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   Federal Courts - U. S. Supreme Court - February 25 - June 22, 1992

  
Hudson v. McMillian, No. 90-6531, SUPREME COURT OF THE UNITED STATES, February 25, 1992, Decided
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Overview: The inmate became involved in an argument with one of the officers. The officers then kicked and punched the inmate, who suffered minor bruises, swelling, and a cracked partial dental plate. The inmate brought suit under 42 U.S.C.S. ¿ 1983, alleging that his beating constituted cruel and unusual punishment prohibited by the Eighth Amendment. A trial court entered judgment for the inmate, but the court of appeals reversed. Although recognizing that the officers' conduct was objectively unreasonable, the court of appeals applied a "significant injury" requirement in denying relief. In overturning the court of appeals' decision, the Court rejected the rule that an inmate had to demonstrate the existence of a "significant injury" before he could prevail on a claim of cruel and unusual punishment. Noting that the Eighth Amendment prohibited the unnecessary and wanton infliction of pain, the Court held that the corrections officers inflicted cruel and unusual punishment if they used force maliciously and sadistically to cause harm, rather than in a good-faith effort to maintain or restore discipline, regardless of whether significant injury resulted.

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Franklin v. Gwinnett County Pub. Sch., No. 90-918, SUPREME COURT OF THE UNITED STATES, February 26, 1992, Decided
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Overview: The school district argued that Title IX only provided equitable relief. The Supreme Court reversed the judgment and remanded the case. In so doing, the Court held that (1) Title IX provided a damages remedy for the student because the Court presumed the availability of all appropriate remedies unless the United States Congress had expressly indicated otherwise, and (2) where liability was created by statute without a remedy, it would have been enforced by a common law action.

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Nationwide Mut. Ins. Co. v. Darden, No. 90-1802, SUPREME COURT OF THE UNITED STATES, March 24, 1992, Decided
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Overview: A decision that vacated a grant of summary judgment to an insurance company in its agent's ERISA action was reversed because the appellate court failed to apply the common-law definition of an employee. Respondent's contract provided that he would be entitled to receive retirement benefits if he refrained from selling insurance for competing companies after termination. When respondent became an independent insurance agent, he brought suit under the Employee Retirement Income Security Act of 1974 (ERISA) pursuant to 29 U.S.C.S. ¿ 1132(a), claiming that the benefits were vested. The district court granted summary judgment to petitioners. The appellate court vacated because respondent had a reasonable expectation of receiving retirement benefits. On appeal, the Court reversed because the proper test of employee status under 29 U.S.C.S. ¿ 1002(6) was the master-servant relationship as defined by common-law agency doctrine. Because Congress had not specified any other test, it should have been presumed that the traditional definition was intended. The Court remanded for a determination of whether respondent could be considered an employee under agency law.

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Quill Corp. v. N.D., No. 91-194, SUPREME COURT OF THE UNITED STATES, May 26, 1992, Decided
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Overview: Petitioner was a mail-order house with no outlets or representatives in respondent's state. Nevertheless, respondent brought suit to collect use taxes from petitioner pursuant to N.D. Cent. Code ¿ 57-40.2-01(6). The trial court ruled in petitioner's favor, but the state supreme court reversed, overruling National Bellas Hess, Inc. v. Department of Revenue of Ill., 386 U.S. 753, 87 S.Ct. 1389 (1967). Petitioner appealed. The court found petitioner purposefully directed sufficient activities at respondent's residents to satisfy due process minimum contacts, but nevertheless fell within the safe harbor provisions of the Commerce Clause "substantial nexus" requirement proffered by Bellas Hess. The court held that stare decisis and the differences between the controlling principles of the Due Process and Commerce Clauses mandated that the Bellas Hess rule remain good law. Accordingly, the judgment of the court was reversed, and the case remanded for further proceedings consistent with the court's opinion.

