The case concerned a New York Education Law provision that limited eligibility to vote in certain school district elections to residents who owned or leased taxable property in the district, their spouses, or parents or guardians of children enrolled in the local public schools. Appellant, a 31-year-old resident without children or taxable property who was otherwise qualified to vote in state and federal elections, sued claiming the restriction violated the Equal Protection Clause of the Fourteenth Amendment. A three-judge district court upheld the law and dismissed the complaint. The Supreme Court reversed, holding that because the franchise is a fundamental right, any restriction on voter eligibility must be necessary to promote a compelling state interest and must be precisely drawn to serve only those with a direct stake in school affairs. The Court found the classification both overinclusive and underinclusive, as it excluded many affected residents while including others with only attenuated interests, and therefore failed strict scrutiny.
The case involved Adam Clayton Powell, Jr., who was duly elected to the U.S. House of Representatives from New York's 18th district but was excluded from taking his seat in the 90th Congress pursuant to a House resolution based on prior allegations of misconduct, even though he satisfied the constitutional requirements of age, citizenship, and residency under Article I, Section 2. Powell and voters from his district sued, claiming the exclusion was unconstitutional because the House could only exclude members for failing those standing qualifications. The Supreme Court held that Powell was entitled to a declaratory judgment that his exclusion was unlawful. The Court's reasoning centered on the text of the Constitution, which sets exclusive qualifications for membership in Congress, and concluded that the House's authority to judge qualifications under Article I, Section 5 does not permit adding further requirements or excluding a member-elect on other grounds such as alleged misconduct.
This case concerns whether a District Court divestiture plan in a Clayton Act § 7 antitrust proceeding complied with the Supreme Court's prior mandate ordering El Paso Natural Gas Company to divest assets of Pacific Northwest Pipeline Corporation to restore competition in the California natural gas market. The Court held that the approved plan, under which El Paso would receive convertible preferred stock in the new company and the new entity would assume substantial debt, failed to satisfy the mandate because it did not immediately create an independent competitor free of El Paso's influence. The reasoning centered on the principle that only the Supreme Court may modify its own mandate and that the decree must fully dissolve the anticompetitive effects identified in earlier decisions by ensuring prompt, effective restoration of competition without ongoing ties between the entities.
This case concerns the obligations of employers under the National Labor Relations Act when unions seek recognition based on signed authorization cards from employees rather than through a formal election. The Supreme Court held that an employer's duty to bargain can arise from a valid majority of authorization cards obtained without misrepresentation or coercion, and that bargaining orders are an appropriate remedy when employers engage in unfair labor practices that undermine union support and make fair elections unlikely. The Court reasoned that such cards are generally reliable indicators of employee preferences, and that employer actions like coercive interrogations, threats, and promises of benefits violate the Act and justify bypassing elections. It also addressed that certain employer statements can constitute unfair labor practices unprotected by the First Amendment or Section 8(c) of the Act.
In Jenkins v. Delaware, the Supreme Court considered whether the interrogation standards announced in Miranda v. Arizona apply to retrials of defendants whose original trials began before Miranda. The Court held that they do not, affirming the Delaware Supreme Court's decision to admit the defendant's pre-Miranda statement at his second trial for murder and burglary. The reasoning rested on the prospective rule set in Johnson v. New Jersey, which limited Miranda to trials commencing after its date, and treated a retrial as a continuation of the original case rather than the start of a new one. The Court further noted that this result was consistent with its other prospectivity decisions that keyed application to the timing of the underlying conduct or initial trial rather than later proceedings.
The case involved unsentenced pretrial detainees in the Cook County jail who were qualified Illinois voters but could not appear at the polls and were denied absentee ballots under state law, which extended such ballots to those absent from the county, medically incapacitated, observing religious holidays, or serving as poll watchers elsewhere. The detainees claimed the exclusion violated equal protection by treating judicially incapacitated persons differently from medically incapacitated ones and by disadvantaging those jailed in their home county versus those detained elsewhere. The Supreme Court affirmed the district court's grant of summary judgment to the election board, upholding the statute as constitutional. The Court reasoned that states have broad power to set voting conditions and that the classifications were rational rather than arbitrary, with no absolute denial of the right to vote shown on the record.
