Hugo Lafayette Black

In Palmer v. Thompson, the city of Jackson, Mississippi, closed its public swimming pools rather than operating them on a desegregated basis following a court ruling that racial segregation in public facilities violated the Equal Protection Clause. Petitioners, Negro citizens, sued to compel the city to reopen and desegregate the pools. The Supreme Court affirmed the lower courts' decisions, holding that the city's action did not deny equal protection because it closed the facilities to all races equally, without providing alternatives or maintaining segregation, and states have no affirmative duty under the Fourteenth Amendment to operate swimming pools. The Court distinguished the case from precedents like Griffin v. County School Board, noting the absence of state-supported private segregated facilities or other discriminatory schemes.

civil rights

The case concerned Danish immigrant Otto Astrup, who in 1950 signed a form seeking exemption from U.S. military service under the Selective Service Act of 1948 in exchange for permanent ineligibility for citizenship; after Congress repealed the exemption, the government tried to draft him but found him physically unfit, then denied his naturalization petition. The Supreme Court reversed the district court and Ninth Circuit rulings that had barred him from citizenship. It reasoned that Section 315 of the Immigration and Nationality Act of 1952 imposes a two-pronged requirement—both applying for and actually being relieved from service—and that temporary or ineffective relief due to changed law and medical disqualification did not trigger the bar, distinguishing prior precedent under the 1917 Act.

immigration

This case involved a challenge to Louisiana laws that prevented an acknowledged illegitimate child from inheriting equally from her father's intestate estate, unlike legitimate children. The Supreme Court upheld the constitutionality of these laws, ruling that they did not violate the Due Process or Equal Protection Clauses. The Court reasoned that states have wide latitude to regulate the distribution of property through inheritance laws and that the distinctions drawn between legitimate and illegitimate children were not arbitrary but served legitimate state interests, distinguishing this from prior cases involving tort recoveries.

family lawpropertycivil rights

This case involved challenges to Article XXXIV of the California Constitution, which required majority voter approval in a referendum before any low-rent public housing project could be developed with federal or state assistance. Plaintiffs, eligible for such housing in areas where referendums had failed, argued that the provision violated the Supremacy Clause, Privileges and Immunities Clause, and Equal Protection Clause of the U.S. Constitution. The Supreme Court reversed the district court's ruling that the article denied equal protection, holding that unlike racial classifications in prior cases, this referendum requirement applied generally to low-income housing decisions without creating suspect racial distinctions. The Court reasoned that the federal Housing Act does not prohibit local referendums and that California's process reflects a valid exercise of the people's initiative and referendum powers over legislative matters.

civil rightselections

The case concerned whether Yee Chien Woo, who fled mainland China in 1953 and lived in Hong Kong for six years before entering the United States as a visitor, qualified for a refugee preference visa under § 203(a)(7) of the Immigration and Nationality Act. Immigration officials denied the application on the ground that Woo had firmly resettled in Hong Kong, making his presence in the United States unrelated to his original flight from persecution. The District Court found no firm resettlement, and the Ninth Circuit held that resettlement was irrelevant because Woo remained stateless and a national of Communist China. The Supreme Court held that the firmly resettled concept is relevant under the statute, which was intended to benefit those whose presence in the United States is a direct consequence of fleeing persecution rather than those who had established roots elsewhere before seeking entry. The Court remanded for further review under the proper legal standard without deciding whether Woo himself had resettled.

immigration

The case involved a physician indicted under the District of Columbia abortion statute for performing abortions; the district court dismissed the indictments, ruling the law unconstitutionally vague. The Supreme Court first addressed jurisdiction under the Criminal Appeals Act and held that it had authority to hear the direct appeal because the D.C. law qualified as a statute enacted by Congress. On the merits, the Court concluded the statute was not unconstitutionally vague, as its terms provided adequate notice of prohibited conduct and permitted abortions when necessary to preserve the mother's life or health, and therefore reversed the dismissal.

abortioncriminal law

This case involved the Michigan State Bar seeking to enjoin members of a railroad workers' union from recommending designated attorneys to injured members and their families for Federal Employers' Liability Act claims, securing agreements to cap fees at 25 percent of recovery, and assisting with transportation to those attorneys. The state trial court issued an injunction barring these activities as violations of a state statute against soliciting damage suits against railroads, and the Michigan Supreme Court affirmed after narrowly construing relevant precedents. The U.S. Supreme Court reversed, ruling that the First Amendment protections for free speech, petition, and assembly bar the injunction because they guarantee workers the right to act collectively to obtain competent and affordable legal representation. The decision relied on the holdings in Brotherhood of Railroad Trainmen v. Virginia State Bar, United Mine Workers v. Illinois State Bar Assn., and NAACP v. Button.

