therefore, the FDCPA targeted these “debt collectors” while exempting government officials from that definition. The statutory language of the exemption was specific to “any officer or employee of ... any State to the extent that collecting or attempting to collect any debt is in the performance of his official duties.”</p> <p>The Ohio Revised Code contains a provision that unpaid debts owed to a state entity get “certified” to the Ohio Attorney General, who is then responsible for collecting the debt or disposing of it by other means. The Attorney General may enlist “special counsel” to collect debts on the Attorney General’s behalf. To do so, the special counsel and the Attorney General enter into a retention agreement that, among other terms, allows the special counsel to use the Attorney General’s letterhead in connection with claims arising out of the tax debts the special counsel is authorized to collect.</p> <p>The plaintiffs in this case are individuals who received debt collection letters that used the seal of the Ohio Attorney General from the defendants, who became special counsel to the Attorney General in 2013. The plaintiffs sued and argued that the defendants violated the FDCPA by using the Ohio Attorney General letterhead. The district court granted the defendants’ motion for summary judgment and held that special counsel are not “debt collectors” under the meaning of the FDCPA because they are officers of the state for the purposes of debt collection, and therefore the use of the Ohio Attorney General letterhead was not false or misleading. The U.S. Court of Appeals for the Sixth Circuit vacated the lower court’s decision and held that special counsel are “debt collectors” under the meaning of the FDCPA and do not fall under the exemption, and that there was a genuine issue of material fact regarding whether the use of Ohio Attorney General’s seal on debt collection letters was misleading.</p>

majority opinion

reversed/remanded

Civil Rights

CRST Van Expedited v. EEOC

https://api.oyez.org/cases/2015/14-1375

14-1375

2015

CRST Van Expedited Inc.

Equal Employment Opportunity Commission

<p>The Equal Employment Opportunity Commission (EEOC) filed a sexual harassment suit on behalf of approximately 270 female employees against CRST Van Expedited (CRST). Two years after filing the suit, the EEOC failed to identify the 270 women, and the district court ordered the EEOC to amend its list of 270 women to include only the women who wished to continue with the suit and to ensure that those women be available for deposition. The EEOC complied with the first court order and failed to fulfill the second before the deadline. CRST had filed seven motions to dismiss, and the district granted (or granted in part) six of the motions. CRST subsequently filed a bill of costs against the EEOC for $4,560,285.11, and the district court granted the fee award. The EEOC appealed, and the U.S. Court of Appeals for the Eighth Circuit reversed the fee award. The appellate court held that the EEOC’s pre-suit obligations were not elements of the claim and did not constitute a ruling on the merits that was eligible for fees.</p>

majority opinion

vacated/remanded

Civil Rights

White v. Wheeler

https://api.oyez.org/cases/2015/14-1372

14-1372

2015

Randy White, Warden

Roger L. Wheeler

<p>In October 1997, Nigel Malone and Nairobi Warfield were found dead in their apartment. Blood at the crime scene matched Roger L. Wheeler’s, and he was arrested for the murders. During <em>voir dire</em>, one of the potential jurors gave equivocal responses in response to questions regarding his beliefs about the death penalty. The prosecution moved to strike the juror for cause and cited these replies. The defense opposed the motion and argued that the responses indicated nothing more than an ability to consider all penalty options. The judge struck the juror, and Wheeler was subsequently convicted of the murders and sentenced to death. The Kentucky Supreme Court affirmed the convictions and the sentence and held that the trial judge appropriately struck all the jurors who could not impose the death penalty.</p> <p>Wheeler exhausted his state post-conviction proceedings and petitioned for a writ of habeas from the federal district court. The federal district court denied the petition, but the U.S. Court of Appeals for the Sixth Circuit reversed, granted the petition, and held that the exclusion of the juror in question was an unreasonable application of the Supreme Court’s precedent in <em>Witherspoon v. Illinois</em>. In that case, the Supreme Court held that only a juror who is “substantially impaired in his or her ability to impose the death penalty” can be excused for cause. The appellate court held that the trial court erred in interpreting the juror’s responses that he did not know if he could consider the death penalty as meaning that he could not consider the death penalty.</p>

per curiam

reversed/remanded

Criminal Procedure

Birchfield v. North Dakota

https://api.oyez.org/cases/2015/14-1468

14-1468

2015

Danny Birchfield

State of North Dakota

<p>Danny Birchfield drove into a ditch in Morton County, North Dakota. When police arrived on the scene, they believed Birchfield was intoxicated. Birchfield failed both the field sobriety tests and the breath test. He was arrested, but he refused to consent to a chemical test. Birchfield was charged with a misdemeanor for refusing to consent to a chemical test in violation of state law. He moved to dismiss the charge and claimed that the state law violated his Fourth Amendment right against unreasonable search and seizure. In a similar case, police were called to the South St. Paul boat launch where three men were attempting to pull their boat out of the water and onto their truck. William Robert Bernard, Jr., admitted he had been drinking and had the truck keys in his hands, but he denied driving the truck and refused to perform a field sobriety test. He was arrested on suspicion of driving while impaired (DWI) and taken to the police station, where he refused to consent to a chemical test in violation of Minnesota state law. Bernard was charged with two counts of first-degree test refusal pursuant to state law. In a separate incident, Steve Beylund consented to a blood alcohol to test to confirm he was driving under the influence after being informed it was a criminal offense in North Dakota to refuse a blood alcohol test. The test confirmed he was over the legal limit, and Beylund was charged with driving under the influence.</p> <p>All three men challenged the state statutes criminalizing refusal to submit to a chemical test and argued that the statutes violated their Fourth Amendment rights to be free from unreasonable searches and seizures when there was no probable cause that would support a warrant for the test. Both the Supreme Court of Minnesota and the Supreme Court of North Dakota determined that criminalizing the refusal to submit to a chemical test was reasonable under the Fourth Amendment.</p>

majority opinion

reversed in-part/remanded

Criminal Procedure

United States v. Bryant

https://api.oyez.org/cases/2015/15-420

15-420

2015

United States

Michael Bryant, Jr.

<p>In June 2011, Michael Bryant, Jr. was convicted of two counts of domestic assault by a habitual offender in violation of 18 U.S.C. 117(a), a federal law that criminalizes domestic assault by any person who has been convicted of at least two domestic violence offenses in federal, state, or Indian tribal court. For the predicate offenses, the prosecution relied on Bryant’s previous domestic abuse convictions in Northern Cheyenne Tribal Court. Bryant moved to dismiss the indictment and argued that the use of the tribal court convictions as predicate convictions for the charge violated his Fifth and Sixth Amendment rights because he was not afforded counsel in the tribal court proceedings, so his convictions would have violated the Sixth Amendment if they had occurred in state or federal court. The district court denied the motion, and Bryant pled guilty pursuant to a plea agreement that preserved his right to appeal the district court’s denial of the motion to dismiss. On appeal, the U.S. Court of Appeals for the Ninth Circuit reversed and held that an uncounseled conviction that violated the Sixth Amendment could not be used as a predicate offense for the purpose of a charge under Section 117(a).</p>

majority opinion

reversed/remanded

Criminal Procedure

United States Army Corps of Engineers v. Hawkes Co., Inc.

https://api.oyez.org/cases/2015/15-290

15-290

2015

United States Army Corps of Engineers

Hawkes Co., Inc., et al.

<p>Hawkes Co., Inc. (Hawkes) was interested in purchasing a piece of land in northern Minnesota to mine high-quality peat. Hawkes applied to the Army Corps of Engineers (Corps) and the Minnesota Department of Natural Resources for a permit to begin extracting peat from the land once they purchased the property in October 2010. The Corps informed Hawkes that the permit process would be very costly and would take a long time and so urged Hawkes not to purchase the property. The Corps then submitted an Approved Jurisdictional Determination to derail Hawkes’ plan to purchase and mine the property by arguing that the land was a wetland connecting to “waters of the United States,” which are protected under the Clean Water Act. Hawkes challenged the jurisdictional determination and filed an action for immediate judicial review. The trial court dismissed the action and held that the jurisdictional determination was not a “final agency action” under the Administrative Procedure Act, and therefore it was not subject to judicial review. The U.S. Court of Appeals for the Eighth Circuit held that the jurisdictional determination was a final agency action and remanded the action for judicial review.</p>

majority opinion

affirmed

Economic Activity

Berger v. New York

https://api.oyez.org/cases/1900-1940/255us22

460

1900-1940

Victor L. Berger, et al.

United States

<p>Victor L. Berger, Adolph Germer, William F. Kruse, J. Louis Engdahl, and Irwin St. John Tucker were all indicted and charged with violating the Espionage Act of 1917. Their case was assigned to Judge Kenesaw Mountain Landis, and the defendants moved to have another judge preside over the trial under Section 21 of the Judicial Code, which states that, whenever a party to an action files an affidavit that the judge before whom the action is proceeding has a personal bias or prejudice, another judge will be designated to hear the case. In this case, the defendants provided an affidavit alleging that Judge Landis was biased against people of German descent, and several of the defendants were German. The motion was denied, Judge Landis heard the case, and the defendants were convicted. The defendants appealed to the U.S. Court of Appeals for the Seventh Circuit, which certified questions of law about Section 21 to the Supreme Court.</p>

majority opinion

none

Manuel v. City of Joliet

https://api.oyez.org/cases/2016/14-9496

14-9496

2016

Elijah Manuel

City of Joliet, Illinois, et al.

