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Ybarra v. Illinois

https://api.oyez.org/cases/1979/78-5937

78-5937

1979

Ventura E. Ybarra

State of Illinois

<p>On March 1, 1976, an Illinois Circuit Court judge authorized a warrant to search the premises of the Aurora Tap Tavern and the person of the bartender Greg for heroin and other drug paraphernalia, based on information the Illinois Bureau of Investigation obtained from an informant. When officers arrived to conduct the search, they also conducted a cursory pat down for weapons on all of the patrons in the bar, pursuant to an Illinois state statute that allows officers to search persons on the premises during the execution of a valid search warrant. During the pat down, an officer found and retrieved a cigarette pouch from the pocket of one of the patrons, Ventura Ybarra, that contained tin foil packets of a substance later confirmed to be heroin.</p> <p>Ybarra was subsequently indicted for possession of a controlled substance. He filed a pretrial motion to suppress the evidence of the contraband that had been seized from his person during the search at the bar. The trial court denied the motion. Ybarra was found guilty. On appeal, the Illinois Court of Appeals upheld the constitutionality of the statute as it applied to the facts of this case because it was obvious that there was a connection between Ybarra and the premises being searched. The Illinois Supreme Court denied Ybarra’s petition for appeal.</p>

majority opinion

reversed/remanded

Criminal Procedure

Supreme Court of Virginia v. Consumers Union of the United States, Inc.

https://api.oyez.org/cases/1979/79-198

79-198

1979

Supreme Court of Virginia, et al.

Consumers Union of the United States, Inc., et al.

<p>The Code of Virginia authorizes the Supreme Court of Virginia to regulate and discipline attorneys. Under this authority, the Virginia court promulgated the Virginia Code of Professional Responsibility (Bar Code), and the content makes it clear that the Virginia court holds all legislative and regulatory power over the legal profession in the state. The court also adjudicates alleged violations of the Bar Code.</p> <p>In 1974, Consumers Union of the United States sought to prepare a legal directory designed to assist consumers in making informed decisions about legal representation. Consumers Union attempted to canvass all of the attorneys of Arlington County, Virginia, for the information for their directory. Many attorneys refused to provide the requested information for fear of violating the Bar Code’s prohibition against attorney advertising and providing the type of information the Consumers Union sought to publish.</p> <p>On February 27, 1975, Consumers Union and the Virginia Citizens Consumer Council sued the Virginia Supreme Court, the Virginia State Bar, the American Bar Association, and other individuals. The plaintiffs alleged violations of their First and Fourteenth Amendment rights to gather, publish, and receive factual information concerning attorneys practicing in Arlington County. The plaintiffs sought a declaration and an injunction against the enforcement of the relevant section of the Bar Code.</p> <p>The district court held that the section of the Bar Code unconstitutionally restricted access to information concerning the attorneys’ initial consultation fees, but did not enjoin the enforcement of the code as it relates to advertising. Consumers Union appealed to the U.S. Supreme Court, which held that the prohibition of attorney advertising violated the First and Fourteenth Amendments. The Court vacated the judgment and remanded the case. On remand, the district court held that the section of the Bar Code was unconstitutional in its entirety and enjoined its enforcement. Consumers Union moved for the awarding of attorneys fees, which the Virginia Court objected to on the grounds that it had judicial immunity. The district court awarded attorneys fees against the Supreme Court of Virginia.</p>

majority opinion

vacated/remanded

Civil Rights

Rummel v. Estelle

https://api.oyez.org/cases/1979/78-6386

78-6386

1979

Rummel

Estelle

<p>After being convicted of three felonies over a period of fifteen years, William James Rummel was given a life prison sentence as mandated by a Texas recidivist statute. Rummel's offenses involved approximately $230, and all of the offenses were nonviolent. Lower courts rejected Rummel's challenge to the sentence.</p>

majority opinion

affirmed

Criminal Procedure

Godfrey v. Georgia

https://api.oyez.org/cases/1979/78-6899

78-6899

1979

Robert Franklin Godfrey

Georgia

<p>In September 1977, Robert Franklin Godfrey and his wife had a heated argument. After Godfrey consumed a number of beers, threatened his wife with a knife, and tore her clothes, she threatened to leave him and then left to stay with relatives. Within a few days, she had secured a warrant against Godfrey for aggravated assault and filed for divorce. On September 20, they argued again, and Godfrey’s wife told him that reconciliation was impossible. Godfrey went to his mother-in-law’s trailer with his shotgun. He shot his wife through the window, struck his daughter with the butt of the gun, and shot his mother-in-law. Godfrey then called the police, explained what had happened, and asked them to come and pick him up.</p> <p>Godfrey was indicted on two counts of murder, and one count of aggravated assault. He pled not guilty, and argued the defense of temporary insanity. Godfrey was found guilty, and at the sentencing phase of the trial, the same jury sentenced him to the death penalty on both counts of murder. Georgia law states that a person my be convicted of murder and sentenced to the death penalty if it was beyond a reasonable doubt that the offense committed was “outrageously or wantonly vile, horrible, or inhuman in that it involved torture, depravity of the mind, or an aggressive battery to the victim.” The Georgia Supreme Court affirmed.</p>

plurality opinion

reversed/remanded

Criminal Procedure

Industrial Union Department, AFL-CIO v. American Petroleum Institute

https://api.oyez.org/cases/1979/78-911

78-911

1979

Industrial Union Department, AFL-CIO

American Petroleum Institute

<p>Acting under authority of the Occupational Safety and Health Act of 1970, the Secretary of Labor, after having demonstrated a link between exposure to benzene and leukemia, set a standard reducing the airborne concentrations of benzene to which workers could be exposed. The standard reduced the allowable amount from 10 parts per million (ppm) to one ppm. This case was decided together with Marshall v. American Petroleum Institute.</p>

plurality opinion

affirmed

Unions

Trammel v. United States

https://api.oyez.org/cases/1979/78-5705

78-5705

1979

Otis Trammel, Jr.

United States

<p>Otis Trammel, Jr. was indicted on federal drug charges. Before his trial, he advised the court that the Government would call his wife as a witness against him. The indictment named Mrs. Trammel as an unindicted co-conspirator and the Government granted her immunity in exchange for her testimony. Otis moved to assert a privilege against adverse spousal testimony to prevent her from testifying against him. The district court denied the motion, and allowed Mrs. Trammel to testify to any act she observed during the marriage and any communication made in the presence of a third party. Only confidential communications between Mr. and Mrs. Trammel remained privileged and inadmissible. Otis was tried and convicted. On appeal, Otis argued that the district court’s ruling violated <em>Hawkins v. United States</em> where the U.S. Supreme Court held that one spouse may not testify against the other unless both consent. The U.S. Court of Appeals for the 10th Circuit affirmed, holding that the <em>Hawkins</em> did not prevent voluntary testimony of a spouse who appears as an unindicted co-conspirator under grant of immunity.</p>

majority opinion

affirmed

Judicial Power

New York v. Belton

https://api.oyez.org/cases/1980/80-328

80-328

1980

New York

Roger Belton

<p>A New York State police officer stopped a car speeding on the New York State Thruway. Roger Belton was a passenger in that car. When the officer spoke with the driver he smelled marijuana and saw an envelope he believed contained marijuana. The officer also found that none of the car’s occupants owned the car or were related to the owner of the car. After asking the four occupants of the car to get out, the officer searched the car and found a leather jacket belonging to Belton with cocaine zipped inside one of the pockets.</p> <p>At trial for criminal possession of a controlled substance, Belton argued that the officer seized the cocaine in violation of the Fourth and Fourteenth Amendments. The trial court denied his motion to suppress that evidence. The Appellate Division of the New York Supreme Court held that the search was constitutional, reasoning that after the officer validly arrested Belton, he could reasonably search the immediate area for more contraband. The Court of Appeals of New York reversed, holding that because Belton had no way of gaining access to the cocaine at the time the officer searched the car, the officer needed a warrant for the search he conducted.</p>

majority opinion

reversed

Criminal Procedure

Flynt v. Ohio

https://api.oyez.org/cases/1980/80-420

80-420

1980

Larry C. Flynt

State of Ohio

<p>In July 1976, Ohio charged petitioners, officers of Hustler Magazine, with disseminating obscene materials for their role in publishing an issue of Hustler that contained a political cartoon that Ohio deemed obscene. The trial court dismissed the charge and held that Ohio violated the petitioners’ rights under the Equal Protection Clause by engaging in discriminatory prosecution. Ohio appealed to the Court of Appeals of Ohio for the Eighth District, which reversed the trial court’s decision and reinstated the charges. Petitioners appealed to the Supreme Court of Ohio and argued that Ohio’s decision to prosecute Hustler, instead of other magazines that routinely published similar content, was discriminatory. The Supreme Court of Ohio ruled that petitioners did not establish the elements for a prima facie case for unconstitutional discriminatory prosecution. To do so, petitioners had to show that they were singled out for prosecution while there were other magazines similarly situated that were not prosecuted, and that the government’s decision to prosecute them was made in bad faith, based upon race, religion, or the desire to prevent their exercise of First Amendment rights. The Supreme Court of Ohio determined the petitioners had not met this burden and remanded the case to the lower courts so that the petitioners could present further evidence to meet this burden.</p>

per curiam

First Amendment

Democratic Party of United States v. Wisconsin ex rel. La Follette

https://api.oyez.org/cases/1980/79-1631

79-1631

1980

Democratic Party of the United States

Wisconsin ex rel. La Follette

<p>The Democratic Party of the United States (National Party) required that delegates sent to its National Convention were chosen exclusively by voters affiliated with the party, but the state of Wisconsin allowed non-Democrats to participate in state primaries. In the primary, voters expressed their choice among Presidential candidates for the Democratic Party's nomination. Although the Wisconsin Democratic Party (State Party) selected delegates at a caucus occurring after the primary, Wisconsin law required these delegates to allot their votes at the National Convention in accord with the amount of support each candidate received in the primary. The National Party prohibited the State Party delegates from participating in the 1980 National Convention because of non-Democrat influence in the state primary. The Wisconsin Supreme Court ruled that the National Party must admit the delegates since Wisconsin had a "compelling interest" to maintain the "open" feature of its primary system.</p>

majority opinion

reversed

First Amendment

Chandler v. Florida

https://api.oyez.org/cases/1980/79-1260

79-1260

1980

Chandler

Florida

<p>Two Miami Beach police officers were charged with burglarizing a local restaurant. Their trial gained much media attention. Local television stations televised a small portion of the trial, thanks to a recent Florida Supreme Court decision which permitted (with certain restrictions) electronic media to record judicial proceedings. Officers Chandler and Granger objected to the coverage and were found guilty as charged.</p>

majority opinion

affirmed

Criminal Procedure

American Textile Mfrs. Institute, Inc. v. Donovan

https://api.oyez.org/cases/1980/79-1429

79-1429

1980

American Textile Manufacturers Institute, Inc., et al.