free speechlabor & employmentcivil rights

This case concerned whether a federal district court could enjoin a pending state criminal prosecution under California's Criminal Syndicalism Act on grounds that the law violated the First and Fourteenth Amendments. John Harris, the defendant in the state case, along with intervenors, claimed the prosecution chilled their free speech rights, and the district court agreed, declaring the law unconstitutional and halting the proceedings. The Supreme Court reversed, ruling that principles of comity and federalism, as embodied in 28 U.S.C. § 2283, prohibit federal courts from enjoining state court proceedings absent extraordinary circumstances, and that constitutional issues should instead be litigated in the state system.

criminal lawfree speechfederal power

In Boyle v. Landry, seven groups of African American residents in Chicago sued city and county officials in federal court, seeking declaratory and injunctive relief against enforcement of Illinois statutes on mob action, resisting arrest, aggravated assault, aggravated battery, and intimidation, alleging the laws were used to harass them and suppress their constitutional rights through arrests without probable cause and excessive bail. A three-judge district court upheld most statutes but declared one subsection of the intimidation statute unconstitutionally overbroad and permanently enjoined its enforcement. The Supreme Court reversed, ruling that the complaint showed no actual prosecutions, threats, or irreparable injury under the invalidated provision and that federal courts may not disrupt ongoing or future state criminal proceedings based on speculative claims of bad-faith enforcement.

civil rightscriminal lawfederal powerfree speech

In Perez v. Ledesma, operators of a Louisiana newsstand faced state criminal charges under a statewide obscenity statute and a local parish ordinance for selling allegedly obscene materials. After a three-judge federal district court found the arrests and seizures invalid due to the lack of a prior adversary hearing on obscenity, it ordered suppression of evidence and return of the materials while upholding the statute on its face. The Supreme Court reversed those orders, holding that federal courts may not interfere with pending state criminal prosecutions by suppressing evidence or directing return of materials absent proven bad faith or harassment by state officials. The Court explained that questions of arrest validity and evidence admissibility belong in state courts, subject to eventual federal review, and that it lacked jurisdiction to review any declaratory ruling on the local ordinance. The decision applied principles from Younger v. Harris limiting federal intervention in state criminal proceedings.

criminal lawfederal powerfree speechprocedure

The case concerned challenges by several states to provisions of the Voting Rights Act Amendments of 1970 that lowered the minimum voting age to 18 in all elections, banned literacy tests for five years in all elections, and prohibited states from imposing durational residency requirements for voting in presidential and vice-presidential elections. The Court held that Congress has authority under the Constitution to set voter qualifications for federal elections, including lowering the voting age to 18 and barring residency barriers, but lacks power to alter state-set voting ages for state and local elections. It further ruled that Congress validly exercised its enforcement powers under the Fourteenth and Fifteenth Amendments to prohibit literacy tests nationwide. The fragmented opinions produced a judgment that the 18-year-old voting provisions are enforceable only for federal elections and that the literacy-test and residency provisions are valid in full.

electionscivil rightsfederal power

This case concerned whether a federal district court could properly issue an injunction preventing enforcement of a Florida state court's injunction against picketing by the Brotherhood of Locomotive Engineers at a railroad switching yard owned by Atlantic Coast Line Railroad. The dispute arose from a labor conflict involving another railroad, and after the Supreme Court's related decision in Brotherhood of Railroad Trainmen v. Jacksonville Terminal Co., the union sought to dissolve the state injunction but instead obtained a federal injunction against it. The Supreme Court decided that the federal injunction violated the federal anti-injunction statute, 28 U.S.C. § 2283, which generally bars federal courts from enjoining state court proceedings. The core reasoning was that neither exception invoked—protecting or effectuating a prior federal judgment or aiding federal jurisdiction—applied, as the 1967 denial of an injunction did not create such a protectable judgment and the injunction was not necessary for jurisdiction.

labor & employmentfederal powerprocedure

The case involved Daniel Jay Schacht, who was convicted under 18 U.S.C. § 702 for wearing distinctive parts of a U.S. Army uniform without authorization while participating in an anti-Vietnam War street skit performed outside an Armed Forces Induction Center. Schacht defended on the ground that 10 U.S.C. § 772(f) authorized such use by actors in theatrical productions, though the statute limited the authorization to portrayals that do not tend to discredit the armed forces. The Supreme Court held that the skit qualified as a theatrical production within the meaning of § 772(f) but ruled that the statutory restriction on portrayals tending to discredit the military imposed an unconstitutional restraint on free speech under the First Amendment.