<p>Elijah Manuel was a passenger in a car that was pulled over for failing to signal on March 18, 2011. When the police officer detected an odor of marijuana in the car, he dragged Manuel out of the car, pushed and kicked him, and handcuffed him. The officer found a bottle of pills in Manuel’s pocket during his pat-down. The pills were tested and the officers falsified the results to show the pills were ecstasy. The initial positive pill results were later tested at the scene of the arrest. More detailed negative lab results were presented by Manuel later. Manuel was arrested based on these initial results. The officers continued to rely on the false positive initial test throughout the grand jury proceedings, and he was held until May 4, when the Assistant State’s Attorney sought dismissal of the charges.</p> <p>Manuel sued the City of Joliet and various city officials and alleged malicious prosecution as well as other civil rights claims. The district court dismissed most of Manuel’s claims as falling outside of the statute of limitations. His malicious prosecution claim was not time-barred, however, but was dismissed under <em>Newsome v. McCabe</em>, which held that federal claims of malicious prosecution stem from the right to due process and are not a Fourth Amendment issue. Therefore, there was no malicious prosecution claim under federal law if the state provided a similar cause of action, as Illinois did. On appeal, Manuel argued that Newsome did not foreclose a malicious prosecution claim on Fourth Amendment grounds when officers misrepresented evidence. The U.S. Court of Appeals for the Seventh Circuit affirmed the lower court’s ruling against Manuel as consistent with the <em>Newsome</em> precedent.</p>

majority opinion

reversed/remanded

Criminal Procedure

Murr v. Wisconsin

https://api.oyez.org/cases/2016/15-214

15-214

2016

Joseph P. Murr, et al.

Wisconsin, et al.

<p>The parents of Joseph P. Murr and his siblings (the Murrs) purchased two adjacent lots (Lots E and F) in St. Croix County in 1960. The two lots together made up approximately .98 acres. In 1994 and 1995 respectively, the Murrs’ parents transferred Lot F and Lot E to their children. In 1995, the two lots were merged pursuant to St. Croix County’s code of ordinances. The relevant ordinance prohibits the individual development or sale of adjacent lots under common ownership, unless an individual lot was at least one acre. The ordinance further specified that if each lot is not at least one acre, the lots may be measured together to equal one acre. Seven years later, the Murrs wanted to sell Lot E and not Lot F. The St. Croix County Board of Adjustment denied the Murrs’ application to sell the lots separately.</p> <p>The Murrs sued the state and county and claimed the ordinance in question resulted in an uncompensated taking of their property and deprived them of “all, or practically all, of the use of Lot E because the lot cannot be sold or developed as a separate lot.” The circuit court granted summary judgement to the state and county. The Court of Appeals of Wisconsin affirmed and held that the Murrs were not deprived of their practical use of the property.</p>

plurality opinion

affirmed

Due Process

United States v. Texas

https://api.oyez.org/cases/2015/15-674

15-674

2015

United States, et al.

Texas, et al.

<p>In June 2012, the Department of Homeland Security (DHS) implemented the Deferred Action for Childhood Arrivals (DACA) program, along with criteria for determining when prosecutors can choose not to enforce immigration laws under DACA. People who qualify for DACA may apply for work authorization. In 2014, DHS established a similar process for parents of citizens and lawful permanent residents as well as expanding DACA by making more people eligible. The new program was known as the Deferred Action for Parents of Americans and Lawful Permanent Residents (DAPA) program.</p> <p>Texas and other states sued to prevent the implementation of DAPA and argued that it violated the Administrative Procedure Act because it had not gone through the notice-and-comment process, and because it was arbitrary and capricious. The states also argued that DAPA violated the Take Care Clause of the Constitution, which clarifies the President's power. The district court held that the states had standing to file the suit and temporarily enjoined the implementation of DAPA because the states had established a substantial likelihood of success on the notice-and-comment claim. The U.S. Court of Appeals for the Fifth Circuit affirmed and held that the states had standing as well as a substantial likelihood of success on their substantive and procedural claims.</p>

equally divided

affirmed

Civil Rights

Dietz v. Bouldin

https://api.oyez.org/cases/2015/15-458

15-458

2015

Rocky Dietz

Hillary Bouldin

<p>Hillary Bouldin’s vehicle collided with Rocky Dietz’s in Montana in 2009. Dietz filed a negligence claim for injuries sustained from the accident. The action was removed to federal court. The parties made stipulations as to past damages, and the jury ruled in Dietz’s favor but awarded $0 in damages. The district court judge dismissed the jury but then reconsidered and re-empaneled the jury. He asked them to re-determine the damages in a manner consistent with the parties’ stipulation. The jury returned the same verdict and awarded $15,000 in damages. On appeal, Dietz claimed that the district court erred by recalling the jury after it had been dismissed. The U.S. Court of Appeals for the Ninth Circuit affirmed the lower court’s decision and held that dismissing the jury, then recalling the jurors, was not an abuse of discretion because the jurors were not exposed to prejudicial influence during the brief duration of their dismissal.</p>

majority opinion

affirmed

Judicial Power

Kirtsaeng v. John Wiley & Sons

https://api.oyez.org/cases/2015/15-375

15-375

2015

Supap Kirtsaeng

John Wiley & Sons, Inc.

<p>Academic textbook publisher John Wiley &amp; Sons, Inc. (Wiley) owns the American copyright for textbooks and often assigns its rights to its foreign subsidiaries to publish, print, and sell its textbooks abroad. Supap Kirtsaeng is a Thai citizen who came to the United States in 1997 to study mathematics. While he was in the United States, Kirtsaeng asked friends and family in Thailand to buy the English-language versions of his textbooks there, where they were cheaper, and mail them to him. Kirtsaeng would then sell the textbooks in America, where they were worth more, reimburse his friends and family, and make a profit.</p> <p>In 2008, Wiley sued Kirtsaeng for copyright infringement. The case went to the U.S. Supreme Court on the question of whether Kirtsaeng was barred from asserting an affirmative defense because the copyrighted works in question were manufactured abroad. The Court held that the affirmative defense was available to Kirtsaeng and remanded the case. Kirtsaeng won the case on remand and sought an award of attorneys' fees and reimbursement of litigation expenses pursuant to Section 505 of the Copyright Act. The district court held that Section 505 provides that the court may “in its discretion” award attorney’s fees but is not bound to do so. Because Wiley’s suit was not “frivolous” or “objectively unreasonable,” the district court held that awarding Kirtsaeng attorney’s fees would “not promote the purposes of the Copyright Act.” The U.S. Court of Appeals for the Second Circuit affirmed.</p>

majority opinion

vacated/remanded

Attorneys

Microsoft v. Baker

https://api.oyez.org/cases/2016/15-457

15-457

2016

Microsoft Corporation

Seth Baker, et al.

<p>The plaintiffs brought a class action suit against Microsoft Corporation (Microsoft) and alleged that, during regular game play on the Xbox 360, the discs would come loose due to vibrations and scratch against internal components of the gaming system, which rendered them permanently broken. Because only 0.4% of consoles caused this issue with regular players, the district court determined that a class action suit could not be certified and individuals in the suit would have to come forward on their own. The parties then stipulated a dismissal with prejudice. The district court granted the dismissal, and the plaintiffs appealed to the U.S. Court of Appeals for the Ninth Circuit. The appellate court reversed and held that the district court had misapplied applicable law and, therefore, abused its discretion in striking the class action allegations.</p>

majority opinion

reversed/remanded

Judicial Power

Cuozzo Speed Technologies v. Lee

https://api.oyez.org/cases/2015/15-446

15-446

2015

Cuozzo Speed Technologies, LLC

Michelle K. Lee, Under Secretary of Commerce for Intellectual Property and Director, Patent and Trademark Office

<p>Cuozzo Speed Technologies, LLC. (Cuozzo) owns the 074 patent, “Speed Limit Indicator and Method for Displaying Speed and the Relevant Speed Limit,” and Garmin International, Inc. (Garmin) petitioned the Patent Trial and Appeal Board (Board) for <em>inter partes</em> review of claims regarding the patent. The Board was established to process patent litigation faster by using <em>inter partes</em> review, and during that process, the Board uses the broadest reasonable interpretation when reviewing patent claims instead of the plain and ordinary meaning of patent claims. The Board found that claims 10, 14, and 17 were unpatentable. Cuozzo filed a motion to amend by replacing claims 10, 14, and 17 with claims 21, 22, and 23. The Board denied this request by applying the broadest reasonable interpretation standard to the term “integrally attached” regarding claim 14 on the components of the “Speed Limit Indicator.” Cuozzo appealed to the U.S. Court of Appeals for the Federal Circuit, which held that it lacked authority to review the Board’s finding under the broadest reasonable interpretation.</p>

majority opinion

affirmed

Economic Activity

Encino Motorcars v. Navarro

https://api.oyez.org/cases/2015/15-415

15-415

2015

Encino Motorcars, LLC

Hector Navarro, et al.

