Lewis Franklin Powell jr

The case concerned whether the Eighth Amendment bars a jury in a capital murder trial from considering a victim impact statement (VIS) during sentencing. The Supreme Court held that such statements are unconstitutional in this context. The VIS, compiled from interviews with the victims' family, described the victims' personal qualities and the emotional, psychological, and practical effects of the murders on surviving relatives. The Court reasoned that this information is irrelevant to the defendant's moral culpability, risks arbitrary sentencing by diverting the jury's focus from the crime itself, and is particularly problematic in death penalty cases where heightened reliability is required.

criminal lawcivil rights

In Greer v. Miller, the Supreme Court addressed whether a prosecutor's single, unanswered question during cross-examination of a criminal defendant about his post-arrest silence violated due process under Doyle v. Ohio and required reversal of the conviction for murder, kidnapping, and robbery. The Court reversed the Seventh Circuit's grant of habeas relief, holding that no constitutional violation occurred because the prosecutor did not exploit the reference, the trial court immediately sustained the objection and instructed the jury to disregard the question, and the comment was isolated. The core reasoning focused on the limited nature of the reference in the context of a lengthy trial, the sufficiency of the other evidence establishing guilt, and the effectiveness of the curative instruction in preventing any unfair prejudice.

criminal lawprocedure

In Arizona v. Mauro, a murder suspect in custody invoked his Miranda right to counsel, after which police allowed him to speak with his wife in an officer's presence and recorded the conversation without asking questions. The recording was admitted at trial to rebut an insanity defense, resulting in conviction, but the Arizona Supreme Court reversed on the ground that permitting the meeting amounted to impermissible interrogation. The U.S. Supreme Court reversed, holding that the officers' actions did not constitute the functional equivalent of interrogation under Miranda because they had legitimate security and safety reasons for the supervised meeting, did not create the situation as a ruse, and the conduct was not reasonably likely to elicit incriminating statements. The decision rested on the principle that interrogation requires words or actions by police that they should know are likely to produce an incriminating response.

criminal lawprocedure

The case involved the San Francisco Arts & Athletics, Inc. (SFAA) attempting to organize the "Gay Olympic Games" and use the word "Olympic" in promotions, which the United States Olympic Committee (USOC) sought to prevent under the Amateur Sports Act of 1978. The Supreme Court affirmed the lower courts' decisions granting the USOC an injunction, ruling that the Act provides the USOC with exclusive rights to the word "Olympic" for commercial and promotional uses without needing to demonstrate consumer confusion or other trademark defenses. The Court reasoned that the statutory grant is broader than traditional trademark protection and does not constitute a First Amendment violation because the USOC is not a state actor and the restriction is narrowly tailored to protect the USOC's authorized interests.

free speechbusiness & regulatory

In Commissioner v. Fink, dominant shareholders of a financially troubled corporation voluntarily surrendered a portion of their shares without consideration to make the company more attractive to outside investors, then claimed an immediate ordinary loss deduction equal to their adjusted basis in the surrendered shares on their federal tax returns. The Commissioner disallowed the deductions, treating the surrenders as contributions to capital with the basis added to the taxpayers' remaining shares. The Supreme Court held that shareholders who surrender stock but retain control may not immediately deduct their basis as a loss. The Court reasoned that the surrenders were made to protect and increase the value of the retained shares, so no loss is realized until the shareholders dispose of their remaining stock.

taxesbusiness & regulatory

This case concerned the validity of a regulation used by the Secretary of Health and Human Services to determine eligibility for Social Security disability benefits under Titles II and XVI of the Social Security Act. The regulation, part of a five-step sequential evaluation process, denies benefits at step two if the claimant lacks a medically severe impairment that significantly limits the ability to perform basic work activities, without considering age, education, or work experience. The Supreme Court held that the Secretary has authority under the Social Security Act to establish this severity threshold and that the regulation is consistent with the statutory definition of disability, which requires an impairment severe enough to prevent substantial gainful activity. The Court reasoned that the Act grants the Secretary broad discretion to implement the disability program efficiently, and the regulation aligns with congressional intent reflected in the 1967 amendments to limit benefits to those with severe impairments.

healthcarefederal powerprocedure

The case involved Warren McCleskey, a Black man convicted in Georgia of murdering a white police officer during an armed robbery, who was sentenced to death after the jury found two statutory aggravating factors. McCleskey challenged his sentence under the Eighth and Fourteenth Amendments, relying on the Baldus statistical study of over 2,000 Georgia murder cases from the 1970s, which showed that defendants charged with killing white victims were far more likely to receive the death penalty than those charged with killing Black victims. The Supreme Court held that the study did not establish that McCleskey's own sentence was unconstitutionally imposed. The Court reasoned that the statistical disparities demonstrated only a risk that race could influence some sentencing decisions, not that it had done so in this particular case or that the Georgia system operated arbitrarily or with discriminatory intent in violation of the Constitution.