Raymond J. Donovan, Secretary of Labor

<p>In 1970, Congress enacted the Occupational Safety and Health Act (the Act), which authorized the Secretary of Labor to enact mandatory nationwide standards to govern workplace safety. On December 26, 1978, the Occupational Safety and Health Administration (OSHA) published a proposal to change the federal standard regarding cotton dust exposure. There was a 90-day comment period followed by a series of hearings over the course of two weeks. After the hearings, the Secretary of Labor, Raymond J. Donovan, determined that exposure to cotton dust represented a significant health risk that warranted the adoption of the new standard. The new standard required a mix of engineering controls, such as the installation of pieces of equipment, along with work practice controls, and required these changes within four years. The petitioners, representing the interests of the cotton industry, challenged the validity of the standard in the U.S. Court of Appeals for the District of Columbia. They argued that the Act required OSHA to demonstrate a reasonable relationship between the costs and benefits associated with the standard. The Court of Appeals held that OSHA had done everything required by the Act.</p>

majority opinion

reversed in-part/remanded

Unions

Steagald v. United States

https://api.oyez.org/cases/1980/79-6777

79-6777

1980

Gary Keith Steagald

United States

<p>On January 14, 1978, a confidential informant contacted the Detroit police with information that wanted-drug dealer Ricky Lyons was at a residence in Atlanta, Georgia. Atlanta police responded to the residence and, without a warrant, searched the home of petitioner Gary Steagald. Although the police did not find Lyons, they did find what appeared to be cocaine. At this point, the police obtained a warrant and completed their search, in which they found 43 pounds of cocaine. <p>Steagald was arrested and brought to trial. He moved to suppress the evidence that police found prior to the warrants, and the district court denied the motion. The United States Court of Appeals for the Fifth Circuit affirmed.</p>

majority opinion

reversed/remanded

Criminal Procedure

Texas Department of Community Affairs v. Burdine

https://api.oyez.org/cases/1980/79-1764

79-1764

1980

Texas Department of Community Affairs

Joyce Ann Burdine

<p>The Texas Department of Community Affairs (TDCA) hired Joyce Burdine as an accounting clerk in the Public Service Careers Division (PSC). Burdine possessed several years’ experience, was promoted and was often assigned additional duties. Burdine applied for the supervisor’s position of Project Director, however, she never received a response and the position remained vacant for six months. When the PSC learned it would lose funding unless it appointed a permanent Project Director and completely reorganized the PSC staff, a male employee from another division was hired as Project Director. Three employees, including Burdine, were let go, leaving a male as the only professional employee in the division. The TDCA rehired Burdine and assigned her to another division where she received the same salary as the Project Director at PSC. Burdine sued the TDCA and alleged that the failure to promote her and the decision to terminate her were gender discrimination that violated Title VII of the Civil Rights Act of 1964. The district held that neither decision was based on gender discrimination. The U.S. Court of Appeals for the Fifth Circuit reversed in part because the TDCA bore the burden of proof and did not prove it was more likely than not that the male employee hired or promoted was better qualified than Burdine. </p>

majority opinion

vacated/remanded

Civil Rights

Thomas v. Review Board of the Indiana Employment Security Division

https://api.oyez.org/cases/1980/79-952

79-952

1980

Eddie C. Thomas

Review Board of the Indiana Employment Security Division et al.

<p>Eddie C. Thomas, a Jehovah's Witness and an employee of Blaw-Knox Foundry &amp; Machinery Co., asked his company to lay him off when it transferred all of its operations to weapons manufacturing. He stated that his religious faith prohibited him from producing arms. His employer refused, so he quit instead. He applied for unemployment compensation benefits under the Indiana Employment Security Act, which the Review Board of the Indiana Employment Security Division denied. The board agreed that he quit because of his religious convictions, but claimed that this was not a "good cause [arising] in connection with [his] work" that would qualify him for benefits. The Indiana Court of Appeals reversed the decision on the ground that it burdened Thomas' First Amendment right to the free exercise of his religion. The Supreme Court of Indiana reinstated the board's initial decision, calling Thomas' decision to quit a "personal philosophical choice" that only indirectly burdened his free exercise right.</p>

majority opinion

reversed

First Amendment

United States v. Morrison

https://api.oyez.org/cases/1980/79-395

79-395

1980

United States

Hazel Morrison

<p>Hazel Morrison was indicted for distributing heroin and obtained private counsel for her defense. Without her counsel's knowledge two agents of the Drug Enforcement Agency (DEA) conversed with her regarding a related investigation. During this conversation the agents advised that she have a public defender represent her instead of her private counsel. They also told her that the severity of her punishment would depend on how well she cooperated with them. Morrison notified her counselor immediately and did not speak to the agents about the investigation. She unsuccessfully petitioned the District Court to dismiss her indictment on the ground that the agents had violated her Sixth Amendment right to counsel. Morrison then entered a guilty plea to one count of the indictment. On appeal the Court of Appeals for the Third Circuit found that Morrison's Sixth Amendment rights had been violated and ruled to drop all charges against her.</p>

majority opinion

reversed/remanded

Criminal Procedure

Minnesota v. Clover Leaf Creamery Company

https://api.oyez.org/cases/1980/79-1171

79-1171

1980

Minnesota

Clover Leaf Creamery Company

<p>Minnesota enacted a statute prohibiting the sale of milk and milk products in non-refillable, non-returnable plastic containers. Clover Leaf Creamery sued to overturn the law. A Minnesota District Court found that the statute did not fulfill the legislature's purpose. The Minnesota Supreme Court affirmed the decision.</p>

majority opinion

reversed

Economic Activity

Lassiter v. Department of Social Services

https://api.oyez.org/cases/1980/79-6423

79-6423

1980

Abby Gail Lassiter

Department of Social Services of Durham County, North Carolina

<p>On September 26, 1974, William L. Lassiter was born out of wedlock. On May 23, 1975, the state determined that William L. Lassiter was a neglected child in need of protection, and placed him in the custody of the Durham County Department of Social Services. The state then placed William in foster care.</p> <p>Abby Gail Lassiter, William’s mother, was convicted of second-degree murder in July of 1976, and began serving her twenty-five to forty year sentence at the North Carolina Correctional Center for Women. In 1978, the Department petitioned the court to terminate Abby’s parental rights. It alleged that Abby had not contacted William since December 1975, and that she willfully left William in foster care. On August 31, 1978, the state brought Abby from prison to the hearing, which opened with a discussion of whether Abby should have more time to find legal assistance. The court concluded that she had ample opportunity to obtain counsel; Abby did not claim to be indigent, and the court did not appoint counsel for her.</p> <p>A social worker from the Department testified about Abby’s lack of contact with William, Abby’s mother’s unfitness to care for William, and William’s condition. Abby cross-examined the social worker, but many of her questions were disallowed because they were arguments. She also testified on her own behalf and later cross-examined her mother, who denied saying she could not care for William, contradicting the Department’s allegation. The court held that Abby willfully failed to maintain concern or responsibility for William’s welfare, and terminated Abby’s status as William’s parent. On appeal, the North Carolina Court of Appeals determined that North Carolina was not constitutionally mandated to provide Abby counsel during the hearing. The Supreme Court of North Carolina denied her application for discretionary review.</p>

majority opinion

affirmed

Criminal Procedure

United States v. Will

https://api.oyez.org/cases/1980/79-983

79-983

1980

United States

Will

<p>Congress enacted legislation in the late 1960s and early 1970s to adjust the compensation of federal employees, including judges, which provided automatic annual pay raises. However, from 1976 to 1979 Congress intervened and blocked cost-of-living increases which were scheduled to occur.</p>

majority opinion

reversed in-part/remanded

Miscellaneous

Rostker v. Goldberg

https://api.oyez.org/cases/1980/80-251

80-251

1980

Rostker

Goldberg

<p>After the Soviet Union invaded Afghanistan in early 1980, President Jimmy Carter reactivated the draft registration process. Congress agreed with Carter's decision, but did not enact his recommendation that the Military Selective Service Act (MSSA) be amended to include the registration of females. A number of men challenged the constitutionality of the MSSA, and the challenge was sustained by a district court.</p>

majority opinion

reversed

Civil Rights

Stone v. Graham

https://api.oyez.org/cases/1980/80-321

80-321

1980

Stone

Graham

<p>Sydell Stone and a number of other parents challenged a Kentucky state law that required the posting of a copy of the Ten Commandments in each public school classroom. They filed a claim against James Graham, the superintendent of public schools in Kentucky.</p>

per curiam

reversed

First Amendment

Michigan v. Summers

https://api.oyez.org/cases/1980/79-1794

79-1794

1980

Michigan

Summers

<p>The Fourth Amendment prohibits the unreasonable seizure of a person by the government, and the Fourteenth Amendment applies that prohibition to the states. On October 10, 1974, George Summers was leaving his house in Detroit, Michigan, as local police officers arrived with a warrant to search the property for narcotics. The officers requested that Summers help them gain entry to the house, and they detained him while they searched the premises. After finding two packages of heroin in the basement, the officers arrested Summers and searched his person. In his coat pocket, they found an envelope containing heroin, and it was this discovery of heroin⎯not the heroin found in the basement⎯that formed the basis of charges against Summers. At trial, Summers argued that the search of his person was illegal because the officers had no authority to detain him during their search of the house. The trial judge agreed and granted Summers’ motion to suppress the heroin evidence. On appeal, the State argued that Summers’ detention was reasonable, given his close proximity to the house when the officers arrived to perform the search. The State also contended that the concealable nature of the narcotics described in the warrant implicitly authorized the search of people found on the property. The Michigan Court of Appeals affirmed the trial court’s order. The State appealed to the Supreme Court of Michigan, which affirmed the ruling of the lower court.</p>

majority opinion

reversed

Criminal Procedure

Michael M. v. Superior Court of Sonoma County

https://api.oyez.org/cases/1980/79-1344

79-1344

1980

Michael M.

Superior Court of Sonoma County

<p>Michael M., a 17 and 1/2 year-old male, was found guilty of violating California's "statutory rape" law. The law defined unlawful sexual intercourse as "an act of sexual intercourse accomplished with a female not the wife of the perpetrator, where the female is under the age of 18 years." The statute thus made men alone criminally liable for such conduct. Michael M. challenged the constitutionality of the law.</p>

plurality opinion

affirmed

Civil Rights

Haig v. Agee

https://api.oyez.org/cases/1980/80-83

80-83

1980

Haig

Agee

<p>In 1974, Philip Agee, a former employee of the Central Intelligence Agency, announced a campaign "to fight the United States CIA wherever it is operating." Over the next several years, Agee successfully exposed a number of CIA agents and sources working in other countries. When Secretary of State Alexander Haig revoked Agee's passport, Agee filed suit claiming that Haig did not have congressional authorization to do so. Agee also claimed that the action violated his right to travel, his First Amendment right to criticize the government, and his Fifth Amendment Due Process rights.</p>

majority opinion

reversed/remanded

First Amendment

Diamond v. Diehr

https://api.oyez.org/cases/1980/79-1112

79-1112

1980

Diamond

Diehr

<p>Engineers James Diehr and Theodore Lutton invented an improved press that cured rubber by controlled heating. The press contained a temperature probe which measured the temperature rise of the rubber from within the press. By repeatedly calculating the rubber cure time from this temperature measurement and comparing this computed cure time to the actual elapsed time, the computer was able to determine precisely when to open the press and eject the cured rubber, which then emerged perfectly cured. The patent examiner, viewing all computer programs as unpatentable because of the earlier Supreme Court decision Gottschalk v. Benson (1972), rejected their patent application because, he argued, the inventors had simply combined an unpatentable program with a conventional rubber curing press. An appellate court reversed the Examiner and ordered a patent to issue. The Commissioner of Patents then petitioned successfully to have the Supreme Court review this decision. Before the Supreme Court, the inventors' attorney argued that the steps of continuously measuring temperature and repeatedly recalculating the rubber cure time and comparing it to the elapsed time were new steps that were worthy of patent protection.</p>

majority opinion

affirmed

Economic Activity

United States Railroad Retirement Board v. Fritz

https://api.oyez.org/cases/1980/79-870

79-870

1980

United States Railroad Retirement Board

Gerhard H. Fritz

<p>In 1974 Congress passed the Railroad Retirement Act, which restructured the retirement system previously established in 1937. Under the old system, employees who were eligible for both railroad benefits and social security benefits received both, along with an additional “windfall” benefit. Since this system threatened to bankrupt the railroad retirement program, the goal of the new Act was to eliminate some of these benefits. The new Act divided employees into different classes based on their employment history as of January 1, 1975. Employees who had worked for the railroad fewer than 10 years would not receive any windfall benefit. Employees who were already retired and receiving the full benefits would continue to do so. Employees who qualified for the full benefits but had not yet retired would receive the full benefits only if they had a current connection to the railroad industry or had served for 25 years or more. Employees who did not meet these requirements received a lesser windfall benefit. </p> <p>The appellee Gerhard H. Fritz was part of a plaintiff class of former railroad employees who were eligible for the windfall benefits under the old system, but who did not have a current connection to the railroad and had worked fewer than 25 years. Alleging that the Act created an irrational distinction between employees that violated the Due Process Clause, they filed a class action suit in district court. The district court held that such a distinction was not “rationally related” to the goal of ensuring the solvency of the retirement system.</p>

majority opinion

reversed

Civil Rights

Metromedia, Inc. v. City of San Diego

https://api.oyez.org/cases/1980/80-195

80-195

1980

Metromedia, Inc. et al.