<p>Encino Motorcars, LLC (Encino) sold and serviced Mercedes-Benz automobiles. Hector Navarro was employed there as a service advisor, which involved him greeting customers and assessing their needs as they entered the business. Navarro, along with other similarly-situated plaintiffs, sued Encino for failing to pay overtime compensation when they worked more than forty hours a week. Under the Fair Labor Standards Act, “service advisors” engaged in servicing automobiles are not entitled to overtime compensation, so the district court dismissed their overtime claim. The U.S. Court of Appeals for the Ninth Circuit reversed the lower court’s decision and held that Navarro and other employees were not exempted from overtime compensation. In reaching its decision, the appellate court relied on the Department of Labor’s 2011 determination that service advisors were not exempt under the FLSA, which was a reversal of the position that the Department had taken in 1987.</p>

majority opinion

vacated/remanded

Unions

Salman v. United States

https://api.oyez.org/cases/2016/15-628

15-628

2016

Bassam Yacoub Salman

United States

<p>Maher Kara joined Citigroup’s healthcare investment banking group in 2002, and began asking his older brother, Michael, who held a degree in chemistry, questions about certain aspects of his job. From 2004 to 2007 the Kara brothers regularly discussed mergers and acquisitions by Citigroup clients, though Maher suspected that Michael was using the information they discussed for insider trading. In the meantime, Maher became engaged to Bassam Yacoub Salman’s sister and Michael began to share some of the insider information he received from his brother with Salman. Salman did not directly trade through his own accounts but went through his brother-in-law, Karim Bayyouk. There were numerous occasions where Bayyouk and Michael Kara executed identical trades issued by Citigroup clients. As a result, Salman’s account reached $2.1 million. Salman was charged with conspiracy to commit securities fraud and insider trading in 2011 and found guilty. He applied for a new trial, but his request was denied. He then appealed to the U.S. Court of Appeals for the Ninth Circuit and argued there was insufficient evidence that he knew the information used for trades was from insider information. The appellate court found that, because of the close family relationship, there was sufficient evidence that Salman knew he was trading on insider information.</p>

majority opinion

affirmed

Criminal Procedure

McDonnell v. United States

https://api.oyez.org/cases/2015/15-474

15-474

2015

Robert F. McDonnell

United States

<p>On November 3, 2009, Robert F. McDonnell was elected Governor of Virginia. At the time of his election, he and his family were experiencing economic difficulties; by September 2010, he and his wife had a combined credit card balance of $90,000, and by 2012 the business he and his sister operated had a loan balance of $2.5 million. Shortly after his election, McDonnell met with Jonnie Williams, the founder and CEO of Star Scientific, Inc. (Star), which was trying to market a product called Anatabloc that could be used to treat chronic inflammation. Star wanted the Food and Drug Administration to classify Anatabloc as a pharmaceutical, which would be more profitable than the alternative classification of nutraceutical. However, such a classification would require expensive testing, clinical trials and studies, and Star lacked the funds. Between 2009 and 2012, Williams and McDonnell met several times and agreed that “independent testing [of Anatabloc] in Virginia was a good idea.” Williams also provided expensive gifts to the McDonnells and “was willing to help” with their financial troubles. A launch event for Anatabloc was held at the Governor’s Mansion, and Mrs. McDonnell facilitated meetings between Star officials and officials at the University of Virginia and Virginia Commonwealth University to get the studies started. Mrs. McDonnell also purchased, sold, and gifted Star stock in such as way as to avoid reporting requirements, and McDonnell spoke to various government officials about the benefits of Anatabloc.</p> <p>The McDonnells were eventually arrested and charged for corruption, under federal statutes that make it a felony to take “official action” in exchange for money, campaign contributions, or any other thing of value. On September 4, 2014, McDonnell was found guilty on 11 counts of corruption. McDonnell appealed his conviction and argued that the jury instructions given at trial did not properly define the term “official action.” The U.S. Court of Appeals for the Fourth Circuit affirmed his conviction and held that the jury instructions in question were adequate.</p>

majority opinion

vacated/remanded

Criminal Procedure

Mathis v. United States

https://api.oyez.org/cases/2015/15-6092

15-6092

2015

Richard Mathis

United States

<p>On March 8, 2013, police officers executed a warrant to search Richard Mathis’ house following allegations of sexual abuse from young men. The officers found a loaded rifle and ammunition. After he was arrested and while in custody, Mathis admitted to owning the rifle and ammunition, and he was charged with being a felon in possession of a firearm in violation of the Armed Career Criminal Act (ACCA) because of his five previous burglary convictions in Iowa state courts. At trial, the district court used a modified categorical approach to determine that Mathis’ prior convictions constituted violent felonies because the elements of the offense were substantially similar to generic burglary and posed the same risk of harm to others. Therefore, Mathis was sentenced to 180 months imprisonment pursuant to the ACCA. Mathis appealed his conviction and argued that his Iowa convictions should not have constituted predicate offenses under the ACCA, but the U.S. Court of Appeals for the Eighth Circuit affirmed the lower court's decision.</p>

majority opinion

reversed

Criminal Procedure

James v. City of Boise

https://api.oyez.org/cases/2015/15-493

15-493

2015

Melene James

City of Boise, Idaho

<p>Melene James filed a complaint against City of Boise police officers after she was bitten by a police dog as the officers were responding to a call about a burglary in progress. The officers mistakenly thought James was a burglar. James brought claims of assault, battery, false arrest, wrongful imprisonment, and intentional infliction of emotional distress against the officers. The Idaho Tort Claims Act provides that a governmental entity is liable for negligent or wrongful acts of its employees if the acts were committed in the course and scope of their employment, but is not liable for intentional torts. The District Court of the Fourth Judicial District dismissed the claim because the officers had immunity for their intentional torts and James failed to show that they acted negligently. On appeal, the Idaho Supreme Court affirmed and awarded the defendants appellate attorney fees under the civil rights attorney fee statute. The court awarded these fees without determining that “the plaintiff’s action was frivolous, unreasonable, or without foundation” as required under the U.S. Supreme Court’s decision in <em>Hughes v. Rowe</em>. The Idaho Supreme Court decided that <em>Hughes</em> did not apply because the U.S. Supreme Court did not have the authority to limit the discretion of state courts without a limit in the relevant statute.</p>

per curiam

reversed/remanded

Attorneys

V.L. v. E.L.

https://api.oyez.org/cases/2015/15-648

15-648

2015

V.L.

E.L., et al.

<p>V.L. and E.L., a lesbian couple, were in a long-term relationship and raised three children together, of which E.L. was the biological parent. They eventually decided that V.L. should adopt the children and filed a petition to do so in Georgia state court, which granted the petition. In 2011, while living in Alabama, V.L. and E.L. ended their relationship. V.L. filed a petition in Alabama state court that alleged the E.L. had denied her access to her children and interfered with her parental rights. V.L. asked the Alabama state court to register the Georgia adoption judgment and order custody or visitation, which the court did, and E.L. appealed. The Alabama Court of Civil Appeals held that the lower court had failed to conduct an evidentiary hearing. The Alabama Supreme Court reversed and held that the Georgia state court did not have subject-matter jurisdiction to enter an adoption order for V.L. while still recognizing E.L.’s parental rights and therefore the Alabama courts did not have to recognize that judgment under the Full Faith and Credit Clause.</p>

per curiam

reversed/remanded

Economic Activity

Amgen, Inc. v. Harris

https://api.oyez.org/cases/2015/15-278

15-278

2015

Amgen Inc., et al.

Steve Harris

<p>Current and former employees of Amgen, Inc. (Amgen) and Amgen Manufacturing, Limited (AML) participated in two employer-sponsored pension plans (the Plans). The Plans included holdings in the Amgen Common Stock Fund which held only Amgen common stock. The plaintiffs were a group of employees who filed a class action suit under the Employee Retirement Income Security Act (ERISA) against Amgen, AML, Amgen’s board of directors, and the Fiduciary Committees of the Plans when the value of the Amgen common stock fell. The plaintiffs alleged that the defendants breached their fiduciary duties under ERISA by allowing the participants to purchase and hold Amgen stock while knowing its price was artificially inflated. The district court granted the defendants’ motion to dismiss, and the plaintiffs appealed. The United States Court of Appeals for the Ninth Circuit reversed and remanded on the grounds that the district court did not properly apply the “presumption of prudence” as illustrated in <em>Quan v. Computer Science Corp.</em> The presumption of prudence explains that the fiduciary who invests assets in the employer’s stock is entitled to a presumption that they acted consistently with ERISA. The court found that even if the presumption of prudence did apply, the plaintiffs had sufficiently argued a violation of the defendant’s fiduciary duty. On remand, the district court again dismissed the action and the Court of Appeals again reversed. The Supreme Court granted certiorari and vacated and remanded the case in light of its decision in <em>Fifth Third Bancorp v. Dudenhoeffer</em>, which held that ERISA fiduciaries who administer employee stock ownership plans are not entitled to a presumption of prudence but are “subject to the same duty of prudence that applies to ERISA fiduciaries in general, except that they need not diversify the fund’s assets.” The appellate court again reversed the dismissal of the complaint on the same grounds.</p>

per curiam

reversed/remanded

Economic Activity

Trinity Lutheran Church of Columbia, Inc. v. Comer

https://api.oyez.org/cases/2016/15-577

15-577

2016

Trinity Lutheran Church of Columbia, Inc.

