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| New York Times Co. v. Sullivan, No. 39,
SUPREME COURT OF THE UNITED STATES, March 9, 1964, Decided **Together with No. 40, Abernathy et al. v. Sullivan, also on certiorari to the same court, argued January 7, 1964.
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Overview: Petitioner newspaper sought review of a decision upholding a judgment awarding respondent damages in a civil libel action. The Court held that the rule of law applied by the Alabama courts was constitutionally deficient for failure to provide petitioner the safeguards for freedom of speech and of the press that were guaranteed by theandin a libel action brought by a public official against critics of his official conduct. The Court held that petitioner's constitutional guarantees required a rule that prohibited a public official from recovering damages for a defamatory falsehood relating to the public official's official conduct unless the official proved that the statement was made with actual malice. The Court defined actual malice as knowledge that the defamatory statement was false or made with reckless disregard of whether it was false or not. Further, the Court held that under the proper safeguards, the evidence presented against petitioner was constitutionally insufficient to support the judgment for respondent. Respondent presented no evidence to show petitioner was aware of erroneous statements or was in any way reckless in that regard.
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| Massiah v. United States, No. 199,
SUPREME COURT OF THE UNITED STATES, May 18, 1964, Decided
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Overview: The Supreme Court reversed a judgment of a court of appeals, which had affirmed a judgment of conviction against petitioner for violation of federal narcotics laws. The Supreme Court held that petitioner was denied the basic protections of U.S. Const. amend. VI when there was used against him at his trial evidence of his own incriminating words, which federal agents had deliberately and secretly elicited from him after he had been indicted and in the absence of his counsel. The court found that any secret interrogation of petitioner, from and after the finding of the indictment, without the protection afforded by the presence of counsel, contravened the basic dictates of fairness in the conduct of the criminal cause and the fundamental rights of petitioner. Petitioner was as much entitled to aid of counsel during the critical period after arraignment and until the beginning of trial as at the trial itself. Here, petitioner was seriously imposed upon since he did not even know that he was under interrogation by a government agent.
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| Schlagenhauf v. Holder, No. 8,
SUPREME COURT OF THE UNITED STATES, November 23, 1964, Decided
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Overview: Bus passengers injured when a bus struck a tractor-trailer sued the bus owner, the bus driver, the tractor-trailer owners, and the tractor-trailer driver. The tractor-trailer owners petitioned for examination of the bus driver under Fed. R. Civ. P. 35. The district court ordered the examinations. The bus driver sought a writ of mandamus setting aside the district court judge's order. The court of appeals denied mandamus. On certiorari, the court vacated the court of appeal's judgment and remanded to the district court, holding that: (1) the court of appeals had power to review on the petition for mandamus the basic, undecided question of whether the district court could order the examinations; (2) Rule 35 was constitutional and within the scope of the Rules Enabling Act; (3) a district court had power to order the examination of a party defendant under Rule 35, even on the application of a codefendant, but lacked power to order examination of nonparties; and (4) the tractor-trailer owners failed to make the necessary showing that the bus driver's physical or mental condition was in controversy or that good cause was shown for the examinations as required by Rule 35.
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| Heart of Atlanta Motel v. United States, No. 515,
SUPREME COURT OF THE UNITED STATES, December 14, 1964, Decided
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Overview: The motel, which discriminated in the renting of its rooms on the basis of race, sought review of a judgment by attacking the constitutionality of Title II of the Civil Rights Act of 1964. The motel contended that in enacting the statute Congress exceeded its power to regulate commerce under the Commerce Clause, U.S. Const. art I, § 8, cl. 3, and violated the Fifth and Thirteenth Amendments. Affirming the judgment, the Court held that the power of Congress over interstate commerce extended to those intrastate activities that so affected interstate commerce or the exercise of Congressional power over it to make regulation of them an appropriate means to exercise its power over interstate commerce. Further, the power of Congress to promote interstate commerce also included the power to regulate the local incidents thereof, including local activities in both the state of origin and destination, which might have a substantial and harmful effect upon that commerce. Accordingly, Congress was within its power to prohibit racial discrimination by motels serving travelers, however local their operations appeared.
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