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Federal Courts -
U. S. Supreme Court - June 25 - December 15, 1997
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Amchem Prods. v. Windsor, No. 96-270,
SUPREME COURT OF THE UNITED STATES, June 25, 1997, Decided
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Overview: This case concerned the legitimacy under Fed. R. Civ. P. 23 of a class-action certification sought to achieve a global settlement of current and future asbestos-related claims. The class proposed for certification potentially encompassed individuals adversely affected by past exposure to asbestos products manufactured by one or more of 20 companies. Those companies--defendants in the lower courts--were petitioners in the case at bar. The district court certified the class for settlement only; however, the appellate court vacated the district court's order holding that the class certification failed to meet the requirements under Rule 23. On appeal, the Court held that the class failed to satisfy the predominance standard and that the class approved by the district court failed to satisfy the requirement that the named parties would fairly and adequately protect the interests of the class.
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City of Boerne v. Flores, No. 95-2074,
SUPREME COURT OF THE UNITED STATES, June 25, 1997, Decided
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Overview: Petitioners challenged the judgment in favor of respondents that upheld the constitutionality of the Religious Freedom Restoration Act of 1993 (RFRA), 42 U.S.C.S. ? 2000bb et seq., under an action challenging respondents' church building permit denial. On review, the court held that Congress was afforded broad powers under the Enforcement Clause of the Fourteenth Amendment. However, in most cases, the state laws to which RFRA applied were not ones motivated by religious bigotry and, thus, the RFRA was not considered remedial or preventative legislation. The court determined that the RFRA appeared to be an attempt to invoke substantive change in constitutional protections. Thus, the court held that the RFRA was unconstitutional because it allowed considerable Congressional intrusion into the states' general authority to regulate for the health and welfare of their citizens.
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United States v. O'Hagan, No. 96-842,
SUPREME COURT OF THE UNITED STATES, June 25, 1997, Decided
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Overview: Respondent was a partner in a law firm which represented a company regarding a potential tender offer for the common stock of another company. During the representation, respondent purchased call options for the other company's stock and sold them for a significant profit. After the Securities Exchange Commission initiated an investigation into respondent's transactions, a jury convicted respondent of securities fraud. On writ of certiorari, the Court held that criminal liability under ? 10(b) of the Securities Exchange Act of 1934 (15 U.S.C.S. ? 78j(b)) may be predicated on the misappropriation theory. The court also held that Securities Exchange Commission Rule 14e-3(a) was the proper exercise of the Commission's prophylactic powers under ? 14e of the Securities Exchange Act of 1934, 15 U.S.C.S. ? 78n(e), regarding the prevention of the misappropriation charged against respondent.
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Reno v. Aclu, No. 96-511,
SUPREME COURT OF THE UNITED STATES, June 26, 1997, Decided
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Overview: After Congress passed the Communications Decency Act of 1996 (CDA), 47 U.S.C.S. ? 223, appellees sought a declaratory judgment deeming it an unconstitutional violation of U.S. Const. amends. I and V. Appellants challenged the ruling of a three-judge federal district court panel that enjoined enforcement of the CDA. The Court upheld the district court's judgment on First Amendment grounds declining to reach the Fifth Amendment question. The Court found that (a) the CDA's vague provisions chilled free speech since speakers could not be certain if their speech was proscribed; (b) the CDA's provisions criminalized legitimate protected speech (including sexually explicit indecent speech) as well as unprotected obscene speech, and thus were overinclusive; (c) since the CDA regulated a fundamental freedom, it must be narrowly tailored; (d) time, place, and manner analysis was inapplicable since the CDA regulated the content of speech, not how it was presented; and (e) the CDA was unconstitutional due to its overbreadth.
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Vacco v. Quill, No. 95-1858,
SUPREME COURT OF THE UNITED STATES, June 26, 1997, Decided
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Overview: At issue on appeal was whether New York's prohibition on assisting suicide violated the Equal Protection Clause of the Fourteenth Amendment. Respondent physicians asserted that although it would be consistent with the standards of their medical practices to prescribe lethal medication for mentally competent, terminally ill patients who were suffering great pain and desired a doctor's help in taking their own lives, they were deterred from doing so by New York's ban on assisting suicide, N.Y. Penal Law ? 125.15. The Court held that New York's statute outlawing assisted suicide neither infringed upon fundamental rights nor involved suspect classifications; thus, it was entitled to a strong presumption of validity. The Court went on to hold that the distinction between assisting suicide and withdrawing life-sustaining treatment had a rational basis.
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Wash. v. Glucksberg, No. 96-110,
SUPREME COURT OF THE UNITED STATES, June 26, 1997, Decided
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Overview: Respondents brought a suit seeking a declaration that Washington state's ban on physician-assisted suicide, Wash. Rev. Code ? 9A.36.060(1) (1994), was unconstitutional on its face. On review, the United States Supreme Court held that history, legal traditions, and practice support criminalizing assisted suicide. The Court held that the assisted-suicide ban was rationally related to a legitimate government interest because Washington sought to preserve human life and also uphold the integrity and ethics of the medical profession. Additionally, Washington's statute sought to protect vulnerable groups, such as the poor, elderly, and disabled from abuse, neglect, and mistakes. Finally, the Court held that Washington's ban on assisted-suicide effectively prevented a broader license to voluntary or involuntary euthanasia. Thus, the Court reversed judgment in favor of petitioners.
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Printz v. United States, Nos. 95-1478, 95-1503,
SUPREME COURT OF THE UNITED STATES, June 27, 1997, Decided **Together with No. 95-1503, Mack v. United States, also on certiorari to the same court.
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Overview: The Brady Act, note following 18 U.S.C.S. ? 922, amended a detailed federal scheme that governed distribution of firearms established by the Gun Control Act of 1968, 18 U.S.C.S. ? 921. Interim provisions directed state law enforcement officers to participate in administration of a federally enacted regulatory scheme. Petitioners, chief law enforcement officials (CLEO) of their respective counties, objected to being pressed into federal service and contended that congressional action that compelled state officers to execute federal laws was unconstitutional. The Supreme Court agreed and held that the interim provisions violated constitutional principles of dual sovereignty and separation of powers. Congress could not compel states to enact or enforce a federal regulatory program. Congress could not circumvent that prohibition by conscripting the state's officers directly. The Brady Act effectively transferred the executive branch's responsibility to administer federal laws to thousands of CLEOs in 50 states, who were left to implement the program without meaningful presidential control.
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GE v. Joiner, No. 96-188,
SUPREME COURT OF THE UNITED STATES, December 15, 1997, Decided
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Overview: After the worker was diagnosed with cancer, he brought a products liability action, claiming exposure to polychlorinated biphenyls (PCBs), furans, and dioxins produced by the companies caused his cancer. After finding the testimony of the worker's experts speculative and unsupported, the district court excluded their testimony and entered summary judgment for the companies upon ruling that, although there was a genuine issue as to whether the worker was exposed to PCBs, there was no factual dispute that he had not been exposed to furans and dioxins. The court of appeals reversed, applying "a particularly stringent standard of review" in ruling that the exclusion of expert testimony was error, in light of the Daubert doctrine, and finding that there was a genuine issue as to whether the worker had been exposed to furans and dioxins. The companies sought review of the expert testimony ruling only. In reversing the ruling on that issue, the Supreme Court held that the proper standard of review was abuse of discretion and it was within the district court's discretion to exclude unreliable expert testimony.
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