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Eastman Kodak Co. v. Image Tech. Servs., No. 90-1029, SUPREME COURT OF THE UNITED STATES, June 8, 1992, Decided
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Overview: Respondents sued, alleging, among other things, that petitioner's attempts to preclude them from servicing its equipment constituted a tying arrangement that violated 15 U.S.C.S. ¿ 1. Although the trial court granted petitioner's motion for summary judgment, the lower court determined that respondents had presented sufficient evidence to raise a genuine issue concerning petitioner's market power. In doing so, it rejected petitioner's claim that competition in the equipment market would necessarily prevent it from engaging in a tying arrangement in the service and parts markets. The Supreme Court affirmed the lower court's judgment after determining that petitioner had not met its burden under Fed. R. Civ. P. 56(c). Specifically, it held that petitioner's economic theory did not dispel direct evidence that petitioner had used its market power to raise prices and drive out competition. Acknowledging that petitioner's parts service and equipment may have been components of one unified market, the court concluded that it would not reach that conclusion as a matter of law on a record so sparse.

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Lujan v. Defenders of Wildlife, No. 90-1424, SUPREME COURT OF THE UNITED STATES, June 12, 1992, Decided
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Overview: Petitioner, the Secretary of the Interior, promulgated a new interpretation ¿ 7 of the Endangered Species Act of 1973 (Act), 16 U.S.C.S. ¿ 1536(a)(2), which required consultation only for actions taken in the United States or on the high seas. Respondents, wildlife conservation organizations, filed suit seeking declaratory judgment and injunctive relief to restore petitioner's initial interpretation. The district court granted petitioner's motion to dismiss for lack of standing, but the circuit court reversed. On writ of certiorari to the United States Supreme Court, the circuit court's decision was reversed and remanded because the Court reasoned that respondents lacked standing under Article III of the Constitution to bring an action, as respondents failed to establish all three prongs required for standing. The burden of proof was not met regarding causation and redressability of respondents' injury. Therefore, petitioner's motion for summary judgment should have been granted.

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New York v. United States, No. 91-543, SUPREME COURT OF THE UNITED STATES, June 19, 1992, Decided * *Together with No. 91-558, County of Allegany, New York v. United States et al., and No. 90-563, County of Cortland, New York v. United States et al., also on certiorari to the same court.
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Overview: Congress, in an effort to combat a burgeoning radioactive waste disposal problem, passed the Low-Level Radioactive Waste Policy Amendments Act of 1985, 42 U.S.C.S. ¿ 2021b et seq. The Act included monetary incentives, access incentives, and a take title provision, which offered states the option of taking title to and possession of low level radioactive waste generated within their borders and assuming liability for damages that waste generators suffer due to the states' tardiness. New York sued, claiming that the Act violated U.S. Const. amend. X. The Supreme Court, after granting certiorari, declared the Act unconstitutional in part, holding that (a) monetary incentives constituted permissible exercises of congressional power under the Commerce, Taxing, and Spending Clauses of the Constitution; (b) access incentives represented permissible conditional exercise of Congress' commerce power; but (c) the take title clause exceeded U.S. Const. amend. X restrictions, because the take title incentive was not an exercise of congressional power enumerated in the Constitution.

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R. A. V. v. St. Paul, No. 90-7675, SUPREME COURT OF THE UNITED STATES, June 22, 1992, Decided
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Overview: Petitioner was charged with violating St. Paul Bias-Motivated Crime Ordinance, St. Paul, Minn., Legis. Code ¿ 292.02 (1990), for allegedly burning a cross in the yard of an African-American family. Petitioner moved to dismiss the charge challenging the statute as overbroad and impermissibly content-based, thus, violating the First Amendment. The trial court granted his motion, but the appellate court reversed and upheld the statute. The Court reversed, concluding that even if the expression reached by the ordinance was proscribable under the "fighting words" doctrine, the ordinance was facially unconstitutional because it prohibited otherwise permitted speech solely on the basis of the subjects the speech addressed. The Court held that the First Amendment did not permit the government to impose special prohibitions on speakers who express views on disfavored subjects. While the statute served a compelling interest, there were content-neutral alternatives available.

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