Stanley Forman Reed

This case concerned a handyman employed on a dredge who suffered injuries from a stove explosion while storing signal lanterns ashore and sued his employer under the Jones Act for damages as a seaman. The Supreme Court held that the jury's finding of crew membership was supported by sufficient evidence, reversing the state appellate court's determination that the employee was not a member of a crew under the Longshoremen's Act. The reasoning centered on the petitioner's duties of deck maintenance, supply handling, and general upkeep of the vessel, which allowed a reasonable inference that he was permanently attached to the dredge and responsible for its seaworthiness, regardless of the vessel being anchored or the injury occurring on land. The Court emphasized that crew status is a factual question for the jury based on the nature of the employment.

labor & employmenttorts & liability

This case concerned the validity of a 1954 federal prison sentence imposed on petitioner Thomas Pollard after he pleaded guilty in 1952 to embezzling a U.S. Treasury check. Following the guilty plea, the district court attempted to place Pollard on probation in 1952 while he was absent from the courtroom, an order the government conceded was invalid under Federal Rule of Criminal Procedure 43; nearly two years later, after a reported probation violation, the court vacated that order and sentenced him to two years' imprisonment. The Supreme Court upheld the 1954 sentence, concluding it was a valid initial sentencing for the embezzlement offense itself rather than punishment for violating the invalid probation, and that the proceedings did not violate Pollard's rights to prompt or proper sentencing.

criminal lawprocedure

In Re Groban concerned whether two witnesses subpoenaed by the Ohio State Fire Marshal to testify privately about the cause of a fire had a Fourteenth Amendment due process right to the presence of their own counsel during the administrative investigation. The Supreme Court held that no such right existed, affirming the denial of habeas corpus relief after the witnesses refused to testify without counsel and were jailed for noncompliance. The Court reasoned that the proceeding was a non-adjudicative fact-finding inquiry into fire causes, akin to a grand jury investigation, rather than a criminal prosecution where the right to counsel would apply; witnesses' protection in this setting was limited to the privilege against self-incrimination.

criminal lawprocedurecivil rights

The case involved a federal criminal charge against Ludenia Howard under the Black Bass Act for delivering fish for interstate transportation in violation of Florida Game and Fresh Water Fish Commission rules, which were enforced by a state statute making violations misdemeanors. The district court quashed the information, ruling that agency regulations did not qualify as the "law of the State" under the federal Act. The Supreme Court reversed, holding that the regulations constituted state law because the Florida constitution delegated regulatory authority to the Commission, the legislature authorized and penalized violations of its rules, and precedents establish that state administrative orders can have the force of law. The Court distinguished United States v. Eaton and noted that congressional intent, supported by legislative history, favored federal enforcement of such state conservation measures at state borders.

criminal lawenvironmentfederal power

The case concerned whether railroads serving the port of Norfolk, Virginia, were obligated to pay the United States an allowance for wharfage and handling services that the Army performed itself on military export freight at government-controlled piers. The Army had complained to the Interstate Commerce Commission that the railroads' refusal to make such payments—while providing the services without extra charge to commercial shippers using public piers—violated sections 1, 2, 3, and 6 of the Interstate Commerce Act by creating unjust discrimination and unreasonable practices. The Commission dismissed the complaint, finding the circumstances dissimilar because the Army used its own facilities and required special handling, and the district court upheld that order. The Supreme Court affirmed, holding that railroads have no statutory duty to furnish piers or unloading services, that their tariffs applied only to shippers conforming to the specified facilities, and that section 22 of the Act did not compel allowances in these circumstances.

business & regulatoryfederal power

General Box Co. sued the United States under the Tucker Act to recover the value of timber it owned on batture land along the Mississippi River that federal contractors destroyed while enlarging a levee. The Supreme Court held that the United States was not liable. Louisiana law subjects batture to a riparian servitude allowing the state to use the land for levee purposes without compensation, and the state had authorized the federal project to proceed under that servitude at no cost. The Court reasoned that the timber destruction occurred in connection with a valid levee project, so neither notice to the owner nor payment was required.

propertyfederal power

The case involved the United States suing E. I. du Pont de Nemours & Co. under Section 2 of the Sherman Act for allegedly monopolizing interstate commerce in cellophane. The Supreme Court affirmed the district court's judgment for du Pont, ruling that the company had not monopolized trade in cellophane. The Court reasoned that the relevant market was flexible packaging materials overall (of which cellophane was less than 20%), other wrapping materials were reasonably interchangeable substitutes with sufficient cross-elasticity of demand, and this competition prevented du Pont from controlling prices or excluding rivals.