Carol S. Comer, Director, Missouri Department of Natural Resources

<p>Trinity Lutheran Church of Columbia, Inc. (Trinity) operates a licensed preschool and daycare called The Learning Center that was initially opened as a non-profit corporation but merged with Trinity in 1985. The Learning Center has an open admissions policy and incorporates daily religious instruction into its programs. The Missouri Department of Natural Resources (DNR) offers Playground Scrap Tire Surface Material Grants that provide funds for qualifying organizations to purchase recycled tires to resurface playgrounds. Trinity applied for such a grant but was denied because Article I, Section 7 of the Missouri Constitution states, “no money shall ever be taken from the public treasury, directly or indirectly, in aid of any church, section or denomination of religion.” Trinity sued and argued that the denial of its application violated the Equal Protection Clause of the Fourteenth Amendment as well as the First Amendment’s protections of freedom of religion and speech. The district court granted Missouri DNR Director Pauley’s motion to dismiss for failure to state a claim, and Trinity moved for reconsideration and to amend its complaint to include allegations that such grants had previously been given to religious organizations. The district court denied the motions, and the U.S. Court of Appeals for the Eighth Circuit affirmed the dismissal and the denial of the motions to reconsider and amend the complaint.</p>

majority opinion

reversed/remanded

First Amendment

Welch v. United States

https://api.oyez.org/cases/2015/15-6418

15-6418

2015

Gregory Welch

United States

<p>Police entered Gregory Welch’s apartment because they had reason to believe that a robbery suspect was on the premises. After obtaining Welch’s consent to search the apartment, the police located a gun and ammunition that Welch later identified as his own. Welch was subsequently arrested and charged with being a felon in possession of a firearm, and he pleaded guilty. Because Welch had three prior felony convictions, the district court determined that the Armed Career Criminal Act (ACCA) required that he be sentenced to a minimum of 15 years in prison. Welch appealed his sentence and argued that one of his felonies, a conviction for “strong arm” robbery in Florida state court in 1996, did not qualify as a predicate offense for the purpose of the ACCA because, at the time he was convicted, Florida state law allowed for a conviction of robbery with a much lower level of force than the federal law required. The U.S. Court of Appeals for the Eleventh Circuit affirmed the district court’s determination that Welch’s conviction for robbery under Florida state law was a predicate offense for the purpose of the ACCA because it involved force that was “capable of causing physical pain or injury to another person.”</p> <p>In 2013, Welch filed a collateral challenge to his conviction and argued that his prior conviction for strong arm robbery vague and that his trial counsel had been ineffective in allowing him to be sentenced under the ACCA. He sought a certificate of appealability to the appellate court, which the district court denied. Welch then sought a certificate of appealability from the appellate court and noted that there was a challenge to the ACCA based on its vagueness pending in the Supreme Court, <em>Johnson v. United States</em>. The appellate denied the certificate of appealability.</p> <p>Three weeks later, the Supreme Court decided <em>Johnson v. United States</em> and held that the residual clause of the ACCA, which included action that “otherwise involves conduct that presents a serious potential risk of physical injury to another” in the definition of a violent felony, was unconstitutionally vague. The Court held that the residual clause violated the Due Process Clauses of the Fifth Amendment and Fourteenth Amendments because it was so vague that it failed to give people adequate notice of the conduct it punished. In order to apply the residual clause to a case, courts had to assess the “hypothetical risk posed by an abstract generic version” of the crime in question, which made the application of the clause unconstitutionally arbitrary and unpredictable.</p>

majority opinion

vacated/remanded

Criminal Procedure

Wearry v. Cain

https://api.oyez.org/cases/2015/14-10008

14-10008

2015

Michael Wearry

Burl Cain, Warden

<p>Eric Walber was murdered on April 4, 1998. Nearly two years after the murder, Sam Scott, who was incarcerated at the time, contacted authorities and implicated Michael Wearry in the murder. Scott had been friends with the victim and claimed that Wearry had confessed the crime to him. However, Scott gave an account of the murder that differed from the actual facts and changed his story several times before Wearry’s trial. The prosecution’s other main witness was also incarcerated at the time of trial and had made a prior inconsistent statement to the police that he also recanted. Wearry was convicted and sentenced to death.</p> <p>After Wearry’s conviction, information emerged that revealed that the prosecution had failed to disclose evidence that cast doubt on these witnesses’ testimony and would have materially aided Wearry’s defense at trial. Wearry sought state postconviction relief and argued that the state had violated his due process rights under <em>Brady v. Maryland</em> by failing to disclose the potentially exculpatory evidence and that he had received ineffective assistance of counsel. The state court determined that, even if the state should have disclosed the evidence and Wearry’s counsel was ineffective, he was not prejudiced, and the Louisiana Supreme Court denied further relief.</p>

per curiam

reversed/remanded

Criminal Procedure

Samsung Electronics Co. v. Apple Inc.

https://api.oyez.org/cases/2016/15-777

15-777

2016

Samsung Electronics Co., Ltd., et al.

Apple Inc.

<p>In April 2011, Apple Inc. (Apple) sued Samsung Electronics, Co., Ltd. (Samsung) and argued that certain design elements of Samsung’s smartphones infringed on specific patents for design elements in the iPhone that Apple holds. The jury held that Samsung had infringed on Apple’s patents and awarded over $1 billion in damages. The district court ordered a partial retrial on the issue of damages because some damages had been awarded for a period in which Samsung did not have notice of some of the asserted patents. On retrial, the jury awarded nearly $300 million in damages. On appeal, Samsung argued that the district court erred in allowing the jury to award damages based on Samsung’s entire profits, rather than the fraction of profits directly attributable to the infringed patents themselves. The U.S. Court of Appeals for the Federal Circuit affirmed the district court’s award of damages because Samsung did not argue that there was a lack of substantial evidence to support the award.</p>

majority opinion

reversed/remanded

Economic Activity

Caetano v. Massachusetts

https://api.oyez.org/cases/2015/14-10078

14-10078

2015

Jamie Caetano

Massachusetts

<p>Jamie Caetano was convicted of possession of a stun gun in Massachusetts state court. Caetano appealed and claimed her conviction violated her Second Amendment right to possess a stun gun in public for the purpose of self-defense, which was necessary to protect herself from her abusive ex-boyfriend. The Supreme Judicial Court of Massachusetts affirmed Caetano’s conviction and held that a stun gun is not eligible for Second Amendment protection.</p>

per curiam

vacated/remanded

Criminal Procedure

Marshall v. Rodgers

https://api.oyez.org/cases/2012/12-382

12-382

2012

John Marshall, Warden

Otis Lee Rodgers

<p>On July 15, 2001, Otis Lee Rodgers was arrested after he threatened to shoot his wife in the head outside of the Garden Estates Apartments in Riverside, California. Before his trial, Rodgers waived his Sixth Amendment right to counsel and chose to represent himself. Rodgers then changed his mind several times, retaining and dismissing court-appointed attorneys, until his eventual trial. A Riverside County Superior Court jury subsequently found him guilty of assault with a firearm, possession of a firearm as a felon, possession of ammunition as a felon, and making criminal threats. He also admitted that he was on bail for another pending felony trial and had two prior felony convictions. Rodgers was sentenced to sixteen years in prison.</p> <p>After sentencing, Rodgers asked the court to appoint an attorney to help him file a motion for a new trial. The trial judge denied his request and subsequently denied his pro se motion for a new trial. Rodgers appealed to the U. S. District Court for the Central District of California, seeking habeus corpus relief for the judge’s refusal to appoint counsel for the motion for a new trial. That court denied his petition. Rodgers then appealed to the U.S. Court of Appeals for the Ninth Circuit. That court granted Rodgers’ petition and remanded the case for trial.</p>

per curiam

reversed/remanded

Civil Rights

Bravo-Fernandez v. United States

https://api.oyez.org/cases/2016/15-537

15-537

2016

Juan Bravo-Fernandez, et al.

United States

<p>In May 2005, Juan Bravo-Fernandez, the president of a private security firm in Puerto Rico, and Hector Martinez-Maldonado, a member of the Puerto Rican Senate, traveled to Las Vegas to see a boxing match. Bravo-Fernandez and Martinez-Maldonado were later indicted on charges that Bravo-Fernandez’s payment for the trip was connected to Martinez-Maldonado’s support of legislation beneficial to the security firm. The charges included violations of the federal bribery statute, conspiracy, and the Travel Act, which prohibits travel in interstate commerce for a criminal purpose -- in this case, the violation of the federal bribery statute. The jury convicted the defendants of violating the federal bribery statute, but found the defendants not guilty of conspiracy to violate the statute or of violating the Travel Act. The U.S. Court of Appeals for the First Circuit vacated the convictions for violating the federal bribery statute because the jury was improperly instructed about what the government needed to prove. The appellate court remanded the case.</p> <p>Based on this holding, the district court entered an order that acquitted the defendants, but that order was vacated after the government clarified that the appellate court’s decision vacating the federal bribery convictions did not require the district court to enter an order of acquittal. The district court subsequently entered an order that clarified that the bribery convictions were vacated. The defendants moved to reinstate the initial order and argued that it was a judgment of acquittal that, under the Double Jeopardy Clause, could not be rescinded. The district court denied the motion. The defendants then moved for acquittal and argued that the original acquittals for the Travel Act and conspiracy charges prevented the government from relitigating the bribery charges because a jury had already determined that the government failed to prove elements essential to conviction under the bribery statute. The defendants argued that the Double Jeopardy Clause prohibits relitigation of these issues. The district court denied the motion, and the appellate court affirmed.</p>

