Harry Andrew Blackmun

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.

criminal lawlabor & employmentprocedure

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.

criminal lawprocedure

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.

labor & employmentfederal power

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.

criminal lawcivil rights

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.

taxesfederal power

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.

criminal law

This case involved a paternity and child support action brought by the State of Alabama, in which the state used nine of its ten peremptory strikes to remove male jurors from a panel that had already been reduced to ten men and twenty-three women, resulting in an all-female jury. The defendant objected that the gender-based strikes violated the Equal Protection Clause of the Fourteenth Amendment. Extending the rule of Batson v. Kentucky, the Supreme Court held that intentional discrimination on the basis of gender in the exercise of peremptory challenges is unconstitutional. The Court reasoned that gender, like race, serves as an impermissible proxy for juror competence and impartiality and that such discrimination ratifies and perpetuates invidious stereotypes about the relative abilities of men and women, denying both litigants and potential jurors the right to nondiscriminatory jury selection procedures in civil as well as criminal trials.

civil rightsprocedurefamily law

The case concerned whether the Federal Mine Safety and Health Amendments Act of 1977 bars federal district courts from hearing a mine operator's pre-enforcement challenge to the Secretary of Labor's interpretation of regulations allowing non-employee union members to serve as miners' representatives with walk-around inspection rights. Thunder Basin Coal Company sued in district court claiming the designations violated its NLRA rights and would cause irreparable harm, and that forcing it through the Act's review process would violate due process. The Supreme Court held that the Mine Act's comprehensive enforcement and review scheme, which routes challenges first to the independent Federal Mine Safety and Health Review Commission and then to the courts of appeals, precludes district court subject-matter jurisdiction over the pre-enforcement claims. The Court reasoned that the statutory structure reflects Congress's intent to channel disputes through the administrative process, that the operator could raise its NLRA, constitutional, and statutory arguments in that forum without irreparable injury, and that no exception for facial constitutional claims applied here.

labor & employmentfederal powerprocedurebusiness & regulatory

In Daubert v. Merrell Dow Pharmaceuticals, Inc., parents of children born with birth defects sued the manufacturer of the antinausea drug Bendectin, alleging it caused the defects. The district court and Ninth Circuit excluded the plaintiffs' expert evidence on causation under the Frye general-acceptance test and granted summary judgment for the defendant. The Supreme Court reversed, ruling that the Federal Rules of Evidence, particularly Rule 702, superseded the Frye standard. It held that trial judges must serve as gatekeepers to admit only expert scientific testimony that is both relevant and based on reliable scientific methods, considering factors such as testability, peer review, error rates, and general acceptance in the scientific community.

proceduretorts & liability

The case Austin v. United States concerned whether the Excessive Fines Clause of the Eighth Amendment applies to civil in rem forfeitures of property under 21 U.S.C. §§ 881(a)(4) and (a)(7) following a drug conviction. The petitioner, who had pleaded guilty to possessing cocaine with intent to distribute, faced forfeiture of his mobile home and auto body shop after authorities found drugs, cash, and paraphernalia on the properties. The Supreme Court held that the Excessive Fines Clause does apply to these forfeitures because they serve in part to punish and deter rather than solely to provide remedial compensation to the government. The Court therefore remanded the case for further consideration of whether the forfeiture at issue was excessive.

criminal lawcivil rights

The case concerned a real estate developer sanctioned by HUD through a limited denial of participation and debarment after using a financing plan involving straw purchasers to obtain single-family mortgage insurance. The developer sued in federal district court under the APA without first seeking discretionary review by the HUD Secretary of the ALJ's decision. The Supreme Court held that federal courts lack authority to require exhaustion of administrative remedies as a prerequisite to APA judicial review when neither the governing statute nor agency rules mandate such exhaustion. The core reasoning rested on the text of APA §10(c), which treats agency action as final and reviewable unless an intra-agency appeal is pursued, along with the statute's legislative history and the Attorney General's Manual confirming that exhaustion is not a court-imposed requirement absent explicit mandate.

procedurebusiness & regulatory

The case concerned a conflict between the federal priority statute, which gives the United States first claim on assets of an insolvent debtor, and an Ohio statute that ranks federal claims fifth in the liquidation of an insolvent insurance company. The Court addressed whether the Ohio priority rules were shielded from federal preemption by the McCarran-Ferguson Act, which preserves state laws enacted for the purpose of regulating the business of insurance. The Court held that the Ohio statute avoids preemption to the extent it assigns priority to policyholder claims and administrative expenses of the liquidation, but remains subject to federal preemption for other categories of creditors. The reasoning centered on the McCarran-Ferguson Act's focus on protecting policyholders through state insurance regulation, while distinguishing priorities that do not directly serve that purpose.

business & regulatoryfederal power

The case concerned whether an employer's contributions of unencumbered property, such as truck terminals and real estate, to its tax-qualified defined benefit pension plans to satisfy minimum funding obligations under ERISA and the Internal Revenue Code constituted prohibited transactions under 26 U.S.C. § 4975(c)(1)(A). The Commissioner assessed excise taxes on these transfers, treating them as sales or exchanges between the employer and the plan, but the Tax Court and Fifth Circuit ruled in favor of the employer. The Supreme Court reversed, holding that such contributions are prohibited sales or exchanges because they are made in satisfaction of a mandatory funding obligation, akin to the transfer of property in exchange for relief from a liability. The Court reasoned that the statutory language bars any direct or indirect sale or exchange of property, without distinguishing between encumbered and unencumbered assets in this context, to prevent potential abuse of pension plans.

