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Born 1906 · Newark, NJ
Rutan v. Republican Party of Illinois
Supreme Court of the United States · 1990-08-30 · cited 1236×
The case concerned Illinois state employment practices under Governor James Thompson, in which a hiring freeze was administered through the Governor's Office to favor applicants and employees who supported the Republican Party for decisions involving hiring, promotions, transfers, and recalls after layoffs. Plaintiffs, including low-level public workers like Cynthia Rutan and others, alleged they were denied these employment benefits solely because they lacked Republican Party support, claiming violations of their First Amendment rights. The Supreme Court held that the First Amendment prohibits basing such employment decisions on party affiliation and support for positions where party affiliation is not an appropriate requirement. This ruling extended the principles from Elrod v. Burns and Branti v. Finkel, which had barred patronage-based discharges, to these related practices. The Court reasoned that such patronage systems impose an unconstitutional condition on public employment by burdening employees' freedom of political belief and association.
free speechcivil rightslabor & employment
Metro Broadcasting, Inc. v. Federal Communications Commission
Supreme Court of the United States · 1990-06-27 · cited 280×
The case concerned two Federal Communications Commission policies that gave preferences to minority-owned businesses in awarding broadcast licenses: an enhancement factor in comparative hearings for new licenses and a distress-sale program allowing certain stations to be sold only to minority-controlled entities. Petitioners challenged these policies as violating the equal protection component of the Fifth Amendment. The Supreme Court upheld the policies, holding that they did not violate equal protection. The Court reasoned that the FCC's interest in promoting diversity of viewpoints through increased minority ownership was legitimate and substantially related to the policies, given the historical underrepresentation of minorities in broadcasting and the public-interest benefits of broader representation in license ownership.
civil rightsbusiness & regulatory
Maislin Industries, U. S., Inc. v. Primary Steel, Inc.
Supreme Court of the United States · 1990-06-21 · cited 508×
The case concerned whether the Interstate Commerce Commission could adopt a policy relieving shippers of the duty to pay filed tariff rates when they had privately negotiated lower rates with motor common carriers under the Interstate Commerce Act. The Supreme Court held that the Commission's policy was invalid and inconsistent with the statute. The Court reasoned that the Act explicitly requires carriers to charge and shippers to pay only the rates filed with the Commission, prohibits deviations through any means, and was designed to prevent discriminatory pricing. This filed-rate doctrine applies even where a lower rate was negotiated in good faith, and the Commission lacked authority to create equitable exceptions based on changes in industry conditions.
business & regulatoryfederal power
Pennsylvania v. Muniz
Supreme Court of the United States · 1990-06-18 · cited 976×
The case involved Inocencio Muniz, arrested for driving under the influence after failing roadside sobriety tests, who made statements and performed additional tests at a booking center before receiving Miranda warnings. The Supreme Court addressed whether Muniz's incriminating utterances during these procedures qualified as testimonial responses to custodial interrogation under the Fifth Amendment's Self-Incrimination Clause. The Court held that most routine booking questions, the physical components of the sobriety tests, and Muniz's refusal to take a breathalyzer did not require prior Miranda warnings because they elicited nontestimonial physical evidence. However, the question asking Muniz the date of his sixth birthday required warnings, as it was reasonably likely to produce an incriminating testimonial response about his cognitive state. The reasoning centered on distinguishing between physical evidence, which is unprotected, and communicative statements compelled by police questioning, which trigger Fifth Amendment safeguards.
criminal lawprocedure
Wilder v. Virginia Hospital Assn.
