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Federal Courts -
U. S. Supreme Court - January 21 - June 20, 1980
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World-Wide Volkswagen Corp. v. Woodson, No. 78-1078,
SUPREME COURT OF THE UNITED STATES, January 21, 1980, Decided
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Overview: New York residents purchased a new car from petitioner retailer. While driving through Oklahoma to a new home in Arizona, the purchasers' car was struck in the rear by another vehicle, causing a fire, which severely injured them. The purchasers brought a products-liability action in an Oklahoma court against petitioners, among others. Petitioners, which were incorporated in New York and did business there, entered special appearances, claiming that, because they had no minimal contacts with the state, Oklahoma's exercise of jurisdiction over them would violate their rights under the Due Process Clause of U.S. Const. amend. XIV. The Oklahoma trial court rejected petitioners' claim, and petitioners sought a writ of prohibition in the Oklahoma supreme court to restrain respondent, a state trial judge, from exercising in personam jurisdiction over them. The state supreme court denied the writ, holding that personal jurisdiction was authorized by Oklahoma's long-arm statute, Okla. Stat. tit. 12, ? 1701.03(a)(4) (1971). On certiorari, the Court reversed on due process grounds, finding that petitioners had no contacts, ties, or relations with the State of Oklahoma.
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Trammel v. United States, No. 78-5705,
SUPREME COURT OF THE UNITED STATES, February 27, 1980, Decided
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Overview: Petitioner was convicted on federal drug charges and appealed his conviction, arguing that, under the Hawkins rule, which barred the testimony of one spouse against the other, the trial court erred in admitting the adverse testimony of petitioner's wife. The lower court rejected petitioner's claim and affirmed his conviction, and petitioner sought review. The Court affirmed. The Court noted that the Federal Rules of Evidence acknowledged the authority of the federal courts to continue the evolutionary development of testimonial privileges in criminal trials, and that since its decision in Hawkins, a number of states had abolished the spousal privilege, and the privilege had been subject to much criticism. Therefore, the Court held that it would modify the Hawkins rule so that the witness-spouse alone had a privilege to refuse to testify adversely; the witness could neither be compelled to testify nor foreclosed from testifying. The Court concluded that such a modification would further the important public interest in marital harmony without unduly burdening legitimate law enforcement needs.
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Chiarella v. United States, No. 78-1202,
SUPREME COURT OF THE UNITED STATES, March 18, 1980, Decided
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Overview: Petitioner printer was indicted and convicted of violating ? 10(b) of the Securities Exchange Act of 1934, 15 U.S.C.S. ? 78j, and SEC Rule 10b-5, 17 C.F.R. ? 240.10b-5. While working for a financial printer, petitioner handled announcements of corporate takeover bids. Without disclosing his knowledge, petitioner purchased the targeted companies stock, selling the shares immediately after the takeover attempts were made public. Reversing petitioner's conviction, the Court held that petitioner had not violated the duty to disclose material information where no relationship of trust or confidence existed between petitioner and the shareholders. While noting that silence in connection with the purchase or sale of securities could have been fraud under ? 10(b), the Court held that petitioner had not violated ? 10(b) where he was under no affirmative duty to disclose the information before trading. Because petitioner was not an agent or fiduciary of the sellers, the Court found that he had no duty to the sellers.
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Payton v. New York, No. 78-5420,
SUPREME COURT OF THE UNITED STATES, April 15, 1980, Decided **Together with No. 78-5421, Riddick v. New York, also on appeal from the same court.
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Overview: Two cases on appeal challenged the constitutionality of N.Y. Penal Law ?? 140.15(4), 120.80. In the first case, police officers established probable cause against defendant in a murder case, and went to defendant's apartment to arrest him. Police officers entered without a warrant and found incriminating evidence in plain view that was admitted at defendant's trial. In the second case, police officers entered defendant's house to arrest him without a search warrant and found narcotics in the dresser. On appeal, the United States Supreme Court reversed and remanded the cases for further proceedings because the Fourth and Fourteenth Amendments prohibited the police from making a warrantless and nonconsensual entry into a suspect's home in order to make a routine felony arrest. The Court held that to be arrested in the home involved not only the invasion attendant to all arrests, but also an invasion of the sanctity of the home, which was too substantial, absent exigent circumstances, even when it was accomplished under statutory authority and when probable cause was present.
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Cuyler v. Sullivan, No. 78-1832,
SUPREME COURT OF THE UNITED STATES, May 12, 1980, Decided
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Overview: Defendant and his co-defendants were indicted for first-degree murder. Two lawyers represented all three defendants throughout the trial. Defendant did not object to the multiple representation. Defendant was convicted while his co-defendants were acquitted. The lower appellate court found that both lawyers had represented defendant, and that reversal was required because there was a possibility of a conflict of interest in that representation. The court vacated, holding that state courts were not required to inquire into the sufficiency of multiple representation where no parties objected and no special circumstances were present. Where defendant raised no objection at the trial to the sufficiency of the multiple representation, he was required to show that an actual conflict of interest adversely affected his lawyer's performance. A possible conflict of interest was not enough to establish an ineffective assistance of counsel.
