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Federal Courts -
U. S. Supreme Court - January - June, 1979
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Parklane Hosiery Co. v. Shore, No. 77-1305,
SUPREME COURT OF THE UNITED STATES, January 9, 1979, Decided
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Overview: Respondent sued, alleging misleading and material misrepresentations in petitioner's proxy statement. Before the action came to trial, the Securities and Exchange Commission (SEC) filed suit against petitioner, making essentially the same allegations, and entered a declaratory judgement after a trial. Respondent moved for a partial summary judgment to estop petitioner from relitigating the issues that had been resolved against them in the SEC action. The district court denied the motion on the ground that it violated petitioner's U.S. Const. amend. VII right to a jury trial. The court of appeals reversed. On review, the Court held that application of collateral estoppel did not violate petitioner's right to a jury trial, and mutuality was no longer required. The Court further held that the preferable approach was not to preclude the use of offensive collateral estoppel, but to grant trial courts broad discretion to determine its application. The general rule adopted by the Court was that offensive estoppel was precluded where plaintiff could have easily joined in the earlier action, or where application would be unfair to a defendant.
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Delaware v. Prouse, No. 77-1571,
SUPREME COURT OF THE UNITED STATES, March 27, 1979, Decided
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Overview: A patrolman stopped defendant's automobile and seized marijuana in plain view on the car floor. Defendant was indicted for illegal possession of a controlled substance. The patrolman testified that he had made the stop only in order to check the driver's license and registration. The trial court granted defendant's motion to suppress, finding the stop and detention to have been wholly capricious and, therefore, violative of the Fourth Amendment. The Court granted certiorari to resolve whether the Fourth Amendment prohibited the automobile stop. The Court held that, except in those situations in which there was reasonable suspicion that a motorist was unlicensed or that an automobile was not registered, or that either the vehicle or an occupant was otherwise subject to seizure for violation of law, stopping an automobile and detaining the driver in order to check his driver's license and the registration of the automobile was unreasonable under the Fourth Amendment. The Court held that the states were not precluded from developing methods for spot checks that involved less intrusion or that did not involve the unconstrained exercise of discretion.
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Bell v. Wolfish, No. 77-1829,
SUPREME COURT OF THE UNITED STATES, May 14, 1979, Decided
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Overview: The matter concerned pretrial detention and the scope of the detainees' rights during the period of confinement prior to trial. The lawsuit challenged the conditions of confinement and practices at a federally operated short-term custodial facility, which the district court found unconstitutional. The United States Supreme Court reversed the decision and held that the district court erred in applying the compelling necessity standard to determine whether respondents' rights were infringed upon. The Court held that in determining the constitutionality of conditions of pretrial detention that implicated the protection against deprivation of liberty without due process, the proper inquiry was whether conditions amounted to punishment because under the Due Process Clause, a detainee could not be punished prior to adjudication. Measures taken by respondents served a legitimate, nonpunitive governmental purpose to ensure the security and order of the institution. The Court further held that courts should defer to the expertise of correction officials in the absence of evidence indicating that the officials exaggerated their response to the issues involved in providing detainment.
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Dunaway v. New York, No. 78-5066,
SUPREME COURT OF THE UNITED STATES, June 5, 1979, Decided
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Overview: A murder occurred during an attempted robbery. An informant supplied a possible lead that implicated petitioner. The police questioned the informant but did not have enough information to get a warrant for petitioner's arrest. The police located petitioner and took him into custody. Although he was not told he was under arrest, he would have been restrained if he had attempted to leave. He was taken to the police headquarters, and questioned after being given Miranda warnings. Petitioner waived his right to counsel and made incriminating statements. On appeal, the Court held that the detention for custodial interrogation intruded on the interests protected by the Fourth and Fourteenth Amendment of the constitution and held that the police violated the constitution when, without probable cause, they seized petitioner for interrogation. The Court held that while proper Miranda warnings were given and petitioner's statements were "voluntary" for purposes of the Fifth Amendment, they were inadmissible since no intervening events broke the connection between petitioner's illegal detention and his confession.
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Smith v. Md., No. 78-5374,
SUPREME COURT OF THE UNITED STATES, June 20, 1979, Decided
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Overview: After the victim of a robbery began receiving phone calls from the person who claimed to be the robber, the police installed a pen register, without a warrant, at the central telephone system in order to determine the identity of the numbers that petitioner, a suspect, was dialing. After the police discovered that petitioner had called the victim, they charged him with robbery. Petitioner alleged that use of the pen register constituted an illegal search within the meaning of U.S. Const. amend. IV. On review of the state court's decision that it did not, the Court determined that petitioner's U.S. Const. amend. IV rights were not violated. The Court found that petitioner did not have a legitimate expectation of privacy regarding the numbers he dialed on his phone because those numbers were automatically turned over to a third party, the phone company. The Court also ruled that even if petitioner did harbor some subjective expectation that the phone numbers he dialed would remain private, this expectation was not one that society was prepared to recognize as "reasonable." Thus, the Court concluded that installation of the pen register was not a "search" and no warrant was required.
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Hutchinson v. Proxmire, No. 78-680,
SUPREME COURT OF THE UNITED STATES, June 26, 1979, Decided
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Overview: Plaintiff was a research behavioral scientist who studied emotional behavior in monkeys. Most of his research was funded by government grants. Respondents were a United States Senator and his legislative assistant. Respondent senator awarded plaintiff the Golden Fleece Award for presenting an egregious example of wasteful governmental spending. Respondents publicized the award through telephone calls, radio and television interviews, and newsletters. Plaintiff filed his action for libel, intentional infliction of emotional distress, interference with contractual relations, and infringement of his rights to privacy, peace, and tranquility. Reversing the district court and the appeals court, the United States Supreme Court held that plaintiff was not a "public figure," and therefore the "actual malice" standard did not apply to him. In addition, the Court held that the Speech and Debate Clause of the United States Constitution did not protect respondents for defamatory statements they made or might make. That meant that the libelous remarks made by respondents in followup telephone calls to executive agencies, and in the television and radio interview, were not protected.
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Jackson v. Virginia, No. 78-5283,
SUPREME COURT OF THE UNITED STATES, June 28, 1979, Decided
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Overview: The inmate claimed that a federal habeas court did not have to consider whether there was any evidence to support his state court conviction, but had to determine whether there was sufficient evidence. The Court held that, assuming the procedural prerequisites were satisfied, the inmate was entitled to habeas relief if there was evidence that no rational trier of fact could have found proof of guilt beyond a reasonable doubt. The Due Process Clause of the Fourteenth Amendment protected a criminal defendant against conviction except upon proof beyond a reasonable doubt of every fact necessary to constitute the crime charged. A state prisoner who alleged the evidence could not be fairly characterized as sufficient to have led a rational trier of fact to find guilt beyond a reasonable doubt stated a constitutional claim cognizable in a federal habeas proceeding. Review of the record in the light most favorable to the prosecution established a rational factfinder could readily have found the inmate guilty beyond a reasonable doubt of first degree murder under state law.
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