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   Federal Courts - U. S. Supreme Court - January 21 - June 25, 1986

  
Daniels v. Williams, No. 84-5872, SUPREME COURT OF THE UNITED STATES, January 21, 1986, Decided
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Overview: The prisoner sought to recover damages for personal injuries that he sustained when he slipped on a pillow case that had been negligently left on a stairway by the correctional officer. The prisoner's ¿ 1983 claim rested on the contention that the officer's negligence deprived the prisoner of his Fourteenth Amendment liberty interest in freedom from bodily injury. The United States Supreme Court held that the prisoner's action was properly dismissed because a prison official's mere lack of due care did not constitute a deprivation of liberty under the Due Process Clause of the Fourteenth Amendment.

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Nix v. Whiteside, No. 84-1321, SUPREME COURT OF THE UNITED STATES, February 26, 1986, Decided
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Overview: Defendant was charged with murder of an acquaintance in a botched drug deal. Defendant initially told his attorney that he stabbed the victim in self defense because he saw a gun in the victim's hand. Defendant later admitted that he did not see a gun, but would testify that he did to bolster his defense. Counsel advised defendant that he could not suborn perjury, and would advise the court of defendant's plan and seek to withdraw, if he insisted on presenting perjured testimony. Defendant followed counsel's advice and testified at trial that he did not see a gun. Defendant was convicted of second-degree murder. Defendant's conviction was affirmed by the appeals court. Petitioner appealed the issuance of writ of habeas corpus to the court. The court reversed because the right to assistance of counsel was not violated when the attorney refused to assist in presenting perjured testimony.

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Moran v. Burbine, No. 84-1485, SUPREME COURT OF THE UNITED STATES, March 10, 1986, Decided
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Overview: Respondent confessed to and was convicted of the murder of a young woman. Respondent later challenged his conviction, claiming his confessions should have been suppressed because the police deceived him by failing to inform him that a public defender had called to speak with him while he was in custody, but prior to arraignment. The court of appeals reversed the conviction. On review, the Court found that respondent at no time requested an attorney, and events occurring outside the presence of respondent and entirely unknown to him had no bearing on his capacity to comprehend and knowingly waive his rights. The Court held that once a person knowingly and voluntarily waived his rights, the waiver was valid as a matter of law. The Court further found that his Sixth Amendment right to counsel had not attached when respondent confessed. The Court accordingly reversed.

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Matsushita Elec. Indus. Co. v. Zenith Radio Corp., No. 83-2004, SUPREME COURT OF THE UNITED STATES, March 26, 1986, Decided
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Overview: Respondents, domestic electronics companies, brought an antitrust conspiracy suit against petitioners, Japanese electronics companies. Respondents claimed that petitioners conspired to depress prices in the American market in order to drive out American competitors. The district court granted summary judgment for petitioners, but the appellate court reversed based on its finding of direct evidence of concert of action. The Court granted certiorari to determine whether the court of appeals applied the proper standard in evaluating the summary judgment decision. The Court concluded that the court of appeals erred in two respects: First, the direct evidence on which the court of appeals relied had little, if any, relevance to the alleged predatory pricing conspiracy. Second, the court of appeals failed to consider the absence of a plausible motive to engage in predatory pricing. The decision was reversed and remanded for the court of appeals to consider any evidence that petitioners conspired to price predatorily despite the lack of any apparent motive to do so. In the absence of such evidence, the Court instructed that petitioners were entitled to have summary judgment reinstated.

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At&T Techs. v. Communications Workers of Am., No. 84-1913, SUPREME COURT OF THE UNITED STATES, April 7, 1986, Decided
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Overview: Respondent union filed an action against petitioner employer pursuant to ¿ 301(a) of the Labor Management Relations Act, 29 U.S.C.S. ¿ 185(a), to compel arbitration of a grievance concerning layoffs under the terms of a collective bargaining agreement. The appellate court affirmed the district court's order directing petitioner to arbitration on the grounds that the threshold issue of arbitrability was to be determined by the arbitrator. Petitioner sought a writ of certiorari and the United States Supreme Court vacated the judgment, ruling that the appellate court erred in ordering the parties to arbitrate the arbitrability question. It was for the court to interpret the agreement and to determine whether the parties intended to arbitrate grievances concerning layoffs based on a "lack of work" as determined by petitioner. If the court found that the agreement so provided, then it was for the arbitrator to decide the relative merits of the parties' substantive interpretations of the agreement. The court was to decide, in the first instance, whether the dispute was to be resolved through arbitration.