criminal lawcivil rights

The case concerned which appellate court has jurisdiction over a district court decision involving both a nontax Little Tucker Act claim and a Federal Tort Claims Act claim arising from the internment of Japanese-Americans during World War II. The Supreme Court held that the Court of Appeals for the Federal Circuit has exclusive jurisdiction over such appeals. The Court reasoned that under 28 U.S.C. § 1295(a)(2), the except clause excludes certain claims like FTCA from independently granting Federal Circuit jurisdiction but does not divest it when those claims are joined with Little Tucker Act claims that do confer such jurisdiction, consistent with the legislative intent for centralized review of mixed cases involving federal claims.

procedurecivil rights

The case concerned whether the Feres doctrine barred a suit under the Federal Tort Claims Act brought by the estate of a Coast Guard helicopter pilot killed during a rescue mission after receiving allegedly negligent radar instructions from civilian FAA employees. The district court dismissed the complaint under Feres, which precludes tort actions by service members for injuries arising out of or in the course of activity incident to service. The court of appeals reversed, reasoning that the doctrine should not apply when the alleged tortfeasors were civilians and the suit would not affect military discipline. The Supreme Court reversed, holding that Feres bars recovery whenever the injury is incident to service, irrespective of whether the negligence is attributed to military or civilian federal employees, to maintain uniformity in treatment of service-related claims and avoid judicial interference in military affairs.

torts & liabilityfederal power

The case concerned whether a California statute known as the Unruh Civil Rights Act, which prohibits discrimination by business establishments, could require Rotary International to admit women as members without violating the organization's First Amendment rights to freedom of association. Rotary International had revoked the charter of the Duarte club after it admitted three women, leading to a lawsuit by the club and the women. The trial court ruled in favor of Rotary International, finding the clubs were not business establishments and that their purposes were primarily social and service-oriented rather than commercial. The California Court of Appeal reversed, holding that the clubs qualified as business establishments under the Act. The U.S. Supreme Court addressed whether the clubs' membership practices involved sufficiently intimate or private associations to receive constitutional protection, noting factors such as club size, business networking benefits, lack of selectivity in some classifications, and the non-intimate nature of many activities.

civil rightsfree speech

The case concerned whether Indiana's Control Share Acquisitions Act, which conditions an acquirer's voting rights in an Indiana corporation on approval by a majority of preexisting disinterested shareholders once ownership thresholds of 20%, 33 1/3%, or 50% are reached, was preempted by the federal Williams Act or violated the Commerce Clause. The Supreme Court held that the Indiana statute was neither preempted by federal law nor unconstitutional. The Court reasoned that the Act regulates voting rights in shares of corporations incorporated in the state, a traditional area of state authority over internal corporate affairs, and is consistent with the Williams Act's purposes of disclosure and shareholder decision-making. The law was also found to regulate evenhandedly without imposing an excessive burden on interstate commerce.

business & regulatoryfederal power

The case involved a multi-billion-dollar Texas state court judgment against Texaco for tortiously interfering with Pennzoil's contract to purchase Getty Oil shares. After the verdict but before final judgment, Texaco filed a federal suit in New York seeking to enjoin Pennzoil from enforcing the judgment under Texas lien and bond rules, claiming those rules violated Texaco's federal constitutional rights. The Supreme Court held that the federal district court should have abstained under Younger v. Harris rather than issuing an injunction. The core reasoning was that federal intervention would improperly interfere with ongoing state judicial proceedings that implicate important state interests in the enforcement of judgments, and principles of comity and federalism require federal courts to defer absent extraordinary circumstances.

business & regulatoryfederal powerprocedure

This case involved a dispute over whether a district court's pretrial order denying intervention as of right but granting permissive intervention with restrictions was immediately appealable in ongoing litigation concerning cleanup of the Stringfellow Acid Pits hazardous waste site. The Supreme Court held that such an order is not immediately appealable under 28 U.S.C. § 1291. The Court reasoned that the order was not final because it did not end the litigation on the merits, did not satisfy the collateral order doctrine as the intervenor's interests remained reviewable after final judgment, and restrictions on permissive intervention are generally not appealable absent an abuse of discretion.

procedureenvironment

The case concerned whether a suspect's waiver of Miranda rights is invalid if police do not inform him in advance of all crimes about which he may be questioned. Spring was arrested on federal firearms charges, waived his rights, and made statements during ATF questioning that touched on a Colorado homicide; he later gave a full confession to state officers after another waiver. The Supreme Court held that the waivers were valid and the statements admissible. It reasoned that Miranda requires only that the waiver be voluntary, knowing, and intelligent with respect to the Fifth Amendment privilege itself, and that a suspect's awareness of the specific topics of interrogation is not a necessary element of that determination.

