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1,700 | 55,310 |
Dixon v. United States
|
https://api.oyez.org/cases/2005/05-7053
|
05-7053
|
2005
|
Keshia Cherie Ashford Dixon
|
United States
|
<p>Keshia Dixon was arrested for illegally purchasing firearms. At her trial, Dixon raised a duress defense, claiming that her boyfriend abused her and that she feared he would harm or kill her or her daughters if she did not buy the firearms. Upon being convicted, Dixon appealed to the Fifth Circuit Court of Appeals, arguing that she should not bear the evidentiary burden of proving her duress claim. The Circuit Court rejected Dixon's argument, noting that the circuit's previous cases had clearly established that the duress defense requires the defendant to prove duress by a preponderance of evidence. This ruling conflicted with a ruling on a similar case in the Sixth Circuit Court of Appeals. Dixon appealed to the Supreme Court, which agreed to consider the narrow question of the burden of proof.</p>
| 814 | 7 | 2 | false |
majority opinion
|
affirmed
|
Due Process
|
1,701 | 55,311 |
Oregon v. Guzek
|
https://api.oyez.org/cases/2005/04-928
|
04-928
|
2005
|
Oregon
|
Randy Lee Guzek
|
<p>A jury found Randy Lee Guzek guilty of capital murder and sentenced him to death. On appeal, the Oregon Supreme Court overturned the death sentence. Guzek was sentenced to death again, and the Oregon Supreme Court again threw out the death sentence. When Guzek was sentenced to death a third time, the Oregon Supreme Court again overturned his sentence and also considered his complaint that he had not been allowed to present testimony about his alibi at the sentencing phase of the trial. Oregon law requires that evidence of innocence, such as an alibi, be presented during the trial, not during the sentencing hearing. The Oregon Supreme Court accepted Guzek's argument that he had a constitutional right under the Eighth and Fourteenth Amendments to introduce the alibi testimony at his sentencing proceeding. Oregon appealed to the Supreme Court, arguing that it was reasonable to restrict the introduction of evidence of innocence to the guilt phase of the trial.</p>
| 978 | 8 | 0 | true |
majority opinion
|
vacated/remanded
|
Criminal Procedure
|
1,702 | 55,312 |
Lockhart v. United States
|
https://api.oyez.org/cases/2005/04-881
|
04-881
|
2005
|
James Lockhart
|
United States et al.
|
<p>In 2002 the U.S. began withholding a portion of Lockhart's Social Security payments to offset his debt on federally reinsured student loans that were more than 10 years overdue. Lockhart sued, arguing the offset was barred by the 10-year statute of limitations of the Debt Collection Act (1982). The district court dismissed Lockhart's suit, and the Ninth Circuit affirmed.</p>
| 381 | 9 | 0 | false |
majority opinion
|
affirmed
|
Judicial Power
|
1,703 | 55,313 |
Wagnon v. Prairie Band Potawatomi Nation
|
https://api.oyez.org/cases/2005/04-631
|
04-631
|
2005
|
Joan Wagnon, Secretary, Kansas Department of Revenue
|
Prairie Band Potawatomi Nation
|
<p>The Prairie Band Potawatomi Nation, a sovereign Indian tribe, raises revenue with a tax on the gasoline sold at an on-reservation gas station. The Nation purchases the gas from non-Indian, off-reservation distributors. Kansas imposed a tax on distributors of motor fuels, which the distributors pass on to the gas stations they sell to. The Nation sued Wagnon, the Secretary of the Kansas Department of Revenue, seeking to avoid the tax. The Nation argued that the state's tax interfered with the tribe's sovereignty, and therefore was not allowed by federal law. Wagnon claimed that since the tax was on off-reservation suppliers, the Nation's sovereignty was unaffected. The District Court accepted that argument and ruled for Wagnon. The Tenth Circuit Court of Appeals reversed, applying the interest-balancing test prescribed by <em>White Mountain Apache Tribe v. Bracker.</em> The Circuit Court found that the tribe's interests in economic development, tribal self-sufficiency, and strong tribal government out-weighed Kansas's interest in raising revenue.</p>
| 1,069 | 7 | 2 | true |
majority opinion
|
reversed
|
Civil Rights
|
1,704 | 55,315 |
Randall v. Sorrell
|
https://api.oyez.org/cases/2005/04-1528
|
04-1528
|
2005
|
Neil Randall et al.
|
William H. Sorrell et al.
|
<p>In 1997 Vermont passed a campaign finance law, Act 64, which imposed strict limits both on expenditures by candidates for office during the election cycle and on the contributions of individuals, political groups, and parties. Neil Randall, a state legislator, sued Vermont Attorney General William Sorrell, arguing that the limits were unconstitutional infringements on First Amendment freedom of speech. In Randall's view, the Supreme Court had declared all expenditure limits unconstitutional in <em>Buckley v. Valeo</em>, and Act 64's contribution limits were unconstitutionally low. Sorrell countered that <em>Buckley</em> was outmoded because that Court had not considered one of Vermont's justifications, namely that expenditure limits prevent candidates from spending too much time trying to raise money. Sorrell also argued that Vermont's interests in combating corruption and ensuring fair elections justified the contribution limits. The District Court struck down the expenditure limits, but upheld most of the contribution limits. Only the limits on contributions by political parties - under which national, state, and local parties together could give only $400 to a statewide candidate - were unconstitutionally low. Both parties appealed the ruling to the Second Circuit Court of Appeals. The Circuit Court reversed, ruling that all of Vermont's contribution limits were constitutional. The Second Circuit also found that the expenditure limits would be constitutional as long as they were "narrowly tailored" to the state's interests.</p>
| 1,560 | 6 | 3 | true |
plurality opinion
|
reversed/remanded
|
First Amendment
|
1,705 | 55,314 |
Whitman v. Dept. of Transportation
|
https://api.oyez.org/cases/2005/04-1131
|
04-1131
|
2005
|
Terry L. Whitman
|
Department of Transportation et al.
|
<p>Terry Whitman works as an air traffic assistant for the Federal Aviation Administration (which is part of the Department of Transportation). Federal law requires that FAA employees who perform "safety-sensitive functions" submit to random drug tests. Whitman brought suit in federal district court, claiming that the FAA was testing him for substance abuse three times more often than other people holding similar positions. The disproportionate testing, he argued, violated his "First Amendment right to privacy" as well as his statutory rights, because the testing was not truly random.</p>
<p>The district court dismissed the suit, finding that the Civil Service Reform Act requires complaint's like Whitman's to be decided through the arbitration procedures set forth in the collective bargaining agreement between the FAA and the National Association of Government Employees. The Ninth Circuit Court of Appeals affirmed.</p>
| 933 | 8 | 0 | true |
per curiam
|
vacated/remanded
|
Judicial Power
|
1,706 | 55,318 |
Sereboff v. Mid Atlantic Medical Services, Inc.
|
https://api.oyez.org/cases/2005/05-260
|
05-260
|
2005
|
Joel Sereboff et ux.
|
Mid Atlantic Medical Services, Inc.
|
<p>Mr. and Mrs. Sereboff held a health insurance policy with Mid Atlantic Medical Services that was governed by the Employee Retirement Income Security Act of 1974 (ERISA). If a beneficiary is injured, Mid Atlantic pays for all covered medical expenses. However, the plan also has a provision that requires the beneficiaries to reimburse Mid Atlantic when an injury has been caused by a third party and the beneficiary receives compensation from that third party. In this case, the Sereboffs were injured in an automobile accident caused by a third party. After they settled their suit against that third party, Mid Atlantic filed suit in federal district court under section 502(a)(3) of ERISA to recover the money it had spent on medical expenses. 502(a)(3) provides that a health insurer may bring suit "to obtain ... appropriate equitable relief ... to enforce ... the terms of the plan." The Sereboff's objected, arguing that the sort of reimbursement provision at issue in this case was not "equitable" because the Sereboffs had not had the funds in their possession when they agreed to the plan. Both the district court and the Fourth Circuit Court of Appeals disagreed, siding with Mid Atlantic.</p>
| 1,208 | 9 | 0 | false |
majority opinion
|
affirmed
|
Economic Activity
|
1,707 | 55,317 |
Howard Delivery Service, Inc. v. Zurich American Ins. Co.
|
https://api.oyez.org/cases/2005/05-128
|
05-128
|
2005
|
Howard Delivery Service, Inc., et al.
|
Zurich American Insurance Co.
|
<p>Under West Virginia law, employers are required to either participate in a state-run workers' compensation fund or demonstrate that they are financially capable of covering any workers' compensation claims that may arise. Howard Delivery service, a West Virginia freight carrier, chose to fulfill its obligation by purchasing insurance from Zurich American Insurance Company. In January of 2002, however, the company cancelled its policy (still owing thousands of dollars in unpaid premiums) and filed for bankruptcy.</p>
<p>Zurich filed for special status as a creditor, arguing that the money owed to them consisted of "contributions to an employee benefit plan arising from services rendered," and that under Chapter 11 of the Bankruptcy Code they should therefore be given priority in recovering the premiums. The bankruptcy court rejected Zurich's claims, however, finding that the provision did not apply to the workers compensation insurance premiums because they were not wage-substitute-type benefits for which the company could bargain (because Howard was required by law to have some form of insurance). A federal district court affirmed the decision, but a divided panel of the Fourth Circuit Court of Appeals reversed, holding that contributions to an employee benefit plan did not need to be voluntary to meet the Chapter 11 definition.</p>
| 1,358 | 6 | 3 | true |
majority opinion
|
vacated/remanded
|
Economic Activity
|
1,708 | 55,319 |
Anza v. Ideal Steel Supply Corporation
|
https://api.oyez.org/cases/2005/04-433
|
04-433
|
2005
|
Joseph Anza, et al.
|
Ideal Steel Supply Corp.
|
<p>Ideal Steel Supply Corporation filed a civil suit against its competitor, National Steel Supply, Inc. in federal court. Ideal alleged that National had failed to charge sales tax for cash purchases, giving it a competitive (but fraudulent) advantage. Under the Racketeer Influenced and Corrupt Organizations Act, "[a]ny person injured in his business or property" by racketeering activity may bring a civil suit. Ideal argued that it had been injured through lost sales because of National's illegal lower prices, and therefore had standing to sue.</p>
<p>The federal district court disagreed, dismissing the suit because Ideal had not had any direct encounters with National or relied on their fraudulent tax records. A Second Circuit Court of Appeals panel reversed the decision, however, finding that a company can sue under RICO when its competitor uses racketeering to gain an advantage.</p>
| 900 | 9 | 0 | true |
majority opinion
|
reversed/remanded
|
Judicial Power
|
1,709 | 55,320 |
Wisconsin Right to Life, Inc. v. Federal Election Commission
|
https://api.oyez.org/cases/2005/04-1581
|
04-1581
|
2005
|
Wisconsin Right to Life, Inc.
|
Federal Election Commission
|
<p>The Bipartisan Campaign Reform Act of 2002 (BCRA) prohibits corporate funds from being used for certain political advertisements in the 60-day period prior to an election. Wisconsin Right to Life (WRTL) ran a series of television advertisements encouraging viewers to contact two U.S. Senators and tell them to oppose judicial filibusters. WRTL anticipated that the ads would probably run afoul of BCRA and sued the Federal Election Commission (FEC), seeking an order barring the FEC from enforcing BCRA against the ads. WRTL's suit alleged that BCRA is unconstitutional as it applies to the ads, which it claimed are "grassroots lobbying advertisements" unrelated to electoral campaigning. The FEC argued that the Supreme Court in McConnell v. Federal Election Commission (2003) had ruled out all "as-applied" challenges to BCRA. The U.S. District Court for D.C. agreed and denied WRTL's motion.</p>
| 904 | 9 | 0 | true |
per curiam
|
vacated/remanded
|
First Amendment
|
1,710 | 55,323 |
Gonzales v. Thomas
|
https://api.oyez.org/cases/2005/05-552
|
05-552
|
2005
|
Alberto R. Gonzales, Attorney General
|
Michelle Thomas et al.
|
<p>A South African family sought asylum in the United States under the Immigration and Nationality Act (INA), which grants asylum to those who cannot return to another country because of “persecution or a well-founded fear of persecution on account of race, religion, nationality, membership in a particular social group, or political opinion.” Their application for asylum claimed that they feared persecution if they returned to South Africa because of their (1) political opinions and (2) “membership in a particular social group,” which they argued included both their race and their kinship with a particular well-known white South African. The immigration judge denied their application, and the Board of Immigration Appeals (BIA) affirmed. On appeal, the U.S. Court of Appeals for the Ninth Circuit held that association with a particular family may fall within the scope of the “particular social group” language in the INA.</p>
| 937 | 9 | 0 | true |
per curiam
|
vacated/remanded
|
Civil Rights
|
1,711 | 55,322 |
Garcetti v. Ceballos
|
https://api.oyez.org/cases/2005/04-473
|
04-473
|
2005
|
Gil Garcetti et al.
|
Richard Ceballos
|
<p>Richard Ceballos, an employee of the Los Angeles District Attorney's office, found that a sheriff misrepresented facts in a search warrant affidavit. Ceballos notified the attorneys prosecuting the case stemming from that arrest and all agreed that the affidavit was questionable, but the D.A.'s office refused to dismiss the case. Ceballos then told the defense he believed the affidavit contained false statements, and defense counsel subpoenaed him to testify. Seeking damages in federal district court, Ceballos alleged that D.A.s in the office retaliated against him for his cooperation with the defense, which he argued was protected by the First Amendment. The district court ruled that the district attorneys were protected by qualified immunity, but the Ninth Circuit reversed and ruled for Ceballos, holding that qualified immunity was not available to the defendants because Ceballos had been engaged in speech that addressed matters of public concern and was thus protected by the First Amendment.</p>
| 1,017 | 5 | 4 | true |
majority opinion
|
reversed/remanded
|
First Amendment
|
1,712 | 55,321 |
Mohawk Industries, Inc. v. Williams
|
https://api.oyez.org/cases/2005/05-465
|
05-465
|
2005
|
Mohawk Industries, Inc.
|
Shirley Williams et al.
|
<p>A group of current and former employees of Mohawk Industries brought suit against Mohawk in federal district court under the Racketeer Influenced and Corrupt Organizations Act (RICO). They claimed that Mohawk had conspired with third-party employment recruiters to bring illegal immigrants into Georgia to work for the company, and that the resulting competition for jobs hurt the legal workers. Mohawk asked the court to dismiss the case because, it argued, the plaintiffs had not shown that there were two distinct entities involved in the illegal activity as required under RICO. The only parties involved were the Mohawk corporation and the third-party recruiters, which were acting as its "agents." Mohawk argued that, because the recruiters were working on behalf of the corporation rather than in cooperation with (but distinct from) it, they should not be considered separate entities. The Eleventh Circuit Court of Appeals disagreed, ruling that the recruiters and the corporation were distinct and that RICO could therefore apply.</p>
| 1,048 | 9 | 0 | true |
per curiam
|
vacated/remanded
|
Judicial Power
|
1,713 | 55,325 |
Schaffer ex rel. Schaffer v. Weast
|
https://api.oyez.org/cases/2005/04-698
|
04-698
|
2005
|
Brian Schaffer, a minor, by his parents and next friends, Jocelyn and Martin Schaffer, et ux, et al.
|
Jerry Weast, Superintendent, Montgomery County Public Schools, et al.
|
<p>The parents of Brian Schaffer, a disabled child, sued their public school district under the Individuals with Disabilities Education Act (IDEA). Schaffer's parents claimed the Individualized Education Program that the school system devised for their son, and which IDEA required for each disabled student, was inadequate. The district court ruled for the Schaffers, but the Fourth Circuit reversed, holding that the lower court incorrectly assigned the burden of proof to the school system. Because IDEA was silent on whether the parents or the school system bear the burden of proof, the Fourth Circuit held, the general rule that the party initiating the suit bears that burden should be applied.</p>
| 706 | 6 | 2 | false |
majority opinion
|
affirmed
|
Civil Rights
|
1,714 | 55,324 |
Gonzales v. Oregon
|
https://api.oyez.org/cases/2005/04-623
|
04-623
|
2005
|
Alberto R. Gonzales, Attorney General, et al.
|
Oregon et al.
