The case concerned a conflict between Utah's Motor Vehicle Safety Responsibility Act, which suspends drivers' licenses and vehicle registrations until judgments for negligent driving are paid and expressly states that a bankruptcy discharge does not relieve this obligation, and the federal Bankruptcy Act's provision releasing debtors from such judgments. After the plaintiff received a bankruptcy discharge for auto accident damages, the state denied restoration of his privileges, leading him to seek an injunction in federal district court on Supremacy Clause grounds. The three-judge District Court upheld the Utah statute and denied relief. The Supreme Court addressed a jurisdictional question, confirming that claims of unconstitutionality based on conflict with federal law under the Supremacy Clause fall within the three-judge court requirement of 28 U.S.C. § 2281, as the statute's text and purpose provide no exception for such claims, and prior precedents treat the requirement strictly without carving out Supremacy Clause issues.
DiBella v. United States consolidated two cases involving the appealability under 28 U.S.C. § 1291 of district court orders granting or denying pretrial motions to suppress evidence allegedly obtained through unreasonable searches and seizures in federal criminal prosecutions. In the first case, a motion filed before indictment in the district of trial was denied; in the second, a motion filed before indictment in a different district was granted as to suppression but denied as to return of property. The Supreme Court held that such orders are not immediately appealable final decisions, whether made before or after indictment. The Court reasoned that the longstanding rule requiring appellate review only after final judgment discourages piecemeal litigation and undue disruption in criminal cases, with no sufficient justification for an exception here despite some prior inconsistent circuit practices and dicta.
The case involved two Alaska Native communities, the Organized Village of Kake and the Angoon Community Association, seeking to operate fish traps despite Alaska's anti-fish-trap conservation law. They argued that federal regulations under the White Act and Alaska Statehood Act, along with permits from the Army Corps of Engineers and Forest Service, authorized their operations and preempted state interference. The Supreme Court affirmed the dismissal of their injunction requests, holding that no federal statute granted the Secretary of the Interior authority to exempt the tribes from state law and that the permits did not confer immunity from state regulation. The Court reasoned that the White Act was limited to conservation measures without creating exclusive rights, and other cited statutes did not provide general rulemaking power over Indian conduct to override state authority.
federal powercivil rightsenvironmentbusiness & regulatory
This case involved the Metlakatla Indian Community's effort to operate salmon fish traps in waters around their Annette Islands reservation, pursuant to federal regulations and congressional reservations dating back to 1891, against Alaska's state statute banning such traps to protect salmon resources. The Alaska Supreme Court had affirmed denial of an injunction against state enforcement of the ban. The U.S. Supreme Court vacated the judgment and remanded to provide the Secretary of the Interior an opportunity to clarify the scope of any federal authority to permit the traps under statutes including the White Act and the Alaska Statehood Act, prior to the 1963 fishing season.
This case concerned a challenge by the Communist Party of the United States to an order by the Subversive Activities Control Board requiring it to register as a Communist-action organization under the Subversive Activities Control Act of 1950. The Court of Appeals for the District of Columbia Circuit affirmed the Board's order, and the Supreme Court granted certiorari to address questions of statutory construction and constitutionality. The Court upheld the registration requirement, relying on congressional legislative findings regarding the structure and control of the world Communist movement, its use of action organizations, and related threats to national security. The opinion addressed various constitutional objections, including claims under the Fifth Amendment concerning compelled registration and self-incrimination.
In Piemonte v. United States, a federal prisoner serving a sentence for heroin sales was subpoenaed before a grand jury investigating narcotics offenses, invoked his Fifth Amendment privilege against self-incrimination, and was ordered to testify after the government granted him statutory immunity under 18 U.S.C. § 1406. When he continued to refuse, citing fear for his and his family's safety, the district court held him in criminal contempt and imposed an 18-month sentence consecutive to his existing term; the Seventh Circuit affirmed. The Supreme Court upheld the conviction, reasoning that the immunity order was clear and comprehensive, the contempt proceedings afforded due process including counsel and opportunity to be heard, and personal safety concerns did not excuse compliance with a lawful order to testify once immunity had removed the risk of self-incrimination. The Court rejected claims of ambiguity in the proceedings and confirmed that the summary contempt power could be used to enforce such orders.