taxeslabor & employmentbusiness & regulatory

The case concerned whether a newspaper publisher that acquired another newspaper company could depreciate for tax purposes the portion of the purchase price allocated to an intangible asset called 'paid subscribers,' consisting of identified existing customers expected to continue their subscriptions. The IRS had disallowed the deductions, treating the asset as nondepreciable goodwill under the tax code. The Supreme Court held that an intangible asset is depreciable under § 167 if the taxpayer can prove it has an ascertainable value and a limited useful life that can be estimated with reasonable accuracy, regardless of whether the IRS classifies it as goodwill. The Court reasoned that the evidence, including actuarial estimates of subscriber duration and valuation based on net revenue streams, satisfied these statutory requirements and allowed matching of expenses with revenues over the asset's life.

taxesbusiness & regulatory

The case concerned whether the National Labor Relations Act preempts enforcement by a state agency, acting as the owner of a large public construction project, of a prehire collective-bargaining agreement negotiated between private parties. The Supreme Court held that the NLRA does not preempt the requirement because the state was engaged in proprietary conduct rather than regulation. The Court reasoned that the Massachusetts Water Resources Authority, responsible for the Boston Harbor cleanup, was acting like a private purchaser by conditioning bids on a project labor agreement authorized under NLRA sections 8(e) and 8(f) to promote labor stability on that specific job, thereby exemplifying market forces instead of regulating them.

labor & employmentfederal power

The case concerned the scope of liability under the Racketeer Influenced and Corrupt Organizations Act (RICO), specifically 18 U.S.C. § 1962(c), which prohibits any person employed by or associated with an enterprise from conducting or participating in its affairs through a pattern of racketeering activity. The dispute arose from an accounting firm's audits of a farmers' cooperative that had sold promissory notes and become insolvent after misrepresenting the value of a gasohol plant on its books; the cooperative's note holders sued the firm (Ernst & Young) under RICO for allegedly helping conceal the cooperative's financial condition. The Supreme Court held that liability under § 1962(c) requires a person to have participated in the operation or management of the enterprise itself. The Court reached this conclusion by interpreting the statutory terms "conduct" and "participate... in the conduct" to impose an operation-or-management test rather than a broader "but for" causation or mere assistance standard.

criminal lawbusiness & regulatory

This case concerned whether Federal Rule of Criminal Procedure 43 allows a criminal defendant who absconds before trial to be tried in absentia. The Supreme Court held that the rule does not permit such a trial, reversing the Court of Appeals and remanding the case. The Court reasoned that Rule 43 explicitly requires the defendant's presence at every stage of trial, including its beginning, with the sole exception for voluntary absence after the trial has commenced, based on the rule's plain language, its historical roots in common law, and practical distinctions between pre-trial and mid-trial flight.

criminal lawprocedure

The case concerned whether a federal appellate court loses jurisdiction in an in rem civil forfeiture proceeding under 21 U.S.C. § 881 after the government seizes and sells property linked to drug trafficking proceeds and transfers the cash to the U.S. Treasury. The Supreme Court held that removal of the res from the district does not automatically terminate jurisdiction. The core reasoning was that established admiralty principles requiring continuous control of the res for in rem actions are not rigidly applicable here, the government's actions in moving the funds did not divest review, and mechanisms exist to protect a claimant's interest if successful on appeal.

criminal lawprocedure

The case concerned Forsyth County's ordinance requiring a permit for parades and demonstrations, with fees adjustable by a county administrator up to $1,000 per day to cover costs of administration and maintaining public order, including police protection. The Nationalist Movement challenged the ordinance after being charged a $100 fee for a proposed rally opposing the Martin Luther King Jr. holiday, leading to litigation over whether the fee structure violated constitutional rights. The Supreme Court ruled that the ordinance was facially invalid under the First and Fourteenth Amendments. The core reasoning was that the ordinance conferred unbridled discretion on the administrator to vary fees and allowed consideration of the costs of protecting speakers from hostile audiences, enabling content-based discrimination without adequate standards to prevent viewpoint discrimination.

free speechcivil rights

The case concerned a challenge to California's Proposition 13, which amended the state constitution to limit real property taxes to 1% of a property's acquisition value (with annual increases capped at 2%) and reassess only upon new construction or change in ownership, creating large disparities in tax burdens between long-term owners and newer purchasers of comparable properties. Petitioner Nordlinger, a recent homebuyer, argued that this acquisition-value system violated the Equal Protection Clause of the Fourteenth Amendment. The Supreme Court upheld the system, holding that it satisfied rational-basis review because it furthered legitimate state interests in local neighborhood preservation, protecting reliance interests of existing owners who purchased under prior rules, and avoiding the administrative burdens of frequent reassessments. The Court rejected arguments that the scheme was arbitrary or lacked any plausible justification, noting that the legislature could reasonably conclude the benefits of stability outweighed the resulting inequalities.

taxesproperty