|
<p>In 1994 Oregon enacted the Death with Dignity Act, the first state law authorizing physicians to prescribe lethal doses of controlled substances to terminally ill patients. Attorney General John Ashcroft declared in 2001 that physician-assisted suicide violated the Controlled Substances Act of 1970 (CSA). Ashcroft threatened to revoke the medical licenses of physicians who took part in the practice. Oregon sued Ashcroft in federal district court. That court and, later the Ninth Circuit, held Ashcroft''s directive illegal. The courts held that the CSA did not authorize the attorney general to regulate physician-assisted suicide, which was the sort of medical matter historically entrusted to the states.</p>
| 718 | 6 | 3 | false |
majority opinion
|
affirmed
|
Privacy
|
1,715 | 55,326 |
Rapanos v. United States
|
https://api.oyez.org/cases/2005/04-1034
|
04-1034
|
2005
|
John A. Rapanos et ux. et al.
|
United States
|
<p>John Rapanos sought to fill in three wetland areas on his property in order to build a shopping center. Rapanos ignored warnings from the Michigan Department of Environmental Quality that the area was protected wetlands under the Clean Water Act (CWA). The CWA allows the government to regulate the discharge of any pollutant (including dirt or sand) into "navigable waters," which the Act defines as "the waters of the United States." Under regulations issued by the Army Corps of Engineers (Corps), wetlands are covered by the CWA as long as they are adjacent to traditionally navigable waters or tributaries of such waters. After Rapanos also ignored cease-and-desist orders from the U.S. Environmental Protection Agency, the government brought a civil suit against him. Rapanos argued before the District Court that the CWA gives the government jurisdiction to regulate only traditionally navigable waters. The government countered that Rapanos's lands were covered by the CWA as "adjacent wetlands" under the Corps's interpretation of the Act; the sites drained into man-made drains which eventually emptied into navigable rivers and lakes. The District Court rejected Rapanos's argument and upheld the Corps's regulations including the wetlands as "waters of the United States." The Sixth Circuit Court of Appeals affirmed, holding that the "hydrological connection" of the wetlands to the navigable waters qualifies them as "waters of the United States" under the Act.</p>
<p>The Carabells sought to fill in a wetland on their property in order to build a condominium, but were denied a permit because the wetland was protected under the Clean Water Act (CWA). The CWA allows the government to regulate the discharge of any pollutant (including dirt or sand) into "navigable waters," which the Act defines as "the waters of the United States." Under regulations issued by the Army Corps of Engineers (Corps), wetlands are covered by the CWA as long as they are adjacent to traditionally navigable waters or tributaries of such waters. Carabell's site is separated from a nearby ditch by a 4-foot-wide berm (earthen barrier), but the Corps's regulations specify that the wetland is nevertheless adjacent to the waterway. The ditch empties into another ditch, which in turn empties into a creek and ultimately into Lake St. Clair, a navigable water. After exhausting administrative appeals, Carabell sued in District Court. Carabell argued that the government lacked jurisdiction under the CWA to regulate the relatively isolated wetland as part of the "waters of the United States." The District Court disagreed, and upheld the Corps's expansive interpretation of the CWA. On appeal, the Sixth Circuit Court of Appeals also ruled for the Corps, holding that as long as wetlands are "adjacent" to tributaries of traditionally navigable waters and share a "significant nexus" with such waters, the wetlands qualify as "waters of the United States" for purposes of the CWA.</p>
| 2,984 | 5 | 4 | true |
plurality opinion
|
vacated/remanded
|
Economic Activity
|
1,716 | 55,328 |
Martin v. Franklin Capital Corp.
|
https://api.oyez.org/cases/2005/04-1140
|
04-1140
|
2005
|
Gerald T. Martin et ux.
|
Franklin Capital Corporation, et al.
|
<p>The Martins filed a class action lawsuit against the defendant companies in New Mexico state court in 1996, alleging illegal conduct with regard to auto financing and insurance contracts the parties had entered into. The defendants removed the case to federal court on diversity jurisdiction grounds under 28 U.S.C. §§ 1332 and 1441. The Martins did not object or seek remand until over a year later, when they argued that their claims did not meet the $50,000 amount in controversy requirement for diversity jurisdiction. The district court denied the motion, agreeing with defendants' arguments that the punitive damages, attorneys' fees, and monetary relief for the named plaintiffs at issue in the case each exceeded the $50,000 threshold. The Martins requested that the district court certify its order denying remand so that they could seek interlocutory review, and the court denied their motion. The plaintiffs next requested that the district court grant judgment against them so that they could appeal the decision regarding jurisdiction, and the court granted their request.</p>
<p>The plaintiffs then appealed to the 10th Circuit, and in a 2001 ruling, the appellate court reversed the lower court's ruling, rejecting the arguments that the amounts sought by the plaintiffs satisfied the diversity jurisdiction requirement. The court remanded the case with instructions to send it back to state court.</p>
<p>Back in district court, the Martins moved for attorney's fees and expenses under § 1447(c), which provides for judicial discretion to make such an award in cases of improper removal. The district court denied this request on the grounds that the defendants had an objectively reasonable basis for removal at the time. The Martins again appealed to the 10th Circuit.</p>
<p>The appellate court affirmed the district court's ruling, explaining that the district court had applied the proper standard under 10th Circuit precedent, stating that even in cases where removal was later found to be improper, if it was deemed to be objectively reasonable at the time, the court had discretion to deny an award of attorney's fees and expenses under § 1447(c); other circuits had employed a different standard. The appellate court also agreed with the district court's conclusion that the removal had an objectively legitimate basis at the time it occurred.</p>
| 2,376 | 9 | 0 | false |
majority opinion
|
affirmed
|
Attorneys
|
1,717 | 55,327 |
Maryland v. Blake
|
https://api.oyez.org/cases/2005/04-373
|
04-373
|
2005
|
Maryland
|
Leeander Jerome Blake
|
<p>Following his arrest for murder, Leeander Blake invoked his right to speak with a lawyer. Before Blake's attorney arrived, however, an officer and a detective approached Blake to give him a copy of the charges against him. The statement of the charges included "DEATH" as a possible penalty, although Blake was 17 years old and therefore too young to face the death penalty. The officer said to Blake "I bet you want to talk now, huh!" The detective then said "No, he doesn't want to talk to us. He already asked for a lawyer. We cannot talk to him now." A half hour later Blake decided to speak to the police without his lawyer, and he proceeded to make incriminating statements about the murder. At trial, Blake argued that the incriminating statements were the product of an illegal interrogation, and therefore inadmissible. (Under <em>Edwards v. Arizona</em>, police must cease interrogating a suspect after he requests an attorney, unless the suspect waives his previous request.) A county circuit court agreed with Blake, and ruled the statement inadmissible. On appeal, Maryland argued that Blake's interaction with the officer and the detective did not constitute an interrogation, because the officer's statement was a mere rhetorical question, and in any case was quickly corrected by the detective. An intermediate state appeals court agreed and allowed the statement to be admitted as evidence. However, the Maryland Court of Appeals reversed that decision, holding that the detective's correction did not reduce the severity of the officer's inappropriate statement. Since the officer's statement was ruled an illegal interrogation in violation of Blake's Miranda rights, the incriminating statement could not be used as evidence at trial.</p>
| 1,761 | 9 | 0 | false |
per curiam
| null |
Judicial Power
|
1,718 | 55,329 |
House v. Bell
|
https://api.oyez.org/cases/2005/04-8990
|
04-8990
|
2005
|
Paul Gregory House
|
Ricky Bell, Warden
|
<p>Paul House was sentenced to death for murder based on circumstantial evidence. House then submitted a habeas petition in federal court, claiming that he had new evidence demonstrating his innocence. The Sixth Circuit Court of Appeals denied his petition, finding he had failed to show that it was "more likely than not that no reasonable juror would have convicted him in the light of the new evidence," the standard of review established for habeas petitions in <em>Schlup v. Delo</em>. Even though the evidence cast some doubt on the original evidence, it was not sufficient to warrant a habeas petition.</p>
| 614 | 5 | 3 | true |
majority opinion
|
reversed/remanded
|
Criminal Procedure
|
1,719 | 55,330 |
Day v. McDonough
|
https://api.oyez.org/cases/2005/04-1324
|
04-1324
|
2005
|
Patrick Day
|
James R. McDonough, Interim Secretary, Florida Department of Corrections
|
<p>Patrick Day was convicted of murder in state court. After a long delay, he filed a petition for federal review, arguing that his counsel was inadequate. Under the Antiterrorism and Effective Death Penalty Act, federal habeas corpus petitions must be filed within a one-year time limit. Day's petition was late, but the state of Florida failed to notice the untimeliness of the petition and instead addressed only the merits of Day's argument. Later a Federal Magistrate Judge did notice Day's failure to meet the deadline, and recommended to the District Court that the petition be dismissed. Day argued that by responding to the petition without disputing the timeliness, the state had forfeited the statute-of-limitations defense. The District Court disagreed and dismissed the petition. Day appealed to the Eleventh Circuit Court of Appeals, claiming that the District Court had acted unfairly when it ruled against him based on an argument that the state had not made. The Circuit Court rejected Day's argument and affirmed the District Court, ruling that the state's erroneous concession of the timeliness of the petition did not prevent the court from dismissing it.</p>
| 1,180 | 6 | 3 | false |
majority opinion
|
affirmed
|
Criminal Procedure
|
1,720 | 55,332 |
Evans v. Chavis
|
https://api.oyez.org/cases/2005/04-721
|
04-721
|
2005
|
Mike Evans, Acting Warden
|
Reginald Chavis
|
<p>After Reginald Chavis was convicted of murder, he filed a petition for a writ of habeas corpus in California court. After the California Court of Appeal denied Chavis' petition, he waited more than three years before appealing the decision to the California Supreme Court, which denied the petition without explanation.</p>
<p>Having exhausted his state-court remedies, Chavis then sought to file a habeas petition in federal court. The district court, however, dismissed Chavis' petition. Under the Antiterrorism and Effective Death Penalty Act there is a one-year period in which a habeas petition must be filed. Chavis' three-year delay, the court ruled, had exceeded that period, and Chavis' petition was therefore untimely. The Ninth Circuit Court of Appeals reversed, however, holding that Chavis' state-court petition had been "pending" for the entire three years. Because the one-year statute of limitations did not apply to time during which state court petitions were pending, Chavis' petition in federal district court was timely under the AEDPA.</p>
| 1,065 | 9 | 0 | true |
majority opinion
|
reversed/remanded
|
Criminal Procedure
|
1,721 | 55,334 |
Bank of China v. NBM L.L.C.
|
https://api.oyez.org/cases/2005/03-1559
|
03-1559
|
2005
|
Bank of China, New York Branch
|
NBM L.L.C., et al.
|
<p>Bank of China alleged that John Chou and Sherry Liu attempted to defraud the bank by borrowing large sums of money and misrepresenting them as debts owed by the bank to various independent businesses. Bank of China alleged that those businesses, such as NBM LLC, were actually just fronts set up for Chou and Liu's scheme. In addition to criminal charges, a civil suit was commenced against Chou, Liu, NBM LLC and other involved businesses, and Patrick Young, a bank employee accused of assisting with the fraudulent transactions. A jury found the defendants guilty of various charges, including mail fraud and wire fraud in violation of the conspiracy provision of the Racketeer Influenced and Corrupt Organizations Act (RICO), and it awarded the Bank large compensatory and punitive damages. On appeal, NBM argued that the District Court should have instructed the jury that in order to find a violation of RICO, they needed to determine that the Bank was justified in believing NBM's misrepresentations. In common-law fraud cases, this is known as "reasonable reliance." Bank of China argued that the RICO statute does not require a demonstration of reasonable reliance, but the Second Circuit Court of Appeals accepted NBM's argument and reversed the jury verdict. The Circuit Court faulted the District Court for instructing the jury that the Bank could have been defrauded in violation of RICO even if some bank officials (such as Young) had known the true nature of the misrepresented sums. Instead, the Circuit Court said, the jury should have been instructed to determine whether Bank of China was justifiably misled by the misrepresentations.</p>
| 1,660 | 0 | 0 | null |
dismissal - rule 46
|
none
| null |
1,722 | 55,333 |
Jones v. Flowers
|
https://api.oyez.org/cases/2005/04-1477
|
04-1477
|
2005
|
Gary Kent Jones
|
Linda K. Flowers et al.
|
<p>In 1993, Gary Jones moved out of his house and into an apartment, while his wife continued to live in the house. Jones failed to notify the state of his new address, however, and after several years of unpaid property taxes the tax authority sent a letter by certified mail to the house notifying him that, if the taxes went unpaid, the house would be sold. The letter was returned as "unclaimed" (because Jones was not living at the house and no one was present to sign for its receipt) and the Arkansas Commissioner of State Lands sold the property in a private sale to Linda Flowers.</p>
<p>Jones sued in state court, claiming that the sale violated his Fourteenth Amendment due process rights because he was never actually notified of the sale. The Arkansas Supreme Court disagreed, however, finding that under the U.S. Supreme Court's decision in <em>Dusenberg v. United States</em> actual notice is not required as long as the state makes a reasonable effort to notify the party of his rights.</p>
| 1,007 | 5 | 3 | true |
majority opinion
|
reversed/remanded
|
Due Process
|
1,723 | 55,335 |
Laboratory Corp. of America Holdings v. Metabolite Laboratories, Inc.
|
https://api.oyez.org/cases/2005/04-607
|
04-607
|
2005
|
Laboratory Corporation of America Holdings, dba LabCorp
|
Metabolite Laboratories, Inc., et al.
|
<p>In the 1980s, research scientists at University Patents, Inc. (UPI) discovered that high levels of the amino acid homocysteine in the body are correlated with dangerously low levels of two B vitamins. UPI filed for a patent, seeking to license both the method of testing for the amino acid, and the correlation of the amino acid levels with B vitamin levels. UPI's successor licensed Metabolite Laboratories, which in 1992 sub-licensed the patent to Laboratory Corporation of America Holdings (LabCorp). When in 1998 LabCorp started using another company's test and stopped paying Metabolite royalties, Metabolite sued. A jury found LabCorp guilty of patent infringement and breach of contract and awarded damages to Metabolite. In an appeal to the Circuit Court of Appeals for the Federal Circuit, LabCorp argued that the patent was invalid. Natural phenomena themselves are not patentable, but new applications of them normally are. LabCorp argued that Metabolite had impermissibly patented a relationship that already existed in nature. The Federal Circuit rejected that argument, however, ruling that Metabolite could patent its discovery of the correlation and that any association of homocysteine levels with B vitamin deficiency could constitute patent infringement. LabCorp appealed its case to the Supreme Court.</p>
| 1,329 | 5 | 3 | false |
per curiam
| null |
Judicial Power
|
1,724 | 55,337 |
Kansas v. Marsh
|
https://api.oyez.org/cases/2005/04-1170
|
04-1170
|
2005
|
Kansas
|
Michael Lee Marsh, II
|
<p>Michael Lee Marsh II was convicted of murdering a mother and her young daughter. During the sentencing phase of the trial, jurors found that the mitigating factors and aggravating factors were in equipoise (i.e., of equal weight). The Kansas capital punishment statute specifically provided for the imposition of the death penalty in that circumstance, so Marsh was sentenced to death. After Marsh's sentencing, however, the Kansas Supreme Court in <em>State v. Kleypas</em> found fault with the concept of the death penalty as a "tie-breaker." The ruled in <em>Kleypas</em> that "fundamental fairness requires that a 'tie goes to the defendant' when life or death is at issue." The State argued that while the prosecution has the burden of proof during the trial, the burden can be shifted to the defendant during the sentencing phase, so that the defendant must show that he deserves less than a death sentence. The Kansas Supreme Court disagreed, and overturned Kansas's death penalty statute as unconstitutional under the Eighth Amendment.</p>
| 1,051 | 5 | 4 | true |
majority opinion
|
reversed/remanded
|
Criminal Procedure
|
1,725 | 55,336 |
Domino's Pizza, Inc. v. McDonald
|
https://api.oyez.org/cases/2005/04-593
|
04-593
|
2005
|
Domino's Pizza, Inc., et al.
