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| Sony Corp. of Am. v. Universal City Studios, Inc., No. 81-1687,
SUPREME COURT OF THE UNITED STATES, January 17, 1984, Decided
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Overview: Petitioners manufactured and sold home video tape recorders. Respondents owned the copyrights to television programs broadcast on public airwaves. Respondents sued petitioners for copyright infringement, alleging that because consumers used petitioners' recorders to record respondents' copyrighted works, petitioners were liable for the copyright infringement allegedly committed by those consumers in violation of the Copyright Act, 17 U.S.C.S. ¿ 101 et seq. The district court held in favor of petitioners. The appellate court reversed. The U.S. Supreme Court held that petitioners demonstrated a significant likelihood that substantial numbers of copyright holders that licensed works for broadcast on free television would not object to having such broadcasts recorded for later viewing by private viewers. The recorders were therefore capable of substantial non-infringing uses and respondents' sale of the recorders to the general public did not constitute copyright infringement.
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| Pennhurst State Sch. & Hosp. v. Halderman, No. 81-2101,
SUPREME COURT OF THE UNITED STATES, January 23, 1984, Decided
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Overview: Petitioners challenged the decision of the federal appellate court in favor of respondent patients, affirming a district court judgment that ordered petitioners to conform their conduct to a state law on patient care. The Supreme Court reversed, holding that federal courts lacked jurisdiction under U.S. Const. amend. XI to enjoin petitioners' actions on the basis of a state law. The record showed that the officials acted in good faith; thus, any state law violation was caused by the state itself in not having fulfilled its legislative promises. Federal courts had no jurisdiction because the relief was sought was against the state. The Court held that federal courts did not have pendent jurisdiction over respondents' claims because pendent jurisdiction could not override the Eleventh Amendment. Federal courts had to examine each claim and determine if their jurisdiction was barred by the amendment. Policy considerations could not override the constitutional limitation on the federal judiciary to adjudicate suits against respondents. Federal courts also had no jurisdiction over the claims against a county because the relief sought ran to the state.
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| Southland Corp. v. Keating, No. 82-500,
SUPREME COURT OF THE UNITED STATES, January 23, 1984, Decided
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Overview: Appellees, franchisees, filed separate suits against appellant, their franchisor, which were consolidated. Appellant filed a motion to compel arbitration pursuant to the franchise contract, and appellees filed a motion for class certification. The trial court granted arbitration except for those claims under the Franchise Investment Law, Cal. Corp. Code ¿ 31000 et seq., because that law required judicial consideration of claims brought under it. The appellate court reversed the ruling, and the state supreme court reversed the appellate court. On appeal, the U.S. Supreme Court held that ¿ 2 of the Federal Arbitration Act (Act), 9 U.S.C.S. ¿ 2, which made arbitration provisions in contracts involving commerce enforceable, was a substantive rule under the Commerce Clause. It was binding on the states and preempted state laws that invalidated arbitration provisions. The Court thus reversed the judgment of the state supreme court on that issue. However, because the Court did not have jurisdiction on the class action issues, as those issues were not drawn in question on federal grounds, the Court dismissed the appeal as to those issues, and remanded the case.
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| Lynch v. Donnelly, No. 82-1256,
SUPREME COURT OF THE UNITED STATES, March 5, 1984, Decided
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Overview: The city's display comprised many of the figures and decorations traditionally associated with Christmas, including, among other things, a Santa Claus house, reindeer pulling Santa's sleigh, candy-striped poles, a Christmas tree, carolers, and the creche at issue. The ACLU and others argued that the city had endorsed and promulgated religious beliefs. The city was permanently enjoined from including the creche in the display. The Court reversed the judgment. In so doing, the Court held that (1) whatever benefit there was to one faith or religion or to all religions, it was indirect, remote, and incidental; (2) the display of the creche was no more an advancement or endorsement of religion than the congressional and executive recognition of the origins of Christmas itself as "Christ's Mass," or the exhibition of literally hundreds of religious paintings in governmentally supported museums; and, (3) the city had a secular purpose (the celebration of Christmas) for including the creche. The Court concluded that the city had not impermissibly advanced religion, and including the creche had not created excessive entanglement between religion and government.
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| Calder v. Jones, No. 82-1401,
SUPREME COURT OF THE UNITED STATES, March 20, 1984, Decided
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Overview: The California resident brought a libel action against a national magazine based in Florida and against petitioners, a reporter and the magazine's editor, individually. Petitioners, served by mail in Florida, moved to quash service for lack of personal jurisdiction, and the state appellate court reversed the lower court order and found jurisdiction. The Supreme Court granted certiorari and affirmed, holding that jurisdiction over petitioners was proper based upon the effects of their intentional conduct in California. Respondent's career was centered in California, the article was drawn from California sources, and the harm was suffered in California. The Supreme Court noted that petitioners were not charged with untargeted negligence, but rather their intentional, and allegedly tortious, actions were expressly aimed at California, and under the circumstances, petitioners must have reasonably anticipated being sued there. The Supreme Court held that petitioners' status as employees did not shield them from jurisdiction, because their individual contacts with California were sufficient. First Amendment concerns did not enter into the Supreme Court's jurisdictional analysis.
