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Federal Courts -
U. S. Supreme Court - June - December, 1976
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Wash. v. Davis, No. 74-1492,
SUPREME COURT OF THE UNITED STATES, June 7, 1976
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Overview: The trial court denied the police recruits' motion for summary judgment because the qualifying test was directly related to the requirements of the police training program, and a positive relationship between the test and training course performance was sufficient to validate the former. The appellate court reversed that ruling because the disproportionate impact resulting from the fact that a greater proportion of blacks failed the test than whites established a constitutional violation. The court reversed, holding that the appellate court erroneously applied legal standards applicable to Title VII cases. The court held a statute, which was otherwise neutral on its face had to be applied so as to invidiously discriminate on the basis of race. The police department's efforts to recruit black officers, the changing racial composition of the recruit classes, and the relationship of the test to the training program negated any inference that the police department discriminated on the basis of race or that a police officer qualified on the color of his skin rather than ability. Thus, it was error for the appellate court to direct summary judgment for the police recruits.
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Tsc Indus. v. Northway, No. 74-1471,
SUPREME COURT OF THE UNITED STATES, June 14, 1976
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Overview: Respondent shareholder brought an action against petitioner companies claiming that their joint proxy statement was incomplete and materially misleading in violation of 15 U.S.C.S. ¿ 78n (a). Respondent's claim under 17 C.F.R. ¿ 240.14a-3 was that petitioners failed to state in the proxy statement that the transfer of certain shareholder interests to the acquiring company had given said company control over the target company. Respondent's claim under 17 C.F.R. ¿ 240.14a-9 was that both companies omitted material facts from the proxy statement relating to the degree of control over the target company. Genuine issues of fact existed as to whether the acquisition of certain shareholder interests in the target had resulted in a change of control. Therefore, summary judgment was inappropriate under 17 C.F.R. ¿ 240.14a-3 . Certain omissions of fact were material as a matter of law under 17 C.F.R. ¿ 240.14a-9 . The Court reversed the partial summary judgment granted to respondent since the proxy statement prominently displayed the fact that the acquiring company owned a percentage of the outstanding shares in the target company.
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United States v. Agurs, No. 75-491,
SUPREME COURT OF THE UNITED STATES, June 24, 1976
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Overview: Defendant was convicted of murdering a man by stabbing him with his own knife. Defense counsel made no discovery request of the prosecutor. The prosecutor failed to voluntarily disclose the victim's past criminal record, which included offenses for assault and carrying a deadly weapon. The court reversed a lower court's reversal of defendant's murder conviction because the prosecutor had no duty, under the Due Process Clause of U.S. Const. amend. V, to voluntarily disclose exculpatory matter absent a pretrial request for specific evidence. In the context of the entire record the omitted evidence was not "material," i.e. it did not create a reasonable doubt that did not otherwise exist. The court held that the trial court employed the proper standard of "materiality," considered the omitted evidence in the context of the entire record, and properly ruled that the evidence supported a finding that defendant was guilty beyond a reasonable doubt. Therefore, the prosecutor's failure to tender the evidence to the defense did not deprive defendant of a fair trial as guaranteed by the Due Process Clause.
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United States v. Santana, No. 75-19,
SUPREME COURT OF THE UNITED STATES, June 24, 1976
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Overview: A drug dealer agreed to sell heroin to an undercover officer. The officer drove the drug dealer to defendant's home, and the drug dealer took money from the officer and entered the home. The drug dealer then returned to the officer's car and gave the heroin that she had purchased to the officer. The officer then arrested the drug dealer. Other police personnel returned to defendant's home where defendant was standing in the threshold of her front door. The police identified themselves, and defendant retreated into her home. The police followed defendant into her home and arrested her. Defendant was charged with possession of heroin with intent to distribute and filed a motion to suppress the heroin and money found in her pockets during and after her arrest. The trial court granted the motion, and the appellate court affirmed the ruling. On further appeal, the Court held that defendant was in a public place when the police arrived to arrest her and that defendant could not thwart the proper arrest by retreating into her home. Once she was arrested, the search incident to that arrest, which produced the drugs and money, was clearly justified.
