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Federal Courts -
U. S. Supreme Court - January 13 - June 22, 1998
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Baker v. GMC, No. 96-653,
SUPREME COURT OF THE UNITED STATES, January 13, 1998, Decided
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Overview: The company settled an employment action against it in a Michigan state court by paying money to its former engineering analyst in exchange for an injunction prohibiting the analyst from testifying against the company in subsequent litigation without its consent, unless he was court-ordered to do so. The survivors sued the company for wrongful death in Missouri state court, later removed to federal court. Over the company's objections based on the Michigan injunction, the survivors were allowed to subpoena the analyst for deposition and trial testimony. Judgment was subsequently entered for the survivors, but the court of appeals reversed, ruling that the Full Faith and Credit Clause, U.S. Const. art. IV, ? 1, required enforcement of the Michigan injunction, such that the analyst's testimony should have been excluded. In reversing, the Supreme Court ruled that, although the injunction was claim preclusive between the company and the analyst, it had no control over others. The full faith and credit provision did not apply to evidentiary rulings and did not bar the survivors, non-parties to the Michigan action, from obtaining the analyst's testimony in their Missouri action.
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Oncale v. Sundowner Offshore Servs., No. 96-568,
SUPREME COURT OF THE UNITED STATES, March 4, 1998, Decided
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Overview: On several occasions, the employee was forcibly subjected to sex-related, humiliating actions against him by fellow employees in the presence of the rest of the oil-platform crew. He was also physically assaulted in a sexual manner and was threatened with rape. When his complaints to supervisory personnel produced no remedial action, the employee filed a complaint against his employer, alleging that he was discriminated against in his employment because of his sex. The district court granted the employer's motion for summary judgment, which the appellate court affirmed, holding that the employee, who was a male, had no cause of action under Title VII for harassment by male co-workers. On certiorari, the Court held that nothing in Title VII necessarily barred a claim of discrimination because of sex merely because the plaintiff and the defendant, or the person charged with acting on behalf of the defendant, were of the same sex. In reversing the judgment, the Court concluded that sex discrimination consisting of same-sex sexual harassment is actionable under Title VII.
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Steel Co. v. Citizens for a Better Env't, No. 96-643,
SUPREME COURT OF THE UNITED STATES, March 4, 1998, Decided
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Overview: On review, the court held that the requirement that jurisdiction be established as a threshold matter arose from the nature and limits of the judicial power of the United States under U.S. Const. art. III, ? 2, and was inflexible and without exception. The court rejected the practice of assuming jurisdiction for the purpose of deciding a case's merits. The association failed to meet the redressability requirement of standing because none of the relief sought served to compensate the association for losses caused by the company's late reporting or to eliminate any effects of that late reporting. The civil penalties authorized under 42 U.S.C.S. ? 11045(c) were not payable to the association but rather to the United States Treasury, and psychic satisfaction with the results of a lawsuit was not an acceptable U.S. Const. art. III remedy because it did not redress a cognizable injury. Nor could the association achieve standing by relying on 42 U.S.C.S. ? 11046(f), which authorized reimbursement of the costs of bringing suit. Further, the injunctive relief sought to deter future violations was not redress for past infractions and was insufficient for purposes of Article III.
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United States v. Ramirez, No. 96-1469,
SUPREME COURT OF THE UNITED STATES, March 4, 1998, Decided
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Overview: An inmate in the state prison system escaped. After law enforcement officials obtained information leading them to believe the inmate was hiding at respondent's home, they obtained a "no knock" search warrant of the residence. In executing the warrant, officers announced their presence via a loud speaker system. Simultaneously, they broke a garage window and pointed a gun inside, in an effort to prevent respondent or the inmate from obtaining weapons believed to be in the garage. The inmate was not found but respondent's weapon was, and he was indicted for possession of a weapon by a felon. Respondent moved to suppress the weapon, claiming that there were insufficient exigent circumstances to justify the destruction of property in executing the warrant. The intermediate court agreed, but the court reversed, noting that a "no knock" entry was warranted if police had a reasonable suspicion that knocking and announcing would have been dangerous or futile. The court held that the determination of whether a reasonable suspicion existed was not contingent upon whether the entry would cause the destruction of property.
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Almendarez-Torres v. United States, No. 96-6839,
SUPREME COURT OF THE UNITED STATES, March 24, 1998, Decided
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Overview: Defendant argued that 8 U.S.C.S. ? 1326 required that the prior felony convictions be stated in the indictment. The court found that ? 1326(a) forbid an alien from returning to the United States following deportation without permission. The United States Supreme Court found that ? 1326(b)(2) authorized an additional prison term if the deportation was following a conviction for an aggravated felony. The court held that the section was a penalty provision to be considered by the trial judge at sentencing, to increase the sentence for a recidivist. It did not define a separate crime and therefore the prior felony convictions did not need to be stated in the indictment. The court held that recidivism was the most traditional basis for a trial court to increase an offender's sentence and ? 1326(b)(2) applied only to punishment.
