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Federal Courts -
U. S. Supreme Court - February 20 - February 27, 2001
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Brentwood Acad. v. Tenn. Secondary Sch. Ath. Ass'n, No. 99-901,
SUPREME COURT OF THE UNITED STATES, February 20, 2001, Decided
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Overview: Respondent was a not-for-profit corporation organized to regulate interscholastic sport among public and private high schools in the state. Respondent imposed sanctions on petitioner's athletic activities based upon alleged recruiting violations. Petitioner alleged that the sanctions were unconstitutional, and respondent argued that it was not a state actor subject to constitutional limitations. The court held that respondent's activity constituted state action in view of the pervasive entwinement of state school officials in the structure of the ostensibly private respondent, and there was no substantial reason to claim unfairness in applying constitutional standards to respondent. Respondent consisted of schools, primarily public schools, represented by school officials acting within the scope of their official duties during official school hours. Also, the state education board acknowledged respondent's authority and was represented in respondent's committees. Neither the unproven threat of expanded civil rights litigation nor the fact that respondent's member schools were undeniably state actors precluded the imposition of constitutional restraints.
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Illinois v. McArthur, No. 99-1132,
SUPREME COURT OF THE UNITED STATES, February 20, 2001, Decided
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Overview: The court found that the warrantless seizure was not per se unreasonable, since it involved exigent circumstances, and the restraint at issue was tailored, avoiding significant intrusion into the home itself. Consequently, the court balanced the privacy-related and law enforcement-related concerns to determine if the intrusion was reasonable. The court concluded that the restriction at issue was reasonable, and hence lawful. Police had probable cause to believe defendant's home contained unlawful drugs, and had good reason to fear that, unless restrained, defendant would destroy the drugs before they could return with a warrant. Also, police made reasonable efforts to reconcile their law enforcement needs with the demands of personal privacy, and they imposed the restraint for a limited period of time, two hours. Given the nature of the intrusion and the law enforcement interest at stake, the brief seizure of the premises was permissible. Moreover, the court found significant support in its case law, and was not persuaded by the countervailing considerations raised by the parties and lower courts.
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Bd. of Trs. of the Univ. of Ala. v. Garrett, No. 99-1240,
SUPREME COURT OF THE UNITED STATES, February 21, 2001, Decided
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Overview: The lower court had held that the Americans with Disabilities Act (ADA) validly abrogated the States' immunity under the,. Relying on its prior equal protection precedent, the court concluded that states were not required byto make special accommodations for the disabled, so long as their actions towards such individuals had a rational basis. Thus, if special accommodations for the disabled were to be required, they would have had to come from positive law and not through the. Congress had not identified a history and pattern of unconstitutional employment discrimination by the states against the disabled because its general findings and the anecdotal incidents in the ADA's legislative history fell short of suggesting a pattern of unconstitutional discrimination on which, legislation was required to be based. Even if a pattern of discrimination were shown, however, the rights and remedies in the ADA were not congruent and proportional to the targeted violation given the ADA's sweeping requirements.
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Semtek Int'l Inc. v. Lockheed Martin Corp., No. 99-1551,
SUPREME COURT OF THE UNITED STATES, February 27, 2001, Decided
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Overview: Petitioner's contract and business tort claims against respondent were dismissed on the merits by the federal court, sitting in diversity, on the ground that the statute of limitations of the court's forum state precluded the claims. Petitioner also asserted the same claims in the state court in a different forum, and the state court determined that the federal court dismissal was on the merits and thus was claim preclusive. The United States Supreme Court held that the federal court's dismissal did not necessarily preclude the action in the alternate forum state. The dismissal on the merits, based on the statute of limitations, merely barred petitioner's remedy without extinguishing its substantive rights, and thus only precluded petitioner from pursuing the same claim in the dismissing court. Federal common law governed the effect of the dismissal by the federal court sitting in diversity, and such law required that the claim-preclusive effect of the federal judgment was governed by the law of claim preclusion of the federal court's forum state.
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Whitman v. Am. Trucking Ass'Ns, Nos. 99-1257 and 99-1426,
SUPREME COURT OF THE UNITED STATES, February 27, 2001, Decided ** Together with No. 99-1426, American Trucking Associations, Inc., et al. v. Whitman, Administrator of Environmental Protection Agency, et al., also on certiorari to the same court.
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Overview: The court found that § 109(b)(1) of the CAA, which required the EPA to set air quality standards at a level to protect the public health with an adequate margin of safety, fit comfortably within the scope of discretion permitted by its precedent. Also, the court affirmed the court of appeal's holding that § 109(b) of the CAA unambiguously barred cost considerations from the NAAQS-setting process. Further, the court found that the court of appeals had jurisdiction to review the EPA's interpretation of the part of the CAA relating to the implementation of the revised ozone NAAQS, since its implementation policy was a final agency action that was ripe for review. However, the court remanded the action, since it held that the EPA's implementation policy for nonattainment areas was unlawful. Whatever effect could be accorded gaps in the section addressing ozone specifically (subpart 2), as implying some limited applicability of the section containing general nonattainment regulations that pertained to every pollutant, they could not be thought to render subpart 2's carefully designed restrictions on EPA discretion utterly nugatory once a new standard had been promulgated.
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