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Federal Courts -
U. S. Supreme Court - June 10 - June 17, 1999
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City of Chi. v. Morales, No. 97-1121,
SUPREME COURT OF THE UNITED STATES, June 10, 1999, Decided
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Overview: Petitioner city enacted a Gang Congregation Ordinance, which prohibited criminal street gang members from loitering in any public place. The Supreme Court of Illinois struck down the ordinance on the basis that it violated the,. Upon review, the court agreed with the Illinois Supreme Court and held that the ordinance was unconstitutionally vague. The ordinance did not meet the fair notice requirement because it did not provide adequate notice of what constituted prohibited conduct. Because no standard of conduct was specified, at all, by the ordinance, the entire ordinance failed to give the ordinary citizen adequate notice of what was forbidden and what was permitted. The ordinance also violated the requirement that a legislature establish minimal guidelines to govern law enforcement. Because the ordinance provided absolute discretion to police officers to determine what activities constituted loitering, the ordinance failed to meet constitutional standards for definitiveness and clarity. Thus, the ordinance was unconstitutional for vagueness.
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Neder v. United States, No. 97-1985,
SUPREME COURT OF THE UNITED STATES, June 10, 1999, Decided
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Overview: Petitioner's convictions under various federal statutes prohibiting fraud, including mail fraud,, wire fraud,, and bank fraud,statutes, were affirmed, and petitioner's application for writ of certiorari was granted. The court held the failure to instruct the jury as to materiality, an element of tax fraud under, was subject to harmless-error analysis because the error did not render the trial fundamentally unfair. The court found the error was harmless because the error did not, beyond a reasonable doubt, contribute to the verdict, petitioner did not contest materiality, which was supported by overwhelming evidence, and the jury verdict would have been the same even if instruction was proper. Materiality was an element of mail, wire, and bank fraud because the terms in the statute were given their established common law meaning, which included materiality. The judgment was reversed and remanded only for consideration of whether the failure to instruct the jury on materiality with respect to mail, wire, and bank fraud was harmless error. The judgment affirming the tax fraud conviction was affirmed.
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Grupo Mexicano De Desarrollo v. Alliance Bond Fund, No. 98-231,
SUPREME COURT OF THE UNITED STATES, June 17, 1999, Decided
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Overview: Petitioner holding company was the debtor of notes purchased by respondent. As part of their breach of contract suit against petitioner holding company, respondents obtained a preliminary injunction requiring petitioners to post a monetary bond. Subsequent to a final judgment in favor of respondents, petitioners argued that the preliminary injunction had been wrongfully granted. The Court first held that the issue of the injunction was not moot, despite final judgment on the merits in respondents' favor, as the final judgment involved a separate issue from the grant of the injunction. The Court then held that the scope of federal equity jurisdiction extended only as far as traditional English courts of equity. As traditional English chancery courts did not have jurisdiction to restrain a party's assets in the absence of an established judgment, the Court held that the trial court lacked jurisdiction to grant the preliminary injunction.
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Strickler v. Greene, No. 98-5864,
SUPREME COURT OF THE UNITED STATES, June 17, 1999, Decided
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Overview: Petitioner was convicted of capital murder and sentenced to death. Petitioner's habeas corpus application was granted by the federal trial court based on a finding that exculpatory evidence was not disclosed. The appellate court reversed, holding petitioner's Brady claim was procedurally defaulted. The court granted certiorari. After reviewing the record, the court found the evidence at issue was exculpatory and not disclosed. Although petitioner's Brady claim was procedurally defaulted, petitioner demonstrated cause for failing to timely raise his claim because respondent withheld exculpatory evidence, petitioner reasonably relied on respondent's open file policy, and respondent confirmed petitioner's reliance on the open file policy was reasonable during state habeas proceedings. Regardless, the court concluded petitioner did not show a reasonable probability that his conviction or sentence would have been different had the evidence been disclosed. Petitioner therefore could show materiality under Brady or prejudice from his failure to timely raise the claim. The appellate court's judgment denying petitioner's application for writ of habeas corpus was thus affirmed.
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