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   Federal Courts - U. S. Supreme Court - April - May, 1938

  
Erie R.R. v. Tompkins, No. 367, SUPREME COURT OF THE UNITED STATES, April 25, 1938, Decided
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Overview: Respondent brought a negligence action against petitioner railroad company, seeking damages for injuries sustained when he was hit by a door projecting from petitioner's train while he was walking along a railroad right of way. The circuit court affirmed the judgment in favor of respondent, refusing to consider petitioner's claim that it was not liable for respondent's injuries under state common law. It held instead that liability was a question of general law about which federal courts were free to render independent decisions. On appeal, the court reversed and remanded, holding that there was no federal general common law, and that except in matters governed by the U.S. Constitution or by acts of Congress, the law to be applied by federal courts in any diversity case was the law of the state. In so holding, the court disapproved the contrary doctrine of Swift v. Tyson, 16 Pet. 1 (1842), finding it an unconstitutional assumption of powers by federal courts that invaded state autonomy and prevented uniformity in administering state law. The court also held that ? 34 of the Federal Judiciary Act of 1789, 28 U.S.C.S. ? 725, was not declarative of the Swift doctrine.

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United States v. Carolene Products Co., No. 640, SUPREME COURT OF THE UNITED STATES, April 25, 1938, Decided
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Overview: Appellant United States obtained an indictment against appellee corporation for a violation of the Filled Milk Act (Act), 21 U.S.C.S. ?? 61-63, which prohibited the shipment of adulterated milk in interstate commerce. Holding that a rational basis for legislation was all that the Fifth Amendment's guarantee of due process required, the Court reversed. The Court first declared the Act a valid exercise of congressional power under the Commerce Clause. The Court then held that the Act did not infringe the Fifth Amendment, as nothing in the guarantee of due process prohibited a national or state legislature from enacting laws for the protection of their citizens. Further, the Court noted the presumption of constitutionality inherent in legislative acts. The Court held that its function, at least with respect to acts not implicating specific constitutional prohibitions, restricting political processes aimed at the repeal of undesirable legislation, or prejudicing "discrete and insular minorities," was to determine if a rational basis existed for the act, and if so, to uphold it.

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Johnson v. Zerbst, No. 699, SUPREME COURT OF THE UNITED STATES, May 23, 1938, Decided
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Overview: Petitioner, while imprisoned in federal penitentiary, was denied habeas corpus by the trial court. Later, the trial court granted petitioner a second hearing, prompted by the peculiar circumstances surrounding the case. Upon consideration of the second petition, the trial court found that it did not substantially differ from the first and therefore denied the petition. In the writ, petitioner contended that he was deprived of his constitutional right under U.S. Const. amend. VI to assistance of counsel. The trial court held that proceedings depriving petitioner of his constitutional right were not sufficient to make the trial void in a habeas corpus proceeding, but could be addressed on appeal. The appellate court affirmed and the Supreme Court granted certiorari. The Court reversed the trial court's decision when the Court found that petitioner was convicted without assistance of counsel, and therefore remanded the issue to the trial court to determine whether petitioner had voluntarily waived that right. If he had, then he wasn't entitled to habeas corpus relief, but if he had not, then the trial court was without jurisdiction to proceed to judgment and convict petitioner.

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