|
John McDonald
|
<p>John McDonald was the president and sole shareholder of JWM Investments. After Domino's terminated its contract with JWM, McDonald brought suit under a section of the Civil Rights Act of 1866 (42 U.S.C. Section 1981). McDonald claimed that Domino's had ended its contract because he was black, and that he therefore had a right to sue under the Civil Rights Act, which gives all citizens, regardless of race, the right to make and enforce contracts. Domino's moved to dismiss the case, arguing that McDonald had not been a party to the contract (it had been between Domino's and JWM) and therefore did not have standing to sue. The district court sided with Domino's, but the Ninth Circuit Court of Appeals reversed, finding that McDonald had suffered injuries separate from those of JWM and therefore had standing to sue.</p>
| 830 | 8 | 0 | true |
majority opinion
|
reversed
|
Civil Rights
|
1,726 | 55,338 |
Clark v. Arizona
|
https://api.oyez.org/cases/2005/05-5966
|
05-5966
|
2005
|
Eric Michael Clark
|
Arizona
|
<p>Eric Clark shot and killed a police officer during a traffic stop. At trial in Arizona state court, Clark, a diagnosed paranoid schizophrenic who believed his town had been taken over by aliens, introduced expert evidence about his mental state. He wanted to use this evidence not only to prove that he was insane (a claim on which he bore the burden of proof) but also to show that he could not form the criminal intent that the government was required to prove beyond a reasonable doubt. The trial judge, however, ruled that Arizona law confined the use of the expert evidence to his insanity claim and did not permit him to use it to show he could not form the necessary criminal intent. The court ruled that he had not sufficiently proved his insanity defense, and Clark was convicted and sentenced to 25 years to life in prison. The Arizona Court of Appeals affirmed.</p>
| 880 | 5 | 4 | false |
majority opinion
|
affirmed
|
Due Process
|
1,727 | 55,339 |
Kircher v. Putnam Funds Trust
|
https://api.oyez.org/cases/2005/05-409
|
05-409
|
2005
|
Carl Kircher et al.
|
Putnam Funds Trust et al.
|
<p>The Security Litigation Uniform Standards Act (SLUSA) states that class action lawsuits involving more than 50 plaintiffs alleging untruth or manipulation "in connection with the purchase or sale" of certain securities may be moved from state court to federal district court. In this case, several class action suits, each involving more than 50 investors in covered securities, were brought in various state courts over the devaluation of the plaintiffs' investments by Putnam Funds Trust and other mutual funds. The mutual funds asked to have the cases heard in federal court, and the state courts agreed. The federal district court sent the cases back to the state courts, however, finding that SLUSA does not cover suits over devaluation, only those related to purchases or sales. When the mutual funds appealed the decision to the Seventh Circuit Court of Appeals, the plaintiffs objected to the appeal because 28 U.S.C. 1447(d) prohibits appeals court review of federal district court decisions to remand cases to state court for lack of jurisdiction. The appeals court, however, found that the district court's decision had been substantive, not jurisdictional, and was therefore not covered by 1447(d). The appeals court then ruled that the plaintiff's claims could not be brought under SLUSA.</p>
| 1,309 | 9 | 0 | true |
majority opinion
|
vacated/remanded
|
Judicial Power
|
1,728 | 55,340 |
Northern Ins. Co. of N.Y. v. Chatham County
|
https://api.oyez.org/cases/2005/04-1618
|
04-1618
|
2005
|
Northern Insurance Company of New York
|
Chatham County, Georgia
|
<p>James Ludwig's yacht was damaged when it collided with a drawbridge. Ludwig's insurance company, Northern, sued Chatham County to recover its costs. The county claimed that it was immune from civil suits due to its sovereign immunity under common law. The District Court agreed and ruled for the county. The court held that the county had sovereign immunity as a local government exercising power delegated by the state. Under Supreme Court precedent, sovereign immunity does not apply to local governments, but only to states and "arms of the state." Although the county did not qualify as an arm of the state under those precedents, the Eleventh Circuit Court of Appeals affirmed the District Court's decision. The Circuit Court held that common law nevertheless guaranteed the county a "residual immunity."</p>
| 817 | 9 | 0 | true |
majority opinion
|
reversed
|
Economic Activity
|
1,729 | 55,341 |
Holmes v. South Carolina
|
https://api.oyez.org/cases/2005/04-1327
|
04-1327
|
2005
|
Bobby Lee Holmes
|
South Carolina
|
<p>Bobby Lee Holmes was sentenced to death after he was convicted of murder and several other crimes. At trial, he was not permitted to introduce evidence suggesting that another person had committed the crimes.</p>
<p>Under South Carolina law, defendants "seeking to present evidence of third-party guilt must [limit the evidence] to such facts as are inconsistent with his own guilt, and to such facts as raise a reasonable inference or presumption as to his own innocence." Evidence that merely casts a bare suspicion on another person is not admissible. Using this standard, the South Carolina Supreme Court affirmed the trial court's decision not to allow the evidence.</p>
| 679 | 9 | 0 | true |
majority opinion
|
vacated/remanded
|
Due Process
|
1,730 | 55,346 |
Georgia v. Randolph
|
https://api.oyez.org/cases/2005/04-1067
|
04-1067
|
2005
|
Georgia
|
Scott Fitz Randolph
|
<p>Scott Randolph was arrested for drug possession after police found cocaine in his home. The police did not have a warrant to search the home, but Randolph's wife consented to the search. Randolph was also present at the time of the search, however, and objected to the police request. At trial, his attorney argued that the search was unconstitutional because of Randolph's objection, while the prosecution argued that the consent of his wife was sufficient. The trial court ruled for the prosecution, but the appellate court and Georgia Supreme Court both sided with Randolph, finding that a search is unconstitutional if one resident objects, even if another resident consents.</p>
| 687 | 5 | 3 | false |
majority opinion
|
affirmed
|
Criminal Procedure
|
1,731 | 55,344 |
United States v. Grubbs
|
https://api.oyez.org/cases/2005/04-1414
|
04-1414
|
2005
|
United States
|
Jeffrey Grubbs
|
<p>On federal trial for possessing child pornography, Grubbs asked the judge to suppress evidence officers seized from his home. Grubbs said the search violated the Fourth Amendment because the officers showed him an "anticipatory warrant," something valid only after triggering events take place, with no mention of the triggering conditions. The condition set on this warrant was that officers could search Grubbs' house only after he received a pornographic video in the mail. The judge denied Grubbs' motion because the trigger was set forth in an affidavit that the officers carried during the search and that the warrant referenced. The Ninth Circuit reversed and said officers had to show the triggering events for an anticipatory warrant to the person being searched.</p>
| 780 | 8 | 0 | true |
majority opinion
|
reversed/remanded
|
Criminal Procedure
|
1,732 | 55,345 |
Volvo Trucks North America, Inc. v. Reeder-Simco GMC, Inc.
|
https://api.oyez.org/cases/2005/04-905
|
04-905
|
2005
|
Volvo Trucks North America, Inc.
|
Reeder-Simco GMC, Inc.
|
<p>Reeder, a Volvo truck dealership, sued Volvo for violating the Robinson-Patman Act (RPA), which prohibits forms of discriminatory pricing that reduce competition. When retail customers take bids from dealers such as Reeder, the dealers ask manufacturers for price concessions, which dealers factor into their bids. Reeder accused Volvo of offering better price concessions to other Volvo dealers bidding for different customers. Reeder cited four instances in which it had received a comparatively low concession from Volvo, but it claimed that its losses due to discriminatory pricing went beyond those four instances. District Court allowed the case to go to a jury, and the jury awarded damages to Reeder. On appeal, Volvo argued that no competition was present, as would be required by the RPA, because Reeder was not actually bidding against the other Volvo dealers that allegedly got favorable concessions. The Eighth Circuit disagreed, ruling that the Volvo dealers - though they did not bid against each other - "competed at the same functional level." Volvo's price discrimination would therefore fall under the RPA.</p>
| 1,133 | 7 | 2 | true |
majority opinion
|
reversed/remanded
|
Economic Activity
|
1,733 | 55,342 |
Rumsfeld v. Forum for Academic and Institutional Rights, Inc.
|
https://api.oyez.org/cases/2005/04-1152
|
04-1152
|
2005
|
Donald H. Rumsfeld, Secretary of Defense, et al.
|
Forum for Academic and Institutional Rights, Inc., et al.
|
<p>The Solomon Amendment, 10 U.S.C. 983(b)(1), withholds some federal funding from colleges and universities that deny U.S. military recruiters the same access to students that other employers are given. The Forum for Academic and Institutional Rights challenged the law, arguing that it violated the schools' First Amendment rights to expressive association by requiring them to assist in military recruitment. The district court rejected the suit, but a Third Court of Appeals panel reversed. It held that, while the schools still had the right to forfeit funds so as to avoid unwanted endorsement of military policy under the amendment, forcing the schools to make such a decision was unconstitutional. Congress could not require them to forfeit a constitutional right in order to receive federal funds.</p>
| 811 | 8 | 0 | true |
majority opinion
|
reversed/remanded
|
First Amendment
|
1,734 | 55,343 |
Arkansas Dept. of Health and Human Servs. v. Ahlborn
|
https://api.oyez.org/cases/2005/04-1506
|
04-1506
|
2005
|
Arkansas Department of Health and Human Services, et al.
|
Heidi Ahlborn
|
<p>Heidi Ahlborn was injured and permanently disabled in a car accident. She received Medicaid payments totaling $215,645 through the Arkansas Department of Human Services (ADHS) to pay for her medical treatment. In order to be eligible for the Medicaid payments, Arkansas law required Ahlborn to give the ADHS the "right to any settlement, judgment, or award" she might receive because of the accident, up to the amount Medicaid had paid for her treatment.</p>
<p>Several years after the accident, Ahlborn received $550,000 in a settlement with the parties liable for her injuries. The sum covered her medical treatment as well as pain and suffering, lost earnings, and her lost earning potential in the future. Only $35,581 of the settlement was earmarked for her medical treatment, however. When the ADHS demanded that she repay the full $215,645, therefore, Ahlborn refused, and the issue went to a federal district court in Arkansas. The judge sided with the ADHS, ruling that it was not unreasonable for Arkansas to require Ahlborn to agree to repay them fully from any settlement she might receive in order to be eligible, even if the portion specifically allocated for medical treatment was less than the amount demanded by Medicaid.</p>
<p>An 8th Circuit Court of Appeals panel reversed, however, finding that seizing money from her settlement that had not been earmarked for medical treatment would violate federal Medicaid regulations, which forbid state governments from seizing the property of Medicaid recipients in order to recover money spent on treatment. The panel therefore ordered that Ahlborn repay just $35,581 to the ADHS.</p>
| 1,650 | 9 | 0 | false |
majority opinion
|
affirmed
|
Civil Rights
|
1,735 | 55,349 |
Ayotte v. Planned Parenthood of Northern New England
|
https://api.oyez.org/cases/2005/04-1144
|
04-1144
|
2005
|
Kelly A. Ayotte, Attorney General of New Hampshire
|
Planned Parenthood of Northern New England et al.
|
<p>After New Hampshire's state legislature approved the Parental Notification Prior to Abortion Act but before the act went into effect, Planned Parenthood of Northern New England challenged the law in federal district court. They claimed that the law, which requires that parents be notified before their minor daughter has an abortion, violated the "undue burden" test laid out in <em>Planned Parenthood v. Casey</em>, a 1992 Supreme Court decision that reformulated the constitutional protections given to abortion in <em>Roe v. Wade</em>. Specifically, they argued that an exemption in the law for abortions necessary to prevent the death of the mother, but not for those abortions necessary to protect merely her health, was unconstitutionally narrow.</p>
<p>The federal district court agreed, rejecting the argument of New Hampshire's Attorney General that the judicial bypass procedure included in the law, in which a judge could approve an abortion without parental notification for a minor who showed she was mature enough to make the decision on her own, could be used to permit abortions necessary to protect the health of the mother. The judge also rejected New Hampshire's argument that the law could not be challenged until it had actually been implemented. A First Circuit Court of Appeals panel unanimously affirmed the decision.</p>
| 1,350 | 9 | 0 | true |
majority opinion
|
vacated/remanded
|
Privacy
|
1,736 | 55,348 |
Arlington Central School District Board of Education v. Murphy
|
https://api.oyez.org/cases/2005/05-18
|
05-18
|
2005
|
Arlington Central School District Board of Education
|
Pearl Murphy, et vir.
|
<p>Using the federal Individuals with Disabilities Education Act (IDEA), Joseph Murphy's parents brought legal action to require the Arlington Central School District to pay for their son's private school tuition. After they prevailed, they sought reimbursement from the school district for fees they had paid to an educational consultant during the proceedings. They relied on an IDEA provision that allows courts to "award reasonable attorneys' fees as part of the costs" to prevailing parents. The school district argued that under <em>Crawford Fitting Co. v. J.T. Gibbons, Inc.</em>, 482 U.S. 437, and <em>West Virginia Univ. Hospitals, Inc. v. Casey</em>, 499 U.S. 83, expert fees can only be reimbursed when there is explicit authorization in the statute. Because the statute made no specific mention of expert fees, the school district argued, the fees could not be reimbursed. The federal district court and Second Circuit Court of Appeals disagreed, however, finding that a Congressional Conference Committee Report and a footnote in <em>Casey</em> referencing it showed that IDEA was intended to authorize reimbursement of expert fees.</p>
| 1,150 | 6 | 3 | true |
majority opinion
|
reversed/remanded
|
Attorneys
|
1,737 | 55,347 |
League of United Latin American Citizens v. Perry
|
https://api.oyez.org/cases/2005/05-204
|
05-204
|
2005
|
League of United Latin American Citizens et al.
|
Rick Perry, Governor of Texas, et al.
|
<p>In 2003, the Texas State Legislature passed a redistricting plan that replaced the one created by a federal judge following the 2000 census. Critics of the plan charged that it was unconstitutional and violated section 2 the Voting Rights Act because it diluted racial minority voting strength and was designed to maximize partisan advantage. A three-judge district court panel disagreed, finding that the plan was constitutional and that the legislature had the right to redistrict in 2003 using census data from 2000.</p>
<p>The case was appealed to the U.S. Supreme Court, but while it was pending the Court decided <em>Vieth v. Jubelirer</em>, another redistricting case from Pennsylvania. Justice Anthony Kennedy, the deciding vote in that case, wrote that the Court could hear claims of partisan discrimination in redistricting cases, but left open the question of the test those claims would be subjected to.</p>
<p>The three-district panel in this case then affirmed its earlier decision, finding that the Texas redistricting plan was not substantively unfair.</p>
| 1,076 | 5 | 4 | true |
plurality opinion
|
vacated/remanded
|
Civil Rights
|
1,738 | 55,355 |
Ash v. Tyson Foods, Inc.
|
https://api.oyez.org/cases/2005/05-379
|
05-379
|
2005
|
Anthony Ash et al.
|
Tyson Foods, Inc.
|
<p>Ash, an African American and an employee at a Tyson Foods poultry plant, was passed over for a promotion and sued the company for employment discrimination under Title VII of the Civil Rights Act of 1964. A jury found for Ash and awarded damages, but the District Court granted Tyson's motion for judgment as a matter of law, and ordered a new trial. The Eleventh Circuit Court of Appeals upheld the District Court's order, finding that the evidence presented by Ash was insufficient to support the damages awarded. Tyson claimed that Ash had been passed over for a more qualified employee, and in response Ash introduced evidence of his own superior qualifications in order to show that Tyson's reason was merely a pretext. The Circuit Court held that Ash's evidence did not meet the standard for establishing pretext: the disparity in qualifications needed to be "so apparent as virtually to jump off the page and slap you in the face." In the course of its opinion, the Eleventh Circuit also held that the Tyson plant manager's use of the word "boy" to refer to Ash was not evidence of racial animus, because it was never coupled with racial classifications.</p>
| 1,169 | 9 | 0 | true |
per curiam
|
vacated/remanded
|
Civil Rights
|
1,739 | 55,354 |
Illinois Tool Works Inc. v. Independent Ink, Inc.
|
https://api.oyez.org/cases/2005/04-1329
|
04-1329
|
2005
|
Illinois Tool Works Inc. et al.
|
Independent Ink, Inc.