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Batson v. Kentucky, No. 84-6263, SUPREME COURT OF THE UNITED STATES, April 30, 1986, Decided
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Overview: At trial, the prosecutor used his peremptory challenges to strike all four minority persons on the venire, and a jury composed only of Caucasians was selected. On petitioner's objection, the trial judge observed that the parties were entitled to use peremptory challenges to strike anyone for any reason. On appeal to the state supreme court, petitioner contended the facts established that the prosecution had engaged in a systematic pattern of discriminatory challenges, thus establishing an equal protection violation. The state supreme court affirmed the conviction. The Court reversed and remanded the case to the trial court, holding that if the trial court decided that the facts established prima facie, purposeful discrimination and that the prosecution did not proffer a neutral explanation for its actions, petitioner's conviction had be reversed. The Court overruled Swain v. Alabama, 380 U.S. 202 (1965), to the extent that it required petitioner to establish a systematic pattern of discrimination in jury selection.

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E. River S.S. Corp. v. Transamerica Delaval, No. 84-1726, SUPREME COURT OF THE UNITED STATES, June 16, 1986, Decided
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Overview: The manufacturer designed, built, and installed turbine engines in ships that were eventually chartered by the charterers. The turbine engines were defective and required repair. The charterers filed an action in tort against the manufacturer, seeking to recover the costs of the repairs. The district court entered summary judgment for the manufacturer. The appellate court upheld the district court's decision. The appellate court's order was affirmed on certiorari review. The court held that the economic loss doctrine applied in admiralty cases. The charterers sustained purely economic losses when the turbine engines failed; only the turbines themselves were damaged when they failed. As the failure of the turbine engines to properly function was the essence of a breach of warranty action, the charterers had to pursue a warranty action to recover.

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Meritor Sav. Bank, FSB v. Vinson, No. 84-1979, SUPREME COURT OF THE UNITED STATES, June 19, 1986, Decided
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Overview: After respondent's employment with petitioner was terminated, she filed an action under Title VII of the Civil Rights Act of 1964, 42 U.S.C.S. ¿ 2000e et seq., claiming that her supervisor had sexually harassed her. The district court found that any relationship between respondent and her supervisor was voluntary and unrelated to her work. The appellate court reversed the judgment of the district court and remanded the case, on a finding that the district court failed to determine it there was a hostile work environment. On certiorari, the court held that if the attentions of respondent's supervisor were unwelcome, then respondent had a claim for sexual harassment on the basis of a hostile work environment, even if any sexual acts were voluntary. Petitioner would be liable for the acts of its employee, if it could be found liable under general agency principles.

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Anderson v. Liberty Lobby, Inc., No. 84-1602, SUPREME COURT OF THE UNITED STATES, June 25, 1986, Decided
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Overview: Respondents filed a libel suit against petitioners following the publication of two articles portraying respondents as racists. Vacating and remanding the partial grant of petitioners' motion for summary judgment, the Court found that the court of appeals erred in holding that, for the purposes of summary judgment in a libel case, the standard of evidence required to prove actual malice was irrelevant. Because the threshold inquiry on a motion for summary judgment revolved around whether any genuine factual issues existed which could have been resolved in favor of either party, the Court held that the determination of whether a given factual dispute required submission to a jury had to be guided by the same substantive evidentiary standards that applied to the case. Where the libel suit involved a limited-purpose public figure, the Court held that the factual dispute involved the issue of actual malice so that the appropriate summary judgment standard required a determination of whether the evidence in record could support a reasonable jury finding that respondent had shown actual malice by clear and convincing evidence.

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Celotex Corp. v. Catrett, No. 85-198, SUPREME COURT OF THE UNITED STATES, June 25, 1986, Decided
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Overview: Respondent alleged that the death of her husband resulted from his exposure to products containing asbestos that were manufactured by petitioner. The district court granted petitioner's summary judgment motion. The court of appeals reversed the district court, holding that petitioner's failure to support its motion with evidence to negate exposure precluded the entry of summary judgment in its favor, and the court of appeals reinstated the suit. On appeal, court held that petitioner did not have to adduce affirmative evidence to disprove respondent's claim. The court held that under the court of appeals ruling, petitioner could have never been granted summary judgment unless he could have produced a detailed chronology of the decedent's life and showed that the decedent never came into contact with one of its products. Respondent was in the best position to produce such information; therefore the burden should have rested on her.

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