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| Strickland v. Washington, No. 82-1554,
SUPREME COURT OF THE UNITED STATES, May 14, 1984, Decided
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Overview: On review by the Supreme Court, respondent contended that his death sentence should have been overturned as the strategic decisions upon which he was advised by his attorney during the guilt and penalty phase of his trial constituted ineffective assistance of counsel, thus violating his right to counsel pursuant to U.S. Const. amend. VI. On appeal, the death sentence was affirmed. In support of its ruling, the Supreme Court held that in order to show that counsel's assistance was so defective as to require reversal of a death sentence, respondent must have shown counsel's performance was deficient, and that such deficient performance prejudiced the defense. In applying this standard, the Court further held that respondent's counsel's performance could not be deemed unreasonable, and even if such was the case, respondent suffered insufficient prejudice to warrant setting aside his death sentence. In addition, in failing to make a showing that the justice of his sentence was rendered unreliable by a breakdown in the adversary process caused by deficiencies in counsel's assistance, respondent also failed to show that his sentencing proceeding was fundamentally unfair.
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| United States v. Cronic, No. 82-660,
SUPREME COURT OF THE UNITED STATES, May 14, 1984, Decided
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Overview: Respondent was indicted on mail fraud charges, and shortly before trial, his retained counsel withdrew. The trial court appointed a young lawyer with a real estate practice to represent respondent, and 25 days were allowed for pretrial preparation even though it had taken the government over four and one-half years to prepare the case. Respondent was convicted on 11 of 13 counts and sentenced to 25 years in prison. The court of appeals reversed the conviction on the basis of ineffective assistance of counsel. The Court granted the government's petition for certiorari and reversed and remanded, holding that the criteria used by the court of appeals did not prove that counsel's defense was ineffective. Counsel's preparation time and his inexperience did not justify a presumption of ineffectiveness. Also, the gravity of the charge, the complexity of the case, and the accessibility of witnesses were not circumstances, in themselves, that made it unlikely that respondent received effective assistance of counsel. The Court concluded that, on remand, respondent could make out an ineffective assistance claim only by alleging specific errors made by trial counsel.
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| Welsh v. Wis., No. 82-5466,
SUPREME COURT OF THE UNITED STATES, May 15, 1984, Decided
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Overview: Petitioner was arrested at night in his home for operating a motor vehicle while intoxicated, a non-jailable offense. The arresting officers had no arrest warrant. Petitioner was taken to the police station, where he refused to take a breath-analysis test. The trial court concluded that petitioner's arrest was lawful and that petitioner's refusal to take the breath test was unreasonable and in violation of state law; therefore, the trial court suspended petitioner's operating license. The suspension order was vacated by a state appellate court, but reinstated by the highest state court. The Court granted certiorari and reversed and remanded, holding that the warrantless arrest of petitioner in his home violated U.S. Const. amend. IV because the State, although demonstrating probable cause to arrest, had not established the existence of exigent circumstances, and petitioner's refusal to submit to a breath test was reasonable. The Court noted that application of the exigent-circumstances exception in the context of a home entry was rarely appropriate when there was probable cause to believe that only a minor offense had been committed.
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| Seattle Times Co. v. Rhinehart, No. 82-1721,
SUPREME COURT OF THE UNITED STATES, May 21, 1984, Decided
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Overview: Respondent religious leader brought a civil action against petitioner newspaper for printing known fictional and untrue statements about respondent. The district court granted petitioner's motion to compel respondent to provide financial documents pertaining to the identity of donors and the amounts donated to his group. Respondent appealed this decision and filed a motion for a protective order prohibiting petitioner from disseminating information gathered through discovery. Petitioner sought review of the order granting respondent's motion on the grounds that the protective order violated petitioner's First Amendment rights. U.S. Const. amend. I. The U.S. Supreme Court held that the protective order prohibiting the dissemination of information gathered through discovery that could result in annoyance, embarrassment, and oppression did not violate petitioner's First Amendment rights. The protective order did not preclude the dissemination of information gathered outside of the discovery process and thus was not an abuse of the court's discretion.
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| Cal. v. Trombetta, No. 83-305,
SUPREME COURT OF THE UNITED STATES, June 11, 1984, Decided
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Overview: Defendants submitted to Intoxilyzer tests upon being stopped for drunken driving. After registering blood-alcohol concentrations substantially higher than 0.10 percent, defendants were charged with driving while intoxicated in violation of Cal. Veh. Code § 23102 (1981). Defendants moved to suppress the test results on the ground that the arresting officers failed to preserve the samples of defendants' breath. Such motions were denied. Upon consolidation, the state appellate court concluded that due process required law enforcement agencies to establish rigorous procedures to preserve the captured evidence or its equivalent for the use of defendants. After the state supreme court denied certiorari, the State sought further review. The court reversed and remanded, holding that the due process clause of the U.S. Const. amend. XIV did not require the State to preserve breath samples in order to introduce the results of breath-analysis tests at trial. Even if it was assumed that the Intoxilyzer results were inaccurate and that the breath samples might, therefore, have been exculpatory, it did not follow that defendants were without alternative means of demonstrating their innocence.