business & regulatory

The case involved a deportable alien who applied for discretionary suspension of deportation under the Immigration and Nationality Act of 1952 after being ordered deported for past membership in the Communist Party. The Attorney General's delegate denied the application based partly on confidential information not disclosed to the applicant, a decision upheld by lower courts. The Supreme Court affirmed, holding that the statute grants the Attorney General broad discretion to suspend deportation and that the regulation allowing use of undisclosed confidential information is valid. The Court reasoned that the Act contains no requirement for a hearing or disclosure on the discretionary aspect of the relief, and due process does not compel it here.

immigration

The case concerned whether Wisconsin could use its Employment Peace Act to enjoin a union's mass picketing, obstruction of plant access, and threats of violence against workers during a strike at the Kohler Company, conduct that could also constitute an unfair labor practice under the federal National Labor Relations Act. The Supreme Court affirmed the state court's enforcement of the injunction, holding that the state labor board had authority to prohibit such activities. The core reasoning was that the NLRA, even after the Taft-Hartley amendments, does not preempt state regulation of violent or coercive union conduct, as Congress preserved state police powers to address actual threats, physical interference, and similar matters outside the federal Board's exclusive domain, consistent with prior decisions like Allen-Bradley Local v. Wisconsin Board.

labor & employmentfederal power

The case concerned three conscientious objectors prosecuted under the Universal Military Training and Service Act for refusing to report for assigned civilian work at state hospitals after being ordered by their local draft boards. The defendants resided in and interacted only with boards in the Western District of Pennsylvania and Oklahoma, yet were indicted in the Eastern District of Pennsylvania and Kansas where the hospitals were located; lower courts split on whether venue was proper in those districts. The Supreme Court held that venue lies in the district where the civilian work was to be performed. The Court reasoned that the crime consists of failing to obey the order to report to and remain at the designated place of employment, so the offense occurs where performance is required rather than where the order was issued or the registrant resided.

criminal lawprocedure

The case concerned Storer Broadcasting Company's challenge to Federal Communications Commission rules that limited the number of standard, FM, and television broadcast stations a single entity could own or control, with the aim of preventing overconcentration of media ownership. Storer argued that the rules conflicted with the Communications Act's requirements to grant licenses serving the public interest and to provide hearings before denials, and that treating 1% stock ownership as equivalent to control was unreasonable, particularly given its publicly traded shares. The Supreme Court addressed whether Storer had standing to seek direct judicial review of the final rules under statutes allowing review for aggrieved parties. The Court held that Storer possessed standing because the rulemaking was complete and the rules directly affected its operations, including the dismissal of a pending application, without needing to await specific enforcement actions.

business & regulatoryfederal power

This case concerned whether employers violated the National Labor Relations Act by barring nonemployee union organizers from distributing literature on company-owned parking lots adjacent to their plants. The NLRB had ruled in three separate proceedings that such refusals unreasonably impeded employees' rights to self-organization under §7 and §8(a)(1) when off-site access was impracticable due to traffic, distance, or layout. Lower courts reached conflicting results on enforcement of the Board's orders requiring limited access. The Supreme Court granted certiorari to address the recurring issue of balancing employees' organizational rights against employers' property interests, emphasizing that access is required only when reasonable alternatives for communication do not exist.

labor & employmentproperty

The case involved an indictment against a union official and his local union under the Hobbs Act (18 U.S.C. § 1951) for alleged extortion, consisting of attempts to obtain wages from employers for unwanted and fictitious "swamper" labor services through actual or threatened force and violence affecting interstate commerce. The district court arrested judgment after a guilty verdict, holding that it lacked jurisdiction because the statute did not reach this conduct, which the court viewed as legitimate union activity not amounting to extortion for personal gain. The Supreme Court reversed, ruling that the Hobbs Act applied to the charged conduct. The Court reasoned that Congress had amended the prior Anti-Racketeering Act specifically to remove the exception for bona fide wages and to ensure coverage of extortionate demands in the employer-employee context, as confirmed by the legislative history following United States v. Local 807.

criminal lawlabor & employment

The case involved Affronti, who was convicted in federal district court on multiple counts of illegal narcotics sales and received consecutive five-year sentences on counts two through ten, with probation granted on the later counts to begin after the earlier ones were served. While serving the first sentence, he moved to suspend the sentences on counts three through five and grant probation, but the district court denied the motion, and the court of appeals affirmed. The Supreme Court held that federal district courts lack authority under the Probation Act to suspend sentences and place a defendant on probation for unserved terms in a cumulative sentence once the prisoner has begun serving any part of it. The core reasoning was that the statute, as interpreted in United States v. Murray and unchanged in substance by the 1948 codification, limits probation to the time before execution of a sentence begins, in order to avoid unnecessary overlap with parole and executive clemency provisions.