|
<p>Independent Ink manufactured printing ink that was compatible with the printheads manufactured by (and patented by) Trident, a company owned by Illinois Tool Works. Trident, however, required that anyone who used their printheads also use their ink, which was not patented. Independent Ink brought suit in federal district court under the Sherman Act, which forbids companies from tying a license to use one product (in this case Trident's printheads) to a customer's agreement to use another product (Trident's ink). The district court ruled in favor of Trident, finding that Independent Ink had failed to show that Trident's control of the printhead allowed them to raise prices above the competitive market rate. The United States Court of Appeals for the Federal Circuit reversed, however, finding that when the product for which a license is granted is under patent, the ability to raise prices of that product above market rates must be assumed, and the burden is on the defendant to show that such power did not exist.</p>
| 1,033 | 8 | 0 | true |
majority opinion
|
vacated/remanded
|
Economic Activity
|
1,740 | 55,352 |
Marshall v. Marshall
|
https://api.oyez.org/cases/2005/04-1544
|
04-1544
|
2005
|
Vickie Lynn Marshall
|
E. Pierce Marshall
|
<p>Vickie Lynn Marshall (a.k.a. Anna Nicole Smith) was involved in a dispute in Texas Probate Court over the estate of her late husband, J. Howard Marshall. While the state-court proceedings were ongoing, Ms. Marshall filed for bankruptcy in federal court. E. Pierce Marshall, J. Howard's son, filed a claim alleging that Ms. Marshall had defamed him, and she filed a counterclaim alleging that E. Pierce had interfered with a gift she expected from her late husband's estate. The bankruptcy court ruled for Ms. Marshall and awarded her a large monetary award. Later, the probate court found J. Howard's will valid and ruled for his son. Under the judicially-created "probate exception" to federal jurisdiction, federal courts do not interfere with state-court judgments concerning wills and estates. E. Pierce Marshall appealed the bankruptcy court decision (awarding Ms. Marshall a large monetary award) to federal district court, invoking the probate exception to argue that the court had no jurisdiction. The district court disagreed and ruled for Ms. Marshall, holding that since her claim did not require invalidating the will, the probate exception did not apply. The Ninth Circuit reversed, broadly interpreting the probate exception as covering any question that would normally be handled in probate court.</p>
| 1,320 | 9 | 0 | true |
majority opinion
|
reversed/remanded
|
Judicial Power
|
1,741 | 55,351 |
Washington v. Recuenco
|
https://api.oyez.org/cases/2005/05-83
|
05-83
|
2005
|
Washington
|
Arturo R. Recuenco
|
<p>Arturo Recuenco was convicted of second degree assault in Washington state court after the jury found that he had attacked his wife "with a deadly weapon." The trial court then applied a 3-year enhancement to his sentence based on its own finding that a firearm had been involved, even though the jury never specifically found that a gun was used. On appeal, the Supreme Court of Washington ruled that the enhancement was unconstitutional under <em>Blakely v. Washington,</em> 542 U.S. 296, a 2004 U.S. Supreme Court decision that held that only those factors found by a jury, not a judge, may be considered for sentencing enhancements. The court disagreed with Washington state's argument that, while a Sixth Amendment violation under <em>Blakely</em> had indeed occurred, that violation could be found legally harmless.</p>
| 829 | 7 | 2 | true |
majority opinion
|
reversed/remanded
|
Criminal Procedure
|
1,742 | 55,353 |
Brown v. Sanders
|
https://api.oyez.org/cases/2005/04-980
|
04-980
|
2005
|
Jill L. Brown, Warden
|
Ronald L. Sanders
|
<p>A California trial court sentenced Sanders to death for murder. The jury was told to consider four special aggravating circumstances during sentencing. On appeal, however, the state supreme court invalidated two of these circumstances, but still upheld Sanders's sentence. Sanders then filed a federal habeas petition, which was rejected by the district court but granted by the Ninth Circuit Court of Appeals. In overturning Sanders's sentence, it held that the sentence had been substantially affected by jury instructions to consider invalid aggravating circumstances. The Ninth Circuit faulted the state supreme court for its standard of review: The court should have determined whether the invalid circumstances were harmless beyond a reasonable doubt in affecting the jury's sentence.</p>
| 798 | 5 | 4 | true |
majority opinion
|
reversed/remanded
|
Criminal Procedure
|
1,743 | 55,356 |
Beard v. Banks
|
https://api.oyez.org/cases/2005/04-1739
|
04-1739
|
2005
|
Jeffrey A. Beard, Secretary, Pennsylvania Department of Corrections
|
Ronald Banks, Individually and On Behalf of All Others Similarly Situated
|
<p>Pennsylvania houses "incorrigible, recalcitrant" prisoners in the Long Term Segregation Unit (LTSU). Ronald Banks was one of about 40 prisoners in level 2 of the LTSU, which is reserved for the most dangerous, worst-behaved inmates. It is the policy of the LTSU to impose severe restrictions on the privileges of level 2 inmates. In particular, level 2 prisoners are the only ones denied newspapers, magazines, and photographs. Beard, the Secretary of the PA Department of Corrections, argued that this policy was necessary to promote rehabilitation and ensure prison safety. Banks brought a suit challenging the policy as a violation of the First Amendment. On the recommendation of a Magistrate Judge, the District Court ruled in favor of Beard. On appeal, however, the Third Circuit Court of Appeals reversed. The Circuit Court found that the prison's policy failed to meet the test laid down by the Supreme Court in <em>Turner v. Safley</em>. The Third Circuit held that the First Amendment rights of the prisoners took precedence, because the policy was unrelated to the goal of rehabilitation, and an ineffective method of increasing prison safety.</p>
| 1,162 | 6 | 2 | true |
plurality opinion
|
reversed/remanded
|
First Amendment
|
1,744 | 55,358 |
Lance v. Dennis
|
https://api.oyez.org/cases/2005/05-555
|
05-555
|
2005
|
Keith Lance, et al.
|
Gigi Dennis, Colorado Secretary of State
|
<p>When the Colorado legislature failed to pass a redistricting plan in 2000, the state courts created one at the request of a group of voters. The legislature succeeded in passing a redistricting plan in 2003. The state attorney general brought suit in the Colorado State Supreme Court to require the secretary of state to use the court-ordered plan, and the Colorado General Assembly defended its own plan. The Colorado Supreme Court ruled that the legislature's plan violated Article V of the State Constitution. A group of citizens including Keith Lance brought another suit in federal court alleging that Article V of the Colorado Constitution, as interpreted by the Colorado Supreme Court, violated the Elections Clause of the U.S. Constitution. Under the Supreme Court's <em>Rooker-Feldman</em> doctrine, no federal court except the Supreme Court may hear appeals from state courts. The District Court held that since Lance was in privity with the General Assembly - that is, their claims were similar enough to constitute a mutual interest - Lance's suit was in effect an appeal of the General Assembly's loss in state court. Therefore, the District Court ruled that it had no jurisdiction under the <em>Rooker-Feldman</em> doctrine and declined to hear the case.</p>
| 1,276 | 9 | 0 | true |
per curiam
|
vacated/remanded
|
Judicial Power
|
1,745 | 55,357 |
Brigham City v. Stuart
|
https://api.oyez.org/cases/2005/05-502
|
05-502
|
2005
|
Brigham City, Utah
|
Charles W. Stuart, et al.
|
<p>Responding to a complaint about a loud party, police arrived at a house where they saw minors drinking alcohol outside and heard shouting inside. As they approached the house, they saw a fight through the window involving a juvenile and four adults, one of whom was punched hard enough to make him spit blood. The officers announced their presence, but the people fighting did not hear them so they entered the home. They arrested the men for contributing to the delinquency of a minor and other related offenses. The trial court judge, however, refused to allow the evidence collected after the police entered the home because it was a warrantless search in violation of the Fourth Amendment. On appeal, the government argued that the search was covered by the "emergency aid doctrine" because the officers were responding to seeing the man be punched. The Supreme Court of Utah disagreed, however, ruling that the doctrine only applies when there is an unconscious, semiconscious, or missing person who is feared injured or dead. The Court also gave weight to the fact that the officers acted exclusively in a law enforcement capacity, not to assist the injured man.</p>
| 1,176 | 8 | 1 | true |
majority opinion
|
reversed/remanded
|
Criminal Procedure
|
1,746 | 55,361 |
Gonzales v. O Centro Espírita Beneficente União do Vegetal
|
https://api.oyez.org/cases/2005/04-1084
|
04-1084
|
2005
|
Alberto R. Gonzales, Attorney General, et al.
|
O Centro Espirita Beneficente Uniao do Vegetal et al.
|
<p>O Centro Espirita Benficiente Uniao do Vegetal (UDV), a religious organization, brought suit in federal court to prevent the government from interfering with UDV's use of hoasca, a substance used during religious ceremonies that contains a drug prohibited by the Controlled Substances Act. UDV argued that the Religious Freedom Restoration Act, which prohibits substantial imposition on religious practices in the absence of a compelling government interest, established their right to use hoasca.</p>
<p>The district court sided with UDV and the Tenth Circuit Court of Appeals affirmed, finding that the government had not sufficiently proved the alleged health risks posed by hoasca and could not show a substantial risk that the drug would be abuse recreationally. In response to the Attorney General's argument that prohibiting the drug was required by an international treaty, the court ruled that the government had failed to "narrowly tailor" its prohibition of the drug.</p>
| 986 | 8 | 0 | false |
majority opinion
|
affirmed
|
First Amendment
|
1,747 | 55,360 |
Hartman v. Moore
|
https://api.oyez.org/cases/2005/04-1495
|
04-1495
|
2005
|
Michael Hartman, Frank Kormann, Pierce McIntosh, Norman Robbins, and Robert Edwards
|
William G. Moore, Jr.
|
<p>William Moore sued six postal inspectors in federal court, alleging that they had brought criminal charges against him in retaliation for lobbying efforts he undertook on behalf of his company. The inspectors claimed that they had qualified immunity (that is, because they filed the charges in their official capacity on good faith, they could not be sued) and also that the case should be dismissed because they had probable cause to charge Moore. The district court sided with Moore, and the Court of Appeals for the District of Columbia agreed, finding that, even with probable cause, they must show that that the prosecution was not motivated by a desire for retaliation.</p>
| 683 | 5 | 2 | true |
majority opinion
|
reversed/remanded
|
First Amendment
|
1,748 | 55,363 |
Lincoln Property Co. v. Roche
|
https://api.oyez.org/cases/2005/04-712
|
04-712
|
2005
|
Lincoln Property Company et al.
|
Christophe Roche et ux.
|
<p>Christophe and Juanita Roche leased an apartment in Virginia managed by Lincoln Property Company. The Roches sued Lincoln, which they identified as a Texas company, and other defendants in state court, alleging a variety of problems that arose from their exposure to toxic mold in their apartment. Lincoln moved the litigation to a federal district court, citing diversity of citizenship, which arises when opposing parties are from different states. The Roches then asked that the case be sent back to state court because there was no diversity of citizenship. Rather, one of the partners in the Lincoln-owned subsidiary partnership resided in Virgina. The court denied the motion and held that Lincoln was a Texas citizen. The Fourth Circuit reversed on the ground that Lincoln failed to show complete diversity of citizenship, because it did not disprove the exsistence of an affiliated Virginia entity that was a real party in interest.</p>
| 948 | 9 | 0 | true |
majority opinion
|
reversed/remanded
|
Judicial Power
|
1,749 | 55,362 |
Woodford v. Ngo
|
https://api.oyez.org/cases/2005/05-416
|
05-416
|
2005
|
Jeanne S. Woodford et al.
|
Viet Mike Ngo
|
<p>Under the Prison Litigation Reform Act of 1995 (PLRA), prisoners must exhaust any available administrative remedies for resolving disputes within the prison system before they can bring suit in federal court. Viet Mike Ngo filed a grievance with the California prison system, but it was dismissed because he had waited too long to file it. He then brought suit in federal district court. California objected, arguing that he had not exhausted his administrative remedies, and that the fact those remedies were no longer available to him because of his delay in filing was immaterial. The district court agreed, but the Ninth Circuit Court of Appeals reversed, finding that all of Ngo's administrative remedies were "exhausted" because they were no longer available to him.</p>
| 780 | 6 | 3 | true |
majority opinion
|
reversed/remanded
|
Judicial Power
|
1,750 | 55,364 |
Sanchez-Llamas v. Oregon
|
https://api.oyez.org/cases/2005/04-10566
|
04-10566
|
2005
|
Moises Sanchez-Llamas
|
Oregon
|
<p>Under Article 36 of the Vienna Convention, a treaty to which the U.S. is a party, any person detained in a foreign country has the right to notify the consulate of his home country of his detention.</p>
<p>Moises Sanchez-Llamas, a Mexican national, was arrested for his role in a shootout with the police. He was given a Miranda warning, but not informed of his right under Article 36 to notify his consulate. After Sanchez-Llamas made incriminating statements to the police, he was charged with attempted murder. Sanchez-Llamas moved to dismiss the charge. He argued that he had a right under Article 36 which had been violated, and that his confession should consequently be inadmissible as evidence. The trial court denied the motion. The Oregon Court of Appeals and the Oregon Supreme Court both affirmed, holding that the Vienna Convention does not create individual rights, but only rights of countries.</p>
<p>Mario Bustillo, a Honduran national, was arrested for murdering a man with a baseball bat. He was not informed that Article 36 would allow him to notify his consulate of his arrest. At trial, Bustillo's counsel brought witnesses testifying that another man had committed the crime. Nevertheless, Bustillo was convicted of first-degree murder, and the conviction was affirmed on appeal. Bustillo then filed a petition for review in state habeas court. He argued for the first time that his conviction should be thrown out because his Article 36 right to notify his consulate had been violated. The state habeas court denied the petition. The court ruled that the petition was "procedurally barred" under state law because he had failed to raise the issue at trial. The Virginia Supreme Court refused to hear an appeal.</p>
| 1,742 | 6 | 3 | false |
majority opinion
|
affirmed
|
Criminal Procedure
|
1,751 | 55,365 |
Hudson v. Michigan
|
https://api.oyez.org/cases/2005/04-1360
|
04-1360
|
2005
|
Booker T. Hudson, Jr.
|
Michigan
|
<p>Booker T. Hudson was convicted of drug and firearm possession in state court after police found cocaine and a gun in his home. The police had a search warrant, but failed to follow the Fourth Amendment "knock and announce" rule which requires police officers to wait 20-30 seconds after knocking and announcing their presence before they enter the home. The trial judge ruled that the evidence found in the home could therefore not be used, but the Michigan Court of Appeals reversed based on two Michigan Supreme Court cases that created an exception to the suppression of evidence when the evidence in question would have inevitably been found.</p>
| 654 | 5 | 4 | false |
majority opinion
|
affirmed
|
Criminal Procedure
|
1,752 | 55,366 |
United States v. Georgia
|
https://api.oyez.org/cases/2005/04-1203
|
04-1203
|
2005
|
United States
|
Georgia et al.