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| Keeton v. Hustler Magazine, Inc., No. 82-485,
SUPREME COURT OF THE UNITED STATES, March 20, 1984, Decided
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Overview: Petitioner filed a libel action against the publisher in the only forum in which the statute of limitations on her claim had not expired. Holding that petitioner's lack of contacts with the forum state was not a factor in considering whether a court in the state could assert jurisdiction over respondent, the Court reversed the judgment. The Court held that there was no question that respondent's contacts with the forum state were sufficient to support jurisdiction, at least where petitioner's claim arose out of those contacts. The Court stated that whether the laws of the forum would require application of the "single publication rule" and expose respondent to extra-jurisdictional damages was not material because jurisdiction, not choice of law, was at issue. The Court noted that the forum state had a substantial interest in deterring tortious acts within its borders, even to the extent that those acts harmed nonresidents. The Court held that while a plaintiff's contacts with the forum could bolster the case for jurisdiction, the lack of contact could not subvert the case, noting that it had upheld jurisdiction where a plaintiff had no contacts with a forum.
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| United States v. Jacobsen, No. 82-1167,
SUPREME COURT OF THE UNITED STATES, April 2, 1984, Decided
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Overview: Defendants were waiting to receive a package containing cocaine that was being shipped using a private freight carrier. The package was damaged in transit, and the carrier opened the package. The carrier called federal agents, who took a sample of the contents for testing without a warrant. Reversing the judgment, the Court found that the search and seizure of the cocaine was reasonable and did not violate the Fourth Amendment because the package had already been opened by a private party to whom the Fourth Amendment did not apply and because the federal agents merely set aside some newspaper covering the contents and reopened a tube to view the contents. The Court stated that the federal agents did not infringe any constitutionally protected privacy interest that had not already been frustrated as the result of private conduct by the carrier. The Court further found that the seizure of a trace amount of the cocaine for testing without a warrant was a de minimis violation of any protected possessory interest and, thus, it was constitutionally reasonable.
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| Oliver v. United States, No. 82-15,
SUPREME COURT OF THE UNITED STATES, April 17, 1984, Decided **Together with No. 82-1273, Maine v. Thornton, on certiorari to the Supreme Judicial Court of Maine.
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Overview: Petitioner was arrested and indicted after police officers, without a warrant and without probable cause, investigated and discovered a marijuana field a mile from petitioner's home that was surrounded by "no trespass" signs. Applying the open fields doctrine, the lower court held that petitioner's rights under U.S. Const. amend. IV had not been violated. In a second similar case, evidence of marijuana found on respondent's property was suppressed by the lower court as a violation of respondent's privacy. Noting that the U.S. Const. amend. IV protection against unreasonable searches did not extend to intrusions into open fields, the court affirmed the introduction of the evidence in petitioner's case and reversed the suppression of evidence in respondent's case. Because the court found that there was no reasonable or legitimate expectation of privacy in open fields, the officers' actions in entering such open fields without a warrant or probable cause did not violate the Constitution. Because privacy for outdoor activities conducted in fields only extended to the area immediately surrounding the home, the court affirmed the validity of the open fields doctrine.
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| Helicopteros Nacionales de Colombia, S. A. v. Hall, No. 82-1127,
SUPREME COURT OF THE UNITED STATES, April 24, 1984, Decided
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Overview: The foreign corporation entered into contract negotiations in Texas with decedents' employer to provide helicopter services. They signed a contract in Peru that provided for decedents' employer to make payments to the corporation's United States bank account. The corporation did not maintain a place of business in Texas, but purchased helicopter parts there and sent employees there for training. The decedents' representatives filed a wrongful death action against the corporation following the decedents' deaths in a helicopter crash in Peru. Reversing the lower court, the Supreme Court held that the corporation's contacts with the state were not sufficient to subject it to the state court's in personam jurisdiction. Because the representatives' causes of action for wrongful death arose out of the crash in Peru, and were not related to the corporation's contacts with the state, and the corporation's business contacts with the state were not continuous and systematic enough to satisfy the requirements of the Due Process Clause of the Fourteenth Amendment, the Supreme Court concluded that the state court lacked personal jurisdiction over the corporation.
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| Bose Corp. v. Consumers Union, No. 82-1246,
SUPREME COURT OF THE UNITED STATES, April 30, 1984, Decided
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Overview: Petitioner sought recovery for defamatory statements made by respondent magazine about petitioner's product. The district court found that petitioner's claims of product disparagement succeeded based upon clear and convincing evidence. The court of appeals determined that it was not bound by the clearly erroneous standard set forth in Fed. R. Civ. P. 52(a) and applied de novo review, concluding that actual malice had not been demonstrated, as required of public figures in defamation actions, and reversed the judgment. On the Supreme Court's grant of certiorari, the judgment was affirmed, ruling that the appellate court was bound to make an independent examination of the record to be certain that U.S. Const. amend. I had not been infringed upon and that such an examination was consistent with the aims of Rule 52(a). Furthermore, the presumption of correctness attending factual findings was stronger in some cases and such a presumption was substantially lessened in cases where the appellate court must conduct an independent review, as in this instance. Lastly, the court held that appellate judges could determine whether the record established actual malice with convincing clarity.
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