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United States v. Scheffer, No. 96-1133,
SUPREME COURT OF THE UNITED STATES, March 31, 1998, Decided
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Overview: Airman tested positive for the use of drugs in a urine test administered by Air Force Office of Special Investigations. He was later court-martialed for various offenses and sought to use results from a polygraph examination pertaining to those matters. The military judge denied airman's motion to admit polygraph, he was convicted, and Air Force Court of Criminal Appeals affirmed. The U.S. Court of Appeals for the Armed Forces reversed. Government was granted certiorari. The Court found the exclusion of evidence to be unconstitutionally arbitrary or disproportionate only where it has infringed upon a weighty interest of the accused and that Rule 707 served several legitimate interests in the criminal trial process. The rule was neither arbitrary nor disproportionate in promoting these ends. Nor did it implicate a sufficiently weighty interest of the airman to raise a constitutional concern under the Court's precedents, and there was no consensus among jurisdictions that polygraph evidence was reliable. Further, the Court concluded that polygraph evidence could diminish the jury's role in making credibility determinations.
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Crawford-El v. Britton, No. 96-827,
SUPREME COURT OF THE UNITED STATES, May 4, 1998, Decided
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Overview: Inmate was serving a life sentence and had been moved several times from prison to prison. He contended that prison official deliberately misdirected his property to punish him for exercising his First Amendment rights and to deter similar conduct in the future. The appellate court established a new rule in imposing the clear and convincing evidence of improper motive requirement on inmate. The court rejected the new rule. It differentiated between the qualified immunity, that required proof that a defendant knew or should have known that a plaintiff's constitutional rights were being violated, from the intent element that the new rule would have imposed on the plaintiff. The court held that the law did not bar claims that depended on proof of an official's motive. Neither the text of 42 U.S.C.S. ? 1983 nor other federal statutes provided any support for imposing the clear and convincing burden of proof of improper motive on plaintiffs either at the summary judgment state or in the trial itself. The court found sufficient exiting safeguards available to trial courts in the management of the factfinding process that were more useful and equitable to all parties.
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County of Sacramento v. Lewis, No. 96-1337,
SUPREME COURT OF THE UNITED STATES, May 26, 1998, Decided
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Overview: Petitioner police officer was involved in a high-speed automobile chase aimed at apprehending a suspected offender. Respondent was the passenger on a motorcycle driven by the offender. The driver of the motorcycle tipped over and petitioner's vehicle struck respondent. Respondent filed suit under 42 U.S.C.S. ? 1983 alleging a deprivation of his due process right to life under U.S. Const. amend. XIV. The trial court granted summary judgment in favor of petitioner. The intermediate appellate court reversed. Petitioner sought review. The court found that petitioner, in deciding whether to give chase, was required to balance the need to stop the suspect with the high-speed threat to everyone within stopping range. The court held that high-speed chases with no intent to harm the suspect physically or to worsen their legal plight did not give rise to liability under U.S. Const. amend. XIV. The driver of the motorcycle's outrageous behavior prompted petitioner's response as a law enforcement officer. Petitioner was not liable because there was no improper or malicious motive in following the motorcycle in a high-speed chase.
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United States v. Bestfoods, No. 97-454,
SUPREME COURT OF THE UNITED STATES, June 8, 1998, Decided
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Overview: A chemical plant generated industrial waste for many years. The chemical plant significantly polluted the soil and ground water. Respondents, succeeding parent corporations, purchased the chemical plant's assets. Petitioner, federal EPA, filed suit to recover funds for the clean up of the hazardous waste site. The district court found respondents directly liable to pay clean up costs as operators. The lower appellate court reversed ruling that respondents maintained separate personalities and did not improperly utilize the subsidiary corporate form. The court vacated and remanded holding that a participation-and-control test looking to the parent corporation's supervision over a subsidiary could not be used to identify operation of a facility resulting in direct parental liability. Any parent corporation liability as an operator, stemmed directly from its control over a polluting plant.
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Gebser v. Lago Vista Indep. Sch. Dist., No. 96-1866,
SUPREME COURT OF THE UNITED STATES, June 22, 1998, Decided
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Overview: A teacher at the school district initiated sexual contact with the student. The teacher and the student had intercourse during class time, although never on school property. The student did not report the relationship to school officials. After a police officer discovered the student and the teacher engaged in sexual intercourse, the teacher was arrested and terminated from employment. The student filed suit for sexual harassment under state law, Title IX, and ? 1983. The trial court dismissed the federal claims and remanded to state court for the state law negligence claims. The intermediate appellate court affirmed dismissal of the federal claims. The student sought review. The United States Supreme Court found that the student was not allowed to recover for sexual harassment by one of the district's teachers unless an official of the district had actual notice of and was deliberately indifferent to the misconduct. It would have frustrated the purposes of Title IX to permit a damages recovery against the district based on the principles of respondeat superior or constructive notice with out actual notice to the district.
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