criminal lawfederal power

This case concerned two mutually exclusive applications for a radio broadcast construction permit on the same frequency, one by Easton Publishing Co. for Easton, Pennsylvania, and one by Allentown Broadcasting Corp. for Allentown, Pennsylvania. The FCC granted the license to the Easton applicant after finding that Easton had a substantially greater need for a second local station than Allentown, which already had multiple stations, and that the Easton applicant was best qualified to serve that need under Section 307(b) of the Communications Act. The Court of Appeals reversed, holding that the FCC first had to determine the applicants were approximately equal in ability before applying a community-need preference. The Supreme Court reversed the Court of Appeals, ruling that the FCC could properly prioritize the community with greater need and then select the applicant best able to serve it, and that substantial evidence supported the FCC's findings.

business & regulatoryfederal power

The case involved a union suing an employer under § 301 of the Labor Management Relations Act to enforce a collective bargaining agreement by recovering unpaid wages for employees who missed work, where the absences were not due to furlough or leave. The district court dismissed on the merits, finding no obligation to pay for voluntary absences, but the court of appeals directed dismissal for lack of jurisdiction. The Supreme Court affirmed, holding that the wage claims arose from individual hiring contracts between the employer and each employee rather than from a breach of the collective bargaining agreement itself. As a result, the suit did not meet the requirements for federal jurisdiction under § 301, which applies to violations of contracts between unions and employers.

labor & employmentfederal power

In Regan v. New York, a former New York City police officer was convicted of criminal contempt for refusing to answer a grand jury question about accepting bribes from gamblers, despite having signed a waiver of immunity. The Supreme Court affirmed the conviction, holding that the petitioner was not deprived of due process under the Fourteenth Amendment. The Court reasoned that New York's immunity statute for bribery testimony required him to testify regardless of the waiver's validity, as the statute would have granted him immunity if no waiver had been signed, eliminating any self-incrimination concern. The validity of the waiver was deemed irrelevant because the obligation to testify remained in either case.

criminal lawcivil rightsprocedure

The case involved a former member of Congress indicted under 18 U.S.C. § 1001 for falsely representing to the House Disbursing Office that a woman was entitled to pay as his official clerk. The district court arrested the judgment of conviction, concluding that the Disbursing Office was not a department or agency within the statute's meaning and that the law did not protect the legislative branch. On direct appeal, the Supreme Court reversed, holding that the statute applies to false statements made in any matter within the jurisdiction of any department or agency of the United States, including the legislative branch. The Court reached this conclusion after reviewing the statute's evolution from 1863 onward, finding that neither the 1934 amendment nor later revisions restricted its scope to the executive branch.

criminal law

The Tee-Hit-Ton Indians, a small Alaska clan, sued the United States under the Fifth Amendment for compensation after the government sold timber from over 350,000 acres of land the group claimed based on aboriginal occupancy and use since time immemorial. The Court of Claims had ruled that this original Indian title, even if it survived the 1867 Alaska purchase from Russia, was not a recognized property right sufficient to support a takings claim absent congressional action. The Supreme Court affirmed the dismissal, holding that unextinguished aboriginal title confers only a right of occupancy that Congress may terminate without triggering constitutional compensation requirements. The decision turned on the distinction between recognized Indian title, which can support Fifth Amendment claims, and unrecognized aboriginal title, which does not create a compensable interest.

civil rightspropertyfederal power

In this case, a construction joint venture partner sued for an accounting of profits in state court, and after removal to federal district court based on diversity, the defendant moved to stay proceedings under Section 3 of the United States Arbitration Act citing a clause calling for an accountant's binding determination of net profit disputes. The district court denied the stay, interpreting the clause as limited to mathematical calculations rather than the alleged improper practices. The Supreme Court held that the denial order was not appealable to the court of appeals under 28 U.S.C. § 1292(1) as the refusal of an injunction, because the stay request was merely a procedural directive on the course of trial rather than equitable relief. The decision rested on the longstanding congressional policy favoring final judgments under § 1291 and limiting interlocutory appeals to avoid piecemeal review, with prior precedents like Shanferoke confirming that arbitration stays do not qualify as appealable injunctions.

procedurebusiness & regulatory