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| Herrera v. Collins, No. 91-7328,
SUPREME COURT OF THE UNITED STATES, January 25, 1993, Decided
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Overview: Over 10 years after the inmate was convicted of capital murder, he filed a habeas corpus petition arguing that he was actually innocent of the crime. The inmate supported his claim with affidavits collected years after the trial indicating that his brother committed the murder. The inmate argued that his showing of innocence entitled him to federal habeas relief. The court held that the inmate's claim of actual innocence based on newly discovered evidence was not a ground for federal habeas corpus relief absent an independent constitutional violation. The State met its burden of proving at trial that the inmate was guilty of the capital murder beyond a reasonable doubt. Thus, the inmate did not come before the courts as one who was "innocent," but as one who had been convicted by due process of law. Texas' refusal to entertain the inmate's newly discovered evidence eight years after his conviction did not transgress any principle of fundamental fairness.
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| Leatherman v. Tarrant County Narcotics Intelligence & Coordination Unit, No. 91-1657,
SUPREME COURT OF THE UNITED STATES, March 3, 1993, Decided
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Overview: The Court reversed the judgment of the court of appeals, which affirmed the dismissal of petitioners' complaints alleging municipal liability under 42 U.S.C.S. ¿ 1983 on the ground that petitioners failed to meet the "heightened pleading standard" required by the Fifth Circuit's decisional law. The Court concluded that federal courts were not permitted to apply a "heightened pleading standard" -- more stringent than the usual pleading requirements of Fed. R. Civ. P. 8(a) -- in civil rights cases alleging municipal liability under ¿ 1983. The Court noted that Fed. R. Civ. P. 9(b) imposed a particularity requirement in only two specific instances, in averments of fraud or mistake, and did not impose a particularity requirement for complaints alleging municipal liability under ¿ 1983. Thus, in the absence of amendment to the Federal Rules of Civil Procedure, federal courts and litigants had to rely on summary judgment and control of discovery to weed out unmeritorious ¿ 1983 claims sooner rather than later.
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| Reno v. Flores, No. 91-905,
SUPREME COURT OF THE UNITED STATES, March 23, 1993, Decided
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Overview: Respondents were a class of alien juveniles who were arrested and held in Immigration and Naturalization Service's custody pending their deportation hearings. Respondents contended that the constitution and immigration laws required them to be released to the custody of responsible adults. The trial court granted partial summary judgment in favor of petitioners on the statutory and international law challenges to the release policy, but granted partial summary judgment in favor of respondents on their equal protection claim that petitioners had no rational basis for treating alien minors in deportation proceedings differently from alien minors in exclusion proceedings. The appellate court affirmed the trial court's decision and the Supreme Court granted a writ of certiorari to review the issue. The court examined the language in the uniform deportation-exclusion rule, 8 C.F.R. ¿ 242.24 (1992), in order to determine whether the alien juveniles should be released to responsible adults was correct. The court concluded that it was not and held that the regulation accorded with both the constitution and the relevant statute, 8 U.S.C.S. ¿ 1252.
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| Pioneer Inv. Servs. Co. v. Brunswick Assocs., No. 91-1695,
SUPREME COURT OF THE UNITED STATES, March 24, 1993, Decided
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Overview: The court affirmed a judgment of the appellate court that found that an attorney's inadvertent failure to file a proof of claim for the creditors within a deadline set by a bankruptcy court could constitute "excusable neglect" within the meaning of Fed. R. Bankr. P. 9006(b)(1). The determination of what type of neglect would be considered "excusable" was an equitable one, taking account of all relevant circumstances surrounding a party's omission. These included the danger of prejudice to debtor, the length of delay and its potential impact on judicial proceedings, the reason for delay, including whether it was within the reasonable control of movant, and whether movant acted in good faith. Although the appellate court erred in not attributing to creditors the fault of their attorney, its decision was still correct. The lack of any prejudice to debtor or to the interests of efficient judicial administration, combined with the good faith of the creditors and their attorney, weighed strongly in favor of permitting the tardy claim. Further, the bankruptcy court's unusual form of notice required a finding that the neglect of the creditors' counsel was "excusable."
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| Hazen Paper Co. v. Biggins, No. 91-1600,
SUPREME COURT OF THE UNITED STATES, April 20, 1993, Decided
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Overview: Petitioner manufactured coated, laminated, and printed paper and paperboard and the company was owned by petitioner owners. Petitioners hired respondent and fired him when he was 62 years old. Respondent brought suit against petitioners alleging a violation of the Age Discrimination in Employment Act of 1967 (ADEA), 29 U.S.C.S. ¿ 621 et seq. Respondent claimed that age had been a determinative factor in petitioners' decision to fire him. Petitioners claimed that respondent had been fired for doing business with competitors. The district court found in respondent's favor and the appellate court affirmed. The Supreme Court granted certiorari to determine whether petitioners' interference with the vesting of pension benefits violated the ADEA and whether the standard under Trans World Airlines, Inc. v. Thurston, for liquidated damages applied to the case. The Supreme Court vacated the lower court's decision and remanded to make a determination of whether a violation of the ADEA actually occurred. The court affirmed that the Thurston definition of willful applied to all disparate treatment cases under the ADEA.
