Potter Stewart

In New York v. Belton, a state trooper stopped a speeding car, arrested its four occupants after smelling marijuana and seeing related evidence, and then searched the passenger compartment, discovering cocaine in the pocket of a jacket on the back seat. The defendant moved to suppress the cocaine, arguing the search exceeded the permissible scope under the Fourth Amendment. The Supreme Court held that a lawful custodial arrest of a vehicle occupant permits a warrantless search of the entire passenger compartment, including containers within it. This ruling extends the Chimel v. California standard by treating the passenger area as within the arrestee's immediate control, allowing searches to ensure officer safety and prevent evidence destruction. The decision applies only to the interior passenger space and excludes the trunk.

criminal law

The case involved Abby Gail Lassiter, an indigent mother serving a prison sentence for second-degree murder, whose parental rights to her son were petitioned for termination by the Durham County Department of Social Services on grounds of no contact since 1975 and failure to address the conditions that led to the child's removal from her custody. The trial court denied her request for appointed counsel at the termination hearing, allowed her to proceed pro se, and ultimately terminated her rights after hearing testimony from a social worker and Lassiter herself. The Supreme Court held that the Due Process Clause does not require appointment of counsel for indigent parents in every state-initiated parental rights termination proceeding. The core reasoning was that whether due process mandates counsel must instead be determined case by case, balancing the parent's interest against the state's interest and the risk of erroneous deprivation without counsel.

family lawcivil rightsprocedure

The case concerned whether an employer's appointed trustees for employee pension and welfare trust funds under §302(c)(5) of the Labor Management Relations Act qualify as employer "representatives" for collective bargaining or grievance adjustment under §8(b)(1)(B) of the National Labor Relations Act, and thus whether a union could lawfully bargain to impasse and strike to require an employer like Amax Coal to participate in national union trust funds rather than its own plan. The Supreme Court held that such trustees are not "representatives" within the meaning of §8(b)(1)(B), so the union's conduct did not constitute an unfair labor practice. The Court reasoned that trust fund trustees owe fiduciary duties of undivided loyalty to the beneficiaries under trust law, rather than serving as agents of the appointing party as in collective bargaining. It distinguished the trustees' role from that of true bargaining representatives, noting that Congress created separate statutory frameworks for each and that the union's demands fell within permitted bargaining over terms and conditions of employment. The decision affirmed the NLRB's ruling that the union had not violated the Act.

labor & employmentbusiness & regulatory

The case concerned whether a plaintiff suing the federal government for age discrimination under section 15(c) of the Age Discrimination in Employment Act has a right to a jury trial. The Supreme Court held that no such right exists in suits against the United States. The Court reasoned that the Seventh Amendment right to jury trial does not apply in actions against the federal government, that Congress must expressly authorize jury trials when waiving sovereign immunity, and that the statute's reference to 'legal or equitable relief' does not imply a jury-trial right, unlike the explicit provision added for private-sector suits under section 7(c).

civil rightsfederal powerprocedure

The case concerned whether federal law under the Vietnam Era Veterans' Readjustment Assistance Act required an employer to give a military reservist employee preferential work scheduling to accommodate weekend training absences, beyond granting unpaid leaves. The Supreme Court held that 38 U.S.C. § 2021(b)(3) imposes no such duty, ruling instead that employers need only treat reservists equally with other employees regarding schedules, shift exchanges, and other incidents of employment. The Court reasoned from the statutory text and legislative history that the provision bars discrimination on account of reserve obligations but does not mandate special accommodations or compensation for missed hours that non-reservists do not receive. The employer had complied by allowing leaves and permitting the same shift-swapping opportunities available to all workers.

labor & employment

This case involved a dispute over whether the Crow Tribe of Montana could regulate hunting and fishing by non-Indians on fee-owned lands within the reservation boundaries and who owned the bed of the Big Horn River. The Supreme Court held that the Tribe lacked authority to prohibit or regulate such activities by nonmembers on non-Indian property and that the riverbed belonged to the State of Montana. The Court reasoned that while tribes possess inherent powers of sovereignty, these are diminished with respect to nonmembers on lands alienated through allotment acts, and treaties did not clearly convey exclusive regulatory rights or the riverbed, which presumptively passes to states upon admission to the Union under precedents like United States v. Holt State Bank.

federal powerproperty

The case concerned whether Actors' Equity's unilateral licensing system for regulating independent theatrical agents—who negotiate employment for union actors—was exempt from federal antitrust laws under the statutory labor exemption. Petitioners, licensed agents, challenged the union's rules that barred members from using non-franchised agents and prohibited commissions on minimum-scale wages or certain expenses. The Court of Appeals held the system immune from antitrust liability. The Supreme Court granted certiorari to examine the exemption's applicability. Its reasoning focused on whether the regulations primarily aimed to safeguard collectively bargained wage scales and prevent agents from eroding union members' compensation, rather than restraining competition among agents.

