This case arose from a labor dispute in which a Virginia trial court issued an injunction against a union's strike-related activities and later imposed over $64 million in prospective fines for more than 400 violations, with most fines directed to state and local governments rather than the affected companies. The Supreme Court held that these fines constituted criminal contempt sanctions, not civil ones, because they punished completed violations without a realistic opportunity for the union to purge them through compliance and served punitive rather than compensatory purposes. As a result, the fines could not be imposed without affording the union the jury trial protections required for criminal proceedings, and the Court reversed the Virginia Supreme Court's judgment upholding the fines.
The case involved Frank McFarland, a Texas death row inmate, who sought appointment of counsel and a stay of execution under federal law providing representation for capital defendants in habeas proceedings without having filed a formal habeas petition. The Supreme Court held that a capital defendant is entitled to the appointment of counsel under 21 U.S.C. § 848(q)(4)(B) upon filing a motion for such appointment, and that this is sufficient to establish federal court jurisdiction to stay the execution. The core reasoning was that the statutory right to counsel for capital defendants includes pre-petition assistance, distinguishing it from non-capital cases where proceedings typically begin with the habeas petition itself.
The case concerned whether the Railway Labor Act (RLA) pre-empts state-law wrongful discharge claims by an aircraft mechanic who alleged he was fired for refusing to certify an unsafe plane and reporting safety issues to the FAA. The Supreme Court held that the RLA does not pre-empt such state tort actions. The core reasoning was that these claims do not require interpretation of the collective bargaining agreement and involve rights independent of the labor contract, applying standards from analogous labor law pre-emption cases under the LMRA.
This case involved a defendant in South Carolina convicted of murder who faced a capital sentencing hearing. The prosecution argued the defendant's future dangerousness as a reason for the death penalty, but the trial court barred the defense from informing the jury that state law made the defendant ineligible for parole if given a life sentence. The Supreme Court held that the refusal to instruct the jury on parole ineligibility violated the Due Process Clause of the Fourteenth Amendment. The core reasoning was that accurate information about parole eligibility is required to prevent the jury from acting on a false assumption that the defendant might be released, when future dangerousness is placed at issue.
The case concerned an estate that purchased and quickly resold stock to an employee stock ownership plan in late 1986 to claim a new federal estate tax deduction enacted that year, only for Congress to amend the deduction in 1987 to require the decedent to have owned the stock immediately before death and to apply the change retroactively to October 1986. The executor sued for a refund after the IRS disallowed the deduction, arguing that the retroactive amendment violated the Due Process Clause of the Fifth Amendment. The Supreme Court upheld the amendment, ruling that retroactive tax legislation satisfies due process if it is rationally related to a legitimate governmental purpose. The Court explained that Congress has broad latitude to adjust tax rules retroactively to prevent unintended revenue losses and close loopholes, and the brief period of retroactivity here met that standard.
The case concerned petitioners' convictions under the Mail Order Drug Paraphernalia Control Act for using interstate commerce to sell items such as pipes, bongs, scales, and diluents alleged to be drug paraphernalia, along with related drug and money-laundering charges. The Supreme Court examined whether the Act contains a scienter requirement and whether it is unconstitutionally vague. The Court held that the statute's definition of drug paraphernalia relies on objective standards tied to the items' design and primary use with illegal drugs, while also requiring proof that the defendant knew the items were likely to be used with controlled substances. It concluded that the Act is not vague as applied and that the jury instructions sufficiently conveyed the knowledge element, leading to affirmance of the convictions.