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| Brecht v. Abrahamson, No. 91-7358,
SUPREME COURT OF THE UNITED STATES, April 21, 1993, Decided
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Overview: Petitioner was charged and sentenced to life imprisonment after he was convicted of first degree murder. The state court of appeals set petitioner's conviction aside on the ground that the state's references to petitioner's post-Miranda silence violated due process under Doyle. The state supreme court reinstated the conviction, and petitioner sought a writ of habeas corpus, reasserting his Doyle claim. The district court set aside the conviction, and the court of appeals reversed, holding that the Chapman harmless error standard, harmless beyond a reasonable doubt, did not apply in reviewing a Doyle error on federal habeas review. The court of appeals held that the standard for determining whether petitioner was entitled to habeas relief, as set forth in Kotteakos, was whether the Doyle violation had a substantial and injurious effect in determining the jury's verdict. The United States Supreme Court agreed with the court of appeals in its determination of the appropriate harmless error standard. The Court held that the Doyle error that occurred at petitioner's trial did not substantially influence the jury's verdict and, therefore, petitioner was not entitled to habeas relief.
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| Prof'l Real Estate Investors v. Columbia Pictures Indus., No. 91-1043,
SUPREME COURT OF THE UNITED STATES, May 3, 1993, Decided
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Overview: Petitioner hotel owners appealed from the court of appeals' affirmance of summary judgment for respondent motion picture owners on petitioners' antitrust counterclaims. Petitioner contended that it was error to hold that an antitrust plaintiff had to establish that a sham lawsuit was baseless as a matter of law. The Supreme Court declined to adopt an approach under which either indifference to the outcome, or failure to prove that a petition for redress of grievances would have been brought but for a predatory motive, would expose a defendant to antitrust liability under the sham exception. The court adhered to precedent in rejecting a purely subjective definition of "sham," and outlined a two-part definition. First, the lawsuit had to be objectively baseless in the sense that no reasonable litigant could realistically expect success on the merits. Secondly, the court should focus on whether the baseless lawsuit concealed an attempt to interfere directly with the business relationships of a competitor through the use of the governmental process as an anticompetitive weapon. Applying the two-part definition, the court concluded that respondents' copyright action was not a "sham."
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| Lamb's Chapel v. Center Moriches Union Free Sch. Dist., No. 91-2024,
SUPREME COURT OF THE UNITED STATES, June 7, 1993, Decided
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Overview: Pursuant to N.Y. Educ. Law ¿ 414's empowerment of local school districts, respondent issued rules regarding the use of school property when not in use for school purposes. Statutory compliance required that the school premises not be used for religious purposes. Petitioners requested use of school premises for a film series concerning Christian family values by a licensed psychologist. When respondent denied petitioners access, petitioner brought suit alleging violations of 42 U.S.C.S. ¿ 1983. The district court entered summary judgment in respondent's favor and the appellate court affirmed. The issue was whether denying a church access to school premises for public viewing of an alleged religious film violated the Free Speech Clause of U.S. Const. amend. I. The court reversed the judgment because it found nothing in the record to support a free speech violation or the holding, and denying petitioners access was viewpoint based discrimination.
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| Minn. v. Dickerson, No. 91-2019,
SUPREME COURT OF THE UNITED STATES, June 7, 1993, Decided
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Overview: Respondent was arrested and charged with possession of a controlled substance after a police officer, during a stop and frisk, retrieved a lump of cocaine from respondent's pocket. The trial court denied respondent's motion to suppress the cocaine. Respondent proceeded to trial and was found guilty. The state supreme court affirmed the state court of appeals' decision reversing the trial court. The state supreme court found that based on the record before it, the officer determined that the lump was contraband only after squeezing, sliding, and otherwise manipulating the contents of respondent's pocket which the officer already knew contained no weapon. The state supreme court held that the stop and the frisk of respondent was valid under Terry, but that the seizure of the cocaine was unconstitutional. The court affirmed. The court stated that the state supreme court was correct in holding that the police officer in this case overstepped the bounds of the "strictly circumscribed" search for weapons allowed under Terry.
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| Church of Lukumi Babalu Aye v. City of Hialeah, No. 91-948,
SUPREME COURT OF THE UNITED STATES, June 11, 1993, Decided
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Overview: Petitioners, church and its president, applied for and received licensing, inspection and zoning approvals to establish a church including a ritual of animal sacrifice from respondent city. In response, an emergency public session of respondent's city council was held and ordinances were passed which prohibited animal sacrifice. Petitioners filed an action pursuant to 42 U.S.C.S. ¿ 1983 alleging that their rights under the Free Exercise Clause, U.S. Const., amend. I, were violated. The trial court ruled for respondent finding no constitutional violations. The appellate court affirmed. The United States Supreme Court reversed the judgment, holding that the ordinances were unconstitutional. It found that they were not neutral nor of general application, therefore it applied a strict scrutiny analysis. The Court determined that the governmental interests were not compelling, the ordinances were not drawn in narrow terms, and were both overbroad and underinclusive in substantial respects.
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