labor & employmentbusiness & regulatory

The case involved a deaf graduate student at the University of Texas who sued the university under Section 504 of the Rehabilitation Act of 1973, claiming that as a recipient of federal funds it had unlawfully refused to pay for a sign-language interpreter. The district court issued a preliminary injunction requiring the university to provide and pay for the interpreter, subject to the student posting a bond and pursuing administrative remedies; the court of appeals affirmed the injunction but eliminated the administrative-stay requirement. By the time the appeals reached the Supreme Court the student had graduated and the university had paid for the interpreter. The Supreme Court held that the appeal concerning the propriety of the preliminary injunction was moot because that specific relief had already been fully performed, but the underlying dispute over ultimate responsibility for the cost was not moot; accordingly it vacated the judgments below and remanded for a trial on the merits of the statutory claim.

civil rightsfederal powerprocedure

The case concerned whether Arizona's Salt River Project Agricultural Improvement and Power District could constitutionally restrict voting for its board of directors to landowners and weight their votes by the acreage they owned. The Supreme Court held that this system did not violate the Equal Protection Clause's one-person, one-vote requirement. The Court reasoned that the district performed a narrow function focused on water storage, delivery, and conservation, with electric power sales merely subsidizing those operations, and that landowners had a special relationship to the district's activities. Because the entity was not a general-purpose government exercising broad police powers, the strict one-person, one-vote rule did not apply.

electionscivil rights

In Carter v. Kentucky, a defendant on trial for third-degree burglary requested that the jury be instructed not to draw any inference of guilt from his decision not to testify, but the trial judge refused and the Kentucky Supreme Court affirmed the conviction. The U.S. Supreme Court reversed, holding that the Fifth Amendment privilege against self-incrimination, made applicable to the states by the Fourteenth Amendment, requires a trial court to give such a "no-inference" instruction when the defendant requests it. The Court reasoned that jurors are likely to notice and draw adverse conclusions from a defendant's silence unless explicitly told otherwise, and that only the judge's instruction can adequately safeguard the constitutional right by limiting the inferences the jury may draw.

criminal law

The case concerned a conflict between the Democratic National Party's rules limiting participation in its presidential delegate selection process to voters who publicly affiliate with the party and Wisconsin's election laws providing for an open primary in which non-Democrats could vote, with delegates bound to follow the primary results at the national convention. The Wisconsin Supreme Court ruled that the state could require the National Party to seat delegates selected under its open primary system. The U.S. Supreme Court reversed, holding that the National Party could refuse to seat such delegates. The Court reasoned that the party's First Amendment right to freedom of political association outweighed the state's interest in its primary system, as forcing the party to accept delegates chosen through procedures it rejected imposed an impermissible burden.

electionsfree speech

This case arose when the EEOC subpoenaed employment records and statistics from Associated Dry Goods Corp. during its investigation of seven discrimination charges filed by the company's employees, after the company refused to cooperate without a guarantee of absolute secrecy from the agency. The District Court and Court of Appeals held that the EEOC's practice of limited prelitigation disclosure of investigative information to charging parties violated Title VII's prohibitions on making charges or obtained information "public." The Supreme Court granted certiorari to decide whether such disclosures to charging parties fall within the statutory restrictions, examining Title VII's text, its combined administrative and private enforcement scheme, and the legislative history emphasizing the role of private lawsuits.

labor & employmentcivil rights

In Watkins v. Sowders, two petitioners convicted in Kentucky state courts argued that their trials violated due process because the courts did not hold hearings outside the jury's presence to determine whether eyewitness identifications resulted from impermissibly suggestive procedures. The Supreme Court held that the Constitution does not require such suppression hearings to be conducted outside the jury's presence in identification cases. The Court reasoned that, unlike the special rules applicable to confessions, there is no constitutional mandate to exclude the jury from hearings on the admissibility of identification evidence, as the jury can properly assess reliability through cross-examination and other trial procedures.

criminal lawprocedure

In Allen v. McCurry, the respondent was convicted in Missouri state court after the trial judge partially denied his motion to suppress evidence seized without a warrant during a search of his home, and he was barred from federal habeas relief under Stone v. Powell. He then brought a damages action under 42 U.S.C. § 1983 against the police officers, alleging an unconstitutional search and seizure. The district court granted summary judgment to the officers on collateral estoppel grounds, but the court of appeals reversed, holding that the § 1983 suit should proceed to allow a federal forum for the constitutional claim. The Supreme Court granted certiorari to decide whether the officers could assert collateral estoppel from the state suppression ruling as a defense. The Court explained that the traditional doctrines of res judicata and collateral estoppel apply in federal court to issues decided in state proceedings, absent a full and fair opportunity to litigate or congressional intent to create an exception in § 1983 actions.

