William Orville Douglas

This case involved a challenge by competing motor carriers to an Interstate Commerce Commission order granting certificates of public convenience and necessity to three applicants for general commodities operations between points in the Southwest and Southeast. The district court set aside the order under the Administrative Procedure Act, finding the Commission's findings and conclusions arbitrary and capricious despite being supported by substantial evidence. The Supreme Court reversed, holding that the Commission had articulated a rational connection between the facts and its decision to grant the applications based on applicants' fitness and evidence of service inadequacies by existing carriers. The Court emphasized the narrow scope of review under the arbitrary-and-capricious standard and concluded that the district court had improperly substituted its judgment for the agency's on matters such as the weight given to evidence of existing service and applicants' performance elsewhere.

business & regulatoryfederal powerprocedure

The case concerned whether an employer commits an unfair labor practice under the National Labor Relations Act by refusing to recognize and bargain with a union that presents authorization cards signed by a majority of employees, when the employer has not engaged in other unfair labor practices and instead insists on a secret-ballot election conducted by the NLRB. In both consolidated cases, unions obtained cards or struck for recognition, the employers declined to bargain without an election, and the unions filed refusal-to-bargain charges; the Board ruled that employers need not accept card evidence alone, but the D.C. Circuit reversed. The Supreme Court reversed the Court of Appeals, holding that an employer may lawfully insist on a Board election to determine majority status absent any employer misconduct that would make a fair election impossible. The Court reasoned that while authorization cards can sometimes reflect employee sentiment, the Act and Board precedent do not compel an employer to forgo the preferred election process when it has a good-faith doubt and has not interfered with employee rights.

labor & employment

The case concerned whether the Immigration and Naturalization Service could lawfully allow aliens residing in Canada or Mexico to commute daily or seasonally to jobs in the United States by treating them as "special immigrants" under the Immigration and Nationality Act. The Act defines a special immigrant as one "lawfully admitted for permanent residence, who is returning from a temporary visit abroad," which exempts them from certain documentation, numerical limits, and labor certification requirements. The Supreme Court held that both daily and seasonal commuters qualify under this definition because they have been admitted for permanent residence, retain that status, and are returning after temporary absences. The Court based its conclusion on the statute's text, the agency's longstanding administrative practice, and indications from legislative history that Congress did not intend to bar the practice. It affirmed the lower court as to daily commuters and reversed as to seasonal commuters.

immigrationlabor & employment

This case involved a Tennessee-based cotton merchant, Allenberg Cotton Co., that contracted through a local Mississippi agent to buy cotton from farmers like appellee Pittman, with the cotton then entering interstate commerce after ginning and warehousing in Mississippi. Pittman refused delivery, and Allenberg sued for breach in Mississippi courts, but the state Supreme Court dismissed the suit because Allenberg had not registered to do business in the state under a local qualification statute. The U.S. Supreme Court reversed, holding that the statute could not be applied to bar the suit. The core reasoning was that the contracts were part of a continuous flow of interstate commerce, so denying court access under the state law violated the Commerce Clause.

business & regulatoryfederal power

This case was a civil rights suit brought by the United Farm Workers Organizing Committee and individual organizers against Texas Rangers and local law enforcement officials, alleging a conspiracy to suppress union activities during a 1966-1967 farmworkers' strike through repeated unlawful arrests, detentions, physical assaults, and harassment that violated rights to free speech and assembly under the First and Fourteenth Amendments. The district court found the challenged conduct unconstitutional, declared five Texas statutes facially invalid, and issued permanent injunctions barring enforcement of those statutes as well as the pattern of abusive practices. On appeal by five Texas Rangers, the Supreme Court examined the jurisdictional basis for the three-judge district court, the propriety of injunctive relief against ongoing official misconduct, and limits on enjoining judicial officers, while upholding the core prohibitory injunction against the unconstitutional conduct.

civil rightsfree speechlabor & employmentcriminal law

The case concerned whether a Colorado air pollution inspector's warrantless entry onto a company's outdoor premises to conduct a visual test of smoke emissions from its chimneys violated the Fourth Amendment. The Supreme Court held that no unreasonable search occurred, as the inspector observed only plumes of smoke visible to the public from open fields without entering any buildings, offices, or examining private records or equipment. The Court reversed the judgments of the lower courts setting aside the cease-and-desist order and remanded for consideration of remaining state-law and due-process questions.