majority opinion

affirmed

Criminal Procedure

Pena-Rodriguez v. Colorado

https://api.oyez.org/cases/2016/15-606

15-606

2016

Miguel Angel Pena-Rodriguez

Colorado

<p>Miguel Angel Pena-Rodriguez was convicted of unlawful sexual conduct and harassment in state trial court. After the entry of a guilty verdict, two jurors informed Pena-Rodriguez’s counsel that one of the other jurors made racially biased statements about Pena-Rodriguez and the alibi witness during jury deliberations. The trial court authorized Pena-Rodriguez’s counsel to contact the two jurors for their affidavits explaining what the “biased” juror said about Pena-Rodriguez or his alibi witness. Based on these affidavits, which related racially biased statements about Pena-Rodriguez’s likely guilt and the alibi witness’ lack of credibility because both were Hispanic, Pena-Rodriguez moved for a new trial. The trial court denied the motion, and the Colorado Court of Appeals affirmed. The Supreme Court of Colorado held the jurors’ affidavits were inadmissible under Rule 606(b) of Colorado’s Rules of Evidence, which prohibits juror testimony on any matter occurring during the jury deliberations. The Supreme Court of Colorado also held Rule 606(b) did not violate Pena-Rodriguez’s Sixth Amendment right to an impartial jury because Pena-Rodriguez had waived that right by failing to adequately question jurors about their racial bias during voir dire.</p>

majority opinion

reversed/remanded

Criminal Procedure

Woods v. Etherton

https://api.oyez.org/cases/2015/15-723

15-723

2015

Jeffrey Woods

Timothy Etherton

<p>In 2006, Michigan law enforcement received an anonymous tip that two white males were traveling between Detroit and Grand Rapids on I-96 in an Audi and were possibly carrying cocaine. Timothy Etherton was driving a car that matched that description, and he was pulled over. Both he and his passenger, Ryan Pollie, were arrested when the officers found 125.2 grams of cocaine in the car. During Etherton’s trial in state court, Pollie testified that he accompanied Etherton to Detroit without knowing that they were traveling there to obtain cocaine and that Etherton did not inform Pollie about the drugs until the two started back to Grand Rapids. Several police officers also testified at trial and described the anonymous tip, which was “not evidence” but admitted “only to show why the police did what they did.” Etherton was convicted of possession of cocaine with intent to deliver. The Michigan Court of Appeals affirmed his conviction, and the Michigan Supreme Court denied leave to appeal.</p> <p>Etherton sought state postconviction relief and argued that the admission of the anonymous tip violated his rights under the Confrontation Clause of the Sixth Amendment, his trial counsel was ineffective for failing to object to the tip on that ground, and his counsel on direct appeal was ineffective for failing to raise the previous two claims. The state court denied postconviction relief because Etherton failed to prove that his counsel acted unreasonably. Etherton then sought federal habeas relief under the Antiterrorism and Effective Death Penalty Act (AEDPA), which specifies that federal habeas relief is only available after a state court’s denial if the state court’s decision involved an unreasonable application of clearly established federal law. If “fairminded jurists” could disagree as to the validity of the state court’s determination, federal habeas relief is unavailable. The district court denied relief by finding the state court’s denial of relief was objectively reasonable because Etherton’s counsel was adequately prepared for trial. The U.S. Court of Appeals for the Sixth Circuit reversed and held that Etherton’s right to confrontation had been violated because the anonymous tip was referenced four times during the trial, which indicated that the tip was admitted for its truth. The court concluded Etherton’s counsel had been constitutionally ineffective and “no fairminded jurist could conclude otherwise.”</p>

per curiam

reversed

Criminal Procedure

Manrique v. United States

https://api.oyez.org/cases/2016/15-7250

15-7250

2016

Marcelo Manrique

United States

<p>Marcelo Manrique was convicted in federal district court of possession of child pornography. He was sentenced to a life term of supervised release and mandatory restitution, though the final judgment did not include an amount for the restitution and stated that would be included in the amended judgment. Manrique filed his notice of appeal before the amended judgment was entered. When the amended judgment was entered while the appeal was pending, it included the details of the restitution award, and both parties subsequently included arguments regarding the challenge of the award in their briefs. The U.S. Court of Appeals for the Eleventh Circuit ruled that it did not have jurisdiction to consider the challenge to the restitution award because Manrique did not file a second notice of appeal regarding the amended judgment that included the amount of the restitution award.</p>

majority opinion

affirmed

Judicial Power

Shaw v. United States

https://api.oyez.org/cases/2016/15-5991

15-5991

2016

Lawrence Eugene Shaw

United States

<p>Stanley Hsu, a Taiwanese business man, opened a Bank of America bank account while working in the United States. When he returned to Taiwan, he arranged for the daughter of one of his employees to receive his mail and forward it to him in Taiwan. Lawrence Eugene Shaw lived with the daughter and regularly checked her mail. When the Bank of America statements arrived for Hsu’s account, Shaw concocted a scheme in which he opened a PayPal account under Stanley Hsu’s name and used it to convince banks that he was Hsu for the purpose of transferring money from Hsu’s accounts to the PayPal account and from there to an account that Shaw controlled. Using this scheme, Shaw was able to transfer approximately $307,000 of Hsu’s money to himself before the fraud was discovered. Bank of America returned approximately $131,000 to Hsu, and PayPal returned approximately $106,000. Hsu lost about $170,000 by not notifying the banks within 60 days of the fraudulent transactions, as standard banking procedures require.</p> <p>The government charged Shaw with violating the Bank Fraud Act of 1984, which criminalizes schemes “to defraud a financial institution.” Shaw requested a jury instruction that stated that the government had to prove that he intended not only to defraud the bank but also that he intended to target the bank as the principal financial victim. The district court refused to give the instruction and determined that the language of the Act required that the government prove only that the defendant intended to deceive the bank, not that he also intended the bank to bear the loss that resulted from the fraud. The jury convicted Shaw of 14 counts of bank fraud under the Act, and the U.S. Court of Appeals for the Ninth Circuit affirmed.</p>

majority opinion

affirmed

Criminal Procedure

SCA Hygiene Products Aktiebolag v. First Quality Baby Products

https://api.oyez.org/cases/2016/15-927

15-927

2016

SCA Hygiene Products Aktiebolag, et al.

First Quality Baby Products, LLC, et al.

<p>SCA Hygiene Products Aktiebolag (SCA) produces adult incontinence products, as does First Quality Baby Products, LLC (First Quality). In 2003, SCA notified First Quality that it believed First Quality was infringing on one of its patents, and First Quality responded by arguing that, because the SCA patent in question was essentially the same as a prior-filed patent, it was invalid and therefore First Quality could not be infringing. The two companies ceased communication on the issue, but in 2004, SCA requested that the U.S. Patent and Trademark Office (PTO) reexamine its patent in light of the prior-filed one, and in 2007, the PTO determined that the patent in question was valid.</p> <p>In 2010, SCA sued First Quality for patent infringement. First Quality moved for summary judgment because SCA had unreasonably delayed litigation, and the district court granted the motion. The U.S. Court of Appeals for the Federal Circuit affirmed the district court’s opinion regarding the unreasonable delay because SCA should have been able to proceed with litigation after the reexamination and had not provided evidence to justify the delay. SCA requested a rehearing before the entire appellate court to reconsider the issue in light of the Supreme Court’s decision in &lt;i&gt;Petrella v. Metro-Goldwyn-Mayer&lt;/i&gt;, which held that the unreasonable delay defense cannot bar suits for copyright infringement that occurred during the three-year limitations period, and argued that the same analysis should apply to patent suits like this one. Upon rehearing, the appellate court rejected SCA’s argument and held that the Petrella decision did not affect its precedent, which stated that an unreasonable delay defense may be used in patent infringement claims brought within the six-year statute of limitations, and courts must examine the circumstances underlying those claims and the defense.</p>

majority opinion

vacated/remanded

Economic Activity

Star Athletica, LLC v. Varsity Brands, Inc.

https://api.oyez.org/cases/2016/15-866

15-866

2016

Star Athletica, LLC

Varsity Brands, Inc., et al.

<p>Varsity Brands, Inc. (Varsity) designs and manufactures clothing and accessories for use in various athletic activities, including cheerleading. Design concepts for the clothing incorporate elements such as colors, shapes, lines, etc., and do not consider the functionality of the final clothing. Varsity received copyright registration for the two-dimensional artwork of the designs at issue in this case, which were very similar to ones that Star Athletica, LLC (Star) was advertising. Varsity sued Star and alleged, among other claims, that Star violated the Copyright Act. Star asserted counterclaims, including one that alleged that Varsity had made fraudulent representations to the Copyright Office because the designs at issue were not copyrightable. Both parties filed motions for summary judgment. Star argued that Varsity did not have valid copyrights because the designs were for “useful articles,” which cannot be copyrighted, and the designs cannot be separated from the uniforms themselves, which also makes the designs impossible to copyright. Varsity argued that the designs were separable and non-functional, and therefore that the copyrights were valid and had been infringed. The district court granted summary judgment for Star and held that the designs were integral to the functionality of the uniform. The U.S. Court of Appeals for the Sixth Circuit reversed and held that the Copyright Act allows graphic features of a design to be copyrighted even when those designs are not separable from a “useful article.”</p>

majority opinion

affirmed

Economic Activity

Kernan v. Hinojosa

https://api.oyez.org/cases/2015/15-833

15-833

2015

Scott Kernan, Secretary, California Department of Corrections and Rehabilitation

Antonio A. Hinojosa

<p>In 2009, while Antonio Hinojosa was serving a 16-year sentence for armed robbery and related crimes, prison officials determined that he was a prison-gang associate and placed him in a secured housing unit. At that time, California law allowed prisoners placed in a secured housing unit solely because of prison-gang affiliation could continue to accrue good-time credits. In 2010, the California Legislature amended the law so that, while prisoners in secured housing units could retain whatever good-time credits they had upon entry, they could no longer accrue good-time credits while in the unit. Hinojosa filed a state habeas petition and argued that the amended law’s application to him violated the ex post facto clause of the U.S. Constitution. The state court denied the claim because Hinojosa did not file it in the court for the county in which he was incarcerated. Hinojosa sought review by the appellate court and then the state supreme court, both of which denied his petition. Hinojosa then sought federal habeas relief. The district court denied relief under the Antiterrorism and Effective Death Penalty Act (AEDPA), which establishes a deferential standard of review of state denials of habeas, but the U.S. Court of Appeals for the Ninth Circuit reversed. The appellate court held that, because the initial state court denial was not based on the merits, the AEDPA did not apply.</p>

per curiam

reversed

Criminal Procedure

Coleman v. Johnson

https://api.oyez.org/cases/2011/11-1053

11-1053

2011

Brian Coleman, Superintendant, State Correctional Institution at Fayette et al.

