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Federal Courts -
U. S. Supreme Court - March 19 - June 13, 1996
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Varity Corp. v. Howe, No. 94-1471,
SUPREME COURT OF THE UNITED STATES, March 19, 1996, Decided
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Overview: The beneficiaries of the benefit plan sued the employer as the plan's administrator, claiming that the employer, through trickery, led them to withdraw from the plan and to forfeit their benefits. They sought, among other things, an order that, in essence, would reinstate each of them as a participant in the employer's ERISA plan. The lower courts entered judgment in beneficiaries' favor. On review, the court found that in the factual circumstances as determined by the lower courts, the employer was acting in its capacity as an ERISA fiduciary when it significantly and deliberately misled the beneficiaries with regard to the benefit plan. Further, the court found that in misleading the beneficiaries, the employer violated the fiduciary obligations imposed upon plan administrators under ERISA ? 404. Finally, the court concluded that the remedial provision of ERISA that the beneficiaries invoked, ERISA ? 502(a)(3), authorized their lawsuit for individual relief.
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Seminole Tribe v. Fla., No. 94-12.,
SUPREME COURT OF THE UNITED STATES, March 27, 1996, Decided
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Overview: The tribe sued the State and its governor, alleging that they refused to enter into any negotiation for the inclusion of gaming activities in a tribal-state compact thereby violating 25 U.S.C.S. ? 2710(d)(3). In their unsuccessful motion to dismiss the complaint, the State and the governor asserted that the suit violated the State's sovereign immunity under U.S. Const. amend. XI. The State and the governor took an interlocutory appeal of the decision that denied their motion to dismiss. The appellate court reversed, holding that amend. XI, barred the tribe's suit. On certiorari, the Court affirmed because amend. XI, prohibited Congress from making the State capable of being sued in federal court. In reaching its conclusion, the Court specifically overruled its decision in Pennsylvania v. Union Gas Co., 491 U.S. 1, 105 L. Ed. 2d 1 (1989). The Court further held that the narrow exception to immunity provided under Ex parte Young was not applicable.
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Markman v. Westview Instruments, No. 95-26.,
SUPREME COURT OF THE UNITED STATES, April 23, 1996, Decided
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Overview: Petitioner, the owner of a patent that described a system that could monitor and report the status, location, and movement of clothing in a dry-cleaning establishment, filed a suit against respondents, the maker of an alleged infringing product (maker) and an operator of a dry-cleaning establishment using the alleged infringing product, for patent infringement. Respondent maker denied infringement. Part of the dispute hinged upon the meaning of the word "inventory," a term found in one of petitioner's claims. A jury found infringement. However, the trial court granted respondents' deferred motion for judgment as a matter of law, because under its interpretation of "inventory," respondent maker's system did not infringe petitioner's patent. That judgment was affirmed by the court below. The judgment of the court below was affirmed on appeal based on the Court's holding that the construction of a patent, including terms of art within its claim, were exclusively within the province of the courts.
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United States v. Armstrong, No. 95-157.,
SUPREME COURT OF THE UNITED STATES, May 13, 1996, Decided
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Overview: Respondents were indicted on charges of conspiring to possess and distribute more than 50 grams of cocaine base, and federal firearms offenses. Respondents filed a motion for discovery or for dismissal of the indictment, alleging that they were selected for federal prosecution because they were African American. The appellate court affirmed the trial court's order of dismissal, holding that a defendant was not required to show that government had failed to prosecute others who were similarly situated. The Court granted certiorari to determine the appropriate standard for discovery for a selective-prosecution claim. The Court reversed because respondents failed to show that government declined to prosecute similarly situated suspects of other races. The phrase "defendant's defense," as used in Fed. R. Crim. P. 16(a)(1)(C), does not encompass allegations of selective prosecution.
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Bmw of N. Am. v. Gore, No. 94-896.,
SUPREME COURT OF THE UNITED STATES, May 20, 1996, Decided
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Overview: Respondent discovered that his new car had been repainted. He brought suit against petitioner distributor alleging that its failure to disclose the repair constituted suppression of a material fact. Evidence was introduced at trial that petitioner had a policy of nondisclosure where pre-delivery repairs amounted to less than 3 percent of the retail price of the car. The jury awarded actual damages of $ 4,000 and punitive damages of $ 4,000,000. Petitioner's motion to set aside the punitive damages award was denied by both the trial court and the appellate court. However, the appellate court reduced the award to $ 2,000,000 because it was inaccurately calculated. The United States Supreme Court granted certiorari. It reversed and remanded the case. It held that petitioner's conduct was not particularly reprehensible because it only caused minor economic harm and the 500 to 1 ratio of punitive damages to compensatory damages was not reasonable.