criminal lawcivil rightsprocedure

The case concerned whether a federal district court could issue a preliminary injunction preventing Imperial County from enforcing a state court judgment that upheld a conditional use permit restricting the sale of well water outside the county, based on a Commerce Clause challenge brought by Mexican merchants who had contracts with the permit holder. The state courts had already ruled against the permit holder McDougal in enforcement proceedings, finding the geographic restriction valid and binding. The Supreme Court held that the Anti-Injunction Act, 28 U.S.C. § 2283, barred the federal injunction because the respondents were not strangers to the state litigation and no statutory exception applied, as the suit did not rely on 42 U.S.C. § 1983 and the injunction was not necessary in aid of jurisdiction. The Court distinguished precedents like Hale v. Bimco Trading and rejected arguments that the state proceedings had terminated or that declaratory relief justified the injunction.

procedurefederal power

The case concerned an Illinois statute restricting state Medicaid funding for abortions to those necessary to preserve the life of the pregnant woman, with plaintiffs including physicians and an indigent woman arguing that federal Medicaid law under Title XIX required coverage for all medically necessary abortions and that the limitation violated equal protection. The District Court enjoined enforcement of the statute as inconsistent with Title XIX, but the Court of Appeals modified the injunction to require state funding only for abortions eligible for federal reimbursement under the Hyde Amendment. The Supreme Court held that Title XIX does not obligate participating states to fund medically necessary abortions for which federal funds are unavailable under the Hyde Amendment, and that the equal protection challenge to the funding restrictions failed for the reasons set forth in the companion case of Harris v. McRae.

abortionhealthcarecivil rights

In Harris v. McRae, the Supreme Court considered challenges to the Hyde Amendment's restrictions on federal Medicaid funding for abortions under Title XIX of the Social Security Act, which limited reimbursement to cases where the mother's life was endangered or in instances of reported rape or incest. The Court held that Title XIX does not obligate participating states to cover medically necessary abortions ineligible for federal funds, and that the Hyde Amendment does not violate the Due Process Clause's liberty or equal protection guarantees or the Religion Clauses of the First Amendment. The core reasoning was that Medicaid is a voluntary program in which Congress may rationally choose to subsidize childbirth but not certain abortions without infringing constitutional rights, as the funding limits do not prohibit or unduly burden the underlying choice to obtain an abortion.

abortionhealthcarefederal power

The case involved an Oklahoma defendant convicted of distributing heroin who, due to prior felony convictions, received a mandatory 40-year sentence under a habitual offender statute later ruled unconstitutional by the state court. The Oklahoma Court of Criminal Appeals upheld the sentence anyway, finding no prejudice since it fell within the allowable range. The U.S. Supreme Court vacated the judgment, holding that the state had denied the petitioner due process by depriving him of his statutory right to have a jury exercise discretion in fixing his punishment, creating a substantial possibility of a shorter term. The Court reasoned that this liberty interest, grounded in state law, cannot be arbitrarily overridden by reliance on an invalid mandatory provision, and the appellate court did not itself resentence the defendant to cure the error.

criminal lawprocedure

The case concerned whether the SEC must prove scienter, or intent to deceive, as an element in a civil enforcement action seeking injunctions for violations of Section 17(a) of the Securities Act of 1933, Section 10(b) of the Securities Exchange Act of 1934, and Rule 10b-5. The petitioner, a brokerage firm supervisor, was found by the district court to have aided violations by failing to stop subordinates from making false statements about a company's stock despite knowing the statements were misleading. The Supreme Court held that scienter is required to establish violations of Section 10(b), Rule 10b-5, and Section 17(a)(1), but not for Sections 17(a)(2) and 17(a)(3). The core reasoning rested on the statutory text, which uses words like 'manipulative,' 'deceptive,' or 'fraud' implying scienter for some provisions but not others, along with legislative history and distinctions between enforcement actions and private suits.

business & regulatory

The case concerned whether federal courts of appeals have jurisdiction under section 307(b)(1) of the Clean Air Act to directly review an EPA Administrator's determination that certain waste-heat boilers at a PPG facility were subject to new source performance standards under section 111 of the Act. PPG and Conoco challenged the decision after EPA concluded that construction of the boilers began after the standards' proposal date, making them subject to emission limits, while PPG argued the integrated facility predated the standards. The Fifth Circuit had held it lacked jurisdiction, finding the Administrator's action did not qualify as reviewable "any other final action" under the statute. The Supreme Court examined the statutory text providing for appellate review of locally or regionally applicable final EPA actions not covered by specific enumerated provisions and considered whether the determination fell within that broad category. It also addressed related issues of finality, the adequacy of the administrative record, and the preclusive effect of direct review on later enforcement proceedings.

environmentprocedurebusiness & regulatory