City of San Diego et al.

<p>The city of San Diego banned most outdoor advertising display signs in order to improve the city's appearance and prevent dangerous distractions to motorists. Only "onsite" billboards with a message relating to the property they stood on would be permitted. Upon petition by a coalition of businesses owning advertising signs, a trial court ruled that the ban was an unconstitutional exercise of the city's police powers and hindered First Amendment rights of the businesses. The California Court of Appeals affirmed that the city had exceeded its police powers, but the California Supreme Court reversed this judgment.</p>

plurality opinion

reversed/remanded

First Amendment

Robbins v. California

https://api.oyez.org/cases/1980/80-148

80-148

1980

Jeffrey Richard Robbins

California

<p>During the early morning hours of January 5, 1975, California Highway Patrol officers pulled over a the driver of a station wagon, Jeffrey Richard Robbins, for driving too slowly at speeds far below the minimum speed limit and drifting across the center lane. Upon smelling marijuana smoke as they approached the car, officers searched the passenger compartment, where they found marijuana. The officers then opened a recessed luggage compartment in the trunk and unwrapped two tightly sealed packages that each contained a pound of marijuana. Robbins was charged with several drug offenses. At trial, he argued that the evidence of the drugs was the product of an illegal search and filed a motion to suppress the evidence. The judge denied the motion, and a jury convicted Robbins. Robbins appealed, but the California Court of Appeal affirmed the judgment. The Supreme Court granted certiorari and remanded the case for the appellate court to consider in light of the Supreme Court’s ruling in &lt;i&gt;Arkansas v. Sanders&lt;/i&gt;, which established that officers could not search closed luggage found during a lawful automobile search. The California Court of Appeal affirmed Robbins conviction a second time on that grounds that Robbins did not have a reasonable expectation of privacy because the package’s contents could be inferred given the shape, size, and wrapping of the exterior.</p>

plurality opinion

reversed

Criminal Procedure

Heffron v. International Soc. for Krishna Consciousness, Inc.

https://api.oyez.org/cases/1980/80-795

80-795

1980

Heffron

International Soc. for Krishna Consciousness, Inc.

<p>A Minnesota law allowed the Minnesota Agricultural Society to devise rules to regulate the annual state fair in St. Paul. Minnesota State Fair Rule 6.05 required organizations wishing to sell or distribute goods and written material to do so from an assigned location on the fairgrounds. In other words, walking vendors and solicitors were not allowed. The International Society for Krishna Consciousness challenged the rule, arguing that it restricted the ability of its followers to freely exercise their religious beliefs at the state fair.</p>

majority opinion

reversed/remanded

First Amendment

Dames & Moore v. Regan

https://api.oyez.org/cases/1980/80-2078

80-2078

1980

Dames & Moore

Regan

<p>In reaction to the seizure of the U.S. embassy and American nationals in Iran, President Jimmy Carter invoked the International Emergency Economic Powers Act (IEEPA) and froze Iranian assets in the United States. When the hostages were released in 1981, Treasury Secretary Donald Regan affirmed the agreements made the Carter administration that terminated all legal proceedings against the Iranian government and created an independent Claims Tribunal. Dames &amp; Moore attempted to recover over $3 million owed to it by the Iranian government and claimed the executive orders were beyond the scope of presidential power.</p>

majority opinion

affirmed

Due Process

Kassel v. Consolidated Freightways Corporation of Delaware

https://api.oyez.org/cases/1980/79-1320

79-1320

1980

Kassel

Consolidated Freightways Corporation of Delaware

<p>An Iowa law restricted the length of vehicles traveling on its highways. Iowa justified the law as a reasonable use of its police power to assure safety on the state's roads.</p>

plurality opinion

affirmed

Economic Activity

CBS, Inc. v. Federal Communications Commission

https://api.oyez.org/cases/1980/80-207

80-207

1980

CBS, Inc.

Federal Communications Commission

<p>On October 11, 1979, the Carter-Mondale Presidential Committee (CMPC) requested time for a thirty-minute program from each of the three major television networks on behalf of President Jimmy Carter. Columbia Broadcasting System, Inc. (CBS) refused to make the requested time available, emphasizing in part the potential disruption of regular programming. CBS offered to sell the CMPC two five-minute segments instead. The American Broadcasting Companies (ABC) and the National Broadcasting Company (NBC) each replied that it had not yet begun to sell political time for the 1980 presidential campaign. On October 29, 1979, the CMPC filed a complaint with the Federal Communications Commission (FCC), charging that the networks violated their obligations under the Federal Communications Act.</p> <p>The Federal Communications Act of 1934, as modified by the Federal Election Campaign Act of 1971, authorized the FCC to revoke broadcasting station licenses for willful or repeated failure to allow reasonable access or failure to permit the purchase of reasonable amounts of time for the use of a broadcasting station by a legally qualified candidate for federal elective office. On November 26, 1979, the FCC ruled in a four-to-three vote that the networks violated the act, rejecting the networks’ arguments that Congress did not intend the act to create a new right of access to the broadcast media and that the FCC improperly substituted its judgment for the networks’ in evaluating the CMPC’s request for time. </p> <p>Following the seizure of American embassy personnel in Iran in November 1979, the CMPC decided to postpone the broadcast of its thirty-minute program; it successfully purchased five minutes of time from CBS, and later purchased thirty minutes of time for the full program from ABC and NBC. Throughout these negotiations, however, all parties maintained their rights relating to the appeal to the FCC’s decision. The United States Court of Appeals, D.C. Circuit, affirmed the FCC’s decision. It held that the act created a new, affirmative right of access to broadcast media for candidates for federal office and that the FCC had the authority to evaluate whether a campaign has begun for purposes of the statute.</p>

majority opinion

affirmed

Economic Activity

Watkins v. Sowders

https://api.oyez.org/cases/1980/79-5949

79-5949

1980

John Gregory Watkins

Dewey Sowders

<p>John Watkins was charged with attempting armed robbery of a liquor store in Louisville, Kentucky. He was arrested based on the identification of two witnesses. One of those witnesses identified Watkins as the gunman two days later in a lineup, and later that same day, the police took Watkins to the other witness’s hospital bed where he identified Watkins as the shooter. At the trial, both witnesses identified Watkins as the shooter. Watkins, along with two other witnesses, testified he was at a pool hall at the time of the shooting. Watkins was convicted, and on appeal he argued that the trial court had a constitutional obligation to conduct a hearing outside the presence of the jury to determine whether the identification evidence was admissible, but the Supreme Court of Kentucky rejected the argument. Watkins then sought a writ of habeas corpus. The district court denied the writ and held that a failure to hold a pretrial hearing does not require the reversal of a conviction. The U.S. Court of Appeals for the Sixth Circuit affirmed.</p>

majority opinion

affirmed

Criminal Procedure

Piper Aircraft Company v. Reyno

https://api.oyez.org/cases/1981/80-848

80-848

1981

Piper Aircraft Company

Reyno

<p>(This summary was prepared by Tom Feledy.)</p> <p>A British company, flying an airplane manufactured by Piper, a Pennsylvania company, equipped with propellers made by Hartzell, an Ohio company, conducted a charter flight in Scotland for five Scottish citizens. When the plane crashed, killing all on board, the next of kin, also Scottish, had a Los Angeles-based lawyer sue Piper and Hartzell for wrongful death. The suit was filed in a California state court, then removed to Federal District Court in California, and finally transferred to Federal District Court in Pennsylvania. There it was dismissed for <em>forum non conveniens</em> under the determination that the case should be tried in Scotland: the crash had occurred, the crash investigation had been conducted there by British authorities, and the pilot's estate, the plane's owners, and the charter company were all located there. However, respondents successfully appealed, claiming that substantive law in Scotland would be unfavorable to their case. Scotland, unlike Pennsylvania, had no strict liability law, which, along with negligence, respondents were relying upon in order to prevail.</p>

majority opinion

reversed

Judicial Power

Mississippi University for Women v. Hogan

https://api.oyez.org/cases/1981/81-406

81-406

1981

Mississippi University for Women

Hogan

<p>Joe Hogan, a registered nurse and qualified applicant, was denied admission to the Mississippi University for Women School of Nursing's baccalaureate program on the basis of sex. Created by a state statute in 1884, MUW was the oldest state-supported all-female college in the United States.</p>

majority opinion

affirmed

Civil Rights

Washington v. Chrisman

https://api.oyez.org/cases/1981/81-1349

81-1349

1981

Washington

Chrisman

<p>In 1978, a Washington police officer stopped a student at the Washington State University after observing the student was carrying a half-gallon bottle of gin. The officer asked for identification. The student, accompanied by the officer, then went into his dormitory to retrieve proof of age. After the student had entered his room, the officer noticed that the student's roommate, Chrisman, had marijuana seeds and a pipe on his desk. Chrisman was subsequently charged with the possession of marijuana and LSD.</p>

majority opinion

reversed/remanded

Weinberger v. Romero-Barcelo

https://api.oyez.org/cases/1981/80-1990

80-1990

1981

Caspar W. Weinberger, Secretary of Defense

Carlos Romero-Barcelo, Radamees Tirado Guevara, Environmental Quality Board

<p>The island of Vieques lay six miles off the southeastern coast of Puerto Rico. Vieques’ population of 8,000 mostly lived in two coastal towns and in a rural area outside of those two towns. Of a total area of approximately 33,000 acres, the United States Navy owned 25,231.72 acres, slightly more than 76% of the island.</p> <p>The Navy’s installations on the eastern part of Vieques were part of a large military complex known as the Atlantic Fleet Weapons Training Facility, headquartered at Roosevelt Roads Naval Station. This consisted of four firing ranges; the outer range was a large area of ocean thirty-five miles to the north and twenty miles to the south of Vieques. Two separate inland areas were used for artillery training, strafing, air-to-ground bombing, and simulating close air support; no targets existed in the area between the eastern border of these areas and Punta Este, the easternmost point of Vieques. During air-to-ground training, however, pilots sometimes accidentally discharged ordnance into the navigable waters around Viques.</p> <p>Carlos Romero-Barceleo was the governor of the Commonwealth of Puerto Rico. Along with Radamees Tirado Guevara, the mayor of Vieques, and Puerto Rico’s Environmental Quality Board, Romero-Barceleo sought to enjoin the United States Navy from using any part of its lands in Vieques, or in its surrounding waters, to carry out naval training operations. Plaintiffs alleged harm to all residents of Vieques and violations of numerous environmental laws, including the Federal Water Pollution Control Act (FWPCA). Under the FWPCA, the addition of any pollutant from any point source into the navigable waters of the United States required a National Pollutant Discharge Elimination System (NPDES) permit from the Environmental Protection Agency.</p> <p>The district court acknowledged that the release of ordnance into navigable waters was a discharge of pollutants, but it refused to enjoin Navy operations, instead ordering the Navy to apply for an NPDES permit. The United States Court of Appeals, First Circuit, reversed. It ordered the Navy to cease operations until it obtained an NPDES permit. It held that the Navy has an absolute statutory obligation to stop any discharges of pollutants until it obtains a permit despite the importance of its operations to the public good.</p>

majority opinion

reversed/remanded

Economic Activity

Edgar v. MITE Corporation

https://api.oyez.org/cases/1981/80-1188

80-1188

1981

Edgar

MITE Corporation

<p>The MITE Corp, organized under Delaware laws with its principal office in Connecticut, initiated a tender offer for all outstanding shares of Chicago Rivet &amp; Machine Co., an Illinois corporation. The Illinois Business Take-Over Act requires a tender offeror to notify the Secretary of State and the target company of its intent to make a tender offer and the terms of the offer 20 days before the offer becomes effective. During that time, the target company, but not the offeror, is free to disseminate information about the offer to the target company's shareholders. In addition, the Secretary of State could call a hearing, and the offer could not proceed until the hearing was completed. Finally, the Secretary of State could deny registration of a takeover offer he or she found inequitable. MITE Corp. sought and won a declaratory judgment holding that the Illinois Act was pre-empted by the Williams Act, 15 U.S.C. Sections 78m(d)-(e) and 78n(d)-(f), and that it violated the Commerce Clause.</p>

majority opinion

affirmed

Economic Activity

Lugar v. Edmondson Oil Company, Inc.

https://api.oyez.org/cases/1981/80-1730

80-1730

1981

Giles M. Lugar

Edmondson Oil Company, Inc.

