Consistently applies existing precedents without questioning their validity, following Full Faith and Credit rules in Wells [7] and post-conviction procedures in Jennings [8]. Wells v. Simonds Abrasive Co. ↗ Jennings v. Illinois ↗
Deference to government powerSkepticism of government power
In Avery v. Georgia, a Black defendant convicted of rape challenged his death sentence on the ground that the petit jury panel was selected through a racially discriminatory process violating the Equal Protection Clause of the Fourteenth Amendment. The Supreme Court reversed the conviction, ruling that the use of differently colored tickets to identify prospective jurors by race, resulting in a panel of sixty with no Black members despite their availability in the county, established a prima facie case of discrimination. The Court reasoned that this system created opportunities for discrimination at multiple stages of selection and that the state failed to rebut the presumption with evidence showing a nondiscriminatory process.
The case concerned the conviction and death sentence of Julius and Ethel Rosenberg for conspiring to commit espionage during wartime under the Espionage Act of 1917. After numerous appeals, motions under 28 U.S.C. § 2255, and petitions for certiorari and habeas corpus were denied by lower courts and the Supreme Court, Justice Douglas issued a stay of execution based on a claim that the Atomic Energy Act of 1946 superseded the Espionage Act and barred the death penalty. The Supreme Court, in a special term, vacated the stay, reasoning that the defendants had exhausted all available legal remedies, prior challenges had been fully considered and rejected, and the new legal argument did not present a substantial question warranting further delay of the execution.
In Pope v. Atlantic Coast Line Railroad, a railroad employee invoked the Federal Employers' Liability Act to sue his employer in an Alabama court for injuries sustained in Georgia during his employment. The employer responded by seeking an injunction in a Georgia state court to halt the Alabama proceeding on grounds that it was vexatious and burdensome. The Georgia Supreme Court upheld the availability of such an injunction under state law, but the U.S. Supreme Court reversed. The Court held that Section 6 of the FELA expressly grants the plaintiff the right to sue in any forum where the railroad does business and displaces state courts' traditional authority to enjoin such suits, and that the 1948 amendment codified at 28 U.S.C. § 1404(a) applies only to federal courts.
The case involved two respondents convicted of willfully refusing induction into the armed forces after their claims for exemption as conscientious objectors under Section 6(j) of the Selective Service Act were denied. The Court of Appeals had reversed the convictions, holding that the Department of Justice's refusal to disclose full FBI investigative reports to the registrants during the appeal process violated the statutory requirement for a hearing. The Supreme Court reversed, ruling that the Act does not entitle registrants to inspect the entire FBI reports. The core reasoning was that the statutory scheme places classification authority with local and appeal boards, while the Department's role is advisory; a fair hearing before an impartial officer, with opportunity to present evidence and receive a resume of adverse information, satisfies the statutory requirements without importing full trial-like confrontation procedures.
In Wells v. Simonds Abrasive Co., the administratrix of an Alabama resident killed by a defective grinding wheel sued the Pennsylvania manufacturer in federal court in Pennsylvania under Alabama's wrongful death statute, which allowed suits within two years. The district court and Third Circuit granted summary judgment for the defendant because Pennsylvania's analogous wrongful death statute imposed a one-year limit and its conflicts rules required applying the forum's limitation period. The Supreme Court affirmed, holding that the Full Faith and Credit Clause does not require a forum state to apply another state's statute of limitations even when the foreign statute creates a right with a built-in time limit, as states may follow the traditional rule that the forum's limitations period governs all such actions. The Court rejected arguments that the Clause compelled adopting the foreign limitation or that prior precedents required otherwise, noting Pennsylvania's rule applied uniformly without discriminating against out-of-state claims.
In Healy v. Commissioner, three cash-basis taxpayers reported salaries received from closely held corporations as income in the year of receipt, but after IRS audits disallowed portions of the corporate deductions as excessive compensation, the corporations incurred tax deficiencies for which the taxpayers were held liable as transferees. The Supreme Court held that the salaries must be included in taxable income in the year received under the claim of right doctrine, with any adjustment occurring in the later year when the transferee liability is paid rather than retroactively. The Court reasoned that the federal income tax system mandates annual accounting, and receipt under an individual claim of right without restriction creates taxable income even if a later constructive trust or liability arises, as established in precedents like North American Oil v. Burnet.