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R.I. v. Innis, No. 78-1076,
SUPREME COURT OF THE UNITED STATES, May 12, 1980, Decided
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Overview: Respondent was convicted of the kidnapping, robbery, and murder of a taxicab driver after the trial court denied respondent's motion to suppress the weapon and statements made by respondent to the police about the weapon. The state supreme court set aside respondent's conviction, finding that respondent had been subjected to subtle coercion that was the equivalent of interrogation after respondent invoked his Miranda right to counsel. On appeal, the court vacated the judgment of the state supreme court. The court held that the Miranda safeguards came into play whenever a person in custody was subjected to either express questioning or its functional equivalent. The court held that the term "interrogation" under Miranda referred not only to express questioning, but also to any words or actions on the part of the police that the police should know were reasonably likely to elicit an incriminating response from a suspect. The court held that respondent was not interrogated within the meaning of Miranda when the police officers voiced safety concerns about children finding the weapon from the crime and respondent interrupted them to say he would show them where the gun was located.
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United States v. Mendenhall, No. 78-1821,
SUPREME COURT OF THE UNITED STATES, May 27, 1980, Decided
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Overview: Defendant was convicted of possessing heroin with intent to distribute after the district court denied her motion to suppress the introduction of the heroin at trial. The lower appellate court reversed, holding that defendant's consent to the search of her person had not been voluntarily given. On appeal, the court reversed the judgment of the lower appellate court. The court held that defendant was not seized when she was approached by the federal agents who asked to see her ticket and identification, even though defendant was not expressly told that she was free to decline to cooperate with their inquiry. The court held that a person had been seized within the meaning of the Fourth Amendment only if, in view of all of the circumstances surrounding the incident, a reasonable person would have believed that she was not free to leave. The court held that the totality of the evidence was adequate to support the district court's findings that defendant voluntarily consented to accompany the officers and that defendant consented to the search of her person freely and voluntarily.
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Walker v. Armco Steel Corp., No. 78-1862,
SUPREME COURT OF THE UNITED STATES, June 2, 1980, Decided
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Overview: The injured person brought suit against the manufacturer within the state statute of limitations, but service was not made until more than 60 days after expiration of the limitations period. Under Okla. Stat. tit. 12, ? 97 (1971), service was too late, but service would have been timely under Fed. R. Civ. P. 3. The district court dismissed the complaint because the Oklahoma tolling statute was an integral part of its statute of limitations. The court of appeals agreed, and the Court affirmed. The Court reviewed prior rulings concerning statutes of limitation, and held that under those rulings, the state tolling provisions applied. The Court noted that in diversity actions, Rule 3 governed the date on which various timing requirements of the Federal Rules began to run, but it did not affect state statutes of limitation. On the other hand, the state statute was a statement of a substantive decision by the state that actual service on the defendant was an integral part of the several policies served by the statute of limitations. Rule 3 and Okla. Stat. tit. 12, ? 97 (1971) therefore each controlled its own intended sphere of coverage without conflict.
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Diamond v. Chakrabarty, No. 79-136,
SUPREME COURT OF THE UNITED STATES, June 16, 1980, Decided
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Overview: Respondent microbiologist filed patent claims for human-made, genetically engineered bacterium that was capable of breaking down multiple components of crude oil. The court affirmed the judgment that allowed respondent's claims. The court rejected the argument of the patent office board of appeals that 35 U.S.C.S. ? 101 was not intended to cover living things such as laboratory created micro-organisms. The court held that respondent's micro-organism constituted a "manufacture" or a "composition of matter" within the meaning of 35 U.S.C.S. ? 101 and thus qualified as patentable subject matter. The court found that respondent had produced a new bacterium with markedly different characteristics from any found in nature and which had the potential for significant utility. The court held that the language of 35 U.S.C.S. ? 101 embraced respondent's invention.
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Cent. Hudson Gas & Elec. Corp. v. Public Serv. Comm'n, No. 79-565,
SUPREME COURT OF THE UNITED STATES, June 20, 1980, Decided
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Overview: Appellee promulgated a regulation that banned all promotional advertising by electric utility companies operating in the state. Appellant challenged a judgment from the state's highest court that ruled that the regulation did not violate U.S. Const. amends. I and XIV rights. On appeal, the Court reversed after applying the four-prong analysis relevant to commercial speech cases. The Court: (1) noted that appellee did not claim that the expression at issue either was inaccurate or related to unlawful activity; (2) ruled that appellant's promotional advertising was not unprotected commercial speech merely because appellant held a monopoly over electricity in its service area; (3) ruled that, while appellee's interests in energy conservation and ensuring fair and efficient energy rates were substantial, the link between the advertising ban and appellant's rate structure was, at most, tenuous, and; (4) ruled that, because the regulation reached all promotional advertising, it was more extensive than necessary to further appellee's interest in energy conservation. As such, the regulation impermissibly infringed appellant's First Amendment rights.
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