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Federal Courts -
U. S. Supreme Court - June, 1994
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Farmer v. Brennan, No. 92-7247,
SUPREME COURT OF THE UNITED STATES, June 6, 1994, Decided
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Overview: The inmate alleged that prison officials violated the Eighth Amendment by their deliberate indifference to his safety. The inmate asked the court to define "deliberate indifference" as civil-law recklessness, which utilized an objective standard. The prison officials urged the Supreme Court to adopt an approach consistent with recklessness in the criminal law, which was based upon a subjective standard. The Court rejected the inmate's invitation to adopt an objective test for deliberate indifference. Instead, the Court held that the prison officials could not be found liable under the Eighth Amendment for denying the inmate humane conditions of confinement unless the officials knew of and disregarded an excessive risk to inmate health or safety. The prison officials needed to be both aware of facts from which the inference could be drawn that a substantial risk of serious harm existed, and they also had to draw the inference. However, the Court concluded that the summary judgment record did not so clearly establish the prison officials' entitlement to judgment as a matter of law on the issue of subjective knowledge.
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Davis v. United States, No. 92-1949,
SUPREME COURT OF THE UNITED STATES, June 24, 1994, Decided
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Overview: Defendant, suspect in murder, was interviewed by the Naval Investigative Service, and was given the military equivalent of Miranda warnings, which he voluntarily waived. After the interview was under way, defendant made comments, indicating at first he might want a lawyer, but then saying he did not want a lawyer. Questioning continued. The military judge at general court-martial denied defendant's motion to suppress evidence obtained during the interview, holding that defendant's mention of a lawyer during interrogation was not a request for counsel and that the agents properly determined that defendant was not invoking his right to counsel. The Navy-Marine Corps Court of Military Review and the United States Court of Military Appeals affirmed. The Supreme Court affirmed the judgment, holding that equivocal requests or comments regarding an attorney did not require questioning officers to stop interrogation so that counsel could be present and that questioning could continue unless a suspect actually requested an attorney.
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Dolan v. City of Tigard, No. 93-518,
SUPREME COURT OF THE UNITED STATES, June 24, 1994, Decided
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Overview: Petitioner applied to respondent city for a permit to redevelop her business. Respondent granted the permit conditioned on petitioner dedicating some of her property to respondent in furtherance of its land use plan. Petitioner brought suit on the grounds that respondent's dedication requirements were not related to the proposed development, and therefore, constituted a taking without just compensation under the U.S. Const. amend. V. The Supreme Court of Oregon found that the conditions were reasonably related to the proposed development. On appeal, the Court held that there must be an essential nexus existing between the legitimate state interest and the permit condition by the respondent. The Court held that if a nexus existed, then exactions imposed by respondent must be roughly proportionate to the projected impact of the proposed development. Respondent's conditions were not reasonably related to the impact of the proposed development, and therefore, the judgment was overturned.
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Heck v. Humphrey, No. 93-6188,
SUPREME COURT OF THE UNITED STATES, June 24, 1994, Decided
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Overview: Petitioner sought monetary damages in his ? 1983 action. He contended that they had engaged in an unlawful, unreasonable, and arbitrary investigation that led to his arrest, knowingly destroyed exculpatory evidence, and caused an illegal and unlawful voice identification procedure to be used at his trial. The Supreme Court held that in order to recover damages for allegedly unconstitutional conviction or imprisonment, or for other harm caused by actions whose unlawfulness would render a conviction or sentence invalid, a plaintiff in a 42 U.S.C.S. ? 1983 action was required to prove that the conviction or sentence had been reversed on direct appeal, expunged by executive order, declared invalid by a state tribunal authorized to make such a determination, or called into question by a federal court's issuance of a writ of habeas corpus under 28 U.S.C.S. ? 2254. The inmate's claim was not cognizable under 42 U.S.C.S. ? 1983. The Court noted that both lower federal courts found inmate's damages claims challenged the legality of his conviction; therefore, the action was correctly dismissed.
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Turner Broad. Sys. v. FCC, No. 93-44,
SUPREME COURT OF THE UNITED STATES, June 27, 1994, Decided
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Overview: Appellants filed consolidated actions against appellees seeking to have the must-carry provisions of the Cable Television Consumer Protection and Competition Act of 1992 (Cable Act), codified at 47 U.S.C.S. ? 534, declared unconstitutional as violative of U.S. Const. amend. I. A three-judge district court panel granted summary judgment to appellees, and appellants appealed. The Supreme Court vacated the summary judgment order and remanded, holding that: (a) the Cable Act's must-carry rules were content-neutral in application, as they were not activated by any particular message spoken by cable operators and thus exacted no content-based penalty; (b) the government must show that the economic health of local broadcasting was in genuine jeopardy and in need of the protections afforded by the must-carry; and (c) since a genuine issue of material fact - i.e., the economic necessity of the must-carry provision - was in doubt, summary judgment was inappropriate.
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Williamson v. United States, No. 93-5256,
SUPREME COURT OF THE UNITED STATES, June 27, 1994, Decided
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Overview: Defendant was convicted of three drug charges. At trial, a witness whose testimony ultimately led to defendant's arrest, refused to testify despite being held in contempt. The Court found that the witness was unavailable and admitted hearsay evidence by a police officer of the witness's statement that included statements incriminating him and defendant, under the exception to the hearsay rule for statements against the interest of the declarant. Defendant's conviction was affirmed on appeal. The Court reversed, holding that the statements against interest of the declarant exception to the hearsay rule did not allow admission of non-self-inculpatory statements, even if they were made within a broader narrative that was generally self-inculpatory.
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