environmentcriminal lawprocedurebusiness & regulatory

The case concerned whether a limited partner in a startup partnership formed to develop and market a new incinerator could deduct his share of the partnership's research and experimental expenses under Section 174(a)(1) of the Internal Revenue Code of 1954. The Tax Court and Sixth Circuit had disallowed the deduction on the ground that the partnership was not yet engaged in a trade or business. The Supreme Court reversed, holding that the expenses were deductible. The Court reasoned that Section 174 uses the broader phrase "in connection with" a trade or business rather than the narrower "carrying on" language of Section 162, and that the legislative history showed Congress intended to equalize tax treatment for small, pioneering firms incurring research costs before they had sales or an established business.

taxesbusiness & regulatory

This case involved shareholders' derivative suits filed in federal district court in New York under diversity jurisdiction, alleging that corporate insiders and others misused confidential earnings projections of a Florida corporation (Lum's) to make profitable stock sales, seeking to hold the defendants liable under a theory like that in New York's Diamond v. Oreamuno. The district court applied Florida law as the state of incorporation and dismissed the complaints, finding no clear Florida precedent supporting liability where the sole fiduciary did not personally sell shares. The Second Circuit reversed, interpreting Florida law as likely to extend Diamond to reach the defendants' conduct. The Supreme Court vacated and remanded, holding that the unsettled question of Florida law should be certified to the Florida Supreme Court under its certification procedure rather than decided by federal courts through conjecture.

business & regulatoryprocedure

Kahn v. Shevin concerned a Florida statute providing widows a $500 annual property tax exemption but offering no equivalent benefit to widowers. A widower challenged the law after his application was denied, claiming it violated the Equal Protection Clause of the Fourteenth Amendment. The Supreme Court upheld the statute, concluding that the gender-based classification had a fair and substantial relation to the state's goal of reducing economic disparities that disproportionately burden widows. The Court emphasized states' broad discretion in designing tax laws and distinguished the provision from classifications lacking any substantial justification.

civil rightstaxes

This case concerned a company rule banning employees from distributing literature on its property, including nonwork areas during nonwork time, despite the union's agreement in collective bargaining contracts to such restrictions and limits on bulletin board use. The NLRB found the rule an unfair labor practice under Section 8(a)(1) of the NLRA as it interfered with employees' Section 7 rights to form, join, or assist unions or refrain from doing so. The Supreme Court held that the ban was invalid and that the union could not waive these distribution rights on behalf of employees. The core reasoning was that the workplace is uniquely suited for sharing views on union representation choices, and unions might have a self-interest in limiting such communications to maintain their position, unlike waivable economic rights such as strikes.

labor & employment

The case concerned a zoning ordinance in the Village of Belle Terre, New York, that restricted land use to single-family dwellings and defined a "family" as one or more persons related by blood, adoption, or marriage, or up to two unrelated persons living together as a housekeeping unit. Six unrelated college students who rented a house in the village were found in violation, prompting the owners and tenants to sue under 42 U.S.C. § 1983 to enjoin enforcement and declare the ordinance unconstitutional as a violation of due process. The District Court upheld the ordinance, but the Court of Appeals reversed; the Supreme Court reversed again and sustained the law. The Court reasoned that, under precedents such as Euclid v. Ambler Realty Co., zoning measures are valid exercises of state police power when the legislative classification is fairly debatable and serves goals such as limiting density, traffic, and noise to preserve residential character.

propertycivil rights

The case concerned whether the Federal Communications Commission could impose annual fees on community antenna television (CATV) systems, calculated at 30 cents per subscriber, under the Independent Offices Appropriation Act of 1952, which authorizes federal agencies to set fees for services that are fair and equitable considering costs, value to the recipient, and other factors. The Court held that the fees were invalid because they went beyond charges for benefits conferred on the CATV operators and instead sought to recoup the Commission's broader costs of regulating the industry in the public interest. The reasoning emphasized that taxation is a legislative power reserved to Congress, while permissible fees must be tied to a voluntary act and the value received by the payor rather than general public policy or oversight expenses; reading the statute to allow broader assessments would improperly delegate taxing authority. The Court remanded for re-examination of the fee schedule to align with these limits.

business & regulatoryfederal powertaxes

The case concerned the Federal Power Commission's attempt to impose annual assessments on electric utilities and natural gas companies to recover the costs of administering the Federal Power Act and the Natural Gas Act, pursuant to the Independent Offices Appropriation Act. The Supreme Court affirmed the Court of Appeals' decision to set aside these annual charges. The Court reasoned that the Appropriation Act authorizes fees only for specific services or benefits provided to particular recipients, not for general regulatory costs imposed on entire industries.