criminal lawprocedure

This case concerned whether the Clean Water Act preempts a Vermont common-law nuisance action brought by Vermont lakeside property owners against a New York paper mill whose effluent discharges into Lake Champlain allegedly harmed Vermont waters. The Supreme Court held that the Act does not entirely displace state-law remedies but does preempt the application of the affected state's (Vermont's) common law to an out-of-state source; only the source state's (New York's) law may be used in such suits. The Court reasoned that the Act's comprehensive permitting and regulatory scheme for point sources would be undermined by allowing multiple states' varying tort standards to impose additional or conflicting requirements on the same discharger. It interpreted the Act's saving clauses as preserving state authority consistent with this single-source-state framework rather than authorizing affected-state suits. The case was remanded for further proceedings under that rule.

environmentfederal powertorts & liabilitybusiness & regulatory

The case concerned New York's Alcoholic Beverage Control Law, which required liquor retailers to sell at no less than 112 percent of wholesalers' posted bottle prices while allowing wholesalers to discount case prices without lowering bottle prices, thereby enabling wholesalers to control retail markups and maintain artificially high prices. A retailer challenged penalties imposed for selling below the required markup, arguing that the system constituted illegal resale price maintenance under Section 1 of the Sherman Act. The Supreme Court held that the pricing scheme was not protected by the state-action immunity doctrine under Parker v. Brown because the state did not actively supervise the resulting prices, and that the Twenty-first Amendment did not shield the law since the state's interest in protecting retailers was insufficient to override federal antitrust policy. The Court reversed the New York Court of Appeals and invalidated the relevant provisions as applied.

business & regulatoryfederal power

The case concerned whether a state criminal restitution obligation imposed as a condition of probation could be discharged in a Chapter 7 bankruptcy proceeding. Carolyn Robinson, convicted of larceny for fraudulently obtaining welfare benefits, was placed on probation and ordered to pay restitution to the state; after her bankruptcy discharge, she stopped payments and sought a declaration that the obligation had been discharged. The Supreme Court held that the restitution was nondischargeable under 11 U.S.C. § 523(a)(7), reasoning that it qualified as a fine, penalty, or forfeiture payable to and for the benefit of a governmental unit and was not merely compensation for pecuniary loss, given its roots in the state's criminal justice and rehabilitative functions. The Court emphasized the traditional restraint of federal courts from interfering with state criminal proceedings.

criminal lawfederal powerprocedure

Darden v. Wainwright was a federal habeas corpus challenge by a Florida death row inmate to his 1974 convictions for murder, robbery, and assault with intent to kill, and the resulting death sentence. The Supreme Court considered three claims: improper exclusion for cause of a prospective juror opposed to the death penalty, prosecutorial misconduct in the guilt-phase closing argument that allegedly rendered the trial unfair, and ineffective assistance of counsel at sentencing. The Court affirmed the denial of relief, upholding the conviction and sentence. It held that the juror exclusion met the impartiality standards of Wainwright v. Witt, that the prosecutor's comments—though improper—did not deprive the defendant of fundamental fairness in light of the evidence and curative instructions, and that the ineffective-assistance claim was without merit.

criminal lawprocedure

The case concerned whether the Flood Control Act's broad immunity clause, 33 U.S.C. § 702c, shields the United States from liability under the Federal Tort Claims Act for personal injuries and deaths caused by negligent failure to warn recreational users of dangerous currents created when federal flood-control projects release water. The accidents occurred at the Millwood Dam in Arkansas and the Courtableau Drainage Structure in Louisiana, where boaters and skiers were swept through open gates despite the government's knowledge of the hazards and inadequate or missing warnings. The Supreme Court held that the statutory immunity applies and bars recovery, reasoning that the phrase "any damage from or by floods or flood waters" encompasses personal injury as well as property damage and that Congress intended an absolute bar without exception for negligence claims arising from flood-control operations. Legislative history and the statute's text were read to confirm that the immunity was enacted as a comprehensive protection tied to federal flood-control activities.

federal powertorts & liability

This case concerned a Tennessee defendant's convictions for first- and second-degree murder, where the trial court instructed the jury that all homicides are presumed malicious unless rebutted by evidence, an instruction later found to violate due process under Sandstrom v. Montana by improperly shifting the burden of proof on the malice element. Lower courts granted habeas relief on the ground that the error could not be harmless because the defendant had contested mens rea. The Supreme Court held that the harmless-error standard of Chapman v. California applies to such Sandstrom errors in jury instructions. The core reasoning was that these errors are trial errors that do not necessarily render a trial fundamentally unfair or preclude the jury from considering the evidence of guilt, unlike certain structural defects that require automatic reversal.

criminal lawprocedure