This case involves a petition for a writ of habeas corpus filed by an attorney on behalf of Charles P. Stevens, who had been convicted of murder in California state court and sentenced to death. The petition claimed that Stevens' chosen trial lawyer conducted the defense unskillfully, amounting to a denial of due process. The court denied the petition, observing first that it should have been presented to a U.S. District Court rather than directly to the circuit judge. It further held that a defendant represented by counsel of his own selection cannot assert a constitutional violation based on that counsel's alleged incompetence or errors, and that no substantial federal constitutional claim had been shown to justify interfering with the state court's judgment.
This case involved a petition to review the Board of Tax Appeals' decision upholding income tax deficiencies against Stanley S. Anderson for 1924 and 1925, based on the Commissioner's determination that all income derived from community property taxable solely to the husband. The taxpayer argued that he and his wife owned the underlying property as tenants in common with each holding a separate one-half interest, due to an oral agreement between them that altered its status under California law. The court observed that the Board's findings recited evidence about the couple's testimony on the agreement but did not make a specific finding on the ultimate fact of ownership or whether the agreement existed. It held that without such a finding, appellate review could not proceed, and remanded the case to the Board of Tax Appeals for explicit determinations on the agreement's existence and terms and the resulting character of the property as community or separate. The core reasoning emphasized the distinction between evidentiary facts and ultimate facts, the reviewing court's inability to assess witness credibility or make findings, and the legal effect of spousal agreements under California Civil Code section 158.
The case involved a property owner who borrowed money secured by two deeds of trust on real properties in San Francisco and Napa County, California, and after a foreclosure sale under the second deed of trust followed by transfers of title, filed suit to quiet title alleging fraud by the lenders and trustees as well as violations of due process in the foreclosure proceedings under state statutes. The district court dismissed the bill for failure to state a cause of action and lack of jurisdiction. On appeal, the court affirmed, reasoning that the Fourteenth Amendment due process claims could not proceed because they targeted only the conduct of private parties rather than any state action, and that the allegations otherwise failed to establish a federal claim.
This case involves appeals from decrees enjoining the Project Manager of the Flathead Irrigation Project from assessing charges on landowners for the project's construction, operation, and maintenance, and from challenging their claimed water rights from Finley Creek. The plaintiffs, owners of former Indian allotments, argued their lands had pre-existing water rights exempting them from project charges. The appellate court reversed the lower court's decisions, holding that the suits could not proceed without joining the United States and the Secretary of the Interior as necessary parties because the project charges are authorized by the Secretary and involve federal property rights. The core reasoning is that a subordinate federal officer cannot be sued alone to adjudicate such federal interests, based on precedents requiring higher officials as defendants.
This case involved a challenge by an employer and its insurance carrier to a compensation award made by a deputy commissioner under the Longshoremen’s and Harbor Workers’ Compensation Act to the widow of a stevedore who became ill and died after performing heavy lifting work on a ship. The district court dismissed the challenge and upheld the award, and the appellate court affirmed that decision. The court reasoned that the deputy commissioner had authority to resolve factual disputes and that evidence supported the finding that the employee’s fatal pneumothorax was caused by strain from the work, qualifying as a compensable accidental injury arising out of and in the course of employment even with a preexisting condition. The court further held that the statutory burial allowance was properly included because the widow’s verified claim stated the expense and it was not contested. The topics are labor & employment and procedure.
The case was a lawsuit by a life insurance beneficiary against the insurer seeking payment on two policies after her husband disappeared in 1929. The jury found for the plaintiff and awarded $10,000, leading to an appeal by the insurance company that challenged the sufficiency of the evidence of death before the seven-year presumption period. The Ninth Circuit affirmed the judgment, concluding that circumstantial evidence of the insured's long-standing suicidal mania, physical frailty, recent threats, and disappearance near the bay supported the jury's finding of death. The court rejected arguments requiring proof of a specific external peril and found no reversible error in the trial court's amendment or jury instructions.