|
<p>Goodman, a paraplegic held in a Georgia state prison, sued Georgia in federal court for maintaining prison conditions that allegedly discriminated against disabled people and violated Title II of the Americans with Disabilities Act (ADA). Georgia claimed the 11th Amendment provided the state immunity from such suits. The district court ruled for Georgia, but the 11th Circuit reversed.</p>
<p>Before the 11th Circuit ruled in the case, the United States sued Georgia, arguing that the ADA's Title II abolished state sovereign immunity from monetary suits. Congress could do this, the U.S. argued, by exercising its 14th Amendment power to enforce equal protection.</p>
| 674 | 9 | 0 | true |
majority opinion
|
reversed/remanded
|
Federalism
|
1,753 | 55,367 |
Empire HealthChoice Assurance, Inc. v. McVeigh
|
https://api.oyez.org/cases/2005/05-200
|
05-200
|
2005
|
Empire HealthChoice Assurance, Inc., dba Empire Blue Cross Blue Shield
|
Denise F. McVeigh, as Administratrix of the Estate of Joseph E. McVeigh
|
<p>In accordance with the Federal Employees Health Benefits Act of 1959 (FEHBA), the Office of Personnel Management has negotiated a health insurance plan for federal employees with the Blue Cross Blue Shield Association. The plan requires the administrator to make a reasonable effort to recoup amounts paid for medical care from beneficiaries if those beneficiaries receive recoveries from another source (for example, a law suit or settlement against a third party that caused injury). In New York State, the plan is administered by Empire Healthchoice Assurance (Empire).</p>
<p>Empire brought suit in federal district court against the estate of Joseph McVeigh, a former federal employee who was injured in an accident and eventually won a settlement with the third party allegedly responsible for his injuries. Empire sought reimbursement for the money spent on McVeigh's medical care. Denise McVeigh, the administrator of Joseph McVeigh's estate, argued that the district court did not have jurisdiction to hear the case under FEHBA and that it should be heard instead by the state court. The district court and Second Circuit Court of Appeals agreed, dismissing the case for lack of jurisdiction.</p>
| 1,209 | 5 | 4 | false |
majority opinion
|
affirmed
|
Judicial Power
|
1,754 | 55,368 |
Fernandez-Vargas v. Gonzales
|
https://api.oyez.org/cases/2005/04-1376
|
04-1376
|
2005
|
Humberto Fernandez-Vargas
|
Alberto R. Gonzales, Attorney General
|
<p>Humberto Fernandez-Vargas entered the United States illegally and was deported in 1981. He illegally re-entered in 1982 and lived in the U.S. until 2001, when he married a U.S. citizen and applied to adjust his status to permanent resident. While applying, Fernandez-Vargas was arrested and eventually deported pursuant to Section 241(a)(5) (the "reinstatement statute") of the Immigration and Nationality Act (INA). The reinstatement statute, which became effective in 1997, allows prior deportation orders to be reinstated against aliens who re-enter the country illegally, and denies those aliens any form of relief under the INA. Fernandez-Vargas petitioned the Tenth Circuit Court of Appeals for review, arguing that Section 421(a)(5) was not intended to reinstate deportation orders that were issued prior to its enactment. The Circuit Court denied the petition. It held that Fernandez-Vargas' application for permanent resident status was a form of relief not allowd by the reinstatement statute. It also held that Congress did intend the reinstatement statute to apply to deportation orders, such as Fernandez-Vargas', that were issued before the statute went into effect. Finally, the Tenth Circuit held that this application of the law was not impermissibly retroactive, because Fernandez-Vargas had no "protectable expectation of being able to adjust his status."</p>
| 1,382 | 8 | 1 | false |
majority opinion
|
affirmed
|
Civil Rights
|
1,755 | 55,369 |
Ministry of Defense and Support for the Armed Forces of the Islamic Republic of Iran v. Elahi
|
https://api.oyez.org/cases/2005/04-1095
|
04-1095
|
2005
|
Ministry of Defense and Support for the Armed Forces of the Islamic Republic of Iran
|
Dariush Elahi
|
<p>Dariush Elahi sued in federal court claiming that the Islamic Republic of Iran had murdered his brother, and he won $300 million in damages. When Iran's Ministry of Defense won an arbitration award against a third party, Elahi sued to claim the award as part of the damages due to him. The Ministry objected, arguing that the Foreign Sovereign Immunities Act of 1976 (FSIA) granted its property immunity from such claims. The District Court ruled for Elahi on the grounds that the Ministry had waived its immunity when it sued to enforce its award against the third party. The Court of Appeals for the Ninth Circuit rejected the District Court's reasoning, but it also ruled for Elahi, pointing to a provision of the FSIA that excepts from immunity the property of any "agency or instrumentality" of a foreign government if the agency is "engaged in commercial activity in the United States." The Ninth Circuit ruled that the exception covers any foreign state as long as it is "engaged in commercial activity in the United States."</p>
| 1,040 | 9 | 0 | true |
per curiam
|
vacated/remanded
|
Economic Activity
|
1,756 | 55,370 |
Davis v. Washington
|
https://api.oyez.org/cases/2005/05-5224
|
05-5224
|
2005
|
Adrian Martell Davis
|
Washington
|
<p>Davis was arrested after Michelle McCottry called 911 and told the operator that he had beaten her with his fists and then left. At trial, McCottry did not testify, but the 911 call was offered as evidence of the connection between Davis and McCottry's injuries. Davis objected, arguing that presenting the recording without giving him the opportunity to cross-examine McCottry violated his Sixth Amendment right to confront his accuser as interpreted by the U.S. Supreme Court in <em>Crawford v. Washington</em>. The Washington Supreme Court disagreed, finding that the call was not "testimonial" and was therefore different from the statements at issue in <em>Crawford</em>.</p>
| 684 | 9 | 0 | false |
majority opinion
|
reversed/remanded
|
Criminal Procedure
|
1,757 | 55,372 |
Dye v. Hofbauer
|
https://api.oyez.org/cases/2005/04-8384
|
04-8384
|
2005
|
Paul Allen Dye
|
Gerald Hofbauer, Warden
|
<p>On August 29, 1982, Glenda Collins and Donna Bartels were shot in the Forbidden Wheels Motorcycle Club. After several witnesses testified against him in exchange for immunity, Paul Allen Dye was convicted of first- and second-degree murder for the shootings. Dye contended that he was innocent and that one of the witnesses who had testified against him was the shooter. The Michigan Court of Appeals affirmed his conviction, and the Michigan Supreme Court denied review.</p>
<p>Dye petitioned for federal habeas relief and argued that he was deprived of his right to a fair trial due to prosecutorial misconduct. The district court denied his petition. On appeal, the U.S. Court of Appeals for the Sixth Circuit initially held that there was flagrant prosecutorial misconduct and therefore reversed the district court’s ruling. The respondent moved for a panel rehearing, but before the rehearing occurred, one of the justices on the original panel retired. In its second opinion, the appellate court affirmed the district court’s ruling and determined that Dye’s prosecutorial misconduct claim was too vague and was not presented as a violation of a federal right to the state court because the state court’s opinion did not mention it.</p>
| 1,246 | 9 | 0 | true |
per curiam
|
reversed/remanded
|
Criminal Procedure
|
1,758 | 55,374 |
Zedner v. United States
|
https://api.oyez.org/cases/2005/05-5992
|
05-5992
|
2005
|
Jacob Zedner
|
United States
|
<p>Under the Speedy Trial Act of 1974, a federal criminal trial must begin within 70 days of the defendant's arrest or first appearance in court. The Act includes a list of delays which do not count toward this 70-day period, and one of these acceptable delays occurs when a federal district court finds on the record that the "ends of justice" served by granting a delay outweigh the public's and defendant's interest in a speedy trial. In this case, Zedner was a defendant in a criminal trial and twice asked the district court to issue such an order. The third time he requested one, the district court judge suggested that he sign a waiver of his right to a speedy trial under the Act for all time. Zedner signed the form, and accordingly the next time he asked for a delay the judge did not make on-the-record findings exempting the 91-day delay. Four years later, Zedner filed a motion to dismiss based on the failure to comply with the Act's 70-day period that resulted from that 91-day delay. The district court rejected the motion because of the waiver, and the Second Circuit Court of Appeals affirmed. Zedner appealed to the Supreme Court, arguing that the waiver he signed was invalid under the Act.</p>
| 1,216 | 9 | 0 | true |
majority opinion
|
reversed/remanded
|
Criminal Procedure
|
1,759 | 55,373 |
United States v. Olson
|
https://api.oyez.org/cases/2005/04-759
|
04-759
|
2005
|
United States
|
Joseph Olson et al.
|
<p>Injured workers sued the United States under the Federal Tort Claims Act (FTCA), alleging that federal mine inspectors' negligence helped cause a mine accident. The FTCA authorized private tort actions against the U.S. when the federal government, if a private person in similar circumstances, would be liable according to the law of the place where the incident occurred. The district court dismissed the suit, holding that the allegations failed to show Arizona law would have imposed liability on a private person in like circumstances. The Ninth Circuit reversed, holding federal mine inspections were a governmental function with no private analogue. In such cases, the Ninth Circuit held, the FTCA waived sovereign immunity if a state or municipal entity would be held liable under the law where the activity occurred.</p>
| 832 | 9 | 0 | true |
majority opinion
|
vacated/remanded
|
Economic Activity
|
1,760 | 55,375 |
Rice v. Collins
|
https://api.oyez.org/cases/2005/04-52
|
04-52
|
2005
|
Bertram Rice, Warden, et al.
|
Steven Martell Collins
|
<p>At Collins' state-court drug trial, he alleged that the prosecutor had used a peremptory challenge to strike a juror on account of her race. The prosecutor gave several race-neutral explanations for the strike, which the trial court accepted. Upon being convicted, Collins appealed to the California Court of Appeal, which upheld the conviction. According to the Court of Appeal, the juror's youth and demeanor were both valid reasons for striking her. The California Supreme Court denied review. The Federal District Court denied Collins' habeas petition, but the Ninth Circuit Court of Appeals reversed that decision. Under the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA), federal courts must defer to a state-court finding of fact unless it is an "unreasonable determination of the facts in light of the evidence presented in the State court proceeding." Applying this standard, the Ninth Circuit ruled that the trial court's acceptance of the prosecutor's race-neutral explanations was an unreasonable determination. The Supreme Court granted certiorari to determine whether the Ninth Circuit had acted correctly.</p>
| 1,143 | 9 | 0 | true |
majority opinion
|
reversed/remanded
|
Criminal Procedure
|
1,761 | 55,377 |
Erickson v. Pardus
|
https://api.oyez.org/cases/2006/06-7317
|
06-7317
|
2006
|
William Erickson
|
Barry J. Pardus, et al.
|
<p>William Erickson was diagnosed with Hepatitis C while imprisoned at Limon Correctional Facility in Limon, Colorado. He was prescribed medication to be administered via injection. One of the syringes he used for injection went missing from the medical center of the correctional facility and was later found in a communal trash can. Erickson was accused of stealing the syringe and utilizing it for illegal drug use, after which he was denied further treatment. Erickson sued prison medical officials under 42 U.S.C. 1983 and argued that the refusal of medical treatment violated his Eighth Amendment rights because he was suffering liver damage and threat of death by not being treated for Hepatitis C. The trial court dismissed Erickson’s suit on the grounds that he could not prove he was suffering substantial harm because he was being denied medical treatment. The U.S. Court of Appeals for the Tenth Circuit affirmed.</p>
| 930 | 7 | 1 | true |
per curiam
|
vacated/remanded
|
Judicial Power
|
1,762 | 55,376 |
Bradshaw v. Richey
|
https://api.oyez.org/cases/2005/05-101
|
05-101
|
2005
|
Margaret Bradshaw, Warden
|
Kenneth T. Richey
|
<p>Kenneth T. Richey attempted to kill his ex-girlfriend and her new boyfriend by setting fire to his ex-girlfriend’s apartment. The ex-girlfriend and her boyfriend escaped, but the neighbor’s two-year-old child was killed in the fire. Richey was convicted of aggravated felony murder and sentenced to death on the theory of transferred intent. On direct appeal with new counsel, his conviction and sentence were affirmed by the Ohio Supreme Court.</p>
<p>Richey sought state post-conviction relief but was denied by both the state trial court and the state appellate court. He then petitioned for federal habeas relief, but the federal district court denied his petition. The U.S. Court of Appeals for the Sixth Circuit reversed and held that under Ohio law, the theory of transferred intent cannot be applied to aggravated felony murder, and Richey received ineffective assistance of counsel based on his trial counsel’s mishandling of the arson expert and expert testimony.</p>
| 981 | 9 | 0 | true |
per curiam
|
vacated
|
Criminal Procedure
|
1,763 | 55,378 |
Los Angeles County v. Rettele
|
https://api.oyez.org/cases/2006/06-605
|
06-605
|
2006
|
Los Angeles County et al.
|
Max Rettele et al.
|
<p>The Los Angeles County Sheriff’s Department obtained a warrant to search a residence connected with a fraud and identity-theft crime ring. Unbeknownst to the police, the residence had been sold three months prior to the search, and there was no longer a suspect living there. The suspect the police thought lived in the residence for which the warrant was obtained was African American. When the police arrived at the house to conduct the search, the family living there was Caucasian. Max Rettele and his girlfriend were ordered out of bed and detained while the police secured the premises, but the police realized their mistake and quickly left. Rettele sued Los Angeles County for violating his Fourth Amendment right to be free from illegal searches and seizures. The trial court held that the police were not liable for violating Rettele’s Fourth Amendment rights. The U.S. Court of Appeals for the Ninth Circuit overturned the lower court’s decision and held that, since the race of Rettele and his girlfriend did not match the race of the suspect identified in the search warrant, the police violated Rettele’s Fourth Amendment rights.</p>
| 1,151 | 8 | 0 | true |
per curiam
|
reversed/remanded
|
Criminal Procedure
|
1,764 | 55,380 |
Fry v. Pliler
|
https://api.oyez.org/cases/2006/06-5247
|
06-5247
|
2006
|
John Francis Fry
|
Cheryl K. Pliler, Warden
|
<p>After extraordinarily long deliberations, a jury convicted John Fry of two counts of first degree murder. Near the end of the trial, the defense attempted to bring a witness who would testify that her cousin rather than Fry had committed the murders. The trial judge refused to let the witness testify. After exhausting his state court appeals, Fry petitioned for a writ of habeas corpus in federal court.</p>
<p>The District Court held that the trial judge had been wrong to exclude the witness, but it ruled that the decision was harmless error and upheld the conviction. The U.S. Court of Appeals for the Ninth Circuit affirmed, holding that the judge's decision met the test for harmless error in <em> <a href="/cases/1992/91_7358/">Brecht v. Abrahamson</a> </em>. Under the <em>Brecht</em> test, evidence is held to be harmless unless it has a "substantial and injurious effect or influence in determining the jury's verdict." Fry argued that the standard for harmless error in habeas cases should instead be the one defined in <em> <a href="/cases/1966/95/">Chapman v. California</a> </em>. The <em>Chapman</em> test requires the state to prove that the error was harmless beyond a reasonable doubt.</p>
| 1,213 | 5 | 4 | false |
majority opinion
|
affirmed
|
Criminal Procedure
|
1,765 | 55,382 |
Long Island Care at Home, Ltd. v. Coke
|
https://api.oyez.org/cases/2006/06-593
|
06-593
|
2006
|
Long Island Care at Home, Ltd., et al.
|
Evelyn Coke
|
<p>Long Island Care at Home (Long Island) employed Evelyn Coke as a "home healthcare attendant" for the elderly. Coke sued her employer, claiming rights to overtime and minimum wage under the Fair Labor Standards Act (FLSA). The District Court ruled for Long Island, holding that Coke fell under the FLSA's exemption for employees engaged in "companionship services." The court gave deference to the Department of Labor's regulation 29 CFR Section 552.109(a), which applies the exemption to employees in "companionship services" who are "employed by an employer or agency other than the family or household using their services."</p>
<p>The U.S. Court of Appeals for the Second Circuit reversed. It ruled that the regulation was a misinterpretation of the statute, and was therefore unenforceable. The Second Circuit declined to give the Department's regulation any of the judicial deference normally due to administrative regulations. No <em>Chevron</em> deference ("strong deference") was due, because the regulation was under a section titled "Interpretations." Regulations that are interpretive rather than legislative are not entitled to <em>Chevron</em> deference. The Court of Appeals also ruled that the regulation was "unpersuasive in the context of the entire statutory and regulatory scheme," and thus not entitled to <em>Skidmore</em> deference ("weak deference") either.</p>
| 1,388 | 9 | 0 | true |
majority opinion
|
reversed/remanded
|
Unions
|
1,766 | 55,381 |
Schriro v. Landrigan
|
https://api.oyez.org/cases/2006/05-1575
|
05-1575
|
2006
|
Dora B. Schriro, Director, Arizona Department of Corrections
|
Jeffrey Timothy Landrigan, aka Billy Patrick Wayne Hill
|
<p>Jeffrey Landrigan was convicted of first degree murder. During sentencing, Landrigan's counsel attempted to call witnesses to testify to Landrigan's disadvantaged upbringing and good character. However, Landrigan opposed his lawyer's decision to present this mitigating evidence, and the witnesses were never called. Landrigan was sentenced to death. He appealed, arguing that his counsel had been ineffective. Landrigan claimed that he had wanted the lawyer to present mitigating evidence showing Landrigan's genetic predisposition to violence.</p>
<p>After state courts rejected the claim as frivolous, Landrigan filed a petition for habeas corpus in federal District Court. The District Court ruled against Landrigan, but he finally prevailed in the U.S. Court of Appeals for the Ninth Circuit. Despite the high degree of deference to state courts required by the Anti-Terrorism and Effective Death Penalty Act of 1996, the Ninth Circuit ruled that the state court had been unreasonable to uphold Landrigan's death sentence. Landrigan's lawyer should have presented the mitigating evidence, the Court ruled, and the omission had rendered counsel ineffective.</p>
| 1,169 | 5 | 4 | true |
majority opinion
|
reversed/remanded
|
Criminal Procedure
|
1,767 | 55,384 |
Sinochem International Co. Ltd. v. Malaysia International Shipping Corp.
|
https://api.oyez.org/cases/2006/06-102
|
06-102
|
2006
|
Sinochem International Co. Ltd.
|
Malaysia International Shipping Corporation
|
<p>Malaysia International Shipping Corporation (MISC) owned a vessel carrying steel coils for Sinochem International, a Chinese company. Sinochem brought an action in Chinese Admiralty Court, alleging that MISC had backdated documents pertaining to the loading of the cargo, and seeking to have the ship detained in China. MISC filed suit in a Pennsylvania district court, accusing Sinochem of fraudulent misrepresentation. Sinochem argued that the U.S. had no personal jurisdiction over the Chinese company, but the District Court declined to rule on the issue. Instead the court dismissed the suit on grounds of "forum non conveniens," which means that the case could be more conveniently tried in another forum, in this case the Chinese Admiralty Court.</p>
<p>On appeal, the U.S. Court of Appeals for the Third Circuit reversed, ruling that the lower court should have first ruled on the jurisdictional issue. The Third Circuit acknowledged the inconvenience of determining jurisdiction before dismissing the case anyway, but nevertheless sent the case back to the District Court.</p>
| 1,089 | 9 | 0 | true |
majority opinion
|
reversed/remanded
|
Judicial Power
|
1,768 | 55,383 |
James v. United States
|
https://api.oyez.org/cases/2006/05-9264
|
05-9264
|
2006
|
Alphonso James, Jr.
