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Federal Courts -
U. S. Supreme Court - April 19 - June 26, 1995
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Celotex Corp. v. Edwards, No. 93-1504,
SUPREME COURT OF THE UNITED STATES, April 19, 1995, Decided
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Overview: After the proceeding for which petitioner bankrupt had posted a supersedeas bond, respondent creditors obtained an order to permit them to execute against petitioner's surety. The court of appeals so ordered even though the bankruptcy court for the previously had issued an injunction prohibiting respondents from executing on the bond without the bankruptcy court's permission. Prior to petitioner filing for bankruptcy, respondents had obtained a judgment from the court of appeals against petitioner for personal injuries. The filing of the bankruptcy petition automatically stayed the continuation proceedings against petitioner in the court of appeals where petitioner had posted a supersedeas bond to stay the execution of judgment pending appeal. The Court held that because the bankruptcy court had jurisdiction under 28 U.S.C.S. ? 1334(b) over all related matters arising under petitioner's Chapter 11 proceeding, the court of appeals' order permitting respondents to execute against petitioner's surety was reversed.
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Kyles v. Whitley, No. 93-7927,
SUPREME COURT OF THE UNITED STATES, April 19, 1995, Decided
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Overview: Petitioner was convicted of first-degree murder. He appealed, claiming that the State knew of evidence favorable to him before and during trial that it failed to disclose. The State supreme court remanded the case for an evidentiary hearing on defendant's claims of newly discovered evidence. The trial court, after review, denied relief. The state supreme court denied petitioner's application for discretionary review. A petition for habeas corpus was then filed in district court, which denied the petition. The court of appeals affirmed by a divided vote. The Supreme Court granted certiorari and reversed and ordered a new trial, holding that the net effect of the evidence withheld by the State in this case raised a reasonable probability that its disclosure would have produced a different result.
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McIntyre v. Ohio Elections Comm'n, No. 93-986,
SUPREME COURT OF THE UNITED STATES, April 19, 1995, Decided
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Overview: Petitioner distributed anonymous leaflets regarding a proposed school tax levy in violation of Ohio Rev. Code Ann. ? 3599.09(A), which prohibited distribution of anonymous campaign literature, and was assessed a fine. In reversing her fine, the Court held an author's decision to remain anonymous was protected by U.S. Const. amend. I. Applying exacting scrutiny, the Court invalidated the statute as it was not narrowly tailored to serve an overriding state interest. Respondent's interest in providing voters with additional relevant information was insufficient to support the constitutionality of the statute. Though respondent had an interest in preventing fraud and libel, the statute punished fraud indirectly by indiscriminately outlawing a category of speech, based on content, with no necessary relationship to the danger sought to be prevented. Respondent failed to show its interest in preventing the misuse of anonymous election-related speech justified a prohibition of all uses of that speech.
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United States v. Lopez, No. 93-1260,
SUPREME COURT OF THE UNITED STATES, April 26, 1995, Decided
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Overview: Respondent was convicted of violating the Gun-Free School Zones Act of 1990 (GFSZA), 18 U.S.C.S. ? 922(q)(1)(A) after carrying a concealed handgun and bullets to school. Respondent's conviction was reversed on appeal. In upholding the reversal, the Court held the GFSZA was invalid because it was beyond the power of Congress under the Commerce Clause, U.S. Const. art. I, ? 8, cl. 3. The GFSZA had nothing to do with commerce or any economic activity, and, therefore, could not be sustained as a regulation of activity arising out of or connected with a commercial transaction, which when viewed in the aggregate, substantially affected interstate commerce.
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First Options v. Kaplan, No. 94-560,
SUPREME COURT OF THE UNITED STATES, May 22, 1995, Decided
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Overview: The clearinghouse cleared stock trades for the investment company, which incurred substantial losses in its trading account. The clearinghouse and the investment company entered into an agreement for repayment of the debt. When the investment company lost additional money, the clearinghouse demanded immediate repayment and insisted that the stock trader and his wife personally pay any deficiency. The clearinghouse sought arbitration under the Arbitration Act, 9 U.S.C.S. ? 1 et seq. Neither the stock trader nor his wife had personally signed the repayment agreement. They contested the arbitrability of the dispute with the clearinghouse. The Court held (1) the record did not show that the stock trader and his wife clearly agreed to have the arbitrators decide the question of arbitrability, (2) the court of appeals correctly held the arbitrability of the dispute between the clearinghouse and the stock trader and his wife was subject to independent review by the courts, and (3) the court of appeals used the proper standard in reviewing the district court's arbitrability determinations by reviewing questions of fact under a clearly erroneous standard and questions of law de novo.