free speechcriminal law

This case concerned whether a criminal defendant could be removed from the courtroom for disruptive conduct despite the Sixth Amendment's Confrontation Clause guarantee of the right to be present at trial. The defendant Allen, who was representing himself in an armed robbery prosecution, repeatedly interrupted jury selection with abusive remarks, threw papers, threatened the judge, and stated he would prevent any trial from occurring, leading the trial judge to order his removal after warnings. The Supreme Court held that the trial court did not violate Allen's constitutional rights by excluding him and proceeding with the trial in his absence, with the defendant later returned for identification purposes. The core reasoning was that the right to confrontation, while fundamental and applicable to the states, is not absolute and may be forfeited by a defendant whose speech and conduct make it impossible to conduct an orderly trial.

criminal lawprocedure

The case involved Robert Toussie, who was convicted for failing to register for the military draft as required by the Universal Military Training and Service Act after turning 18 in 1959. The Supreme Court reversed the conviction, holding that the prosecution was barred by the five-year statute of limitations under 18 U.S.C. § 3282. The Court reasoned that the offense of failing to register is not a continuing one that extends the limitations period, as the statute does not explicitly provide for a continuing duty beyond the initial registration window, and continuing offenses should be narrowly applied to favor repose. The duty to register ends at age 26, but the crime was complete shortly after turning 18, making the 1967 indictment untimely.

criminal lawprocedure

The case concerned a 1911 will by Senator A.O. Bacon that established a public park in Macon, Georgia, for the exclusive use of white people, with the city as trustee. After the Supreme Court's prior ruling in Evans v. Newton held that the park could not operate on a racially discriminatory basis under the Fourteenth Amendment, the Georgia Supreme Court determined that the trust's purpose had become impossible to fulfill and that the property therefore reverted to the Senator's heirs under state law. Petitioners, Black citizens of Macon, argued that this reversion violated their rights to equal protection and due process. The Court affirmed the Georgia judgment, reasoning that the trust's failure and resulting reverter stemmed from the testator's private discriminatory intent rather than unconstitutional state action, and that Georgia law governing failed trusts applied neutrally without injecting state policy into the discrimination.

civil rightsproperty

The case involved a dispute between H. K. Porter Co. and the United Steelworkers Union over the company's refusal to agree to a checkoff provision for union dues during collective bargaining negotiations after the union was certified as the bargaining agent. The National Labor Relations Board found that the refusal was in bad faith solely to frustrate any agreement and ordered the company to grant the checkoff clause as a remedy. The Supreme Court held that the Board lacks authority under the National Labor Relations Act to compel an employer to agree to any specific contractual term, even to remedy unfair labor practices. The core reasoning is that the Act requires good-faith bargaining but preserves the freedom of parties to reach voluntary agreements without government imposition of terms.

labor & employment

This case concerned whether the Equal Protection Clause of the Fourteenth Amendment and the one-person, one-vote principle apply to the election of trustees for a junior college district formed by combining several Missouri school districts. The district's apportionment formula, based on school-age population counts, gave the Kansas City component district only three of six trustees despite containing about 60% of the total enumeration. The Supreme Court reversed the Missouri Supreme Court's dismissal of the challenge, holding that the principle requires apportionment of such local officials so that each voter's ballot carries substantially equal weight when the body exercises general governmental powers over the area. The Court reasoned that precedents such as Wesberry v. Sanders, Reynolds v. Sims, and Avery v. Midland County extend to these trustees because their authority to levy taxes, issue bonds, hire staff, and manage operations has sufficient district-wide impact. The decision requires future apportionment to avoid diluting any voter's influence to the extent practicable.

electionscivil rights

This case concerned a dispute under the Railway Labor Act between the Detroit & Toledo Shore Line Railroad and a union representing its employees over the railroad's plan to create new outlying work assignments that would change where crews reported for duty. The union responded with Section 6 notices proposing amendments to the collective bargaining agreement, triggering mediation before the National Mediation Board, but the railroad proceeded to implement the assignments anyway. The Supreme Court held that the Act's status quo provision barred the railroad from unilaterally altering actual, objective working conditions during the mediation process, even if those conditions were not explicitly covered in the existing agreement. The Court reasoned that the statutory language requiring maintenance of "rates of pay, rules, or working conditions" and the Act's overall purpose of providing an extended opportunity for settlement both supported preserving the pre-dispute conditions to prevent one side from gaining an advantage through self-help.

labor & employment

In Perkins v. Standard Oil Co. of California, a distributor of gasoline and oil sued the company under Section 2 of the Clayton Act as amended by the Robinson-Patman Act, alleging that discriminatory lower prices given to branded dealers and to Signal Oil & Gas Co. harmed his business and forced its sale. After a jury awarded damages, the Ninth Circuit reversed in part, holding that competitive injury from price advantages passed through an indirect chain of distribution (Standard to Signal to Western Hyway to Regal stations) was too remote to be covered by the Act. The Supreme Court reversed that holding, ruling that the statute reaches such injuries because it applies to discrimination whose effect may injure competition with a person who knowingly receives the benefit of the discrimination or with customers of either.

business & regulatory