John Marshall Harlan 2

The case involved a union member, Wilson Lockridge, who sued his union in Idaho state court after the union suspended him for late dues payment and caused his discharge from employment under a valid union security clause in the collective bargaining agreement. The Idaho courts awarded Lockridge damages on the ground that the union had breached obligations in its constitution and bylaws by treating him as suspended when he was merely not in good standing. The Supreme Court reversed, holding that the National Labor Relations Act preempts state court jurisdiction over claims involving conduct that is arguably protected or prohibited by the Act. The core reasoning, building on San Diego Building Trades Council v. Garmon, was that the federal labor law scheme and the NLRB's centralized authority require uniform national administration and necessarily displace traditional state court processes in this area.

labor & employmentfederal power

The case involved Paul Cohen, who was convicted under California Penal Code § 415 for disturbing the peace through offensive conduct after wearing a jacket displaying the words "Fuck the Draft" in a Los Angeles courthouse corridor. The state courts upheld the conviction on the ground that the words were likely to provoke a violent reaction from others. The U.S. Supreme Court reversed, holding that the conviction rested solely on the content of Cohen's speech rather than any separately identifiable conduct or incitement to violence. The Court reasoned that the First and Fourteenth Amendments protect such expression in the absence of a showing that it was intended to incite disobedience or disruption, and that the statute as applied did not justify punishing the message conveyed.

free speechcriminal law

The case concerned a long-running dispute between the Chicago and North Western Railway and the United Transportation Union over work rules, including the number of brakemen required on trains. After the parties had exhausted the Railway Labor Act's negotiation and mediation procedures, the railroad sued in federal court to enjoin a threatened strike, alleging that the union had violated its duty under § 2 First of the Act to exert every reasonable effort to make and maintain agreements. The district court and court of appeals ruled that § 2 First was merely a policy statement, nonjusticiable by courts, and that the Norris-LaGuardia Act deprived federal courts of jurisdiction to issue strike injunctions. The Supreme Court reversed, holding that § 2 First imposes a legally enforceable obligation on carriers and unions and that the Norris-LaGuardia Act does not bar judicial enforcement through injunctions, as this duty is central to the Railway Labor Act's purpose of preventing interruptions to commerce.

labor & employment

The case involved two petitioners convicted of first-degree murder in state courts and sentenced to death under statutes that gave juries absolute discretion to decide between life imprisonment and death, without any specific standards. In one case the penalty decision occurred in a separate proceeding after the guilt trial, while in the other the jury decided both guilt and punishment in a single trial and verdict. The Supreme Court granted certiorari on the questions of whether unguided jury discretion in imposing the death penalty violated the Constitution and whether combining the guilt and penalty determinations in one proceeding was permissible. The Court held that neither practice infringed the petitioners' constitutional rights and affirmed both convictions. Its reasoning centered on the conclusion that the Due Process Clause does not require states to provide juries with governing standards for the life-or-death choice or to separate the guilt and sentencing phases.

criminal lawprocedure

This case involved the U.S. government's attempt to forfeit $8,674 in cash that had been seized from Donald Angelini, who had been convicted of failing to register as a gambler and pay related taxes under federal law. After the Supreme Court ruled in Marchetti v. United States and Grosso v. United States that such convictions could violate the Fifth Amendment privilege against self-incrimination, the Court of Appeals held that Angelini could assert this privilege in the forfeiture proceeding, leading to the return of the money. The Supreme Court affirmed this decision, reasoning that forfeiture proceedings under 26 U.S.C. § 7302 are criminal in nature for Fifth Amendment purposes, making them equivalent to imposing a criminal fine based on the owner's wrongful conduct. The Court rejected the government's distinction that the owner's guilt was irrelevant, noting that the forfeiture still depends on a finding of illegal use tied to the owner's actions.

criminal lawcivil rightstaxesprocedure

The case involved petitioner Whiteley, who was convicted in Wyoming state court of breaking and entering and being an habitual criminal after evidence was seized during a search incident to his arrest. Whiteley challenged the constitutionality of the arrest warrant and the search under the Fourth Amendment, arguing that the warrant lacked probable cause. The Supreme Court held that the arrest was invalid because the complaint supporting the warrant contained only a bare conclusion without sufficient facts for a magistrate to independently determine probable cause, and the radio bulletin relied upon by the arresting officer did not supply additional information to establish probable cause. As a result, the evidence obtained from the search was inadmissible, and the Court reversed the judgment of the Court of Appeals affirming the denial of habeas relief.