Supreme Court of the United States · 1990-06-14 · cited 1320×
The case concerned whether health care providers could sue state officials under 42 U.S.C. § 1983 to challenge Virginia's Medicaid reimbursement rates as violating the Boren Amendment's requirement that rates be reasonable and adequate for efficiently operated facilities. The Supreme Court held that providers may bring such an action because the Amendment's language creates enforceable federal rights and imposes binding obligations on participating states. The Court reasoned that the statutory text is sufficiently specific and mandatory, that Congress did not intend to foreclose private enforcement through the available administrative scheme, and that prior precedents supported allowing § 1983 suits to enforce similar statutory entitlements in cooperative federal-state programs like Medicaid.
healthcarecivil rightsfederal power
United States v. Eichman
Supreme Court of the United States · 1990-06-11 · cited 216×
This case involved the prosecution of individuals under the Flag Protection Act of 1989 for burning United States flags during protests against government policies and the Act itself. The District Courts dismissed the charges, finding the Act unconstitutional as applied, and the Supreme Court affirmed those rulings. The Court reasoned that, consistent with its prior decision in Texas v. Johnson, flag burning constitutes expressive conduct protected by the First Amendment, and the Act's prohibition targets conduct precisely because of its potential to communicate a particular message, subjecting it to strict scrutiny which it fails to satisfy. The government's interests in preserving the flag's symbolic value were deemed insufficient to justify the restriction on free expression.
free speechcriminal law
McKesson Corp. v. Division of Alcoholic Beverages and Tobacco, Fla. Dept. of Business Regulation
Supreme Court of the United States · 1990-06-04 · cited 690×
This case involved McKesson Corporation's challenge to Florida's liquor excise tax, which imposed higher rates on out-of-state distributors while granting preferential lower rates to certain in-state products made from Florida-grown crops. The Florida Supreme Court ruled the tax violated the Commerce Clause and barred its future enforcement but denied McKesson any refund or other relief for taxes already paid under the discriminatory scheme. The U.S. Supreme Court reversed that denial, holding that when a state requires taxpayers to pay a challenged tax first and seek review later, the Due Process Clause mandates a meaningful opportunity for post-payment relief if the tax is found unconstitutional. The Court reasoned that precedents require such relief to remedy the deprivation of property under an invalid tax, though states retain flexibility in choosing the form of remedy, such as refunds limited to excess amounts paid.
business & regulatorytaxesfederal power
Grady v. Corbin
Supreme Court of the United States · 1990-05-29 · cited 1620×
In Grady v. Corbin, the case arose after Thomas Corbin pleaded guilty to misdemeanor traffic offenses of driving while intoxicated and failing to keep right of the median following a fatal car accident; two months later, the state indicted him on felony charges including reckless manslaughter, vehicular manslaughter, criminally negligent homicide, and assault based on the same incident. The Supreme Court held that the Double Jeopardy Clause of the Fifth Amendment bars the subsequent prosecution because the government would need to prove the same conduct (intoxicated driving and crossing the median) that constituted the prior offenses in order to establish essential elements of the new charges. The Court adopted and applied the approach suggested in Illinois v. Vitale, ruling that even if the statutory elements differ under the Blockburger test, successive prosecutions are prohibited when the second case relies on proving conduct already prosecuted. The decision reversed the lower courts' denial of Corbin's motion to dismiss the indictment on double jeopardy grounds.
criminal law
Atlantic Richfield Co. v. USA Petroleum Co.
Supreme Court of the United States · 1990-05-14 · cited 783×
This case involved a lawsuit by USA Petroleum, an independent gasoline retailer, against Atlantic Richfield (ARCO) alleging that ARCO's vertical maximum price-fixing agreement with its dealers violated Section 1 of the Sherman Act by setting artificially low prices that caused USA to lose sales and drove competitors out of business. The Supreme Court held that USA did not suffer an antitrust injury under Section 4 of the Clayton Act and therefore could not bring a private suit. The core reasoning was that antitrust injury requires harm from the anticompetitive effects of the violation; nonpredatory maximum price fixing tends to lower prices for consumers rather than reduce competition, so any lost sales by rivals do not qualify as the type of injury the antitrust laws are designed to prevent.
business & regulatoryprocedure
Dole v. United Steelworkers
Supreme Court of the United States · 1990-02-21 · cited 352×
The case concerned whether the Office of Management and Budget could review and disapprove certain provisions of an OSHA hazard communication standard under the Paperwork Reduction Act of 1980. The standard required chemical manufacturers and employers to provide safety data sheets and labels to workers at multiemployer sites and narrowed exemptions for consumer products and drugs. The Supreme Court held that OMB lacked authority to review these disclosure requirements because the Act applies only to the collection of information for the government's own use, not to rules mandating disclosure directly to employees or the public. The Court reached this conclusion based on the statutory definitions of "collection of information," the Act's purposes and legislative history, and the absence of any requirement that the information be provided to or used by a federal agency.