|
United States
|
<p>When Alphonso James was convicted of firearm possession after having been convicted of a felony, the government sought an enhanced sentence under the Armed Career Criminal Act (ACCA). The ACCA allows for a minimum 15-year sentence if the convicted criminal has three prior convictions for serious drug offenses or violent felonies. A "violent felony" under the ACCA includes burglary and "conduct that presents a serious potential risk of physical injury to another." James had previously been convicted once for attempted burglary and twice for drug trafficking, so the government argued that he had the necessary three "countable" convictions for the increased sentence. James argued that one of his drug-related convictions did not count as a serious drug offense, and that attempted burglary did not count as a violent felony. A federal District Court held that attempted burglary was a violent felony, but also that James's drug offense was not serious. Therefore, James had only two countable offenses and could not be sentenced under the ACCA.</p>
<p>On appeal, the Court of Appeals for the Eleventh Circuit reversed and held that James's drug-trafficking offense was serious. The Eleventh Circuit agreed with the District Court that attempted burglary counted as a violent felony, a ruling that put it at odds with other Circuits. The Circuit Court ruled that attempted burglary is a violent felony because it presents as much risk of violence as a successful burglary.</p>
| 1,485 | 5 | 4 | false |
majority opinion
|
affirmed
|
Criminal Procedure
|
1,769 | 55,385 |
Purcell v. Gonzalez
|
https://api.oyez.org/cases/2006/06-532
|
06-532
|
2006
|
Helen Purcell, Maricopa County Recorder, et al.
|
Maria M. Gonzalez et al.
|
<p>In 2002, Arizona passed Proposition 200, which required a photo ID for voter registration. The Election Assistance Commission (EAC) notified Arizona’s Secretary of State that Proposition 200 conflicted with the National Voter Registration Act (NVRA) regarding the need for photo ID as proof of citizenship for mailed voter registration forms. Shortly thereafter, the plaintiffs — Arizona residents, Indian tribes, and community organizations — filed a restraining order to prevent the state of Arizona from enforcing the new rules for voter registration. The petition for a restraining order was denied by the district court. The plaintiffs appealed to the U.S. Court of Appeals for the Ninth Circuit and argued that it should grant an emergency injunction based on the fact that elections were about to begin. The appellate court granted the injunction to stop the enforcement of Proposition 200.</p>
| 905 | 9 | 0 | true |
per curiam
|
vacated/remanded
|
Judicial Power
|
1,770 | 55,386 |
Cunningham v. California
|
https://api.oyez.org/cases/2006/05-6551
|
05-6551
|
2006
|
John Cunningham
|
California
|
<p>John Cunningham, a former police officer, was convicted of continuous sexual abuse of his young son. Under California's Determinate Sentencing Law, the trial judge can choose between three possible sentences for a given crime: a minimum, medium, and maximum sentence. Judges normally hand down the medium sentence unless there are special circumstances. In Cunningham's case, the judge found six aggravating factors, and sentenced him to the maximum 16-year sentence. However, in determining some of the aggravating factors the judge relied on evidence not considered by the jury.</p>
<p>Cunningham appealed his sentence, arguing that the judge's discretion was a violation of Cunningham's right to a trial by jury. In <em>Blakely v. Washington</em>, the Supreme Court had ruled that for the right to a jury trial to be effective, any fact which increases a sentence "beyond the prescribed statutory maximum" must be proved before the jury. Cunningham argued that the judge can consider only factors determined by the jury when deciding which sentence to impose.</p>
<p>A California Court of Appeal disagreed and upheld the sentence, ruling that the judge had merely handed down the maximum sentence prescribed by the statute. The California Supreme Court denied Cunningham's appeal, but the U.S. Supreme Court agreed to hear the case.</p>
| 1,343 | 6 | 3 | true |
majority opinion
|
reversed/remanded
|
Criminal Procedure
|
1,771 | 55,387 |
National Association of Home Builders v. Defenders of Wildlife
|
https://api.oyez.org/cases/2006/06-340
|
06-340
|
2006
|
National Association of Home Builders et al.
|
Defenders of Wildlife et al.
|
<p>The Clean Water Act (CWA) instructs the Environmental Protection Agency (EPA) to turn over pollution permitting authority to a state if the state's proposal meets nine listed criteria. When Arizona issued such a proposal, the EPA regional office raised the concern that the transfer might violate Section 7(a)(2) of the Endangered Species Act (ESA), which prohibits agencies from taking actions that might jeopardize endangered species. In accordance with the ESA, the EPA consulted with the Fish and Wildlife Service (FWS). The FWS's opinion was that the ESA was inapplicable because the agency had no authority to consider any additional factors beyond the nine CWA criteria (none of which concerned endangered species). On the advice of the FWS, the EPA approved the transfer.</p>
<p>The Defenders of Wildlife challenged the transfer, arguing that the ESA imposed an authoritative, independent requirement on the EPA's decision to approve the transfer. The agency countered the ESA was not an independent source of authority. Rather, the ESA imposes requirements only on the discretionary decisions of federal agencies. Since its decision was non-discretionary under the CWA, the agency argued, the ESA did not apply. The U.S. Court of Appeals for the Ninth Circuit agreed with Defenders of Wildlife and invalidated the transfer. The Ninth Circuit found the FWS opinion legally flawed and the EPA's reliance on it "arbitrary and capricious." It noted that the EPA's decision was inconsistent with previous transfers of permitting authority, in which the impact on endangered species was considered.</p>
| 1,609 | 5 | 4 | true |
majority opinion
|
reversed/remanded
|
Economic Activity
|
1,772 | 55,388 |
Lawrence v. Florida
|
https://api.oyez.org/cases/2006/05-8820
|
05-8820
|
2006
|
Gary Lawrence
|
Florida
|
<p>Gary Lawrence was convicted of first-degree murder and sentenced to death. Lawrence appealed his conviction, arguing that his counsel had been ineffective. After exhausting his state-court appeals, Lawrence filed a petition for certiorari, asking the Supreme Court to review the decisions of the Florida courts. Later, Lawrence petitioned for a writ of habeas corpus, which would allow his appeal to be heard in federal court.</p>
<p>The federal District Court rejected Lawrence's habeas petition, because he had exceeded the one-year statute of limitations in the Antiterrorism and Effective Death Penalty Act (AEDPA). The AEDPA gives defendants one year to submit habeas petitions, but that does not include any time that the petitioner has a "properly filed application" pending for "State post-conviction or other collateral review." In Lawrence's case, whether or not he had exceeded the one-year time limit depended on whether or not the time spent waiting for the Supreme Court to process his pending certiorari petition counted toward the time limit. Federal Circuit Courts have disagreed on this question.</p>
<p>In his appeal, Lawrence argued that time spent on Supreme Court certiorari petitions, like time spent on state-court appeals, was not countable toward the one-year statute of limitations. Lawrence also made an alternative argument that the incompetence of his state-appointed counsel, as well as the disagreement among federal courts on the statute of limitations question, constituted "extraordinary circumstances." If the Court were to find that the delay was due to extraordinary circumstances beyond the defendant's control, it could set aside the time limit under the doctrine of "equitable tolling."</p>
<p>The U.S. Court of Appeals for the Eleventh Circuit upheld the District Court and rejected Lawrence's petition. The Circuit Court ruled that Lawrence had failed to demonstrate how his lawyer's actions or the confusion over the statute of limitations caused him to miss the deadline. The Circuit Court acknowledged that the statute of limitations had been in dispute, but it followed Circuit precedent that said time spent waiting for a pending Supreme Court certiorari petition did count toward the AEDPA's one-year time limit.</p>
| 2,269 | 5 | 4 | false |
majority opinion
|
affirmed
|
Criminal Procedure
|
1,773 | 55,390 |
Massachusetts v. Environmental Protection Agency
|
https://api.oyez.org/cases/2006/05-1120
|
05-1120
|
2006
|
Massachusetts et al.
|
Environmental Protection Agency et al.
|
<p>Massachusetts and several other states petitioned the Environmental Protection Agency (EPA), asking EPA to regulate emissions of carbon dioxide and other gases that contribute to global warming from new motor vehicles. Massachusetts argued that EPA was required to regulate these "greenhouse gases" by the Clean Air Act - which states that Congress must regulate "any air pollutant" that can "reasonably be anticipated to endanger public health or welfare."</p>
<p>EPA denied the petition, claiming that the Clean Air Act does not authorize the Agency to regulate greenhouse gas emissions. Even if it did, EPA argued, the Agency had discretion to defer a decision until more research could be done on "the causes, extent and significance of climate change and the potential options for addressing it." Massachusetts appealed the denial of the petition to the Court of Appeals for the D.C. Circuit, and a divided panel ruled in favor of EPA.</p>
| 948 | 5 | 4 | true |
majority opinion
|
reversed/remanded
|
Judicial Power
|
1,774 | 55,389 |
Ayers v. Belmontes
|
https://api.oyez.org/cases/2006/05-493
|
05-493
|
2006
|
Robert L. Ayers, Jr., Acting Warden
|
Fernando Belmontes
|
<p>In 1981, Fernando Belmontes Jr. was convicted of the first-degree murder of Steacy McConnell. During the sentencing phase of the trial, prosecutors sought the death penalty. Belmontes's defense lawyers argued for a life term in prison, and presented evidence of his history as a victim of abuse and poverty as well as his capacity for rehabilitation as mitigating factors. Before sentencing, the California trial judge instructed the jury to consider 11 possible mitigating factors, labeled (a) through (k), which jurors are required by California law to consider. The judge read factor (k), a catch-all factor, verbatim from the statute, telling jurors to consider "[a]ny other circumstance which extenuates the gravity of the crime even though it is not a legal excuse for the crime."</p>
<p>After the jury sentenced Belmontes to death, he appealed to the California Supreme Court, arguing that the jury had misunderstood the ambiguous factor (k) instruction to mean that they should not consider non-crime-related mitigating factors. Since the Supreme Court has ruled that jurors must consider all mitigating evidence offered by a defendant in a capital case, this would render the conviction unconstitutional. The California Supreme Court upheld the conviction, relying on <em>Boyde v. California</em>, in which the Supreme Court affirmed that factor (k) is constitutional unless there is a "reasonable likelihood" that jurors misunderstood it. Belmondes appealed to the Court of Appeals for the Ninth Circuit, where his death sentence was finally overturned in 2003. The Circuit Court ruled that jurors had been confused by the factor (k) instruction, which caused them to fail to consider the mitigating evidence of Belmondes's capacity for rehabilitation.</p>
<p>After the Supreme Court remanded the case back to the Ninth Circuit for reconsideration, the Circuit Court reaffirmed its decision in 2005. The Circuit Court held that the verbatim or "unadorned" reading of the factor (k) instruction would have misled a reasonable juror. The Supreme Court agreed to consider the constitutional sufficiency of factor (k), as well as the possible retroactive applicability of the Circuit Court's holding.</p>
| 2,214 | 5 | 4 | true |
majority opinion
|
reversed/remanded
|
Criminal Procedure
|
1,775 | 55,391 |
Davenport v. Washington Education Association
|
https://api.oyez.org/cases/2006/05-1589
|
05-1589
|
2006
|
Gary Davenport et al.
|
Washington Education Association
|
<p>In some states, public sector labor unions are allowed to collect fees from non-union members. The Supreme Court has ruled that unions may use these fees for political purposes, but only if the non-union member does not object. Washington state also has a "paycheck protection" law, RCW 42.17.760, which requires unions to obtain specific permission from non-members before using their fees for political activity. Davenport, a non-union teacher, sued the Washington Education Association (WEA) teacher's union for violating the law.</p>
<p>WEA appealed to the Washington Court of Appeals, arguing that Washington's requirement that unions get prior permission was an unconstitutional burden on the unions' First Amendment right to associate for political purposes. Davenport countered that his own First Amendment rights were being violated when his fees went to political causes he did not agree with. The state Court of Appeals ruled in favor of WEA.</p>
<p>On appeal, the Washington Supreme Court affirmed, ruling that the burden must lie on the nonmember to assert his rights and object to the political fees.</p>
| 1,122 | 9 | 0 | true |
majority opinion
|
vacated/remanded
|
Unions
|
1,776 | 55,393 |
Hein v. Freedom From Religion Foundation, Inc.
|
https://api.oyez.org/cases/2006/06-157
|
06-157
|
2006
|
Jay F. Hein, Director, White House Office of Faith-Based and Community Initiatives, et al.
|
Freedom From Religion Foundation, Inc., et al.
|
<p>Shortly after taking office, President Bush created by executive order the Office of Faith-Based and Community Initiatives, a program aimed at allowing religious charitable organizations to compete alongside non-religious ones for federal funding. Another executive order instructed various executive departments to hold conferences promoting the Faith-Based Initiative. The Freedom from Religion Foundation sued, alleging that the conferences favored religious organizations over non-religious ones and thereby violated the Establishment Clause of the First Amendment. The government argued that there was no "Case or Controversy" as required by Article III of the Constitution. According to the government, the Foundation had no standing to sue, because the Foundation had not been harmed in any way by the conferences. The fact that an individual pays taxes to the federal government is not normally enough to give the individual standing to challenge a federal program, but the Foundation noted that exceptions have been made for Establishment Clause challenges (see <em>Flast v. Cohen</em> and <em>Bowen v. Kendrick</em> ).</p>
<p>The District Court ruled that the Foundation lacked standing to sue. The court held that the exceptions only covered challenges to specific congressional expenditures, not executive-branch actions funded by the general funds allotted to the executive departments. The U.S. Court of Appeals for the Seventh Circuit reversed, ruling that any taxpayer has standing to bring an Establishment Clause challenge against an executive-branch program, whether funded by a specific congressional grant or by a discretionary use of a general appropriation.</p>
| 1,688 | 5 | 4 | true |
plurality opinion
|
reversed
|
Judicial Power
|
1,777 | 55,394 |
Roper v. Weaver
|
https://api.oyez.org/cases/2006/06-313
|
06-313
|
2006
|
Don Roper, Superintendent, Potosi Correctional Center
|
William Weaver
|
<p>William Weaver was convicted of the first degree murder of a prospective witness in a drug trial. During the penalty phase of the trial, the prosecutor gave a closing statement arguing for a death sentence. In the course of the statement, the prosecutor said: "You've got to think beyond William Weaver [...] This is society's worst nightmare" and "Sometimes killing is not only fair and justified; it's right. Sometimes it's your duty [...] it's right to kill him [Weaver] now." The jury sentenced Weaver to death. Weaver appealed in state court, arguing that the prosecutor's statements had inflamed and prejudiced the jury.</p>
<p>The Missouri state courts denied the appeal, but a federal District Court granted habeas corpus. The District Court overturned the sentence, ruling that the "unfairly inflammatory" closing statement had violated Weaver's right to due process. The U.S. Court of Appeals for the Eighth Circuit affirmed. On appeal to the Supreme Court, the state cited the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA), which states that federal courts shall not grant a prisoner's habeas petition unless the state court's decision was "contrary to [...] clearly established Federal law, as determined by the Supreme Court of the United States." The Eighth Circuit had cited some Supreme Court cases pertaining to prejudicial closing statements in the guilt phase of the trial, but the state argued that the federal courts should not have granted habeas relief, because the Supreme Court had not specifically addressed the issue of closing statements in the penalty phase.</p>
| 1,611 | 6 | 3 | false |
per curiam
| null |
Criminal Procedure
|
1,778 | 55,396 |
Powerex Corp. v. Reliant Energy Services, Inc.
|
https://api.oyez.org/cases/2006/05-85
|
05-85
|
2006
|
Powerex Corp.
|
Reliant Energy Services, Inc., et al.