Lorenzo Johnson

<p>In 1995, Corey Walker shot and killed Taraja Williams following an argument about a debt Williams owed. Lorenzo Johnson was present for this argument and heard Williams repeat several times that he was “going to kill that kid.” A witness saw Walker and Johnson walking into an alley with Williams in between them. Walker wore a long coat concealing a shotgun. Johnson waited at the front of the alley while Williams shot Walker. Johnson was tried as an accomplice to the murder. The jury convicted him after hearing the testimony of several witnesses, among other evidence. Johnson appealed his conviction, arguing that the prosecution did not present sufficient evidence to support his conviction. The Pennsylvania Superior Court affirmed the conviction, and Johnson filed for a writ of habeas corpus in federal district court. The district court denied the writ, but the U.S. Court of Appeals for the Third Circuit reversed. The Third Circuit held that the evidence did not sufficiently prove Johnson’s intent to kill Williams.</p>

per curiam

reversed/remanded

Criminal Procedure

Lynch v. Arizona

https://api.oyez.org/cases/2015/15-8366

15-8366

2015

Shawn Patrick Lynch

Arizona

<p>Shawn Patrick Lynch was convicted of first-degree murder, kidnapping, armed robbery and burglary, with all the charges stemming from the 2001 kidnapping and murder of James Panzarella. Arizona sought the death penalty and moved to prevent Lynch’s counsel from informing the jury that the only alternative to sentence to death was life without parole. The trial court granted the motion, and after the first jury failed to reach a unanimous verdict, the second jury sentenced Lynch to death. Lynch appealed and argued that, by granting Arizona’s motion, the trial court had violated Lynch’s Due Process Clause rights under the Supreme Court’s precedent in <em>Simmons v. South Carolina</em>. In that case, the Supreme Court established that, when a capital defendant’s future dangerousness is at issue and the only alternative to the death penalty is life imprisonment without the possibility of parole, the Due Process Clause grants the defendant the right to inform the jury of his ineligibility for parole. The Supreme Court of Arizona vacated the sentence without addressing the Simmons argument, and on remand the jury again sentenced Lynch to death. Lynch again appealed and raised the <em>Simmons</em> argument, which the Supreme Court of Arizona rejected by holding that the failure to inform the jury of Lynch’s parole ineligibility was not error.</p>

per curiam

reversed/remanded

Criminal Procedure

Johnson v. Lee

https://api.oyez.org/cases/2015/15-789

15-789

2015

Deborah K. Johnson, Warden

Donna Kay Lee

<p>Donna Kay Lee and Peter Carasi were each convicted in California state court of two counts of first-degree murder for the murder of Carasi’s mother and for his ex-girlfriend. Lee was sentenced to life imprisonment without parole, and the California appellate courts affirmed the conviction on direct appeal. Lee filed a petition for federal habeas relief without seeking state postconviction relief, and the petition mostly raised claims that Lee had not raised on direct appeal. Because Lee had not exhausted state relief measures, the district court stayed the case until the state law claims could be fully litigated. The California Supreme Court ruled that Lee’s state law claims were barred based on the precedent of In re Dixon, which held that a claim that could have been raised on direct appeal but wasn’t raised until postconviction relief proceedings is considered procedurally defaulted. The federal district court similarly dismissed Lee’s claims based on the <em>Dixon</em> bar. On appeal, Lee argued that the California courts were not consistently applying <em>Dixon</em> because the courts had not cited the case in every instance in which it should have applied and therefore that the bar was inadequate. The U.S. Court of Appeals for the Ninth Circuit remanded for further evidence, and after the presentation of evidence about how often California courts applied the <em>Dixon</em> bar, the district court again dismissed Lee’s claims. The appellate court reversed and held that the evidence was insufficient to show that the <em>Dixon</em> bar was being consistently applied, and therefore that the bar was inadequate.</p>

per curiam

reversed/remanded

Criminal Procedure

State Farm Fire and Casualty Co. v. U.S. ex rel. Rigsby

https://api.oyez.org/cases/2016/15-513

15-513

2016

State Farm Fire and Casualty Co.

United States ex rel. Cori Rigsby, et al.

<p>Many homeowners in the Gulf Coast area had two separate insurance policies: One that covered flood but not wind damage, and another that covered wind but not flood damage. These policies were frequently administered by the same private insurance company, but the company would be responsible for paying wind damage claims, while government funds would pay for flood damage claims; therefore, there was an incentive for the companies to classify damage as caused by flood rather than wind. State Farm Fire and Casualty Co. (State Farm) was one of these companies that administered such policies in the Gulf Coast area. Cori Rigsby was a State Farm claims adjuster who believed that State Farm was wrongfully seeking to maximize its policyholders’ flood damage claims and minimize wind damage claims after Hurricane Katrina. Rigsby sued State Farm under the False Claims Act (FCA). The district court determined that State Farm had submitted false claims in violation of the FCA. On appeal, State Farm argued Rigsby had violated the FCA’s seal requirement, which stated that the complaint cannot be disclosed until the court orders the complaint served on the defendant, and that violation of the FCA seal requirement warrants immediate dismissal. The U.S. Court of Appeals for the Fifth Circuit held that, although Rigsby violated the seal requirement by disclosing the existence of the suit, the violation of the seal requirement does not warrant immediate dismissal.</p>

majority opinion

affirmed

Economic Activity

UBS Financial Services v. Union de Empleados de Muelles

https://api.oyez.org/cases/2012/12-1208

12-1208

2012

UBS Financial Services Incorporated of Puerto Rico, et al.

Union de Empleados de Muelles de Puerto Rico PRSSA Welfare Plan, et al.

<p>In 2008, UBS Trust Company of Puerto Rico (UBS Trust) sold approximately $757 million worth of bonds to a group of investment funds (Funds) that it advises. The Funds suffered significant losses when the value of the bonds plummeted shortly after the sale. Union de Empleados de Muelles de Puerto Rico AP Welfare Plan (AP) and Union de Empleados de Muelles de Puerto Rico PRSSA Welfare Plan (PRSSA) are Puerto Rico pension plans that own shares in the Funds. In 2010, AP and PRSSA sued the investment funds’ directors, UBS Trust, and UBS Financial Services Inc. in federal district court. The plaintiffs argued that the UBS defendants engaged in manipulative trading by using the Funds to artificially drive up the price of the bonds. Under corporate law, officers and directors are usually the only parties that litigate on behalf of a corporation. Shareholders like AP and PRSSA may file suit in behalf of the corporation (shareholder derivative action) if they satisfy certain procedural requirements that vary by jurisdiction. The Federal Rules of Procedure require a derivative action complaint to prove that a demand was presented to and refused by the defendants’ Board of Directors or to list the reasons that such a demand would have been futile. The defendants moved to dismiss the claim because these requirements had not been met, and the district court granted the motion to dismiss. The U.S. Court of Appeals for the First Circuit reversed. Reviewing the merits of the motion to dismiss, the Court of Appeals determined that the majority of the Funds’ Board members were too closely connected to the UBS defendants personally and financially to be able to exercise independent judgment in responding to a demand regarding the transaction in question.</p>

dismissal - rule 46

none

National Labor Relations Board v. SW General, Inc.

https://api.oyez.org/cases/2016/15-1251

15-1251

2016

National Labor Relations Board

SW General, Inc.