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Neb. Press Ass'n v. Stuart, No. 75-817,
SUPREME COURT OF THE UNITED STATES, June 30, 1976
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Overview: Respondent state district judge, acting out of a legitimate concern in an effort to protect an accused's right to a fair trial, entered an order restraining petitioners, members of the press, from publishing accounts of confessions made by the accused or facts strongly implicative of the accused in a widely reported murder of six persons. Petitioners filed an application for certiorari. The Court granted certiorari to decide whether the order violated the constitutional guarantee of freedom of the press. The Court reversed, holding that the order was invalid because the barriers to prior restraint were not passed. Although the trial judge was justified in concluding that there would be intense pre-trial publicity and that it might impair the accused's right to a fair trial, the trial judge did not determine whether other measures, besides prior restraint, would have sufficed. In addition, prior restraint on publication was not a workable method of protecting the accused's right to a fair trial because the events took place in a community of 850 people. The lower court could not restrain an entire community.
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Gregg v. Georgia, No. 74-6257,
SUPREME COURT OF THE UNITED STATES, July 2, 1976
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Overview: Upon certiorari review, the Supreme Court held that the punishment of death did not invariably violate the United States Constitution; that the death penalty was not a form of punishment that could never be imposed, regardless of the circumstances of the offense, regardless of the character of the offender, and regardless of the procedure followed in reaching the decision to impose it; and that the concerns that the penalty of death not be imposed in an arbitrary or capricious manner were met by a carefully drafted statute that ensured that the sentencing authority was given adequate information and guidance. With regard to the Georgia statute, the Court held that the statutory system under which defendant was sentenced, which focused the jury's attention on the particularized nature of the crime and the particularized characteristics of the individual defendant and provided a method for review, did not violate the Constitution.
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Estelle v. Gamble, No. 75-929,
SUPREME COURT OF THE UNITED STATES, November 30, 1976
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Overview: The inmate injured his back while performing a prison work assignment. He was placed on various pain relievers but continued to experience pain and refused to return to work because of the pain. After experiencing chest pains he was placed on medication for treatment of irregular cardiac rhythm. Soon thereafter he filed a complaint under 42 U.S.C.S. ¿ 1983, alleging petitioners subjected him to cruel and unusual punishment in violation of the Eighth Amendment. The inmate based his complaint solely on the lack of diagnosis and inadequate treatment of his back injury. The Court held that the inmate's claims against a physician, both in his capacity as a treating physician and as medical director of the corrections department, were not cognizable under ¿ 1983. The inmate was seen by medical personnel on 17 occasions spanning a 3-month period. The Court reversed the court of appeals' judgment as to the medical director and remanded to the court of appeals to consider whether a cause of action had been stated against the other corrections officials.
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Craig v. Boren, No. 75-628,
SUPREME COURT OF THE UNITED STATES, December 20, 1976
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Overview: Appellants, a male between 18 and 21 years of age and a liquor vendor, filed an action in district court that sought declaratory and injunctive relief against the enforcement of Okla. Stat. tit. 37, ¿¿ 241 and 245 (1958 and Supp. 1976). Together, the statutes prohibited the sale of non-intoxicating three and two-tenths percent beer to males under the age of 21 and to females under the age of 18. Appellants alleged that the statutes constituted invidious discrimination against males between 18 and 20 years of age. The district court sustained the constitutionality of the statutory differential and dismissed the action. The Court reversed, holding that the gender-based differential that resulted from ¿ 245 invidiously discriminated and constituted a denial of the equal protection of the laws to males who were 18 to 20 years of age. The Court held that gender did not represent a legitimate, accurate proxy for the regulation of drinking and driving, and therefore, the classification was not substantially related to the achievement of a legitimate government objective. The court also noted that U.S. Const. amend. XXI did not save the gender-based discrimination from invalidation.
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