|
<p>The state of California suffered an energy crisis in 2001. Citizens filed suit against energy company Reliant Energy Services et al (Reliant) for conspiring to fix energy price levels. Reliant filed cross-claims against multiple energy companies and regulatory agencies involved in the price fixing, including the Canadian company Powerex Corporation. PowerEx exported surplus Canadian hydropower on behalf of its owner, the British Columbia Hydro and Power Authority (BC Hydro). Since BC Hydro was a governmental corporation and Powerex was its subsidiary, both argued that they were entitled to sovereign immunity under the Foreign Sovereign Immunity Act of 1976 (FSIA). FSIA defines a foreign sovereign as an "organ of a foreign state" (28 U.S.C. Section 1603(b)). Reliant claimed that the two companies were exempt from FSIA sovereign immunity because their commercial activity had a "direct effect" on California energy markets.</p>
<p>A District Court ruled that BC Hydro was a foreign sovereign, but PowerEx was not. The District Court issued a remand order sending the case back to state court. Powerex appealed to the U.S. Court of Appeals for the Ninth Circuit, claiming that it operated for the "public interest" as an instrumentality of the government. The Ninth Circuit held that PowerEx was not a "foreign sovereign" because BC Hydro, not the Canadian government, owned PowerEx's shares.</p>
| 1,409 | 7 | 2 | true |
majority opinion
|
vacated/remanded
|
Judicial Power
|
1,779 | 55,398 |
BCI Coca-Cola Bottling Company of Los Angeles v. Equal Employment Opportunity Commission
|
https://api.oyez.org/cases/2006/06-341
|
06-341
|
2006
|
BCI Coca-Cola Bottling Company of Los Angeles
|
Equal Employment Opportunity Commission
|
<p>BCI Coca-Cola Bottling Company of Los Angeles fired African-American employee Stephen Peters. Human Resources Manager Pat Edgar decided to fire Peters in part because of a report of insubordination filed against Peters by his immediate supervisor, Cesar Grado. The Equal Employment Opportunity Commission (EEOC) claimed that Peters was a victim of invidious discrimination because Grado, an Hispanic, treated non-African American employees less harshly. EEOC filed suit against BCI on behalf of Stephens under Section 703(a) of Title VII of the Civil Rights Act of 1964, which prohibits discrimination against employees. Though a District Court concluded that Grado was racially biased, it dismissed the case because the evidence failed to prove that Edgar's decision to fire Stephens was sufficiently affected by Grado's discriminatory bias.</p>
<p>The U.S. Court of Appeals for the Tenth Circuit decided that a jury should determine whether or not Grado's bias affected Edgar's decision to fire Stephens, and it sent the case to trial. The Tenth Circuit cited the subordinate bias theory of liability, which holds a company liable for a discriminatory firing even if the employee who made the actual decision to fire was not the employee harboring racial bias.</p>
| 1,270 | 0 | 0 | false |
dismissal - other
|
none
| null |
1,780 | 55,400 |
Rita v. United States
|
https://api.oyez.org/cases/2006/06-5754
|
06-5754
|
2006
|
Victor A. Rita
|
United States
|
<p>Victor Rita received a thirty-three month sentence from a trial judge after a jury convicted him of perjury, obstruction of justice, and making false statements. Though the sentence fell within the range prescribed by the Federal Sentencing Guidelines and under the statutory maximum, Rita appealed to the U.S. Court of Appeals for the Fourth Circuit. He argued that the judge should not have sentenced him without explicitly considering factors enumerated in 18 U.S.C. 3553(a) that might justify imposing a lesser sentence. The government argued that the judge could presume the sentence reasonable if it fell within the guidelines, even without an explicit analysis of 18 U.S.C. 3553(a) factors. The Supreme Court had previously ruled in <em>U.S. v. Booker</em> that sentencing judges could only treat the guidelines as advisory, not as mandatory. The Fourth Circuit accepted the government's arguments and ruled that a presumption of reasonableness for within-Guidelines sentences did not violate <em>Booker</em>.</p>
| 1,024 | 8 | 1 | false |
majority opinion
|
affirmed
|
Criminal Procedure
|
1,781 | 55,397 |
Sole v. Wyner
|
https://api.oyez.org/cases/2006/06-531
|
06-531
|
2006
|
Michael W. Sole, Secretary, Florida Department of Environmental Protection, et al.
|
T.A. Wyner et al.
|
<p>Florida state park officials prohibited T.A. Wyner and George Simon from forming a peace symbol from nude individuals at a public beach. Wyner and Simon petitioned a district court, which issued a preliminary injunction barring the officials' interference and awarded Wyner and Simon their attorney fees in accordance with 42 U.S.C. Section 1988. Later, the district court reversed the injunction because state laws prohibited nudity at the beach. The officials argued that Wyner and Simon did not qualify as a "prevailing party," and therefore should not have their attorney fees refunded.</p>
<p>The U.S. Court of Appeals for the Eleventh Circuit ruled that Wyner and Simon were the "prevailing party" because the district court had decided to issue the preliminary injunction based on merits of the case. The park officials responded that the preliminary injunction was based on a "mistake of the law," because the case was dismissed upon further review. The U.S. Court of Appeals for the Fourth Circuit had previously ruled that a preliminary injunction is not a ruling based on the merits, and therefore does not determine the "prevailing party."</p>
| 1,159 | 9 | 0 | true |
majority opinion
|
reversed/remanded
|
Attorneys
|
1,782 | 55,399 |
Marrama v. Citizens Bank of Massachusetts
|
https://api.oyez.org/cases/2006/05-996
|
05-996
|
2006
|
Robert Louis Marrama
|
Citizens Bank of Massachusetts et al.
|
<p>Robert Marrama filed for Chapter 7 bankruptcy and agreed to turn over all of his non-exempt assets to a trustee for payment of his creditors. Trustees later accused Marrama of acting in bad faith by attempting to conceal two assets: a tax refund and some real estate. Marrama then moved to convert his bankruptcy petition from Chapter 7 to Chapter 13, which would allow him to keep more of his assets. Citizens Bank, one of Marrama's creditors, opposed the conversion. Citizens Bank argued that Marrama should not be able to convert to Chapter 13 due to his initial bad faith Chapter 7 petition. The bankruptcy court agreed and denied the conversion.</p>
<p>The bankruptcy appeals panel affirmed the court's ruling. On appeal to the U.S. Court of Appeals for the First Circuit, Marrama argued that the plain language of Section 706(a) of the Bankruptcy Code supported his right to convert to Chapter 13, regardless of the circumstances. Section 706(a) states, "The debtor may convert a case under [Chapter 7] to a case under Chapter 11, 12 or 13 of this title at any time [...]" Citizens Bank countered that the word "may" indicates a privilege rather than a right. It also argued that the bankruptcy system could be abused if debtors were able to convert to Chapter 13 after filing bad faith Chapter 7 petitions. The First Circuit upheld the panel's ruling, denying Marrama his conversion.</p>
| 1,398 | 5 | 4 | false |
majority opinion
|
affirmed
|
Economic Activity
|
1,783 | 55,401 |
Tennessee Secondary School Athletic Association v. Brentwood Academy
|
https://api.oyez.org/cases/2006/06-427
|
06-427
|
2006
|
Tennessee Secondary School Athletic Association
|
Brentwood Academy
|
<p>Brentwood Academy, a private school, was a voluntary member of the Tennessee Secondary School Athletic Association (TSSAA). After Brentwood's football coach violated TSSAA recruiting rules by contacting some prospective players at other schools, the TSSAA imposed various penalties on Brentwood. Brentwood sued the TSSAA, claiming that its First Amendment and Due Process rights were being violated. The Supreme Court had ruled previously that because the TSSAA was composed primarily of public schools, it was a state actor subject to the limitations of the Constitution (see <em>Brentwood Acad. v. TN Sec. School Ath. Assn.</em> No. 99-901). Accordingly, the District Court faulted the TSSAA for violations of Brentwood's constitutional rights and threw out the TSSAA's penalties.</p>
<p>On appeal, the TSSAA argued that it had not exercised the "police power" of the State, but merely enforced a voluntary contractual agreement with Brentwood. The U.S. Court of Appeals for the Sixth circuit rejected this argument, characterizing the TSSAA's actions as those of a "government regulator." The Sixth Circuit held that the state interest in regulating athletic competition was not substantial enough to counter-balance Brentwood's First Amendment rights, and it affirmed the lower court's ruling for Brentwood.</p>
| 1,319 | 9 | 0 | true |
majority opinion
|
reversed/remanded
|
First Amendment
|
1,784 | 55,402 |
United States v. Atlantic Research Corp.
|
https://api.oyez.org/cases/2006/06-562
|
06-562
|
2006
|
United States
|
Atlantic Research Corporation
|
<p>Atlantic Research Corp. (Atlantic) built rocket motors for the United States government at an Arkansas facility. When residue from burnt rocket fuel contaminated the site, Atlantic voluntarily cleaned up the contamination and later sought cost recovery from the government under Section 107(a) and Section 113(f) of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). Some Courts of Appeals had interpreted Section 107(a) as implicitly allowing a party responsible for contamination to compel other partly-responsible parties to contribute to the clean-up. The Superfund Amendments and Reauthorization Act of 1986 added Section 113(f), which makes explicit the right to sue for contribution.</p>
<p>While Atlantic was negotiating with the government, the Supreme Court ruled in <em>Cooper Industries, Inc. v. Aviall Services, Inc.</em> that a party cannot bring a Section 113(f) claim for contribution unless it is already the subject of a Section 107(a) contamination action. Atlantic filed a new claim for contribution under Section 107(a), but a district court denied the claim. The U.S. Court of Appeals for the Eighth Circuit had previously ruled that a liable party must use Section 113(f), not Section 107(a), to file a contribution claim. Atlantic argued that failure to meet the requirements of Section 113(f) did not foreclose the implied Section 107(a) right to sue other partly-responsible parties for contribution.</p>
| 1,467 | 9 | 0 | false |
majority opinion
|
affirmed
|
Economic Activity
|
1,785 | 55,404 |
MedImmune, Inc. v. Genentech, Inc.
|
https://api.oyez.org/cases/2006/05-608
|
05-608
|
2006
|
MedImmune, Inc.
|
Genentech, Inc., et al.
|
<p>Genentech held the patent for "Cabilly I", a process for using cell cultures to manufacture human antibodies. MedImmune had a licensing agreement with Genentech under which MedImmune paid royalties to Genentech in return for the use of the patent. Later, Genentech also obtained the patent to "Cabilly II," a continuation of the Cabilly I process. Under the licensing agreement, MedImmune became a licensee for Cabilly II as well. Genentech informed MedImmune that it would have to pay royalties on one of its most lucrative products, Synagis, which uses the Cabilly II process. MedImmune sued Genentech, claiming that the patent was invalid and unenforceable. However, MedImmune kept paying the royalties.</p>
<p>A federal District Court dismissed the suit because it did not present a controversy. Article III of the Constitution limits the jurisdiction of federal courts to "cases or controversies." This is implemented in the Declaratory Judgment Act, which requires that a suit involve an "actual controversy." Genentech argued that since MedImmune was still paying royalties on the patent, there was no controversy. MedImmune countered that though it was indeed still paying royalties on the patent it claimed was invalid, it was paying "under protest." It would be unreasonable, MedImmune argued, for the company to be required to break its contractual obligations by stopping royalty payments before suing. This might jeopardize MedImmune's legal rights to one of its best-selling products.</p>
<p>The U.S. Court of Appeals for the Federal Circuit ruled for Genentech and upheld the District Court, holding that the suit presented no actual controversy.</p>
| 1,669 | 8 | 1 | true |
majority opinion
|
reversed/remanded
|
Judicial Power
|
1,786 | 55,405 |
Rockwell International Corp. v. United States
|
https://api.oyez.org/cases/2006/05-1272
|
05-1272
|
2006
|
Rockwell International Corp. et al.
|
United States and United States ex rel James S. Stone
|
<p>Stone sued his employer, nuclear weapons plant operator Rockwell International, under the False Claims Act (FCA). He took advantage of the FCA's "qui tam" provision, which allows an individual to sue on behalf of the government. Stone alleged that Rockwell had made false claims about the environmental safety of "pondcrete," a mixture of cement and sludge used for nuclear waste storage. In a qui tam action under the FCA, the person bringing the suit must be the "original source" of the information on which his claim is based. Rockwell argued that Stone was not an original source because he did not have "direct and independent knowledge" of the information at issue in the suit, as required by the FCA.</p>
<p>The District Court ruled that Stone qualified as an original source, and a divided panel of the U.S. Circuit Court for the Tenth Circuit affirmed. The Supreme Court agreed to resolve the question of how much and what kind of knowledge an FCA qui tam plaintiff must have.</p>
| 994 | 6 | 2 | true |
majority opinion
|
reversed
|
Economic Activity
|
1,787 | 55,406 |
Leegin Creative Leather Products, Inc. v. PSKS, Inc.
|
https://api.oyez.org/cases/2006/06-480
|
06-480
|
2006
|
Leegin Creative Leather Products, Inc.
|
PSKS, Inc., dba Kay's Kloset . . . Kay's Shoes
|
<p>Leegin Creative Leather Products, a manufacturer of women's accessories, entered into vertical minimum price agreements with its retailers. The agreements required the retailers to charge no less than certain minimum prices for Leegin products. According to Leegin, the price minimums were intended to encourage competition among retailers in customer service and product promotion. When one retailer, PSKS, discounted Leegin products below the minimum, Leegin dropped the retailer. PSKS sued, arguing that Leegin was violating Section 1 of the Sherman Act by engaging in anticompetitive price fixing. Under the Supreme Court's 1911 decision in <em>Dr. Miles Medical Co. v. John D. Park & Sons Co.</em>, mandatory minimum price agreements are per se illegal under the Act - that is, they are automatically illegal regardless of the circumstances.</p>
<p>Leegin argued that this rule was based on outdated economics. It contended that a better legal analysis would be the "rule of reason," under which price minimums would be held illegal only in cases where they could be shown to be anticompetitive. Both the District Court and U.S. Court of Appeals for the Fifth Circuit rejected these arguments. The courts felt compelled to follow the Supreme Court's rule in the <em>Dr. Miles</em> case, under which Leegin's practices were illegal regardless of the economic arguments put forward by the company.</p>
| 1,412 | 5 | 4 | true |
majority opinion
|
reversed/remanded
|
Economic Activity
|
1,788 | 55,407 |
Scott v. Harris
|
https://api.oyez.org/cases/2006/05-1631
|
05-1631
|
2006
|
Timothy Scott
|
Victor Harris
|
<p>After a police officer attempted to pull him over for speeding, Victor Harris fled in his vehicle, initiating a high-speed car chase. Attempting to end the chase, Deputy Timothy Scott rammed Harris's vehicle with his police cruiser. Harris crashed and was rendered a quadriplegic. Harris sued Scott in federal District Court, alleging that Scott had violated his Fourth Amendment rights by using excessive force. Scott claimed qualified immunity as a government official acting in his official capacity, but the District Court rejected the claim. The U.S. Court of Appeals for the Eleventh Circuit affirmed.</p>
<p>In order to show that a government official is not entitled to qualified immunity, a plaintiff is required to prove that the official violated a clearly established constitutional right. The Eleventh Circuit ruled that Scott's actions constituted an unreasonable seizure in violation of the Fourth Amendment. Because there was no imminent threat - Harris remained in control of his vehicle and the roads were relatively empty - Scott's use of deadly force was unconstitutional. Although no Appellate Court had ruled on the specific question of the use of deadly force in a high-speed chase, the Eleventh Circuit ruled that the limits on deadly force were "clearly established."</p>
| 1,300 | 8 | 1 | true |
majority opinion
|
reversed
|
Criminal Procedure
|
1,789 | 55,408 |
Permanent Mission of India to the United Nations v. City of New York
|
https://api.oyez.org/cases/2006/06-134
|
06-134
|
2006
|
Permanent Mission of India to the United Nations et al.
|
City of New York, New York
|
<p>Foreign countries can own buildings surrounding the United Nations in New York City tax-free if the buildings are used exclusively for diplomatic purposes. The City filed lawsuits against the Indian and Mongolian consulates in a District Court for failing to pay taxes on properties used for non-diplomatic purposes. The two consulates argued that the Foreign Sovereign Immunity Act (FSIA) granted them immunity from suit. The District Court ruled that it had jurisdiction to hear the suit under the FSIA's "immovable property" exception, which removes immunity from foreign countries when "rights in immovable property situated in the United States are in issue." The two countries argued that "rights" denoted a narrow set of property laws and did not extend to tax matters. The U.S. Court of Appeals for the Second Circuit affirmed.</p>
| 843 | 7 | 2 | false |
majority opinion
|
affirmed
|
Economic Activity
|
1,790 | 55,412 |
Federal Election Commission v. Wisconsin Right to Life, Inc.
|
https://api.oyez.org/cases/2006/06-969
|
06-969
|
2006
|
Federal Election Commission
|
Wisconsin Right to Life, Inc.