business & regulatorylabor & employmentfederal power
Preseault v. Interstate Commerce Commission
Supreme Court of the United States · 1990-02-21 · cited 673×
The case involved a challenge to the National Trails System Act Amendments of 1983, which allow the conversion of unused railroad rights-of-way into recreational trails even when state law might provide for reversion of the property to adjacent landowners upon abandonment. Petitioners argued that this statute violated the Fifth Amendment's Takings Clause by preventing reversionary interests and exceeded Congress's power under the Commerce Clause. The Supreme Court held that it was unnecessary to decide if a taking occurred because any such taking would be compensable under the Tucker Act, satisfying constitutional requirements, and that the statute was a valid exercise of Commerce Clause authority to regulate railroads and preserve rail corridors for potential future use.
propertyfederal power
James v. Illinois
Supreme Court of the United States · 1990-01-10 · cited 171×
The case concerned whether the impeachment exception to the Fourth Amendment exclusionary rule, which allows illegally obtained evidence to impeach a defendant's testimony, could be extended to impeach testimony from other defense witnesses. After the defendant was convicted of murder and attempted murder, the Illinois Supreme Court upheld the use of suppressed statements about his hair color to contradict a defense witness, but the U.S. Supreme Court reversed. The Court decided that the exception does not extend beyond the defendant himself. Its core reasoning was that expanding the exception would substantially undermine the exclusionary rule's deterrent effect on police misconduct while providing only marginal benefits to the truth-seeking process at trial.
criminal lawprocedure
Breininger v. Sheet Metal Workers International Ass'n Local Union No. 6
Supreme Court of the United States · 1989-12-05 · cited 277×
The case involved a union member suing his local union for breaching its duty of fair representation under the NLRA and violating the LMRDA by allegedly discriminating against him in job referrals from a nonexclusive hiring hall based on his political opposition to union leadership. The Supreme Court held that federal courts have jurisdiction over the fair representation claim and that the NLRB's jurisdiction is not exclusive, but affirmed dismissal of the LMRDA claims. The Court reasoned that duty of fair representation suits may proceed in court without an allegation of employer breach of the collective bargaining agreement, while LMRDA §§ 101(a)(5) and 609 prohibit only formal union discipline affecting membership status, not economic reprisals such as denial of hiring hall referrals.
labor & employmentfederal power
South Carolina v. Gathers
Supreme Court of the United States · 1989-08-30 · cited 540×
The case concerned whether a prosecutor's closing argument at the sentencing phase of a capital murder trial, which highlighted the victim's religious items, beliefs, and voter's registration card, violated the Eighth Amendment by introducing victim impact evidence unrelated to the crime. The Supreme Court affirmed the South Carolina Supreme Court's reversal of the death sentence, ruling that such references were impermissible. The core reasoning was that the sentencer may consider only evidence tied to the circumstances of the offense and the defendant's moral culpability, consistent with Booth v. Maryland, rather than the victim's personal qualities or perceived societal worth.
criminal law
H. J. Inc. v. Northwestern Bell Telephone Co.
Supreme Court of the United States · 1989-06-26 · cited 2771×
The case involved customers of Northwestern Bell Telephone Co. suing the company, its officers, and members of the Minnesota Public Utilities Commission under the civil provisions of the Racketeer Influenced and Corrupt Organizations Act (RICO), alleging that the company engaged in bribery and related acts to improperly influence utility rate decisions between 1980 and 1986. The district court and the Eighth Circuit dismissed the claims, holding that the allegations described only a single fraudulent scheme, which was insufficient to establish the required 'pattern of racketeering activity' under RICO. The Supreme Court reversed, ruling that RICO's pattern element demands proof of both a relationship among the predicate acts of racketeering and their continuity, meaning they must amount to or threaten ongoing criminal activity rather than isolated or sporadic conduct. The Court rejected the lower courts' 'multiple schemes' test as inconsistent with the statute's text and legislative history, noting that the definition of a scheme is too vague and elastic to serve as a reliable dividing line.