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| Nix v. Williams, No. 82-1651,
SUPREME COURT OF THE UNITED STATES, June 11, 1984, Decided
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Overview: Respondent was found guilty of first-degree murder. He successfully challenged the conviction on the ground that evidence of his incriminating statements, which led the police to the victim's body, should have been excluded because the evidence was the product of unlawful questioning by the police. At his second trial, no such evidence was admitted, but the trial court admitted evidence of the body's location and condition on the theory that the body would have been discovered in any event, even had the incriminating statements not been elicited from respondent. Respondent attacked his state-court conviction by seeking a writ of habeas corpus in federal district court. The district court denied the petition, but the appellate court reversed, holding that if there was an inevitable discovery exception to the exclusionary rule, it required proof that the police did not act in bad faith. The Court held that there was an inevitable discovery exception to the exclusionary rule, but that it included no such "good faith" requirement. It concluded that the record supported the finding that the victim's body would inevitably have been discovered; and reversed the appellate court decision.
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| New York v. Quarles, No. 82-1213,
SUPREME COURT OF THE UNITED STATES, June 12, 1984, Decided
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Overview: A police officer pursued respondent suspect in a supermarket after a woman identified him as the man who raped her. The officer frisked respondent and discovered that he was wearing an empty shoulder holster. After handcuffing respondent, the officer asked him where the gun was. Respondent said, "the gun is over there." After the officer retrieved the loaded gun, he placed respondent under arrest and read him his Miranda rights. In the subsequent prosecution of respondent for criminal possession of a weapon, the judge excluded the statement and the gun because the officer had not given respondent his Miranda warnings before asking him where the gun was located. The state appellate courts affirmed, rejecting petitioner State's argument that the exigencies of the situation justified the officer's failure to read respondent his Miranda rights until after he had located the gun. The Court reversed. The Court held that there was a "public safety" exception to the requirement that Miranda warnings be given before a suspect's answers could be admitted into evidence, and that the availability of that exception did not depend upon the motivation of the individual officers involved.
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| Copperweld Corp. v. Independence Tube Corp., No. 82-1260,
SUPREME COURT OF THE UNITED STATES, June 19, 1984, Decided
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Overview: Petitioner parent corporation bought petitioner subsidiary from a corporation. The sales agreement bound the seller corporation and its subsidiaries not to compete with petitioner. A corporate officer of seller corporation formed respondent to compete in the same market as petitioner subsidiary. When a business accepted respondent's order for a tubing mill, petitioner parent sent the business letters warning of petitioner parent's intent to protect the trade secrets acquired from the seller corporation, and the business voided its acceptance. Petitioners also contracted others contemplating doing business with respondent. The issue was whether the acts of petitioner parent and its wholly owned petitioner subsidiary could constitute a combination or conspiracy under 15 U.S.C.S. § 1, as the court of appeals had found. The U.S. Supreme Court held that petitioner parent and petitioner subsidiary were incapable of conspiring with each other for purposes of 15 U.S.C.S. § 1. The Court reasoned that antitrust liability should not depend on whether a corporate subunit is organized as an unincorporated division or a wholly owned subsidiary.
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| Chevron, U.S.A., Inc. v. NRDC, Inc., No. 82-1005,
SUPREME COURT OF THE UNITED STATES, June 25, 1984, Decided **Together with No. 82-1247, American Iron & Steel Institute et al. v. Natural Resources Defense Council, Inc., et al.; and No. 82-1591, Ruckelshaus, Administrator, Environmental Protection Agency v. Natural Resources Defense Council, Inc., et al., also on certiorari to the same court.
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Overview: Petitioner argued that the Environmental Protection Agency (EPA) regulation, implementing permit requirements for nonattainment states pursuant to the Clean Air Act Amendments of 1977 (Act), 42 U.S.C.S. § 7502(b)(6), permitting states to treat all of the pollution-emitting devices within the same industrial groupings as though they were encased within a single bubble, was a reasonable construction of the statutory term stationary source. On appeal, the judgment below was reversed. In support of its ruling, the Supreme Court held that if a statute was silent or ambiguous with respect to the specific issue, the question for a court was whether the agency's action was based on a permissible construction of the statute. Further, considerable weight was to be accorded to an agency's construction of a statutory scheme. The Court noted that while the legislative history of the statute was silent on the instant issue, it did reveal that the EPA's interpretation was fully consistent with one of the two principal goals of the statute -- namely, allowance of reasonable economic growth. Accordingly, the EPA's interpretation was entitled to deference.
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| National Collegiate Athletic Ass'n v. Board of Regents, No. 83-271,
SUPREME COURT OF THE UNITED STATES, June 27, 1984, Decided
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Overview: Respondent universities contracted with a network to air football games, challenging petitioner athletic association's control over how many football games a university could televise. Petitioner threatened disciplinary action and respondents filed suit. The district court held that petitioner's control violated the Sherman Act, 15 U.S.C.S. § 1. The court of appeals court affirmed the judgment and found that petitioner's plan constituted illegal per se price fixing. The Court affirmed on the ground that petitioner's actions were a horizontal restraint of trade and unreasonable as a matter of law. Petitioner limited the number of games that a university televised, the number of games available to the public, and barred negotiation between broadcasters and universities. The Court found that televising university football was a separate market over which petitioner had monopolistic control. Petitioner restrained trade by raising prices and reducing output. Under the Rule of Reason, it was anticompetitive conduct that petitioner did not justify. The Court determined that it would be inappropriate to apply a per se rule under the facts.
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