criminal lawprocedurecivil rights

In Ohio v. Wyandotte Chemicals Corp., the State of Ohio sought to invoke the Supreme Court's original jurisdiction under Article III to bring a nuisance action against chemical companies incorporated in other states and Canada, alleging that their mercury discharges into Lake Erie's tributaries polluted the lake and harmed its waters, fish, wildlife, and Ohio citizens. The Court denied Ohio's motion for leave to file the complaint. Although the complaint presented a justiciable case or controversy within the Court's original jurisdiction, the Court declined to exercise it, citing the case's factual complexity, the availability of other forums such as state courts or federal district courts, and the evolution of the legal system making it impractical for the Supreme Court to hear all such disputes.

environmentfederal powerprocedure

In Boddie v. Connecticut, welfare recipients challenged Connecticut's requirements for court filing fees and service of process costs as a barrier to filing for divorce due to their indigency. The Supreme Court held that these requirements violated due process by denying indigent individuals access to courts for marital dissolution. The reasoning centered on the fundamental importance of marriage in society and the state's exclusive control over legal divorce proceedings, which together prohibit denying court access solely based on inability to pay.

civil rightsfamily lawprocedure

In Sanks v. Georgia, indigent tenants challenged Georgia statutes that required posting a surety bond equal to double the potential rent due before they could raise any defense to a landlord's summary eviction action and that imposed double-rent damages if the landlord prevailed. After the Court noted probable jurisdiction to consider due process and equal protection claims, both tenants voluntarily vacated the premises and Georgia enacted a new statute repealing the bond and double-rent provisions, replacing them with a system allowing tenants to contest eviction by answer and to retain possession by paying accruing rent into court. The Court held that these subsequent events had so altered the posture of the case that adjudication of the constitutional issues was no longer appropriate, dismissed the appeal, and remanded to the Georgia Supreme Court, leaving open the possibility of later review if the repealed provisions were applied retroactively. The core reasoning was that changed circumstances had rendered the controversy moot or too unfocused for a definitive constitutional ruling, consistent with precedents declining to decide issues whose context had become uncertain.

civil rightspropertyprocedure

This case involved the United States government's attempt to appeal a district court ruling that prevented the criminal conviction of John Sisson for refusing induction into the military due to his conscientious objection to the Vietnam War specifically. The Supreme Court determined that it lacked jurisdiction to hear the appeal under the Criminal Appeals Act. The district court's decision, which relied on trial evidence regarding Sisson's beliefs and weighed them against national needs, was classified as a directed acquittal rather than an arrest of judgment. Therefore, the appeal was dismissed without addressing the constitutional merits.

criminal lawprocedure

This case concerned whether federal maritime law provides a cause of action for wrongful death on navigable waters within a state's territorial limits. The widow of a longshoreman killed aboard a vessel in Florida waters sued the shipowner for damages based on negligence and unseaworthiness, but lower courts dismissed the wrongful death portion of the claim, relying on the 1886 precedent in The Harrisburg that held maritime law afforded no such remedy absent a statute. The Supreme Court overruled The Harrisburg and reversed, concluding that general maritime law does recognize a wrongful death action, because the old rule was an unjustifiable anomaly that conflicted with the evolution of maritime remedies and with federal statutes addressing deaths on the high seas and elsewhere.

torts & liability

In Adickes v. S. H. Kress & Co., a white teacher sued a restaurant chain under 42 U.S.C. § 1983, alleging that the refusal to serve her lunch because she was accompanied by Black students violated her rights under the Equal Protection Clause of the Fourteenth Amendment, and that the refusal and her subsequent vagrancy arrest resulted from a conspiracy with local police. The district court directed a verdict against her on the substantive claim and granted summary judgment on the conspiracy claim, rulings affirmed by the court of appeals. The Supreme Court reversed and remanded, holding that summary judgment was improper because the defendant had not shown the absence of any disputed material facts, and that the plaintiff could prevail on the substantive count by proving the refusal occurred pursuant to a state-enforced custom of racial segregation in local restaurants. The Court further held that the lower courts had applied an overly narrow definition of the relevant custom and state enforcement.

civil rightsprocedurecriminal law

The case concerned whether amendments to New York's Social Services Law complied with the federal requirements of § 402(a)(23) of the Social Security Act governing state plans for Aid to Families with Dependent Children (AFDC) benefits. Petitioners challenged the state's elimination of certain grants from benefit calculations, after an initial equal protection claim was mooted by further state amendments. The Supreme Court held that the district court properly exercised jurisdiction to decide the federal statutory claim and ruled that New York's program failed to meet the federal statute's conditions. The Court reversed the Second Circuit's contrary decision, relying on the statutory text and its purpose to ensure that states maintain benefit levels tied to their standards of need.