|
<p>Wisconsin Right to Life (WRTL), a nonprofit political advocacy corporation, ran three advertisements encouraging viewers to contact two U.S. Senators and tell them to oppose filibusters of judicial nominees. WRTL intended to keep running the ads through the 2004 election, but the Bipartisan Campaign Reform Act of 2002 (BCRA) prohibits corporate funds from being used for certain political advertisements in the 60-day period prior to an election. WRTL sued the Federal Election Commission (FEC), claiming that the BCRA was unconstitutional as applied to the advertisements. In 2006, the Supreme Court let the "as applied" challenge proceed (see <em>Wisconsin Right to Life v. Federal Election Commission</em>, 04-1581). In <em>McConnell v. Federal Election Commission</em>, the Court had upheld Congress's power to regulate "express advocacy" ads that support or oppose political candidates, but WRTL claimed that its ads were "issue ads" rather than express advocacy. WRTL also argued that the government lacked a compelling interest sufficient to override the corporation's First Amendment free speech interest. The FEC countered that WRTL's ads were "sham issue ads," which refrain from explicitly endorsing or opposing a candidate but are intended to affect an election.</p>
<p>A three-judge District Court agreed with WRTL's arguments and ruled the BCRA unconstitutional as applied to the ads. The court refused the FEC's request that it inquire into the intent and likely effect of the ads, because those determinations would be impractical and would have a chilling effect on protected speech. Analyzing only the explicit content of the ads, the court found them to be legitimate issue ads and not express advocacy or sham issue ads. The court also held that the government's justification for banning express advocacy ads by corporations - the need to reduce political corruption and public cynicism - did not apply to ads that do not endorse or oppose a candidate. Therefore, the court ruled that the government lacked a compelling interest to justify the burden on WRTL's First Amendment rights.</p>
| 2,115 | 5 | 4 | false |
majority opinion
|
affirmed
|
First Amendment
|
1,791 | 55,409 |
Microsoft Corp. v. AT&T Corp.
|
https://api.oyez.org/cases/2006/05-1056
|
05-1056
|
2006
|
Microsoft Corporation
|
AT&T Corporation
|
<p>AT&T owned the patent for certain speech codecs (a type of software code) included in Microsoft's Windows operating system. When Microsoft sent master versions of the software overseas, copied them, and sold the copied software, AT&T sued for patent infringement. A company is guilty of infringement under the Patent Act if it "supplies...from the United States...components of a patented invention...in such manner as to actively induce the combination of such components." Microsoft argued that it was not liable because 1) software code is intangible and cannot not be considered a "component" of an invention and 2) no software had been "supplied" from the U.S. because the copies were made overseas.</p>
<p>The District Court rejected both of Microsoft's arguments, and the U.S. Court of Appeals for the Federal Circuit affirmed. The Federal Circuit ruled that software code could be a component, because the Patent Act was not limited to physical structures. The Circuit Court also held that each overseas copy made of the U.S.-originated software code was "supplied" from the United States.</p>
| 1,113 | 7 | 1 | true |
majority opinion
|
reversed
|
Economic Activity
|
1,792 | 55,411 |
Weyerhaeuser Co. v. Ross-Simmons Hardwood Lumber Co., Inc.
|
https://api.oyez.org/cases/2006/05-381
|
05-381
|
2006
|
Weyerhaeuser Company
|
Ross-Simmons Hardwood Lumber Company, Inc.
|
<p>Ross-Simmons Hardwood Lumber Co. (Ross-Simmons) sued Weyerhaeuser, a competing sawmill, for "predatory buying" in violation of Section 2 of the Sherman Act. Specifically, Weyerhaeuser was accused of buying more raw materials than it needed at unnecessarily high prices. Ross-Simmons alleged that Weyerhaeuser's business practices were aimed at monopolizing the market for purchasing unprocessed sawlogs and forcing its competitors out of business. At the jury trial, jurors were instructed to rule against Weyerhaeuser if Ross-Simmons could prove that Weyerhaeuser bought more sawlogs "than it needed" and paid more "than necessary" for them. Weyerhaeuser objected, arguing that the more stringent guidelines in the case of <em>Brooke Group v. Williamson Tobacco Corp.</em> required a ruling in its favor. In <em>Brooke Group</em>, the Court held that in order for a company to be liable for "predatory pricing," a company must be shown to have been operating at a loss, and to have a "dangerous probability" of recouping its losses.</p>
<p>The District Court rejected Weyerhaeuser's motion, ruling that <em>Brooke Group</em> applies only to predatory pricing, where a company prices its products too low in order force competitors out of the market, and not to predatory buying. Under the less stringent guidelines, the jury found Weyerhaeuser to be in violation of the Sherman Act, and awarded Ross-Simmons $78.8 million in damages. On appeal, the Ninth Circuit Court of Appeals upheld the District Court, ruling that the higher standard of liability for predatory pricing compared to predatory buying is appropriate, because business practices that resemble predatory pricing may result in benefits such as efficiency incentives and lower prices for consumers.</p>
| 1,771 | 9 | 0 | true |
majority opinion
|
vacated/remanded
|
Economic Activity
|
1,793 | 55,410 |
Panetti v. Quarterman
|
https://api.oyez.org/cases/2006/06-6407
|
06-6407
|
2006
|
Scott Louis Panetti
|
Nathaniel Quarterman, Director, Texas Department of Criminal Justice, Correctional Institutions Division
|
<p>Scott Louis Panetti was convicted of the murder of his wife's parents and sentenced to death. He petitioned for a writ of habeas corpus in federal District Court, claiming mental illness. The Supreme Court had ruled in <em>Ford v. Wainwright</em> that execution of the mentally ill is barred by the Eighth Amendment's prohibition on cruel and unusual punishment. A psychiatric evaluation found that Panetti believed that the State was "in league with the forces of evil" and was executing him in order to "prevent him from preaching the Gospel." However, doctors also found Panetti to be aware of his crime, of the fact that he was to be executed, and of the State's stated reason for executing him. The District Court concluded that he was sufficiently sane to be executed.</p>
<p>On appeal, the U.S. Court of Appeals for the Fifth Circuit affirmed the lower court. The Fifth Circuit rejected Panetti's argument that an inmate cannot be executed if he lacks a rational understanding of the State's motivation for the execution. The Court of Appeals instead relied on Justice Lewis Powell's concurrence in <em>Ford</em>, holding that an inmate need only have an awareness of the State's reason for execution, not necessarily a rational understanding of it.</p>
| 1,264 | 5 | 4 | true |
majority opinion
|
reversed/remanded
|
Criminal Procedure
|
1,794 | 55,413 |
Whorton v. Bockting
|
https://api.oyez.org/cases/2006/05-595
|
05-595
|
2006
|
Glen Whorton, Director, Nevada Department of Corrections
|
Marvin Howard Bockting
|
<p>Marvin Bockting was accused of sexually assaulting his six year old stepdaughter. The girl told a detective about Bockting's crimes against her, but at the trial she became very upset and refused to testify. The judge declared the witness unavailable and allowed the detective to give hearsay testimony on what Bockting's daughter had told him. Bockting was convicted and sentenced to life in prison without having had a chance to cross-examine the only witness against him.</p>
<p>Bockting's appeals in state court were denied. He filed a petition for habeas corpus in federal court, claiming that his Sixth Amendment right to confront his accuser had been violated. During Bockting's appeals, the Supreme Court ruled in <em>Crawford v. Washington</em> that hearsay testimony given outside the court by an unavailable witness is only admissible if the defendant had an opportunity to cross-examine the witness before trial.</p>
<p>Bockting appealed to the U.S. Court of Appeals for the Nith Circuit, arguing that <em>Crawford</em> should apply retroactively to his case. The Circuit Court ruled that <em>Crawford</em> had announced a "new rule" of criminal procedure; new rules are normally not applied to cases that were final before the rule was announced. However, the Ninth Circuit held that the rule on hearsay testimony was a "watershed" rule that was fundamental to a fair trial. Under an exception defined by the Supreme Court in <em>Teague v. Lane</em>, watershed rules are applied retroactively.</p>
| 1,514 | 9 | 0 | true |
majority opinion
|
reversed/remanded
|
Criminal Procedure
|
1,795 | 55,414 |
Carey v. Musladin
|
https://api.oyez.org/cases/2006/05-785
|
05-785
|
2006
|
Thomas L. Carey, Warden
|
Mathew Musladin
|
<p>Mathew Musladin was convicted of the murder of Tom Studer. At Musladin's trial, Studer's family wore buttons showing pictures of the victim. Musladin's defense attorney requested that the trial judge tell the family to take off the buttons because they were prejudicial to the defense, but the judge denied the motion. Musladin later appealed his conviction to a state appellate court, and the appellate court affirmed the trial court. The appellate court held that though the buttons were an "impermissible factor" and should be discouraged, they were not so prejudicial that he had been denied his Due Process right to a fair trial. Musladin filed a petition for habeas corpus in federal District Court, but it was denied. However, the Ninth Circuit Court of Appeals granted the petition, reversed the appellate court, and sent the case back the District Court.</p>
<p>Under 28 U.S.C. Section 2254(d)(1), a provision of the Anti-Terrorism and Effective Death Penalty Act (AEDPA), a federal court can grant habeas relief to a defendant convicted in state court only if the state court decision was "contrary to, or involved an unreasonable application of, clearly established Federal law, as determined by the Supreme Court of the United States." The Ninth Circuit found that this standard had been met, because the state court decision had been "objectively unreasonable." The Ninth Circuit ruled that the state court should have recognized the buttons as inherently prejudicial to the defense. In addition to Supreme Court precedents, the majority of the Circuit Court panel relied on one of the Circuit's own precedents that specifically dealt with buttons in the courtroom. The dissent argued that this reliance contradicted AEDPA's requirement that habeas courts consider the law "as determined by the Supreme Court." The majority considered the use of the Circuit precedent appropriate because it applied general principles set down by the Supreme Court.</p>
| 1,969 | 9 | 0 | true |
majority opinion
|
vacated/remanded
|
Criminal Procedure
|
1,796 | 55,415 |
Burton v. Stewart
|
https://api.oyez.org/cases/2006/05-9222
|
05-9222
|
2006
|
Lonnie Lee Burton
|
Belinda Stewart, Superintendent, Stafford Creek Corrections Center
|
<p>Burton was convicted of burglary, robbery, and rape. Under the standard state sentencing guidelines, the burglary and robbery alone warranted the maximum sentence for a single criminal event. In order to make sure the rape was punished as well, the trial judge added a consecutive sentence for the rape to the standard sentence.</p>
<p>Burton filed a habeas corpus petition challenging his sentence in federal court. He argued that under <em>Blakely v. Washington</em>, handed down after his conviction, the jury rather than the judge should have decided whether to add the extra sentence. The government argued that the holding in <em>Blakely</em> was a "new rule." Under the Court's decision in <em>Teague v. Lane</em>, new rules of criminal procedure do not apply retroactively. Burton countered that the relevant rule was actually established in <em>Apprendi v. New Jersey</em>, a decision handed down before his conviction became final. Burton also argued that even if <em>Blakely</em> is a new rule, it is essential for a fair trial. New rules that are essential for the fundamental fairness of trials can apply retroactively.</p>
<p>The Ninth Circuit Court of Appeals ruled against Burton. The Appeals Court held that <em>Blakely</em> was a new rule, so it could not be used by Burton in his appeal.</p>
| 1,314 | 9 | 0 | false |
per curiam
|
vacated/remanded
|
Criminal Procedure
|
1,797 | 55,421 |
Environmental Defense v. Duke Energy Corp.
|
https://api.oyez.org/cases/2006/05-848
|
05-848
|
2006
|
Environmental Defense et al.
|
Duke Energy Corporation
|
<p>A 1977 amendment to the Clean Air Act created the Prevention of Significant Deterioration program (PSD), which requires power companies that want to make emissions-increasing modifications to their facilities to first apply for permits. Between 1988 and 2000, Duke Energy Corporation (Duke) made twenty-nine extensive improvements to its power plants without obtaining PSD permits. When the government, along with Environmental Defense and several other environmental groups, sued Duke, the company pointed to a PSD regulation explicitly defining "modification" for purposes of PSD as any change that increases the hourly rate of emissions from a facility. Duke's improvements increased the number of hours the plants remained open, and therefore also increased the total annual emissions from the plants. But since the improvements left the hourly rate of emissions unchanged, Duke argued that it did not have to obtain PSD permits. The government countered by citing the Environmental Protection Agency's current interpretation of the PSD regulations, which holds that a power company making improvements that increase the hours of operation of its plants does need to obtain a permit in all cases where construction is involved.</p>
<p>The District Court ruled in favor of Duke. The judge refused to rely on the EPA's current interpretation, ruling that it was inconsistent with the wording of the PSD regulations. Environmental Defense appealed to the Fourth Circuit Court of Appeals, and the Circuit Court affirmed the District Court's decision. The Fourth Circuit pointed out that the 1977 PSD amendment had taken its definition of "modification" directly from a 1975 Clean Air Act amendment concerning the New Source Performance Standards program (NSPS). In the 1975 amendment, the term "modification" explicitly excluded improvements that merely increase the hours of operation of a facility. Therefore, the Fourth Circuit held, the EPA did not have statutory authority to interpret "modification" differently for the PSD program. Environmental Defense appealed to the Supreme Court, with the added argument that the Fourth Circuit never should have heard the case, because challenges to Clean Air Act regulations can only be brought in the D.C. Cricuit.</p>
| 2,270 | 9 | 0 | true |
majority opinion
|
vacated/remanded
|
Economic Activity
|
1,798 | 55,417 |
BP America Production Co. v. Burton
|
https://api.oyez.org/cases/2006/05-669
|
05-669
|
2006
|
BP America Production Co., successor in interest to Amoco Production Co., et al.
|
Rejane Burton, Act Assistant Secretary, Land and Minerals Management, Department of the Interior, et al.
|
<p>The Department of the Interior (DOI) leases the rights to the mining of natural resources on federal lands to private companies like BP America Production (BP) in return for royalty payments. BP obtained a lease for the mining of coalbed methane gas, a natural gas that requires removal of excess carbon dioxide from the gas in order to make in marketable. In 1996, the Minerals Management Service (MMS) of the DOI issued an administrative order clarifying that the companies themselves must bear the full cost of removing the carbon dioxide. BP had been deducting the removal cost from its royalty payments, so the MMS ordered BP to pay more than $4 million in past royalites. BP cited 28 U.S.C. Section 2415(a), which establishes a six-year statute of limitations for government actions for monetary damages. BP argued that the government could not claim past royalties from more than six years before the 1996 administrative order, because the six-year time limit had expired.</p>
<p>The DOI Assistant Secretary rejected BP's arguments and ruled for the government. A District Court affirmed the decision, ruling that an agency administrative order was not a government action for monetary damages, so the statute of limitations did not apply. On appeal, the Court of Appeals for the D.C. Circuit upheld the lower court's ruling. The Circuit Court ruled that the government would have had to file a complaint in court in order for the statute of limitations to take effect; an agency administrative order did not activate the time limit.</p>
| 1,548 | 7 | 0 | false |
majority opinion
|
affirmed
|
Judicial Power
|
1,799 | 55,418 |
Gonzales v. Duenas-Alvarez
|
https://api.oyez.org/cases/2006/05-1629
|
05-1629
|
2006
|
Alberto R. Gonzales, Attorney General
|
Luis Alexander Duenas-Alvarez
|
<p>Luis Duenas-Alvarez, a Peruvian citizen living in California, was convicted of unlawful driving or taking of a vehicle. The Immigration and Nationality Act (INA) allows for the deportation of aliens who are convicted of an aggravated felony, which includes "theft offenses." The Department of Homeland Security began deportation proceedings against Duenas-Alvarez. An immigration judge ruled in favor of the government and ordered Duenas-Alvarez deported to Peru, and the Board of Immigration Appeals affirmed.</p>
<p>On appeal to the U.S. Court of Appeals for the Ninth Circuit, Duenas-Alvarez argued that he was not guilty of a theft offense for purposes of the INA because he had only aided and abetted the theft of the car. The California anti-theft law did not distinguish between auto-theft and merely aiding an auto-theft, but the Ninth Circuit had ruled that the INA "theft offense" includes only the person who actually stole and took possession of the car, and not necessarily anyone who aided in the theft. Accordingly, the Circuit Court ruled in favor of Duenas-Alvarez and reversed the lower courts.</p>
| 1,120 | 9 | 0 | true |
majority opinion
|
vacated/remanded
|
Civil Rights
|
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