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| Gasperini v. Ctr. for Humanities, No. 95-719,
SUPREME COURT OF THE UNITED STATES, June 24, 1996, Decided
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Overview: Petitioner journalist was awarded $ 450,000 in compensatory damages by a federal court jury for the loss of 300 slide transparencies. Respondent's motion for a new trial was denied. The appellate court set aside the verdict as excessive, relying on N.Y. C.P.L.R. § 5501(c) (McKinney 1995) which empowered New York appellate courts to review the size of jury verdicts and to order new trials when the award was unreasonable. The United States Supreme Court vacated the judgment with instructions to the appellate court to remand the case to the district court to revisit the motion for a new trial. The Court determined that the New York statute could properly be given effect in federal court, without detriment to U.S. Const. amend VII, if the statutory review standard was applied by the federal trial court judge, with appellate control of the trial court's ruling limited to review for abuse of discretion.
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| Lewis v. Casey, No. 94-1511,
SUPREME COURT OF THE UNITED STATES, June 24, 1996, Decided
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Overview: ADOC contended that the district court exceeded its authority in imposing an injunction that mandated sweeping changes in access to prison law libraries and legal assistance. The Court found that actual injury was required to establish standing for a violation of constitutional rights, which meant a showing that the inmates were denied the tools required to attack their sentences, directly or collaterally, or to challenge conditions of their confinement. Apart from the district court's identification of two instances of actual injury to two inmates, there was no evidence that illiterate prisoners could not obtain the minimal help necessary to file claims. Thus, the district court's granting of a systemwide remedy improperly went beyond what was necessary to provide relief to the two inmates. The Court also found that the district court failed to accord adequate deference to the judgment of the prison authorities with respect to restrictions on lockdown prisoners' access to law libraries, that the injunction was inordinately intrusive, and that the order was developed through a process that failed to give adequate consideration to the views of state prison authorities.
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| Medtronic, Inc. v. Lohr, No. 95-754,
SUPREME COURT OF THE UNITED STATES, June 26, 1996 * , Decided*Together with No. 95-886, Lohr et vir v. Medtronic, Inc., also on certiorari to the same court.
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Overview: Relying on Florida common law, the injured sued the manufacturer for damages when the wife's pacemaker failed. The manufacturer argued, and the lower court held, that the Medical Device Amendments of 1976 (MDA), particularly 21 U.S.C.S. § 360(k), pre-empted state common law actions against the manufacturer for negligent manufacturing or failure to warn, but allowed claims based on negligent design. The Court held that § 360(k) did not deny a state the right to provide traditional remedies for violations of common law duties when those duties paralleled federal requirements. Pre-emption would have had the effect of granting complete immunity from design defect liability to an entire industry that needed stringent regulation because there was no explicit private cause of action against manufacturers in the MDA. Legislative history also showed that it was not Congress's intent to pre-empt most general common law duties enforced by damages actions. The federal requirements reflected generic concerns about device regulation generally, not concerns regarding a specific device that the statute was designed to protect from potentially contradictory state requirements.
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| United States v. Virginia, No. 94-1941,
SUPREME COURT OF THE UNITED STATES, June 26, 1996, Decided **Together with No. 94-2107, Virginia et al. v. United States, also on certiorari to the same court.
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Overview: The United States sued Virginia for violating the Equal Protection Clause of U.S. Const. amend. XIV owing to Virginia's policy of denying women admission to a publicly funded university. The Supreme Court, reviewing the decision of the federal appeals court, held for the United States. The court opined that in cases of official classification based on gender, the proffered justification must be exceedingly persuasive; that the burden of justification was demanding and rested entirely on the state; that the state must show at least that the challenged classification served important governmental objectives and that the discriminatory means employed were substantially related to the achievement of those objectives; that the justification was genuine, not hypothesized or invented post hoc in response to litigation; and that it did not rely on overbroad generalizations about the different talents, capacities, or preferences of males and females. Since Virginia failed to satisfy the burden placed upon, the judgment below was reversed.
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| United States v. Winstar Corp., No. 95-865,
SUPREME COURT OF THE UNITED STATES, July 1, 1996, Decided
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Overview: Petitioner federal government was obligated to compensate respondents, savings and loans associations for damages incurred as a result of legislation enacted subsequent to a contract between the parties. In an effort to reduce petitioner's liabilities in paying out insurance for failing savings and loans during a time of financial crisis for the industry, petitioner entered into contracts with respondents to enlist their aid in buying out some of those failing organizations. Clauses within the contracts between the parties incorporated existing law as specific terms of the contract or specifically called on petitioner's duty to accept liability for damages caused to respondents in the event of statutory changes related to respondents' status as a result of these transactions. Subsequent legislation was enacted that resulted in the failure of two respondents and the near-failure of a third. The Court held that terms of the contract "unmistakably" spelled out petitioner's obligation to indemnify respondents for damages incurred. Petitioner was not immune on the basis of sovereignty from complying with the express terms of their contracts, and was held in breach for failing to comply.
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| Ohio v. Robinette, No. 95-891.,
SUPREME COURT OF THE UNITED STATES, November 18, 1996, Decided
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Overview: Police stopped defendant for speeding, and defendant was issued a verbal warning. The officer then asked whether defendant was carrying illegal contraband, to which defendant answered "no." Subsequently, defendant consented to a search of the car, and drugs were discovered. Defendant was charged with knowing possession of drugs. The state supreme court held that any attempt by the police at casual interrogation had to be proceeded by the phrase "At this time you are legally free to go." Initially, the United States Supreme Court decided that it had jurisdiction to review the state court decision because the opinion clearly relied on federal law. The Court held that the officer was objectively justified in asking defendant to get out of the car, subjective thoughts notwithstanding. The Court found that the touchstone inquiry was reasonableness measured in objective terms by examining the totality of the circumstances. The Court concluded that it would be unrealistic to require police officers to always inform detainees that they were free to go before consent to a search could be deemed voluntary. Voluntariness was a fact question to be determined from all the circumstances.
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| Caterpillar Inc. v. Lewis, No. 95-1263.,
SUPREME COURT OF THE UNITED STATES, December 10, 1996, Decided
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Overview: Petitioner corporation applied for a writ of certiorari from the judgment of the court of appeals rendered for respondent employee that vacated the district court judgment based on the jury verdict in favor of respondent on the grounds that complete diversity of citizenship for proper subject matter jurisdiction was absent when the district court permitted the removal, from the state court, of petitioner's personal injury action premised on state law. The court granted the writ as requested by petitioner. The court reversed the judgment from the court of appeals and remanded the cause. The court held that the district court's error in failing to remand respondent's lawsuit after it was improperly removed was not fatal to the subsequent adjudication because the federal jurisdictional requirements were satisfied when the judgment was entered. The court found that the jurisdictional defect of one nondiverse party, which existed when petitioner requested removal, was cured by an intervening settlement agreement reached by the nondiverse party. Thus, the district court had complete diversity before the trial occurred between petitioner and respondent, who were both diverse parties.
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