criminal lawbusiness & regulatory
Granfinanciera, S.A. v. Nordberg
Supreme Court of the United States · 1989-06-23 · cited 1582×
The case concerned whether defendants who had not filed claims against a bankruptcy estate were entitled to a jury trial when sued by the bankruptcy trustee to recover allegedly fraudulent monetary transfers under the Bankruptcy Code. The Supreme Court held that the Seventh Amendment guarantees such defendants a jury trial, despite Congress having labeled fraudulent conveyance actions as core proceedings that bankruptcy judges could decide without juries. The Court reasoned that these actions are fundamentally legal in character, akin to common-law suits for damages, rather than equitable, and that Congress cannot strip the jury right by assigning the claims to a specialized non-Article III forum. The decision reversed the lower courts' rulings that had denied the jury demand.
procedure
Texas v. Johnson
Supreme Court of the United States · 1989-06-21 · cited 1671×
In Texas v. Johnson, Gregory Lee Johnson was convicted under a Texas statute for burning an American flag during a political protest at the 1984 Republican National Convention in Dallas. The Supreme Court held that Johnson's conviction violated the First Amendment, reversing the lower court's decision. The Court reasoned that Johnson's flag burning constituted symbolic speech protected by the First Amendment, as it was intended to convey a political message in the context of a demonstration. The state's interests in preserving the flag as a symbol of national unity and preventing breaches of the peace did not justify the restriction on this expressive conduct, particularly since no actual disturbance occurred and the law was not narrowly tailored.
free speechcriminal law
Public Citizen v. United States Department of Justice
Supreme Court of the United States · 1989-06-21 · cited 992×
The case concerned whether the Federal Advisory Committee Act (FACA) applied to the Department of Justice's longstanding practice of consulting the American Bar Association's Standing Committee on Federal Judiciary for confidential evaluations of potential federal judicial nominees before the President makes nominations under Article II. The Supreme Court held that FACA does not apply to this advisory relationship. The Court reached this conclusion by interpreting FACA's definition of 'advisory committee' in light of its purposes and history, determining that the ABA Committee's role in the nomination process fell outside the statute's intended scope due to the unique constitutional context of presidential appointments. Because FACA was found inapplicable, the Court did not address the constitutional challenges involving separation of powers or First Amendment rights.
federal powerprocedure
Missouri v. Jenkins Ex Rel. Agyei
Supreme Court of the United States · 1989-06-19 · cited 1583×
This case arose from a school desegregation lawsuit filed in 1977 by students against the State of Missouri and the Kansas City school district, alleging racial segregation and seeking remedies including capital improvements and magnet schools. After prevailing on the merits, the plaintiffs sought attorney's fees under the Civil Rights Attorney's Fees Awards Act, 42 U.S.C. § 1988, leading to disputes over enhancements for payment delay and compensation for paralegals and law clerks. The Supreme Court held that the Eleventh Amendment does not prohibit enhancing fee awards against states to account for delay in payment, distinguishing such awards from barred retroactive damages, and that fees for paralegals and law clerks may be calculated at prevailing market rates consistent with local billing practices. The Court affirmed the lower courts' fee awards in all respects.
civil rightsprocedure
Lauro Lines S.R.L. v. Chasser
Supreme Court of the United States · 1989-05-22 · cited 268×
In Lauro Lines S.R.L. v. Chasser, passengers sued an Italian cruise line in federal court in New York for damages arising from a terrorist hijacking, and the defendant moved to dismiss based on a forum-selection clause in the tickets requiring suits to be brought in Naples, Italy. The district court denied the motions, finding the clause did not provide reasonable notice, and the defendant sought immediate appeal without obtaining certification. The Supreme Court held that such an interlocutory order is not immediately appealable under 28 U.S.C. § 1291 as a collateral final order. The Court reasoned that the order fails the collateral order doctrine's requirement that it be effectively unreviewable on appeal from final judgment, because any error could be corrected after trial by reversing a judgment obtained in the wrong forum, and the right created by private contract is not deemed sufficiently important to warrant pre-trial review.
procedurebusiness & regulatory