federal powerfamily law

The case involved commercial fishing boat owners who sought refunds of taxes paid under the Federal Insurance Contributions Act and Federal Unemployment Tax Act on the earnings of boat captains and crews, after the owners had treated the fishermen as employees. The lower courts ruled in favor of the owners, holding that the captains and crews were not employees under land-based common-law standards of control. The Supreme Court reversed this approach, concluding that the statutory definition of employee under the "usual common law rules" requires application of maritime law to determine the relationship between shipowners and seamen. The core reasoning emphasized that Congress incorporated the specialized maritime common-law framework when amending the statutes in 1948, as evidenced by legislative history and the need for uniform treatment of maritime workers, resolving a conflict with prior Court of Claims precedent.

taxeslabor & employmentbusiness & regulatory

This case involved Vermont dairy farmers challenging a federal milk marketing order issued by the Secretary of Agriculture under the Agricultural Marketing Agreement Act of 1937. The order required milk handlers to pay higher prices to 'nearby' producers located closer to marketing areas than to more distant 'country' producers, creating what was called a farm location differential. The District Court and Court of Appeals ruled in favor of the plaintiffs by enjoining the differential payments. The Supreme Court affirmed, holding that the Act did not authorize such location-based price premiums, as its provisions for adjustments were limited to specific factors like transportation costs or quality and did not permit payments based solely on proximity to markets.

business & regulatoryfederal power

The case concerned whether shareholders could bring a private action under § 14(a) of the Securities Exchange Act of 1934 to challenge a corporate merger approved through a proxy statement that omitted material facts about the board's domination by the acquiring companies. The district court held the statement materially misleading as a matter of law and found the requisite causal link after a hearing, granting partial summary judgment on liability, while the court of appeals affirmed the materiality ruling but reversed on causation. The Supreme Court considered the precise causal relationship that must be shown between a materially false or misleading proxy solicitation and the consummation of the merger. The opinion focused on the standard for establishing that the violation caused the injury in the context of an already-completed transaction where minority shareholder votes were required for approval.

business & regulatory

The case concerned a 1955 conviction of petitioner Bryson under 18 U.S.C. § 1001 for willfully filing a false affidavit with the National Labor Relations Board denying Communist Party affiliation, as required by the since-repealed § 9(h) of the National Labor Relations Act. After his direct appeal failed, Bryson sought collateral relief in 1967, arguing that § 9(h) was unconstitutional as a bill of attainder and on First Amendment and vagueness grounds, rendering his conviction invalid. The district court set aside the conviction, but the Ninth Circuit reversed, and the Supreme Court affirmed. The Court held that the constitutionality of § 9(h) was irrelevant to the § 1001 prosecution for making false statements to the government, following the principle from Dennis v. United States that one who engages in deliberate fraud cannot avoid liability by later challenging the validity of the underlying statute.

criminal lawlabor & employmentfree speech

The case involved defendant Knox, who was indicted on charges related to his wagering business for failing to file required IRS Form 11-C and pay the occupational tax under 26 U.S.C. §§ 4411 and 4412, as well as for filing forms that understated the number of employees in violation of 18 U.S.C. § 1001. The district court dismissed all counts, holding that the Fifth Amendment privilege against self-incrimination barred prosecution because Knox could not have filed truthful forms without incriminating himself under state law. The Supreme Court reversed the dismissal of the § 1001 counts, ruling that a defendant who submits false information to the government cannot avoid prosecution for fraud by challenging the validity of the underlying statutory requirement on self-incrimination grounds. The Court reasoned that the Fifth Amendment protects against compelled truthful disclosures but does not privilege the submission of false statements, even when the alternative of non-compliance carried criminal penalties. It distinguished this from cases like Marchetti v. United States where truthful compliance itself was at issue.

criminal lawtaxes

This case involved an alien crewman from Yugoslavia who, after being granted temporary shore leave in the U.S., claimed he would face persecution if returned to his home country and refused to depart on his vessel. The Immigration and Naturalization Service revoked his landing permit under section 252(b) of the Immigration and Nationality Act and had the district director hear and reject his persecution claim, rather than providing a full hearing before a special inquiry officer under section 242(b). The Court of Appeals for the Ninth Circuit ruled that the crewman was entitled to the section 242(b) proceeding. The Supreme Court granted certiorari to resolve a split with the Second Circuit's contrary decision in Kordic v. Esperdy. The core reasoning centered on the statutory language of section 252(b), which expressly states that its procedures do not require application of section 242, along with related regulations permitting district directors to address persecution claims for crewmen.

immigrationprocedure

This case involved a dispute between inventor John Adkins and Lear, Inc., over royalties under a licensing agreement for improvements to gyroscopes that Adkins had patented. Lear sought to challenge the validity of Adkins' patent to avoid paying royalties, but the California Supreme Court held that as a licensee, Lear was estopped from denying the patent's validity. The U.S. Supreme Court reversed, ruling that the doctrine of licensee estoppel is inconsistent with federal patent policy promoting free competition in unpatentable ideas, allowing licensees to challenge patent validity.

business & regulatoryfederal power