<p>Giles Lugar leased a truckstop from Edmondson Oil Co. and fell behind on his rent payments. Edmondson issued a suit against him in a Virginia state court for failing to repay his debt. Before the court reached a decision, it issued a "writ of attachment" against Lugar. This disabled him from selling any property he owned while the case was open, since Edmondson wanted the property as collateral in case he could not repay his debt. A state trial judge cancelled the "writ of attachment" one month later after finding no statutory justification for its issuance. Lugar claimed that Edmondson worked with the government to deprive him of his property without the due process of law guaranteed by the Fourteenth Amendment. He said this caused him financial loss and sought to recover damages from Edmondson in a District Court under 42 U.S.C. Section 1983. This code provides rewards to those who have had their rights violated because of "state action." The District Court rejected Lugar's claim because it deemed that no "state action" had occurred. On review, the United States Court of Appeals for the Fourth Circuit rejected using solely "state action" to validate Section 1983 suits. It claimed that certain instances where private parties acted "under the color of state law" also validated Section 1983 suits. However the Fourth Circuit found that none of these actions occurred in Lugar's case and rejected his suit.</p>

majority opinion

reversed in-part/remanded

Civil Rights

Board of Education, Island Trees Union Free School District No. 26 v. Pico by Pico

https://api.oyez.org/cases/1981/80-2043

80-2043

1981

Board of Education, Island Trees Union Free School District No. 26

Pico by Pico

<p>The Island Trees Union Free School District's Board of Education (the "Board"), acting contrary to the recommendations of a committee of parents and school staff, ordered that certain books be removed from its district's junior high and high school libraries. In support of its actions, the Board said such books were: "anti-American, anti-Christian, anti-Semitic, and just plain filthy." Acting through his friend Francis Pico, and on behalf of several other students, Steven Pico brought suit in federal district court challenging the Board's decision to remove the books. The Board won; the U.S. Court of Appeals for the Second Circuit reversed. The Board petitioned the U.S. Supreme Court, which granted certiorari.</p>

plurality opinion

affirmed

First Amendment

Nixon v. Fitzgerald

https://api.oyez.org/cases/1981/79-1738

79-1738

1981

Nixon

Fitzgerald

<p>In 1968, Fitzgerald, then a civilian analyst with the United States Air Force, testified before a congressional committee about inefficiencies and cost overruns in the production of the C-5A transport plane. Roughly one year later he was fired, an action for which President Nixon took responsibility. Fitzgerald then sued Nixon for damages after the Civil Service Commission concluded that his dismissal was unjust.</p>

majority opinion

reversed/remanded

Economic Activity

Washington v. Seattle School District No. 1

https://api.oyez.org/cases/1981/81-9

81-9

1981

Washington

Seattle School District No. 1

<p>In 1978, a Seattle school district adopted a mandatory busing plan to integrate its schools. No court or administrative body found the district to be engaged in unlawful segregation. A statewide initiative adopted in 1978 mandated a neighborhood school policy. The policy provided for some exceptions including voluntary busing options and mandatory busing if so ordered by state or federal courts. The initiative blocked the implementation of Seattle's mandatory busing plan. School officials challenged the Washington government in federal court.</p>

majority opinion

affirmed

Civil Rights

Eddings v. Oklahoma

https://api.oyez.org/cases/1981/80-5727

80-5727

1981

Monty Lee Eddings

Oklahoma

<p>On April 4, 1977, sixteen-year-old Monty Lee Eddings and several of his friends ran away from home. Before leaving, Eddings took three of his father’s firearms, including a .410 gauge shotgun with a shortened barrel. Before reaching the Turner Turnpike near Tulsa, the group stopped at a Howard Johnson restaurant. As they were leaving, Eddings lost control of the car, briefly sending it over a curb and into a ditch before regaining control. A witness observed this and informed an officer of the Oklahoma Highway Patrol, Patrolman Larry Crabtree, who followed their car and pulled it over. When Crabtree was within about six feet of the car, Eddings stuck the shotgun out of the window and fired it, killing Crabtree, then immediately drove the car away.</p> <p>At trial, the defense presented evidence of circumstances mitigating Eddings’ guilt, including the details of his extensive juvenile record in Missouri. Eddings’ parents divorced when he was five, after which he was shuffled between his mother’s house and his father’s house and also spent some time in a group home. Witnesses testified that Eddings was emotionally disturbed and at a level several years below his age in terms of mental and emotional development. A state psychologist testified that Eddings had a sociopathic or antisocial personality disorder.</p> <p>The state provided evidence of aggravating circumstances. Oklahoma alleged 1) that the murder was especially heinous, atrocious or cruel, 2) that the crime was committed to avoid a lawful arrest, and 3) that there was a probability that the defendant would commit more criminal acts of violence constituting a threat to society. The trial judge found that the state proved all three aggravating circumstances beyond a reasonable doubt. The judge also found that Eddings’ age was a mitigating factor of great weight, but would not consider evidence of Eddings’ “violent background.” The judge then found that the aggravating circumstances proven by the state outweighed the fact of Eddings’ age and sentenced him to death. The Court of Criminal Appeals of Oklahoma affirmed the sentence, also holding that Eddings' death penalty sentence did not constitute cruel and unusual punishment under the Eighth and Fourteenth Amendments.</p>

majority opinion

reversed/remanded

Criminal Procedure

Valley Forge Christian College v. Americans United for Separation of Church and State, Inc.

https://api.oyez.org/cases/1981/80-327

80-327

1981

Valley Forge Christian College

Americans United for Separation of Church and State, Inc.

<p>The Secretary of Defense closed the Valley Forge General Hospital in an effort to reduce the number of military installations in the country. In accordance with a congressional statute regulating the dispersal of surplus government property, part of the hospital's land was given, free-of-charge, to the Valley Forge Christian College.</p>

majority opinion

reversed

Judicial Power

Rogers v. Lodge

https://api.oyez.org/cases/1981/80-2100

80-2100

1981

Rogers

Lodge

<p>Eight black citizens of Burke County, Georgia, challenged the at-large system of elections within the county. Although a substantial number of blacks lived within the county, no minority candidate had ever been elected to the Burke County Board of Commissioners, the chief governing body. To be elected, candidates had to receive a majority of the votes cast in the primary or general election.</p>

majority opinion

affirmed

Civil Rights

Florida Department of State v. Treasure Salvors, Inc.

https://api.oyez.org/cases/1981/80-1348

80-1348

1981

Florida Department of State

Treasure Salvors, Inc.

<p>Immediately after Treasure Salvors, Inc. ("Treasure") located a 17th-century Spanish wreck of its coast, Florida claimed ownership of the remains. Treasure contracted with the Florida Division of Archives ("Archives") to salvage the wreck in exchange for 75% of the recovered artifacts' appraised value. Meanwhile, in the unrelated proceedings of United States v. Florida, the United States won a judgment granting it ownership of the lands, minerals, and other natural resources in the area of the Spanish wreck's discovery. Upon learning of this ruling, Treasure sought a declaration of title to the wreck. Following a second favorable appellate decision, Treasure sought and received a warrant to seize all artifacts from the Archives. Florida challenged the warrant and its issuing district court's jurisdiction, but lost on both counts. On appeal from an unfavorable appellate ruling, the Supreme Court granted Florida certiorari.</p>

plurality opinion

reversed in-part

Judicial Power

Widmar v. Vincent

https://api.oyez.org/cases/1981/80-689

80-689

1981

Gary E. Widmar

Clark Vincent

<p>Cornerstone was an officially recognized student organization on the campus of the University of Missouri - Kansas City. The avowed purpose of Cornerstone was to promote a knowledge and awareness of Jesus Christ on the campus. From 1973 to 1977, Cornerstone obtained permission to use university facilities for its weekly meetings and events.</p> <p>In January 1977, the group sought permission from the university to use two rooms of its Haag Hall Annex for two and a half hours every week. University officials asked for a description of the activities that would be conducted at the proposed meetings. Cornerstone told the university that worship in the form of prayer and biblical teaching would be an important part of the general atmosphere of the meetings. University officials rejected Cornerstone’s application for regular use of the rooms, concluding the meetings would violate several sections of the Collected Rules and Regulations of the University of Missouri. These regulations prohibited the use of university buildings and grounds for religious worship or religious teaching.</p> <p>On December 11, 1979, the trial court granted summary judgment to Gary Widmar, the Dean of Students at the university, and the university’s Board of Curators, rejecting a motion for summary judgment filed by Cornerstone’s members. It concluded that the university’s ban on religious services in its buildings was required by the First Amendment’s establishment clause. It also held that the university did not violate the students’ free exercise rights, and that any violation was outweighed by Missouri’s compelling interest in the separation of church and state. The United States Court of Appeals for the Eighth Circuit reversed. It held that the university’s regulation had the primary effect of inhibiting religion, in violation of the First Amendment’s Establishment Clause. Instead, the Eighth Circuit suggested that a neutral policy toward religious groups would satisfy the university’s First Amendment obligations.</p>

majority opinion

affirmed

First Amendment

Board of Ed. of Hendrick Hudson Central School Dist., Westchester Cty. v. Rowley

https://api.oyez.org/cases/1981/80-1002

80-1002

1981

Board of Education of the Hendrick Hudson Central School District, Westchester County, The Commissioner of Education of the State of New York

Amy Rowley, by her parents Clifford and Nancy Rowley, and Clifford and Nacy Rowley in their own right