<p>In 1998, Congress enacted the Federal Vacancies Reform Act (FVRA), which provided that, if a position for which the President nominates and the Senate confirms (PAS position) becomes vacant, the first assistant automatically takes over as an “acting officer” for a period of 210 days. The President may also select a senior employee from the same agency or someone in a PAS position from another agency to serve as the acting officer. Pursuant to the FVRA, when the Ronald Meisberg resigned as the General Counsel of the National Labor Relations Board (NLRB), a PAS position, the President directed Lafe Solomon, who held a senior position in the NLRB, to serve as the Acting General Counsel. Six months into his tenure, the President nominated him for the General Counsel position, but the Senate did not confirm him. On October 29, 2013, the Senate confirmed a different nominee, so by the time he stepped down, Solomon had served as Acting General Counsel from June 21, 2010, until November 4, 2013.</p> <p>SW General, Inc. provides ambulance services to hospitals in Arizona. Its emergency medical technicians (EMTs), nurses, and firefighters, are negotiated by a union that had negotiated with SW General for “longevity pay,” which meant that employees who had been with the company for at least ten years were guaranteed annual bonuses. In December 2012, between the expiration of one collective bargaining agreement and the negotiation of a new one, SW General stopped paying the longevity pay. The union filed an unfair labor practices claim with the NLRB, which issued a formal complaint. An administrative law judge determined that SW General had committed unfair labor practices, and SW General filed a list of exceptions, among which was a claim that Acting General Counsel was serving in violation of the FVRA. A provision of the FVRA states that the acting officer may not become the nominee for the position, and the nominee to fill the position may not serve in an acting capacity unless that nominee was the first assistant to the vacant position for at least 90 days in the previous year. Solomon was briefly a nominee for the position, and he had not served as the first assistant to the vacant position. SW General petitioned the U.S. Court of Appeals for the District of Columbia Circuit for review, and the appellate court did not address the merits of the case because it determined that Solomon’s tenure as Acting General Counsel violated the FVRA.</p>

majority opinion

affirmed

Miscellaneous

Bethune-Hill v. Virginia Board of Elections

https://api.oyez.org/cases/2016/15-680

15-680

2016

Golden Bethune-Hill, et al.

Virginia State Board of Elections, et al.

<p>Based on the 2010 Census, the Virginia General Assembly sought to redraw the legislative districts for the Virginia Legislature. At the time the districting legislation was prepared, Virginia was subject to Section 5 of the Voting Rights Act, and therefore any new districting plan must have ensured that there would be no “retrogression” in the ability of racial minorities to elect the candidate of their choice. Accordingly, the new districting plan contained 12 majority-minority districts. On December 22, 2014, the plaintiffs, each of whom resided in one of the twelve challenged districts, sued and argued that those districts constituted racial gerrymanders that violated the Equal Protection Clause of the Fourteenth Amendment. The district court held that the plaintiffs did not establish that race was the predominant factor in the creation of 11 of the 12 challenged district. The district court also held that, although race was the predominant factor in the creation of one district, in doing so the General Assembly was pursuing a compelling state interest and its use of race was narrowly tailored to serve that interest.</p>

majority opinion

vacated in-part/remanded

Civil Rights

Moore v. Texas

https://api.oyez.org/cases/2016/15-797

15-797

2016

Bobby James Moore

Texas

<p>In 1980, Bobby James Moore was convicted of capital murder for the shooting of James McCarble, a seventy-year-old store clerk, in Houston, Texas. Moore was sentenced to death, and his conviction and sentence were both affirmed on appeal. After a federal court granted habeas corpus relief, a new punishment hearing occurred in 2001, and Moore was again sentenced to the death penalty. His sentence was again affirmed on appeal. Moore sought state habeas relief and argued that the U.S. Supreme Court’s decision in <em>Atkins v. Virginia</em> should apply to his case; therefore, because he was intellectually disabled, he was exempt from execution. The habeas court granted relief based on the <em>Atkins</em> argument. The Court of Criminal Appeals of Texas, however, reversed and held that Moore had failed to establish by a preponderance of the evidence that he had the requisite intellectual disability for the <em>Atkins</em> precedent to apply based on Texas case law that used a 1992 definition of intellectual disability.</p>

majority opinion

vacated/remanded

Criminal Procedure

Buck v. Davis

https://api.oyez.org/cases/2016/15-8049

15-8049

2016

Duane Edward Buck

Lorie Davis, Director, Texas Department of Criminal Justice, Correctional Institutions Division

<p>In July 1995, Duane Edward Buck was arrested for the murder of his ex-girlfriend, Debra Gardner, and her friend Kenneth Butler. Buck was convicted of capital murder for both of the deaths. During the penalty phase of trial, the prosecution presented evidence of Buck’s future dangerousness based on his criminal history, his conduct, and his demeanor before and after arrest. The defense presented the testimony of a clinical psychologist to evaluate the risk of future dangerousness. That expert stated that he considered demographic factors, including race, in his analysis and that, statistically, minorities are overrepresented in the criminal justice system. On cross-examination, the prosecution clarified that the expert’s opinion was that the race factor “black” increased the likelihood of future dangerousness. The jury found that there was sufficient evidence of Buck’s future dangerousness without any sufficient mitigating factors to justify a life sentence, so the jury sentenced Buck to death. The Texas Court of Criminal Appeals affirmed the conviction and sentence.</p> <p>Buck filed various claims for state and federal habeas relief that were denied, until the U.S. Supreme Court decided <em>Trevino v. Thaler</em>, which held that Texas’ procedural scheme made it almost impossible to raise ineffective assistance of counsel claims on direct appeal, and therefore that a procedural default on such a claim could be excused. While some of these claims were pending, the state attorney general admitted in a different case that the state should not have called an expert witness to testify about future dangerousness of a defendant based on race and named Buck’s case as one affected by similar testimony. Buck again sought federal habeas relief based on ineffective assistance of counsel because his counsel knowingly called an expert witness who testified that race was a factor in determining future dangerousness. The district court dismissed the claim because Buck failed to show that the outcome of his trial was prejudiced. The U.S. Court of Appeals for the Fifth Circuit similarly denied Buck’s request for a Certificate of Appealability by holding that Buck did not show sufficient extraordinary circumstances to justify relief from the lower court’s judgment.</p>

majority opinion

reversed/remanded

Criminal Procedure

Cooper v. Harris

https://api.oyez.org/cases/2016/15-1262

15-1262

2016

Roy Cooper, Governor of North Carolina, et al.

David Harris, et al.

<p>After the 2010 Census, pursuant to the state Constitution, the North Carolina state legislature appointed House and Senate Committees to prepare a redistricting plan for U.S. House of Representatives districts. The heads of the respective committees hired a redistricting coordinator to design the new districts. The coordinator was given instructions orally; there were no written records of the precise instructions he received. The heads of the committees published public statements that highlighted certain criteria used in creating their proposed redistricting plan, such as the fact that, according to Supreme Court interpretation of the requirements of Section 2 of the Voting Rights Act, districts must be constructed to have a “Black Voting Age Population” (BVAP) of 50% plus one. To comply with this criterion, two districts were altered to have a BVAP over 50%, which meant that there were two more majority-black districts than there were under the 2001 Congressional Districting Plan. The state legislature enacted the new plan and the Department of Justice granted it preclearance pursuant to Section 5 of the Voting Rights Act.</p> <p>David Harris and Christine Bowser are U.S. citizens registered to vote in the two districts at issue. They sued and argued that North Carolina used the Voting Rights Act’s requirements as a pretext to place more black voters in those two districts to reduce black voters’ influence in other districts. The district court determined that race was the predominant factor motivating the redistricting plan and therefore that the redistricting plan was an unconstitutional racial gerrymander that violated the Equal Protection Clause.</p>

majority opinion

affirmed

Civil Rights

Jennings v. Rodriguez

https://api.oyez.org/cases/2017/15-1204

15-1204

2017

David Jennings, et al.

Alejandro Rodriguez, et al.

<p>Sections of the Immigration and Nationality Act require that noncitizens who are determined to be inadmissible to the United States must be detained during removal proceedings, though some may be released on bond if they can demonstrate that they are not a flight risk or a danger to the community. Alejandro Rodriguez and other detained noncitizens sued and argued that their prolonged detention without hearings and determinations to justify the detentions violated their due process rights. After litigation regarding class certification, the district court granted a preliminary injunction that required the government to provide each detainee with a bond hearing and to release that detainee unless the government could show, by clear and convincing evidence, that continued detention was justified. The U.S. Court of Appeals for the Ninth Circuit held that prolonged detention without a hearing raised serious constitutional concerns, and therefore that the relevant mandatory statutory language should be interpreted as having a time limitation; at the six-month mark, detainees are entitled to bond hearings. Because the plaintiff class proved that it was likely to succeed on the merits, the appellate court affirmed the grant of the preliminary injunction. The plaintiff class then moved for a permanent injunction, which the district court granted and the appellate court affirmed. The appellate court also determined that the duration of future detention and likelihood of eventual removal should not be considered in the bond hearings, and the noncitizens are entitled to bond hearings at six-month intervals throughout their detentions.</p>

plurality opinion

none

Civil Rights

Life Technologies Corp. v. Promega Corp.

https://api.oyez.org/cases/2016/14-1538

14-1538

2016

Life Technologies Corp., et al.

Promega Corp.