federal powerbusiness & regulatory

The case Lau v. Nichols involved a class action by non-English-speaking Chinese students in the San Francisco Unified School District, who alleged that the lack of supplemental English instruction denied them equal educational opportunities in violation of the Fourteenth Amendment and the Civil Rights Act of 1964. The Supreme Court reversed the lower courts' decisions denying relief, holding that the school district's failure to address the language deficiencies of these students violated Section 601 of the Civil Rights Act, which prohibits discrimination on the basis of race, color, or national origin in programs receiving federal financial assistance. The Court reasoned that providing identical facilities, textbooks, teachers, and curriculum to students who do not understand English effectively forecloses meaningful education, as basic English skills are central to the curriculum, and relied on HEW guidelines requiring school systems to rectify such language deficiencies in federally funded programs.

civil rights

The case concerned a union representation election at Savair Manufacturing Co. in which the Mechanics Educational Society of America won by a 22-20 vote after circulating recognition slips that promised to waive initiation fees for employees who signed before the election. The National Labor Relations Board certified the union and ordered the company to bargain, but the company refused on the ground that the conditional fee waiver improperly influenced the outcome. The Supreme Court affirmed the Sixth Circuit's denial of enforcement, holding that the pre-election promise of fee waivers only to those who signed recognition slips interfered with employees' free and uncoerced choice in the election. The Court reasoned that such targeted offers could induce employees to sign and feel obligated to support the union or fear future costs if they did not, unlike a waiver available regardless of the vote.

labor & employmentelections

The case concerned a North Dakota statute requiring that a majority of the stock in any corporation seeking a pharmacy permit be owned by registered pharmacists in good standing who are actively involved in management. The state Board denied a permit to Snyder’s Drug Stores because its stock was owned by a non-compliant parent company, and the North Dakota Supreme Court held the statute unconstitutional under the 1928 Liggett precedent before remanding for administrative proceedings. The U.S. Supreme Court granted certiorari to address whether the state court’s judgment was sufficiently final for review under 28 U.S.C. § 1257, examining the policy goals of avoiding piecemeal litigation while permitting review of intermediate rulings that resolve key federal issues or would otherwise cause unnecessary delay.

business & regulatoryprocedure

The case concerned whether Washington state's prohibition on net fishing for steelhead trout by the Puyallup Tribe violated their treaty rights under the Treaty of Medicine Creek, which secured fishing rights in common with other citizens. The Supreme Court decided that the state's total ban on Indian net fishing, which effectively allocated the entire steelhead run to sports fishermen, raised issues of discrimination under the treaty and remanded the case for further proceedings on fair allocation considering conservation needs. The core reasoning was that while states may regulate Indian fishing for conservation, such regulations must not discriminate against treaty-protected rights and must accommodate both Indian commercial fishing and non-Indian sports fishing equitably, including accounting for hatchery-raised fish funded by license fees.

civil rightsfederal powerenvironment

The case concerned a provision of the Food Stamp Act that disqualified entire households from receiving benefits for two years if they included a person age 18 or older who had been claimed as a tax dependent by someone ineligible for food stamps. The Supreme Court held the provision unconstitutional under the Due Process Clause. The Court reasoned that the statute created a conclusive and irrebuttable presumption of non-need that bore no necessary relation to actual household resources or eligibility and afforded no opportunity for a hearing to rebut the presumption.

federal powercivil rights

The case involved the application of the 1962 amendments to the Federal Food, Drug, and Cosmetic Act to Lutrexin, a drug approved by the FDA before 1962 solely on safety grounds. The amendments redefined new drugs to require substantial evidence of effectiveness and authorized the FDA to withdraw prior approvals lacking such evidence. Hynson argued that its drug qualified for exemptions under the amendments' grandfather clauses because it was not a new drug under the 1938 Act and was not covered by an effective NDA. The Supreme Court held that the drug did not qualify for those exemptions and that the FDA could require proof of efficacy and withdraw approval through administrative proceedings under the statute's transition provisions, which were designed to ease the burden of reviewing thousands of pre-1962 drugs while protecting public health.

healthcarebusiness & regulatoryfederal power

This case involved pharmaceutical companies marketing drugs containing pentylenetetrazol that sought a declaratory judgment declaring their products generally recognized as safe and effective (and thus not new drugs under the Federal Food, Drug, and Cosmetic Act) and exempt from new effectiveness requirements under the 1962 grandfather clause. After NAS-NRC panels found the drugs ineffective and the FDA withdrew related new drug application approvals, the companies challenged the FDA's authority to apply those withdrawals to their similar me-too drugs. The district court found concurrent jurisdiction with the FDA, while the court of appeals held that only courts could decide new drug status in enforcement proceedings. The Supreme Court reversed, ruling that the FDA has primary jurisdiction to resolve the new drug and grandfather issues in administrative proceedings. The Court reasoned that these determinations involve complex scientific and medical evaluations best suited to the agency's expertise, which also promotes uniformity in drug regulation.

business & regulatoryfederal powerhealthcare