<p> Furnace Woods School refused to provide deaf student Amy Rowley with a sign language interpreter. Amy was an excellent lip reading and had minimal residual hearing. School administrators, along with a sign language expert, determined Amy was able to succeed in school without an interpreter. Amy’s parents sued the school on her behalf for violation of the Education of All Handicapped Children Act of 1975. The Act requires all schools that accept federal funds to provide a “free appropriate public education” to all handicapped students. The Act also allows schools discretion in deciding what steps to take to accommodate handicapped students.</p> <p>The district court ruled in the Rowleys' favor, holding that while Amy was doing better in school than the average hearing student, she was not achieving to her full potential because she was unable to understand as much as she would with a sign language interpreter. The U.S. Court of Appeals for the Second Circuit affirmed.</p>

majority opinion

reversed/remanded

Civil Rights

Rodriguez v. Popular Democratic Party

https://api.oyez.org/cases/1981/81-328

81-328

1981

Rodriguez

Popular Democratic Party

<p>In 1981, a representative of Puerto Rico's Popular Democratic Party ("Party") died in office. Searching for a replacement, the Governor of Puerto Rico held a "by-election" open to candidates of all parties. The Party challenged the Governor, alleging that under Puerto Rico statutes only candidates and electors affiliated with the Party could participate in the by-election. On appeal from a Superior Court judgment favoring the Party, Puerto Rico's Supreme Court modified the judgment holding that a by-election was only required if the party of the legislator vacating the seat fails to name a replacement within 60 days. Before Puerto Rico's Supreme Court could deliver its decision, the Party held an election open only to its members and, then, pursuant to the Supreme Court's mandate, swore in a new representative. Rodriguez appealed and the Supreme Court granted certiorari.</p>

majority opinion

affirmed

Civil Rights

Youngberg v. Romeo

https://api.oyez.org/cases/1981/80-1429

80-1429

1981

Duane Youngberg

Nicholas Romeo

<p>Nicholas Romeo was a 33-year-old man with the mental capacity of an 18-month-old child. Following the death of his father, Romeo’s mother was unable to adequately care for Romeo and had him involuntarily committed to Pennhurst State School and Hospital (“Pennhurst”) on a permanent basis. During his time in the state facility, Romeo suffered injuries on numerous occasions and was physically restrained at times. Romeo’s mother became concerned, and after objecting to Romeo’s treatment several times, sued the facility on behalf of Romeo. Romeo’s mother claimed that his treatment violated the protections of the Due Process Clause of the Fourteenth Amendment and the prohibition against cruel and unusual punishment in the Eighth Amendment. Specifically, Romeo’s mother claimed Romeo had the right to safe conditions of confinement, freedom from bodily restraints, and access to habilitation (training or treatment with the goal of eventual release).</p> <p>At trial, the court instructed the jury that they could only find that Pennhurst violated Romeo’s constitutional rights if the officials had been “deliberately indifferent” to Romeo’s medical and psychological needs, and the jury found in favor of Pennhurst. On appeal, the U.S. Court of Appeals for the Third Circuit reversed and remanded for a new trial. The Court of Appeals held the Eighth Amendment’s prohibition of cruel and unusual punishment was inapplicable, because it applies to individuals convicted of crimes, not the involuntarily committed. However, under the Due Process Clause of the Fourteenth Amendment, Romeo had liberty interests in freedom from restraint, safe conditions, and minimally adequate habilitation, which could only be violated if three distinct standards were met. An infringement of the right to safe conditions can only be justified by “substantial necessity,” the right to freedom from bodily restraints can only be infringed for “compelling necessity,” and the access to habilitation must be “acceptable in the light of present medical or other scientific knowledge.</p>

majority opinion

vacated/remanded

Due Process

Globe Newspaper Co. v. Superior Court, County of Norfolk

https://api.oyez.org/cases/1981/81-611

81-611

1981

Globe Newspaper Co.

Superior Court, County of Norfolk

<p>A Massachusetts law required trial courts to exclude members of the press and public from certain cases involving sexual offenses and testimony of victims less than eighteen years old. In a trial involving a male who was accused of raping three minors, the court, acting in reference to the Massachusetts statute, conducted a closed trial.</p>

majority opinion

reversed

First Amendment

Engle v. Isaac

https://api.oyez.org/cases/1981/80-1430

80-1430

1981

Ted Engle, Superintendant, Chillicothe Correctional Institute

Lincoln Isaac, et al.

<p>In 1974, Ohio enacted a statute that stated, while the burden to prove the defendant guilty beyond a reasonable doubt rested on the prosecution, the burden of proof for an affirmative defense rested on the defendant. From 1974 until 1976, Ohio state courts operated as though this statute did not affect Ohio's traditional rule that a defendant had to prove an affirmative defense by a preponderance of the evidence. However, in 1976 the Supreme Court of Ohio found that the statute placed only the burden of production of such evidence — as opposed to the burden of persuasion — on the defendant, and jury instructions were altered accordingly. </p> <p>The respondents, Lincoln Isaac, Kenneth Bell, and Howard Hughes, each had separate trials that occurred after the 1974 statute was put in place, but before the 1976 decision. At the time of their trials, none of the respondents objected to the jury instructions regarding how the jury should consider evidence of self-defense. The Ohio Criminal Code required defendants to raise any objections to jury instructions at the time the instructions are given. The respondents filed petitions in federal district courts for writs of habeas corpus and used the 1976 decision to challenge the jury instructions trial. The courts denied the writs. The U.S. Court of Appeals for the Sixth Circuit affirmed the convictions, and rejected the argument regarding the jury instructions because it had not been made at the time of the trial. The Ohio Supreme Court declined to review the case.</p>

majority opinion

reversed/remanded

Criminal Procedure

New York v. Ferber

https://api.oyez.org/cases/1981/81-55

81-55

1981

New York

Ferber

<p>A New York child pornography law prohibited persons from knowingly promoting sexual performances by children under the age of sixteen by distributing material which depicts such performances.</p>

majority opinion

reversed/remanded

First Amendment

American Tobacco Company v. Patterson

https://api.oyez.org/cases/1981/80-1199

80-1199

1981

American Tobacco Company, et al.

John Patterson, et al.

<p>American Tobacco Company operated two plants in Richmond, VA. Until 1963, both plants were segregated, and the better job opportunities were reserved for white employees. Between 1963 and 1968, the plants were officially desegregated, but the promotion policies were left mostly to the discretion of the supervisors. The best jobs continued to go to the white employees. In November 1968, the company proposed nine new lines of employment progression that linked bottom jobs with the top job a worker could eventually receive. Four of the lines linked majority-white bottom jobs with majority-white top jobs; two of the lines linked majority-black bottom jobs with majority-black top jobs. The top jobs for the majority-white progression lines were the best jobs in the factories.</p> <p>On January 3, 1969, John Patterson and two other employees filed a complaint with the Equal Employment Opportunity Commission (EEOC). In 1973, alleging violations of the Civil Rights Act, the employees sued the company in district court . The district court held that the lines of progression violated the Act and prohibited the company from using them. The United States Court of Appeals for the Fourth District affirmed and remanded the case for further proceedings to determine the remedy. The Supreme Court denied certiorari.</p> <p>On remand, the petitioners filed a motion to dismiss the complaints by arguing that the seniority system was exempt from the Civil Rights Act. The district court denied the motion. The Court of Appeals affirmed the decision because that the lines of progression are not a seniority system. The Court of Appeals also held that the immunity for seniority systems only extends to those in place before the effective date of the Civil Rights Act.</p>

majority opinion

vacated/remanded

Civil Rights

National Association for the Advancement of Colored People v. Claiborne Hardware Company

https://api.oyez.org/cases/1981/81-202

81-202

1981

National Association for the Advancement of Colored People

Claiborne Hardware Company

<p>In 1966, at a local meeting of the National Association for the Advancement of Colored People (NAACP) attended by several hundred people in Claiborne County, Mississippi, the group launched a boycott of white merchants. The purpose of the boycott was to promote equality and racial justice. The boycott consisted of nonviolent picketing, but some acts and threats of violence also occurred. In 1969, white merchants sued the NAACP for damages as a result of the injuries to their businesses that the boycott caused. These damages included loss of earnings over a seven-year period. The Chancery Court imposed damages liability and the Mississippi Supreme Court upheld the imposition of tort liability as well as concluding the entire boycott was unlawful since the NAACP agreed to use force, violence, and “threats” to carryout the boycott.</p>

majority opinion

reversed/remanded

First Amendment

Larson v. Valente

https://api.oyez.org/cases/1981/80-1666

80-1666

1981

John R. Larson, et al.

Pamela Valente, et al.

<p>In 1961, Minnesota passed the Minnesota Charitable Solicitation Act, which established a system of registering charitable organizations that solicit money. All organizations subject to the Act must file extensive annual reports with the Minnesota Department of Commerce. The Department may deny or withdraw the registration of any organization that engages in fraudulent, deceptive, or dishonest practices. From 1961 until 1978, all religious organizations were exempt from the Act. In 1978, the state legislature amended the Act to include religious organizations that received more than fifty percent of their funding from solicitations of nonmembers. </p> <p>Shortly after the amendment, the Department notified the Holy Spirit Association for the Unification of World Christianity (Unification Church) that it must register under the Act. Pamela Valente and other members of the Church responded by suing and alleging that the Act violated the First and Fourteenth Amendments. The United States Magistrate granted a preliminary injunction and held that the Act failed the second part of the Lemon Test, that the primary effect of a law must neither advance nor inhibit religion. Accepting the recommendation of the Magistrate, the District Court granted summary judgment in favor of the plaintiff. </p> <p>The U.S. Court of Appeals for the Eighth Circuit affirmed in part and reversed in part. The Court of Appeals affirmed that the fifty percent rule violated the Establishment Clause, but held that proof of status as a religious organization was required to be exempt from the Act.</p>

majority opinion

affirmed

First Amendment

Northern Pipeline Constr. Company v. Marathon Pipe Line Company

https://api.oyez.org/cases/1981/81-150

81-150

1981

Northern Pipeline Constr. Company

Marathon Pipe Line Company

<p>The Bankruptcy Reform Act of 1978 created a system of bankruptcy courts as an adjunct to the federal system of district courts. This case was decided together with United States v. Marathon Pipeline Co.</p>

plurality opinion

affirmed

Judicial Power

United Mine Workers of America Health & Retirement Funds v. Robinson

https://api.oyez.org/cases/1981/81-61

81-61

1981

United Mine Workers of America Health & Retirement Funds

Gracie Robinson and Juanita Hager, et al.

<p>A new collective bargaining agreement increased health benefits for widows of coal miners who were receiving pensions when they died. The agreement did not increase benefits for widows of coal miners who were still working at the time they died, although they were eligible for pensions. These health benefits were paid out of a trust fund financed by the operators. Gracie Robinson and Juanita Hager brought this class action on behalf of all similarly situated widows. They alleged that requiring the worker to be receiving a pension at the time of death to qualify for increased health benefits bore no relation to the purpose of the trust. The district court denied relief, but the U.S. Court of Appeals for the District of Columbia Circuit reversed. The Court of Appeals held that the collective bargaining agreement failed to meet the reasonable standard set out in the Labor Management Relations Act (LMRA). The LMRA requires pension trusts to be maintained “for the sole and exclusive benefit of employees…and their families”.</p>

majority opinion

reversed

Unions

United States v. Lee

https://api.oyez.org/cases/1981/80-767

80-767

1981

United States

Edwin D. Lee

<p>Edwin Lee, a member of the Old Order Amish, employed several other Amish workers on his farm and in his carpentry shop. He did not pay quarterly social security taxes, and in 1978, the Internal Revenue Service (IRS) assessed $27,000 in unpaid taxes. Lee paid the portion due for the first quarter of 1973 and sued for a refund. Lee argued that the tax violated his First Amendment right to free exercise of religion. In the Amish religion, it is a sin not to provide for the community’s elderly and needy citizens. Lee argued that paying the federal government for Social Security violates that provision of his religion by giving the responsibility of caring for the elderly and needy to the government. The district court held that the Social Security tax was unconstitutional as applied. The court also noted that §1402(g) provides an exception to the social security tax for certain self employed individuals. The U.S. Supreme Court heard this case on direct appeal.</p>

majority opinion

reversed/remanded

First Amendment

United States v. Ross

https://api.oyez.org/cases/1981/80-2209

80-2209

1981

United States

Ross

<p>Acting on a tip that Ross was selling drugs from his car in the District of Columbia, police officers pulled Ross over, opened his trunk, and discovered a bag of heroin. After returning to the station, another search uncovered $3200 in cash. Officers acted without a warrant in each search.</p>

majority opinion

reversed/remanded

Criminal Procedure

INS v. Chadha

https://api.oyez.org/cases/1981/80-1832

80-1832

1981

Chadha

Immigration and Naturalization Service (INS)