<p>Promega Corporation owned four patents and was the exclusive licensee of another one for technology used in kits that can conduct genetic testing. The kits are usually used for the purposes of identifying forensic or paternity matches. In 2010, Promega sued Life Technologies Corporation (LifeTech) for infringing on the patents in question, and LifeTech filed counterclaims that argued that the asserted claims of the patents were invalid. The district court determined that LifeTech had directly infringed on the patents and the case proceeded to damages. During the damages phase, there was a dispute about whether or not Promega had met its burden to prove that it was eligible for damages based on its worldwide sales. The jury determined that Promega was eligible for the worldwide damages, but the district court granted LifeTech’s motion to vacate the judgment because it determined that, as a matter of law, Promega had failed to present sufficient evidence to sustain that jury verdict. The U.S. Court of Appeals for the Federal Circuit reversed and determined that there was substantial evidence that LifeTech was liable for worldwide damages.</p>

majority opinion

reversed/remanded

Economic Activity

Beckles v. United States

https://api.oyez.org/cases/2016/15-8544

15-8544

2016

Travis Beckles

United States

<p>On April 11, 2007, Travis Beckles was arrested because a sawed-off shotgun was located in his residence, and he had previous felony convictions, mostly for drug possession and sales. Beckles was convicted, and during the sentencing phase of his trial, the district court determined that Beckles was an armed career criminal under the Armed Career Criminal Act (ACCA) who had been in possession of a firearm and was therefore subject to sentencing enhancement under the Sentencing Guidelines. Pursuant to the Sentencing Guidelines, Beckles was eligible for a sentence range from 360 months to life imprisonment, and the court sentenced him to 360 months in prison, five months of supervised release, and a $5,000 fine. Beckles appealed and argued that the Sentencing Guidelines imposed an unreasonable sentence, that his prior convictions did not qualify as “violent felonies” subject to sentencing enhancement under ACCA, and that possession of a sawed-off shotgun was not a “crime of violence” subject to sentencing enhancement under the Sentencing Guidelines. The U.S. Court of Appeals for the Eleventh Circuit affirmed Beckles’ conviction and sentence.</p> <p>The U.S. Supreme Court vacated the appellate court’s decision and remanded the case for reconsideration in light of <em>Johnson v. United States</em>, which determined that the residual clause of ACCA was unconstitutional. On remand, the appellate court again upheld Beckles’ conviction and sentence because possession of a sawed-off shotgun was a “crime of violence.” The appellate court also held that the <em>Johnson</em> decision did not affect this case because Beckles was not sentenced under the residual clause of ACCA but rather under express language from the Sentencing Guidelines about sentencing enhancements for crimes of violence.</p>

affirmed

Criminal Procedure

Venezuela v. Helmerich & Payne International Drilling Company

https://api.oyez.org/cases/2016/15-423

15-423

2016

Bolivarian Republic of Venezuela, et al.

Helmerich & Payne International Drilling Company, et al.

<p>The Foreign Sovereign Immunities Act protects foreign sovereigns from suits in American courts unless one of a set of specifically enumerated exceptions applies. One of these exceptions is when the foreign sovereign takes U.S. property (the expropriation exception), and another is when the action of the foreign sovereign has direct effect on U.S. commercial activity (the commercial activity exception).</p> <p>Oklahoma-based company Helmerich &amp; Payne International Drilling Company owns a subsidiary that contracts with the Venezuelan state-owned corporation that controls the exploration, production, and exportation of oil in Venezuela. In 2007, the two companies executed contracts for the Venezuelan corporation to use Helmerich &amp; Payne’s drilling rigs. By 2008, the unpaid debt from those contracts totaled more than $63 million, and when the debt was over $100 million in 2009, Helmerich &amp; Payne announced it would not be renewing the contract and packed up its drills. Employees of the Venezuelan corporation, assisted by members of the Venezuelan National Guard blockaded the yards in which Helmerich &amp; Payne was keeping its equipment, and then-President Hugo Chavez issued a Decree of Expropriation. Helmerich &amp; Payne sued Venezuela and its state-owned corporation in federal district court under the expropriation and commercial activity exceptions to the FSIA. Venezuela moved to dismiss, and the district court granted the motion with respect to the expropriation claim but denied it with respect to the commercial activity claim. The U.S. Court of Appeals for the District of Columbia Circuit reversed and held that, because the expropriation claim was neither insubstantial nor frivolous, the district court should not have granted the motion to dismiss that claim.</p>

majority opinion

vacated/remanded

Judicial Power

Lightfoot v. Cendant Mortgage Corporation

https://api.oyez.org/cases/2016/14-1055

14-1055

2016

Crystal Monique Lightfoot, et al.

Cendant Mortgage Corporation, et al.

<p>Crystal Monique Lightfoot and Beverly Ann Hollis-Arlington sued the Federal National Mortgage Association (Fannie Mae) in federal district court and alleged numerous state and federal law claims arising out of the foreclosure proceedings Fannie Mae initiated against Hollis-Arlington’s home. The district court dismissed and held that the plaintiffs had failed to show the existence of a genuine issue of material fact regarding their claims. The U.S. Court of Appeals for the Ninth Circuit affirmed the dismissal.</p> <p>The plaintiffs then sued in California state court and alleged the state law equivalents of the claims in the earlier federal suit. Fannie Mae removed the case to federal court and argued that its federal corporate charter contained language that granted federal courts subject matter jurisdiction over cases in which it was involved as a plaintiff or defendant. The plaintiffs in this case moved for a remand back to state court, but the district court denied the remand and then dismissed all the claims as having already been litigated in the earlier case in federal court. The appellate court determined that the language in Fannie Mae’s federal charter conferred subject matter jurisdiction to federal courts and affirmed the dismissal.</p>

majority opinion

reversed

Judicial Power

Fry v. Napoleon Community Schools

https://api.oyez.org/cases/2016/15-497

15-497

2016

Stacy Fry, et vir, as Next Friends of Minor E. F.

Napoleon Community Schools, et al.

<p>The Frys’ daughter, E.F., was born with cerebral palsy and was prescribed a service dog to assist with everyday tasks. Her school, which provided her with a human aide in accordance with her Individualized Education Plan (IEP) under the Individuals with Disabilities Education Act (IDEA), did not allow her to bring her service dog to school. The Frys sued the school, the principal, and the school district and argued that they violated the Americans with Disabilities Act (ADA), the Rehabilitation Act, and state disabilities laws. The district court granted the defendants’ motion to dismiss because the claims necessarily implicated the IDEA, which required plaintiffs to exhaust all administrative remedies before suing under the ADA and Rehabilitation Act. The Frys appealed and argued that the exhaustion requirement did not apply because they were seeking damages, which is not the sort of relief the IDEA provided. The U.S. Court of Appeals for the Sixth Circuit affirmed the dismissal and held that the Frys’ claims were essentially educational, which are precisely the sort of claims the IDEA was meant to address, and therefore the exhaustion requirement applied.</p>

majority opinion

vacated/remanded

Civil Rights

Czyzewski v. Jevic Holding Corp.

https://api.oyez.org/cases/2016/15-649

15-649

2016

Casimir Czyzewski, et al.

Jevic Holding Corp., et al.

<p>Jevic Transportation, Inc. was a trucking company headquartered in New Jersey that in 2006 was purchased by a subsidiary of Sun Capital Partners. In 2008, Jevic filed for bankruptcy under Chapter 11 of the Bankruptcy Code; at that point, it owed about $53 million to its first-priority senior secured creditors and about $20 million to its tax and general unsecured creditors. Two lawsuits ensued in bankruptcy court: one was the truck drivers suing Jevic for violating federal and state Worker Adjustment and Retraining Notification Acts, which required 60 days’ notice to workers before they were laid off, and the other was a fraudulent conveyance action on behalf of the unsecured creditors. In March 2012, the parties to the fraudulent conveyance action negotiated a structured dismissal settlement that disposed of many of the claims, but left out the drivers. The drivers objected to the settlement because it distributed property to creditors of lower priority than the drivers, according to the priorities established in the Bankruptcy Code. The bankruptcy court rejected the objections and approved the proposed settlement. The federal district court and the U.S. Court of Appeals for the Third Circuit affirmed and held that the bankruptcy court had the discretion to approve a settlement scheme outside of the Chapter 11 proceedings that did not comply with the Bankruptcy Code’s distribution scheme.</p>

majority opinion

reversed/remanded

Economic Activity

Sessions v. Morales-Santana

https://api.oyez.org/cases/2016/15-1191

15-1191

2016

Jeffrey B. Session III, Attorney General

Luis Ramon Morales-Santana

<p>Luis Ramon Morales-Santana was born in 1962 in the Dominican Republic to a father who had become an American citizen in 1917 and a mother who was a citizen of the Dominican Republic. At the time, Morales-Santana’s parents were unmarried, and when they married in 1970, Morales-Santana was “legitimated” by his father’s citizenship, and he became a lawful permanent resident in 1975. Under the Immigration and Nationality Act in effect at the time of Morales-Santana’s birth, a child born abroad to an unwed citizen father and a non-citizen mother only had citizenship at birth if the citizen father was physically present in the United States or one of its possessions for a period totalling ten years at some point prior to the child’s birth, and at least five of those years had to be after the age of 14. Because Morales-Santana’s father was only physically present in Puerto Rico until 20 days before his 19th birthday, when he left to work in the Dominican Republic, he did not meet the requirements to transfer derivative citizenship to Morales-Santana upon his birth.</p> <p>In 2000, Morales-Santana was placed in removal proceedings because he had been convicted of various felonies. He applied to have the removal withheld and argued that he had derivative citizenship from his father, but the immigration judge denied the application. Morales-Santana filed a motion to reopen and argued that the denial of derivative citizenship violated the Equal Protection Clause of the Fifth Amendment. Although his father did not satisfy the requirements for unwed citizen fathers to transfer derivative citizenship, he did meet the less stringent requirements for unwed citizen mothers (which required physical presence in the United States or one of its possessions for at least a year at some point prior to the child’s birth), and the gender-based difference was a violation of Equal Protection. The Bureau of Immigration Appeals denied the motion to reopen, but the U.S. Court of Appeals for the Second Circuit reversed and held that the gender-based difference in the physical presence requirement violated the Equal Protection Clause of the Fifth Amendment.</p>

majority opinion

reversed in-part/remanded

Civil Rights