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Romer v. Evans, No. 94-1039.,
SUPREME COURT OF THE UNITED STATES, May 20, 1996, Decided
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Overview: In Colorado, various ordinances that afforded protection to persons discriminated against by reason of sexual orientation gave rise to a statewide controversy. In a statewide referendum, voters passed what was known as Amendment 2 (Colo. Const. art. II, ? 30b). Amendment 2 prohibited all legislative, executive, or judicial action at any level of state or local government designed to protect homosexual persons. Respondents, homosexual persons and municipalities whose ordinances were invalidated, commenced litigation to declare Amendment 2 invalid and enjoin its enforcement. The state supreme court affirmed the judgment that enjoined enforcement of Amendment 2. The United States Supreme Court affirmed. Amendment 2 violated the Equal Protection clause, U.S. Const. amend. XIV, because the classification was unrelated to any legitimate state interest. Amendment 2 withdrew from homosexuals, but no others, specific legal protection from the injuries caused by discrimination, and it forbid reinstatement of protective laws and policies. Amendment 2 thus classified homosexuals not to further a proper legislative end but to make them unequal to everyone else.
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Ornelas v. United States, No. 95-5257.,
SUPREME COURT OF THE UNITED STATES, May 28, 1996, Decided
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Overview: Petitioners pled guilty to possession of cocaine with intent to distribute. When they appealed the denial of their motion to suppress the cocaine, the issue centered around what constituted reasonable suspicion to stop and question petitioners as they entered their car, and probable cause to remove the interior panel of petitioners' car where a package of cocaine was found. The intermediate appellate court opined that findings of reasonable suspicion to stop, and probable cause to search, were to be reviewed deferentially for clear error. Petitioners appealed. The issue on appeal was the appropriate standard for appellate review for findings of probable cause and reasonable suspicion. The United States Supreme Court vacated the judgment and remanded the matter to the intermediate appellate court to review de novo the district court's determinations that the officer had reasonable suspicion and probable cause because, as a general matter, determinations of reasonable suspicion and probable cause should have been reviewed de novo on appeal.
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Quackenbush v. Allstate Ins. Co., No. 95-244.,
SUPREME COURT OF THE UNITED STATES, June 3, 1996, Decided
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Overview: Petitioners, state insurance commissioner and trustee over assets of bankrupt insurance company, sought review of a judgment that reversed an order to remand the case to state court, in an action seeking contract and tort damages for respondent insurance company's alleged breach of reinsurance agreements. The reversal was premised on a holding that a federal district court could abstain from hearing a case only when equitable relief was sought. The Court held a remand order was appealable as a final decision under 28 U.S.C.S. ? 1291 because it put the litigants effectively out of court, it surrendered jurisdiction of a federal suit to a state court, it presented an important issue separate from the merits, amounted to a refusal to adjudicate the case in federal court, and could not be reviewed on appeal from a final judgment. The Court also held federal courts could dismiss or remand cases based on abstention principles only where the relief sought was equitable or otherwise discretionary, and consequently the remand order of the district court was unwarranted because petitioner sought damages. Accordingly, judgment that reversed the remand order was affirmed.
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Whren v. United States, No. 95-5841.,
SUPREME COURT OF THE UNITED STATES, June 10, 1996, Decided
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Overview: Plainclothes vice-squad officers were patrolling "high drug area" in an unmarked car. An officer who had observed traffic violations approached a vehicle that was occupied by defendants. When the officer approached defendant driver's car window, he observed two large plastic bags of what appeared to be crack cocaine in defendant passenger's hands. Defendants were arrested and illegal drugs were retrieved from the vehicle. On appeal, defendants accepted that the officer had probable cause to believe the traffic code was violated, but argued that the test for traffic stops should have been whether a police officer, who acted reasonably, would have made stop for the given reason. Court disagreed because the officer's motive did not apply outside the context of inventory search or administrative inspection, and performance of balancing analysis was unnecessary where probable cause existed and a traffic stop out of uniform did not remotely qualify as an extreme practice.
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Jaffee v. Redmond, No. 95-266,
SUPREME COURT OF THE UNITED STATES, June 13, 1996, Decided
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Overview: Petitioner was administrator of decedent's estate and respondent here was a former police officer. Respondent shot petitioner's deceased during the course of duty. As a result, petitioner brought suit alleging respondent had violated deceased's constitutional rights under 42 U.S.C.S. ? 1983 and for wrongful death under 740 Ill. Comp. Stat. ? 180/1 et seq. (1994). During the course of discovery, petitioner requested notes obtained during respondent's psychotherapist sessions. Respondents refused to disclose the notes. The trial court advised the jury that there was no legal justification for respondents' failure to respond and that the jury could therefore presume that the contents of the notes would have been unfavorable to respondents. The appellate court reversed and remanded. The Supreme Court accepted the question of whether it was appropriate for federal courts to recognize a "psychotherapist privilege" under Fed. R. Evid. 501 on certiorari. The Court affirmed the existence of a psychotherapist-patient privilege, but rejected the balancing component of the privilege because doing so would eviscerate the effectiveness of the privilege.
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