<p>In one section of the Immigration and Nationality Act, Congress authorized either House of Congress to invalidate and suspend deportation rulings of the United States Attorney General. Chadha had stayed in the U.S. past his visa deadline. Though Chadha conceded that he was deportable, an immigration judge suspended his deportation. The House of Representatives voted without debate or recorded vote to deport Chadha. This case was decided together with United States House of Representatives v. Chadha and United States Senate v. Chadha.</p>

majority opinion

affirmed

Miscellaneous

Enmund v. Florida

https://api.oyez.org/cases/1981/81-5321

81-5321

1981

Earl Enmund

Florida

<p>Earl Enmund and two codefendants were found guilty of the felony murder and robbery of Thomas and Eunice Kersey, an elderly couple. Enmund was the getaway driver, who waited in the car during the robbery, did not participate in the killing and had no idea anyone would be killed. Enmund argued that the evidence did not show any intent to kill, so the death penalty was cruel and unusual punishment. Despite this, the jury sentenced him to death along with his codefendants. The Supreme Court of Florida affirmed the conviction.</p>

majority opinion

reversed/remanded

Criminal Procedure

United States v. MacDonald

https://api.oyez.org/cases/1981/80-1582

80-1582

1981

United States

MacDonald

<p>In May 1970, Jeffrey MacDonald, an army captain living at Fort Bragg, North Carolina, was charged with the murders of his wife and two children. However, after an investigation by the Army Criminal Investigation Division (“CID”), the murder charges were dropped, and MacDonald was given an honorable discharge. Following MacDonald’s discharge, the U.S. Justice Department asked the Army CID to continue its investigation into the murders, and in 1972 the CID created a report on the murders that recommended further investigation into MacDonald. After evaluating the report, the Justice Department presented the case to a grand jury in the fall of 1974, which returned an indictment for MacDonald in January of 1975 that charged him again with all three murders.</p> <p>MacDonald moved to dismiss the indictment and argued that the delay between the original murder charge in 1970 and the grand jury indictment in 1974 violated his Sixth Amendment right to a speedy trial. The district court denied MacDonald’s motion. On appeal, the U.S. Court of Appeals for the 4th Circuit reversed the district court by finding that the time-gap between the 1972 CID report to the Justice Department and the 1974 convening of a grand jury infringed on MacDonald’s Sixth Amendment rights. The U.S. Supreme Court granted certiorari, reversed and remanded. The Court held that MacDonald could not appeal the denial of a motion to dismiss on the basis of the 6th amendment right to speedy trial until after the trial has been completed. MacDonald was tried and convicted of all three murders. On appeal, the U.S. Court of Appeals for the 4th Circuit again held the indictment violated MacDonald’s Sixth Amendment rights.</p> <p> </p>

majority opinion

reversed/remanded

Criminal Procedure

Plyler v. Doe

https://api.oyez.org/cases/1981/80-1538

80-1538

1981

Plyler

Doe

<p>A revision to the Texas education laws in 1975 allowed the state to withhold from local school districts state funds for educating children of illegal aliens. This case was decided together with Texas v. Certain Named and Unnamed Alien Child.</p>

majority opinion

affirmed

Civil Rights

North Haven Bd. of Educ. v. Bell

https://api.oyez.org/cases/1981/80-986

80-986

1981

North Haven Bd. of Educ.

Bell

<p>In 1972, the United States Congress passed Title IX of the Education Amendments of 1972, which prohibited federally funded education programs from discriminating on the basis of gender and allowed the government to withhold federal funds to non-complying educational institutions. Government agencies tasked with supplying federal funding to educational institutions were authorized to create regulations to enforce Title IX. In 1975, one of these agencies, the Department of Health, Education and Welfare (“HEW”) passed regulations that extended the prohibition on gender discrimination to school personnel.</p> <p>Employees of two Connecticut school districts, North Haven and Trumbull, accused the districts of practicing gender discrimination. HEW opened investigations into both districts and eventually warned both that they were in jeopardy of losing their federal funds. Both districts filed separate suits against HEW, claiming that the regulation went beyond the authority of Title IX, which does not explicitly cover gender-based employee discrimination. In both cases, the district court found for the school districts by holding that Title IX was intended to apply to students, not employees. On appeal, the U.S. Court of Appeals for the Second Circuit reversed the district courts and held that Congress had intended Title IX to apply to both students and employees.</p> <p> </p>

majority opinion

affirmed

Civil Rights

Harlow v. Fitzgerald

https://api.oyez.org/cases/1981/80-945

80-945

1981

Bryce Harlow and Alexander Butterfield

A. Ernest Fitzgerald

<p>On November 13, 1968, A. Ernest Fitzgerald, a management analyst in the Department of the Air Force, testified before the Subcommittee on Economy in Government of the Joint Economic Committee of the U. S. Congress regarding $2 billion in unexpected costs associated with the C5-A transport plane along with its technical difficulties. In January 1970, he was fired, and he believed his dismissal was in retaliation for his testimony. Fitzgerald sued presidential aides Bryce Harlow and Alexander Butterfield for civil damages and claimed they were involved in a conspiracy that resulted in his wrongful dismissal. Both Harlow and Butterfield claimed to have no knowledge of any conspiracy and asserted that their actions surrounding this issue were undertaken in good faith. Harlow and Butterfield moved for summary judgment, which the court denied. The district court also found them ineligible for immunity. They appealed the denial of immunity to the Court of Appeals for the District of Columbia Circuit, and the Court of Appeals dismissed the appeal without issuing an opinion.</p>

majority opinion

vacated/remanded

Economic Activity

Regan v. Taxation With Representation of Washington

https://api.oyez.org/cases/1982/81-2338

81-2338

1982

Donald Regan, Secretary of the Treasury

Taxation With Representation of Washington

<p>Two non-profit groups merged to form the group Taxation With Representation of Washington (TWR). One of the original groups obtained 501(c)3 status from the Internal Revenue Service (IRS), which allowed donors to make tax-deductible donations to it. Because the other group participated in political lobbying, it did not qualify for 501(C)(3) status and could not offer tax-deductible donations. Since the newly formed TWR also participated in "substantial lobbying," the IRS denied it tax-deduction privileges. TWR alleged in District Court that the IRS's "substantial lobbying" restriction for 501(C)(3) status violated its First Amendment rights by imposing an "unconstitutional burden" on its ability to receive tax-deductible donations. TWR also argued that the restriction violated its Fifth Amendment equal protection rights since veterans' organizations that lobbied extensively could receive tax-deductible donations. The District Court dismissed the complaint but the Court of Appeals for the District of Columbia ruled that the "substantial lobbying" restriction did impair TWR's Fifth Amendment equal protection rights.</p>

majority opinion

reversed

First Amendment

City of Los Angeles v. Lyons

https://api.oyez.org/cases/1982/81-1064

81-1064

1982

City of Los Angeles

Lyons

<p>In 1976, police officers of the City of Los Angeles stopped Adolph Lyons for a traffic code violation. Although Lyons offered no resistance, the officers, without provocation, seized Lyons and applied a chokehold. The hold rendered Lyons unconscious and damaged his larynx. Along with damages against the officers, Lyons sought an injunction against the City barring the use of such control holds.</p>

majority opinion

reversed

Judicial Power

United States v. Rodgers

https://api.oyez.org/cases/1982/81-1476

81-1476

1982

United States

Rodgers

<p>Phillip Bosco died with a great deal of tax debt, so the government sued his widow, Lucille Mitzi Bosco Rodgers, to force her to sell the house in which she currently resided to pay off his debt. Rodgers, however, was not in debt and under Texas law, had a separate right to the homestead. The district court held Rodgers had a state-created right not to have her homestead subjected to a force sale. The U.S. Court of Appeals for the Fifth Circuit affirmed.</p>

majority opinion

reversed/remanded

Federal Taxation

Solem v. Helm

https://api.oyez.org/cases/1982/82-492

82-492

1982

Solem

Helm

<p>Helm was convicted of writing a check from a fictitious account, a crime carrying with it a five-year jail sentence. However, since this was his seventh felony conviction in South Dakota since 1964, he was sentenced to life imprisonment without parole under a state recidivist statute.</p>

majority opinion

affirmed

Criminal Procedure

Martinez v. Bynum

https://api.oyez.org/cases/1982/81-857

81-857

1982

Martinez

Bynum

<p>A Texas law permitted public school districts to deny tuition-free admission to minors living apart from their parents if their primary purpose of living in the district was to attend school free of charge. Roberto Morales left his family in Mexico to live with his sister, Oralia Martinez, in Texas. When the school district denied Morales' application for free admission, Martinez challenged the law in court.</p>

majority opinion

affirmed

Civil Rights

Pacific Gas & Electric Company v. State Energy Resources Conservation and Development Commission

https://api.oyez.org/cases/1982/81-1945

81-1945

1982

Pacific Gas & Electric Company

State Energy Resources Conservation and Development Commission

<p>A California law dictated that before additional nuclear power plants could be built, the state energy commission had to determine that there would be adequate storage capacity for spent fuel rods. Two utility companies challenged the law, arguing that its provisions had been preempted by the federal Atomic Energy Act of 1954.</p>

majority opinion

affirmed

Federalism

Exxon Corporation v. Eagerton

https://api.oyez.org/cases/1982/81-1020

81-1020

1982

Exxon Corporation

Ralph P. Eagerton Jr.

<p>Since 1945, Alabama had imposed a severance tax on oil and gas operations. Exxon Corporation (Exxon), along with other gas and oil producers in Alabama, had contractual agreements regarding the tax with the owners of the land on which operations occurred and with oil and gas purchasers. The owners were paid a royalty on all gas and oil produced, but were contractually assessed a portion of the severance tax, and the purchasers were required to reimburse the producers for any severance tax paid by them. In 1979, the Alabama Legislature passed a statute altering the severance tax. The statute increased the severance tax, exempted royalty landowners from the increase, and prohibited gas and oil operators from passing the tax increase on to oil and gas purchasers.</p> <p>Exxon and other oil and gas producers sued Ralph Eagerton, the Commissioner of Revenue in Alabama and argued that the National Gas Policy Act, which allowed natural gas producers to take steps to recoup state severance tax, preempted the prohibitions on passing along the costs to purchasers. Furthermore, the oil and gas producers argued that the exemption and the prohibition violated the oil and gas producers’ Constitutional rights under the Contract Clause and the Equal Protection Clause of the Fourteenth Amendment. The Circuit Court of Montgomery County ruled the new severance tax provisions unconstitutionally violated the Equal Protection Clause of the 14th amendment and the Contract Clause. The state appealed to the Supreme Court of Alabama, which reversed the lower court’s decision, holding any constraints imposed by the new tax were generally applicable and therefore valid.</p> <p> </p>

majority opinion

reversed in-part/remanded

Economic Activity

Marsh v. Chambers

https://api.oyez.org/cases/1982/82-23

82-23

1982

Marsh

Chambers

<p>Ernest Chambers, a member of the Nebraska legislature, challenged the legislature's chaplaincy practice in federal court. This practice involves the offering of a prayer at the beginning of each legislative session by a chaplain chosen by the state and paid out of public funds. The district court supported Chambers on the use of public funds. The appeals court supported Chambers on the prayer practice. Both parties appealed to the U.S. Supreme Court.</p>

majority opinion

reversed

First Amendment

Kolender v. Lawson

https://api.oyez.org/cases/1982/81-1320

81-1320

1982

Kolender

Lawson

<p>Lawson was a law-abiding black man of unusual deportment (he wore his hair in long dreadlocks). Lawson was frequently subjected to police questioning and harassment when he walked in white neighborhoods. Lawson challenged the California law "that requires persons who loiter or wander on the streets to provide a 'credible and reliable' identification and to account for their presence when requested by a peace officer."</p>

majority opinion

affirmed

Due Process

United States v. Knotts

https://api.oyez.org/cases/1982/81-1802

81-1802

1982

United States

Leroy Carlton Knotts

<p> Tristan Armstrong, a former employee of the 3M Company, which manufactures chemicals in St. Paul, came under suspicion for stealing chemicals that could be used to manufacture illegal drugs. The company notified a narcotics agent, and further investigation determined that Armstrong had been purchasing similar chemicals from the Hawkins Chemical Company in St. Louis. With the consent of Hawkins Chemical Company, narcotics agents installed a radio transmitter in the container of chloroform that Armstrong would receive. By tracking the radio transmitter, officers were able to track Armstrong delivering the chloroform to Darryl Petschen. Petschen drove it to a cabin owned by Leroy Carlton Knotts in Shell Lake, Wisconsin. Relying on this information, the officers obtained a search warrant for the cabin and found a fully operable drug-manufacturing lab. </p> <p>Knotts was convicted in district court after the court denied his motion to suppress the evidence. The United States Court of Appeals for the Eighth Circuit reversed the conviction and held that the monitoring of the radio transmitter violated Knotts’ Fourth Amendment rights.</p>

majority opinion

reversed

Criminal Procedure

Motor Vehicle Manufacturers Association of the United States, Inc. v. State Farm Mutual Automobile Insurance Company

https://api.oyez.org/cases/1982/82-354

82-354

1982

Motor Vehicle Manufacturers Association of the United States, et al.