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Adarand Constructors v. Pena, No. 93-1841,
SUPREME COURT OF THE UNITED STATES, June 12, 1995, Decided
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Overview: Petitioner, low bidder on a federal contract, was denied the contract because a presumptive preference was given to minority business entities; petitioner sued, claiming violation of its U.S. Const. amend. V equal protection rights. Lower federal courts rejected claim, relying upon precedent which subjected U.S. Const. amend. V equal protection claims to intermediate scrutiny. The Supreme Court reversed and remanded, holding that (a) petitioner could claim injury owing to a discriminatory classification which prevented it from competing on an equal footing (petitioner need not allege that it would have obtained a benefit but for the discriminatory classification); (b) U.S. Const. amends. V and XIV equal protection claims are analyzed precisely the same way - applying strict scrutiny analysis (that is, government racial classifications must serve a compelling governmental interest and be narrowly tailored to further that interest); and (c) since lower courts applied intermediate scrutiny, remand for strict scrutiny analysis was required.
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Hurley v. Irish-American Gay, No. 94-749,
SUPREME COURT OF THE UNITED STATES, June 19, 1995, Decided
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Overview: Petitioners, a parade organizer and a parade council, organized a special annual parade. Petitioners controlled who the parade participants would be. When petitioners denied respondent, a gay organization, access to their parade, respondent sued petitioners claiming their conduct violated respondent rights under Mass. Gen. Laws ? 272:98 (1992). The trial court entered judgment in favor of respondent and the state supreme court affirmed. The United States Supreme Court granted certiorari and reversed the judgments of the lower courts. The Court reasoned the requirement to admit a parade group expressing a message not of the private organizers' own choosing violated petitioners' First Amendment, U.S. Const. amend. I, rights, because in the content of free speech, outside of the commercial advertising setting, a state could not compel affirmance of a belief with which the speaker disagrees.
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Sandin v. Conner, No. 93-1911,
SUPREME COURT OF THE UNITED STATES, June 19, 1995, Decided
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Overview: Petitioner State requested certiorari to enable review of the appeals court's judgment that reversed a summary judgment in petitioner's favor because the appeals court found that respondent prisoner was entitled to call witnesses at a disciplinary hearing. The Court found that states may under certain circumstances create liberty interests that are protected by the Due Process Clause. However, the Court held that respondent prisoner's discipline in segregated confinement did not present the type of atypical, significant deprivation in which a state might conceivably create a liberty interest. The Court noted that the record showed that respondent's punishment, with insignificant exceptions, mirrored the conditions imposed upon inmates in administrative segregation and protective custody. Furthermore, the Court found that the regime respondent was subjected to as a result of the misconduct hearing was within the range of confinement normally expected for someone serving an indeterminate term of 30 years to life.
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Vernonia Sch. Dist. 47j v. Acton, No. 94-590,
SUPREME COURT OF THE UNITED STATES, June 26, 1995, Decided
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Overview: Petitioner school district required student athletes to submit to drug testing, for which the student's parents had to sign consent forms. Respondents, a seventh grade student and his parents, refused to sign the testing consent forms and filed suit seeking declaratory and injunctive relief from enforcement of the policy on the grounds that it violated the Fourth and Fourteenth Amendments, U.S. Const. amends. IV and XIV, and Or. Const. art. I, ? 9. The trial court denied the claims and dismissed the action. The appeals court reversed and held that the policy violated the asserted constitutional provisions. On appeal, the Court vacated and remanded. Students were not entitled to full Fourth Amendment protections where the state's interest in preventing drug addiction among students was compelling and student athletes had a decreased expectation of privacy. Also, the urinalysis and accompanying disclosure requirements were not significant invasions of privacy.
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