State Farm Mutual Automobile Insurance Company, et al.

<p>In 1966, Congress passed the National Traffic and Motor Vehicle Safety Act of 1966, which gave the Secretary of Transportation the power to issue motor vehicle safety standards. The Secretary also has the ability to delegate that power to another agency, in this case the National Highway Transportation Safety Administration (NHTSA). The Act also authorizes judicial review to determine whether the NHTSA acted arbitrarily and capriciously.</p> <p>In 1967, the Department of Transportation first issued Standard 208, which at that point only required all automobiles to have seat belts. By 1975, Standard 208 had been revised multiple times to require passive restraints, such as airbags and seat belts that would operate automatically and not require action on the part of the occupants. Because of the unpopularity of the standard, in 1974 Congress amended the Act to allow alternative safety measures. In 1976, Secretary of Transportation William Coleman suspended the passive restraint requirement entirely. The succeeding Secretary of Transportation, Brock Adams, issued Modified Standard 208, which required passive restraints in large cars of model year 1982 or later and in all cars of model year 1984 or later. In 1981, Secretary of Transportation Andrew Lewis began reconsidering Modified Standard 208. The NHTSA rescinded the passive restraint requirement of Modified Standard 208 because it determined that the restraints would not have the expected safety benefits, so the requirement would not be reasonable or practicable.</p> <p>State Farm Mutual Automobile Insurance Company and the National Association of Independent Insurers filed for review of the NHTSA’s decision, and the U.S. Court of Appeals for the District of Columbia Circuit held that the NHTSA’s decision to rescind the standard was arbitrary and capricious. The Court of Appeals held that there was not enough evidence to support the NHTSA’s position and that the NHTSA failed to properly consider alternative possibilities under which the standard could be effective.</p>

majority opinion

vacated/remanded

Judicial Power

Verlinden B. V. v. Central Bank of Nigeria

https://api.oyez.org/cases/1982/81-920

81-920

1982

Verlinden B. V.

Central Bank of Nigeria

<p>Verlindin B.V., a Dutch Corporation, sued Central Bank of Nigeria in U.S. District Court for the Southern District of New York for breaching a letter of credit. Verlindin alleged that the court had jurisdiction under the Foreign Sovereign Immunities Act (FSIA). The FSIA grants jurisdiction for actions against foreign parties who are not entitled to immunity. Central Bank moved to dismiss the case due to lack of subject matter jurisdiction. The district court dismissed the case, holding that Central bank had sovereign immunity. The U.S. Court of Appeals for the Second Circuit affirmed, but held that the entire FSIA exceeded the scope of Article III of the U.S. Constitution.</p>

majority opinion

reversed/remanded

Judicial Power

Lehr v. Robertson

https://api.oyez.org/cases/1982/81-1756

81-1756

1982

Jonathan Lehr

Lorrain Robertson, Richard N. Robinson

<p>Jonathan Lehr, the biological father of Jessica M., filed a petition to vacate an order of adoption. He argued that Jessica was adopted by her mother’s husband in violation of the Constitution because Lehr was never notified of the proceedings. Under New York law, Lehr was not in any of the classes of people entitled to notification of adoption proceedings. Lehr never supported the child financially, had a significant relationship with the child, or entered his name into the state’s father registry. The Ulster County Family Court denied Lehr’s petition and the Appellate Division and New York Court of Appeals affirmed.</p>

majority opinion

affirmed

Civil Rights

Falls City Industries, Inc. v. Vanco Beverage, Inc.

https://api.oyez.org/cases/1982/81-1271

81-1271

1982

Falls City Industries, Inc.

Vanco Beverage, Inc.

<p>From 1972 through 1978, Falls City Industries, Inc. sold beer to Vanco Beverage, Inc., the sole wholesale distributor for Falls City in Indiana at a higher price than Falls City charged its only wholesale distributor in Kentucky. Under Indiana law, brewers were required to sell to all Indiana wholesalers at a single price, Indiana wholesalers were prohibited from selling to out-of-state retailers, and Indiana retailers were not permitted to purchase beer from out-of-state wholesalers. Vanco filed suit, alleging that Falls City's price discrimination violated section 2(a) of the Clayton Act, as amended by the Robinson-Patman Act. The Federal Court found that Vanco had established a prima facie case of price discrimination. The court rejected Falls City's "meeting-competition" defense under section 2(b) of the Clayton Act, which provides that a defendant may rebut a prima facie showing of illegal price discrimination by establishing that its lower price to any purchaser or purchasers was made in good faith to meet an equally low price of a competitor. The Court of Appeals affirmed.</p>

majority opinion

vacated/remanded

Economic Activity

Akron v. Akron Center For Reproductive Health

https://api.oyez.org/cases/1982/81-746

81-746

1982

Akron

Akron Center For Reproductive Health

<p>In 1978 the Akron City Council enacted an ordinance which established seventeen provisions to regulate the performance of abortions. Among other things, the ordinance required: all abortions performed after the first trimester to be done in hospitals, parental consent before the procedure could be performed on an unmarried minor, doctors to counsel prospective patients, a twenty-four hour waiting period, and that fetal remains be disposed of in a "humane and sanitary manner." Some of the ordinance's provisions were invalidated by a federal district court.</p>

majority opinion

reversed in-part

Privacy

Michigan v. Long

https://api.oyez.org/cases/1982/82-256

82-256

1982

Michigan

Long

<p>David Long was convicted for possession of marijuana found by Michigan police in the passenger compartment and trunk of his car. The police searched the passenger compartment because they suspected Long's vehicle contained weapons potentially dangerous to the officers. After a state appellate court affirmed the conviction, the Michigan Supreme Court reversed. The Michigan Supreme Court held that the search violated the Fourth Amendment and the Michigan Constitution.</p>

majority opinion

reversed/remanded

Criminal Procedure

Simopoulos v. Virginia

https://api.oyez.org/cases/1982/81-185

81-185

1982

Chris Simopoulos

Virginia

<p>Dr. Chris Simopoulos, a practicing obstetrician-gynecologist, performed an abortion for a 17-year-old girl at his clinic in Falls Church, Virginia. The girl was in her second trimester and did not inform her parents about the procedure, despite Dr. Simopoulos’ suggestion. Dr. Simploulous was indicted under a Virginia law prohibiting second trimester abortions outside of a licensed hospital. The Circuit Court of Fairfax County convicted him without a jury and the Supreme Court of Virginia affirmed the conviction.</p>

majority opinion

affirmed

Privacy

Sony Corporation of America v. Universal City Studios, Inc.

https://api.oyez.org/cases/1982/81-1687

81-1687

1982

Sony Corporation of America

Universal City Studios, Inc.

<p>Sony Corporation of America manufactured and sold the "Betamax" home video tape recorder (VTR). Universal City Studios owned the copyrights to television programs broadcast on public airwaves. Universal sued Sony for copyright infringement, alleging that because consumers used Sony's Betamax to record Universal's copyrighted works, Sony was liable for the copyright infringement allegedly committed by those consumers in violation of the Copyright Act. Universal sought monetary damages, an equitable accounting of profits, and an injunction against the manufacturing and marketing of the VTR's. The District Court denied all relief, holding that the noncommercial home use recording of material broadcast over the public airwaves was a fair use of copyrighted works and did not constitute copyright infringement. Moreover, the court concluded that Sony could not be held liable as contributory infringers even if the home use of a VTR was considered an infringing use. In reversing, the Court of Appeals held Sony liable for contributory infringement.</p>

majority opinion

reversed

Economic Activity

Bob Jones University v. United States

https://api.oyez.org/cases/1982/81-3

81-3

1982

Bob Jones University

United States

<p>Bob Jones University was dedicated to "fundamentalist Christian beliefs" which included prohibitions against interracial dating and marriage. Such behavior would lead to expulsion. In 1970, the Internal Revenue Service (IRS) changed its formal policy to adopt a district court decision that prohibited the IRS from giving tax-exempt status to private schools engaging in racial discrimination. The IRS believed that the University's policies amounted to racism and revoked its tax-exempt status. The University claimed that the IRS had abridged its religious liberty. This case was decided together with Goldsboro Christian Schools Inc. v. United States, in which Goldsboro maintained a racially discriminatory admissions policy based upon its interpretation of the Bible, accepting for the most part only Caucasian students. The IRS determined that Goldsboro was not an exempt organization and hence was required to pay federal social security and unemployment taxes. After paying a portion of such taxes for certain years, Goldsboro filed a refund suit claiming that the denial of its tax-exempt status violated the U.S. Constitution.</p>

majority opinion

affirmed

Civil Rights

Minneapolis Star & Tribune Company v. Minnesota Commissioner of Revenue

https://api.oyez.org/cases/1982/81-1839

81-1839

1982

Minneapolis Star & Tribune Company

Minnesota Commissioner of Revenue

<p>From 1967 to 1971, the Minneapolis Star and Tribune Company, a publisher of a morning and evening newspaper in Minneapolis, was exempt from a state sales and use tax provided periodic publications. In 1971, the Minnesota legislature imposed a "use tax" on the cost of paper and ink products consumed in publishing. In 1974, the legislature exempted the first $100,000 worth of ink and paper consumed a year. After the enactment of this exemption, the Star Tribune found itself paying roughly two-thirds of the total revenue raised by the tax.</p>

majority opinion

reversed

First Amendment

United States v. Place

https://api.oyez.org/cases/1982/81-1617

81-1617

1982

United States

Raymond J. Place

<p>(Tom Feledy prepared this summary.)</p> <p>A traveler at an airport alerted the suspicions of drug agents, who, based upon his behavior and discrepancies in his luggage tags, believed he was carrying narcotics. They relayed this information to fellow agents at his destination airport. There, the agents met him and seized his bags without his consent. Ninety minutes after the seizure, his bags were subjected to a "sniff" test by a drug-detection dog. The dog signaled the presence of a controlled substance in one of the bags. The agents then obtained a warrant for that suitcase, which turned out to contain cocaine, and the man was convicted of the drug offense. The Court of Appeals reversed his conviction on the ground that the ninety minutes exceeded the investigative stop permitted by _Terry v. Ohio</p> <p>, and thus violated the Fourth Amendment's search and seizure privilege.</p>

majority opinion

affirmed

Criminal Procedure

Mueller v. Allen

https://api.oyez.org/cases/1982/82-195

82-195

1982

Mueller

Allen

<p>A Minnesota law allowed taxpayers to deduct from their state income tax expenses incurred in providing tuition, textbooks, and transportation for their children's elementary or secondary school education. Parents who sent their children to parochial school also qualified for the deductions.</p>

majority opinion

affirmed

First Amendment

Barefoot v. Estelle

https://api.oyez.org/cases/1982/82-6080

82-6080

1982

Thomas A. Barefoot

W.J. Estelle, Director, Texas Department of Corrections

<p>On November 14, 1978, a Texas jury in Bell County found Thomas A. Barefoot guilty of the murder of a police officer. A separate sentencing hearing was held before the same jury to determine whether the death penalty should be imposed. The prosecution called two psychiatrists to the stand who testified that Barefoot was likely to commit further acts of violence and would remain a danger to society. The jury sentenced Barefoot to death. Barefoot appealed to the Texas Court of Criminal Appeals and argued that the use of the psychiatrists to testify as to future conduct was unconstitutional because psychiatric testimony cannot accurately predict future dangerousness and is likely to produce erroneous convictions. He also argued that this specific testimony was unconstitutional, as neither psychiatrist had personally examined Barefoot. The Texas Court of Criminal Appeals affirmed the conviction and sentence.</p> <p>Barefoot’s execution was scheduled for September 7, 1980. A stay of execution was granted by the Supreme Court pending the filing and disposition of a petition of certiorari. The petition was denied, and Barefoot’s execution was rescheduled for October 1981. The Texas Court of Criminal Appeals denied Barefoot’s application for habeas corpus, and he filed a petition for habeas corpus in district court. The district court granted a stay of execution pending action on the petition, and later denied the petition and vacated the stay of execution. The district court also issued a certificate of probable cause that would allow Barefoot to continue the appeals process. The Texas Court of Criminal Appeals again denied Barefoot’s petition for habeas corpus and motion for a stay of execution. Barefoot appealed to the U.S. Court of Appeals for the Fifth District for a stay of execution, pending the consideration of his appeal of the denial of his petition for habeas corpus, and the Court of Appeals denied the motion.</p>

majority opinion

affirmed

Criminal Procedure

Karcher v. Daggett

https://api.oyez.org/cases/1982/81-2057

81-2057

1982

Karcher

Daggett

<p>Democrats in control of the New Jersey Legislature designed a plan for congressional redistricting in the state which the outgoing Democratic governor signed into law. Even though the district populations differed by less than one percent from each other, they were clearly drawn to maximize Democratic power in the state.</p>

majority opinion

affirmed

Civil Rights

Dirks v. Securities and Exchange Commission

https://api.oyez.org/cases/1982/82-276

82-276

1982

Raymond L. Dirks

Securities and Exchange Commission

<p>In 1973, Raymond Dirks was an officer of a New York-based firm that specialized in providing investment analysis of insurance company securities to institutional investors. On March 6, he received insider information that Equity Funding of America, a corporation engaged primarily in selling life insurance and mutual funds, had vastly overstated assets as a result of fraudulent company policies. Dirks did not do any business with Equity Funding, but he decided to investigate and, during the investigation, discussed his information with investors who did hold Equity Funding stock. Some of these people sold their stock based on Dirks’ information. Dirks also urged the Wall Street Journal to publish an article on the fraud allegations, but it would not for fear of the story being libelous. The drop in Equity Funding’s share price caused the New York Stock Exchange to halt trading on March 27 and the Securities and Exchange Commission (SEC) began an investigation. On April 2, the Wall Street Journal ran a story that was based largely on Dirks’ information, and the SEC then began investigating Dirks’ role in the affair.</p> <p>In their investigation of Dirks’ actions, the SEC found that he had aided and abetted the violations of the Securities Act of 1933 and the Securities Exchange Act of 1934 by informing other members of the investment community of the fraud allegations. However, because he assisted in exposing the fraud, Dirks was only censured. Dirks appealed to the U.S. Court of Appeals for the District of Columbia Circuit, which affirmed the SEC’s decision.</p>

majority opinion

reversed

Economic Activity

Connick v. Myers

https://api.oyez.org/cases/1982/81-1251

81-1251

1982

Harry Connick

Sheila Meyers

<p>Sheila Meyers worked as an Assistant District Attorney for just over five years when her boss transferred her to a different section of the criminal court. Meyers strongly opposed this transfer, and made her feelings known to several supervisors, including District Attorney Harry Connick. Before the official transfer took place, Meyers prepared a questionnaire asking for her co-workers views on the transfer policy, office morale, and the level of confidence in supervisors. When Connick learned of the questionnaire, he immediately terminated Meyers. He said he fired her because she refused to accept her transfer. He also said that distributing the questionnaire was insubordination. Meyers sued, alleging that her termination violated her First Amendment right to free speech. The district court ruled in favor of Meyers and ordered her reinstatement, payment of back pay, damages, and attorney fees. The U.S. Court of Appeals for the Fifth Circuit affirmed. </p>

majority opinion

reversed

First Amendment

Zant v. Stephens

https://api.oyez.org/cases/1982/81-89

81-89

1982

Walter Zant, Warden of Georgia Diagnostic and Classification Center

Alpha Otis O'Daniel Stephens

<p>A jury in the Bleckly County Superior Court convicted Alpha Stephens of murder and sentenced him to the death penalty based on two of three possible statutory aggravating circumstances. While Stephens’ appeal was pending, the Supreme Court of Georgia ruled one of the aggravating circumstances that justify the death penalty invalid. After exhausting all post conviction remedies, Stephens filed a writ of habeas corpus in Federal district court. The district court denied relief, but the U.S. Court of Appeals for the Fifth Circuit reversed.</p> <p>On certiorari, the U.S. Supreme Court certified the Supreme Court of Georgia to answer the question of what state law premises support affirming Stephens death sentence, even though one of the aggravating circumstances was now invalid. The Georgia court responded, holding that the jury used other aggravating circumstances along with the invalid one to sentence Stephens, so his sentence should stand.</p>

majority opinion

reversed

Criminal Procedure

Perry Education Association v. Perry Local Educators' Association

https://api.oyez.org/cases/1982/81-896

81-896

1982

Perry Education Association

Perry Local Educators' Association

<p>The Perry Education Association (PEA) won an election against the Perry Local Educators' Association (PLEA) to serve as the sole union representing teachers in Perry Township, Indiana. As part of the collective-bargaining agreement reached between PEA and the Board of Education of Perry Township, PEA obtained exclusive rights to use the internal school mail system and PLEA was denied access. PLEA contended that denying their members use of the mail system violated the First Amendment and the Equal Protection Clauses of the Fourteenth Amendment. A Federal District Court ruled against PLEA but the United States Court of Appeals for the Seventh Circuit reversed.</p>

majority opinion

reversed

First Amendment

Brown v. Thomson

https://api.oyez.org/cases/1982/82-65

82-65

1982

Brown

Thomson

<p>In apportioning its state legislative seats, the State of Wyoming made provisions to allocate to each county at least one state representative. With the state's total population and its sixty-four House seats, the ideal apportionment would have been 7,337 persons per representative. Given the guarantee of county representation, Niobrara County, with a population of less than half the ideal (2,924), was allocated a House seat.</p>

majority opinion

affirmed

Civil Rights

IIllinois v. Gates

https://api.oyez.org/cases/1982/81-430

81-430

1982

Illinois

Lance Gates, et ux

<p>The Bloomingdale, Illinois Police Department received an anonymous tip that Lance and Susan Gates were selling drugs out of their home. After observing the Gates's drug smuggling operation in action, police obtained a warrant and upon searching the suspects' car and home uncovered large quantities of marijuana, other contraband, and weapons.</p>

majority opinion

reversed

Criminal Procedure

Energy Reserves Group, Inc. v. Kansas City Power & Light Company

https://api.oyez.org/cases/1982/81-1370

81-1370

1982

Energy Reserves Group, Inc.

Kansas City Power & Light Company

<p>The Kansas Power &amp; Light Company (KPL) entered long-term contracts in 1977 governing its purchase of natural gas from the Energy Reserves Group (ERG), a Kansas-based oil company. The contracts contained "price escalator" clauses which provided for gas prices to rise to the levels set by governmental authorities. In 1978, the federal government established a new system for regulating natural gas prices under the Natural Gas Policy Act. The Act set maximum lawful prices that could be charged for different types of natural gas and applied these price levels to intrastate gas markets. The Act allowed states to set maximum price levels below federal levels, which Kansas did under the Kansas Natural Gas Price Protection Act (Kansas Act). When ERG tried to raise its prices to the higher federal levels using the "price escalator" clause, KPL insisted that it was only legally obligated to buy gas at the lower prices set by the Kansas Act. ERG claimed that KPL violated the contract by refusing to pay federal prices. In response, KPL argued that the Kansas Act clearly prohibited the use of federal price levels to trigger "price escalator" clauses. After a state trial court ruled in favor of KPL, ERG claimed that the Kansas Act violated the Contract Clause by preventing federal price changes from affecting state contracts. The Supreme Court of Kansas held that the Kansas Act did not violate the Contract Clause since it was a legitimate effort by the state of Kansas to protect its economy from rapid price changes.</p>

majority opinion

affirmed

Economic Activity

Bush v. Lucas

https://api.oyez.org/cases/1982/81-469

81-469

1982

Bush

Lucas

<p>Bush, an aerospace engineer at the George C. Marshall Space Flight Center (Center), a facility operated by the National Aeronautics and Space Administration (NASA), made a series of public comments critical of the Center. Lucas, the Center <em>s director, demoted Bush on the ground that the comments were false and misleading. The Federal Employee Appeals Authority upheld the demotion, but the Civil Service Commission</em> s (CSC) Appeals Review Board later found that the demotion had violated his First Amendment rights. NASA accepted the Board_s recommendation that Bush be restored to his former position retroactively, with back pay. While his administrated appeal was pending, Bush brought suit against Lucas in Alabama state court, seeking to recover damages for violation of his First Amendment rights. Lucas removed the action to federal district court, which granted summary judgment for Lucas. The Fifth Circuit affirmed, holding that Bush had no cause of action for damages under the First Amendment in view of the available remedies under the CSC regulations.</p>

majority opinion

affirmed

Economic Activity

Hawaii Housing Authority v. Midkiff

https://api.oyez.org/cases/1983/83-141

83-141

1983

Hawaii Housing Authority

Midkiff

<p>After extensive hearings in the mid-1960s, the Hawaii legislature discovered that while Federal and State governments owned nearly 49 percent of the land in Hawaii, another 47 percent was owned by only 72 private landowners. To combat this concentration of ownership, the legislature enacted the Land Reform Act of 1967. The Act adopted a method of redistribution in which title in real property could be taken from lessors and transferred to lessees. Frank E. Midkiff, a landholder, challenged the Act.</p>

majority opinion

reversed/remanded

Due Process

Roberts v. United States Jaycees

https://api.oyez.org/cases/1983/83-724

83-724

1983

Roberts

United States Jaycees

<p>According to its bylaws, membership in the United States Jaycees was limited to males between the ages of eighteen and thirty-five. Females and older males were limited to associate membership in which they were prevented from voting or holding local or national office. Two chapters of the Jaycees in Minnesota, contrary to the bylaws, admitted women as full members. When the national organization revoked the chapters' licenses, they filed a discrimination claim under a Minnesota anti-discrimination law. The national organization brought a lawsuit against Kathryn Roberts of the Minnesota Department of Human Rights, who was responsible for the enforcement of the anti-discrimination law.</p>

majority opinion

reversed

First Amendment

Immigration and Naturalization Service v. Phinpathya

https://api.oyez.org/cases/1983/82-91

82-91

1983

Immigration and Naturalization Service

Padungsri Phinpathya

<p>The Immigration and Nationality Act grants the Attorney General the power to suspend the deportation of any otherwise deportable alien if the person has been consistently physically present in the United States for at least seven years, is of good moral character, and whose deportation would represent great hardship to the person and/or family members.</p> <p>Padrungsi Phinpathya, a citizen of Thailand, first entered the United States in 1969 as a nonimmigrant student. She and her husband, a Thai citizen who entered the country in 1968, were granted permission to stay until July 1971. When their visas expired, they chose to stay without the permission of the proper authorities. In January 1977, Immigration and Naturalization Services (INS) commenced deportation processes on the couple. They applied for a suspension, which an immigration judge granted to Phinpathya’s husband but denied for her because she did not meet the continuous residency requirement. Phinpathya’s own testimony showed that she left the country in 1974 and improperly obtained a visa from the US consular office in Thailand for her return three months later.</p> <p>The Board of Immigration Appeals affirmed the judge’s ruling and held that Phinpathya’s illegal status when she left and returned to the US made the absence “meaningfully interruptive” of her residency and made her ineligible for the suspension of deportation. The U.S. Court of Appeals for the Ninth Circuit reversed and held that, despite her absence, Phinpathya’s intent was always to return to the US.</p>

majority opinion

reversed

Civil Rights