This case involved a Nevada prison inmate who sued prison officials under 42 U.S.C. § 1983, claiming that being housed with a cellmate who smoked heavily exposed him to environmental tobacco smoke (ETS) in violation of the Eighth Amendment's ban on cruel and unusual punishment. The Supreme Court held that such exposure could form the basis of an Eighth Amendment claim if it posed an unreasonable risk of serious damage to the inmate's future health and if officials were deliberately indifferent to that risk. The Court reasoned that conditions of confinement claims require both an objective showing of a substantial risk of serious harm, which can include future health dangers supported by scientific evidence, and a subjective showing of deliberate indifference, consistent with precedents like Estelle v. Gamble and Wilson v. Seiter. It remanded for further proceedings on whether the inmate could prove these elements.
The case concerned whether the Secretary of Health and Human Services must allow Medicare-participating hospitals to obtain reimbursement above the applicable routine cost limits when they demonstrate that their excess costs were reasonable and efficiently incurred. The Supreme Court held that the Secretary is not required to provide such additional opportunities for relief beyond the exceptions and exemptions already set forth in the regulations. The Court reasoned that the statutory directive in 42 U.S.C. § 1395x(v)(1)(A)(ii) for retroactive corrective adjustments applies only when the Secretary's chosen methods of cost determination prove inadequate or excessive as a whole, not on a provider-by-provider basis whenever actual costs exceed the prospectively set limits; the regulatory scheme's existing waiver provisions adequately implement Congress's intent.
In Lamb's Chapel v. Center Moriches Union Free School District, a New York school district denied an evangelical church permission to use school facilities after hours to show a film series on family and child-rearing issues from a Christian perspective, relying on a state law and local rule that barred religious uses while permitting social, civic, recreational, and other community activities. The church sued, alleging that the denial violated its First Amendment free speech rights (among other claims). The Supreme Court held that the district's policy violated the Free Speech Clause because the facilities constituted a limited public forum and the exclusion constituted impermissible viewpoint discrimination against religious perspectives on otherwise permissible subjects like family values. The Court reasoned that once the district opened the space to a wide range of non-school groups discussing similar topics, it could not selectively exclude speech solely because it expressed a religious viewpoint.
In Minnesota v. Dickerson, police officers conducted a Terry stop and protective patdown of respondent after observing suspicious behavior near a building known for drug activity. During the frisk, an officer felt a small lump in the respondent's jacket pocket, manipulated it with his fingers, and concluded it was crack cocaine before reaching in to seize the item. The trial court upheld the seizure by analogy to the plain-view doctrine, but Minnesota appellate courts reversed, declining to recognize a plain-feel exception. The Supreme Court held that while a Terry frisk is limited to weapons detection, contraband may be seized if its identity is immediately apparent by touch without further manipulation; however, the officer's exploratory squeezing here exceeded Terry's scope and violated the Fourth Amendment. The Court therefore affirmed suppression of the cocaine evidence.
The case concerned whether Section 801 of the Department of Housing and Urban Development Reform Act of 1989, which authorized the use of comparability studies to limit rent adjustments under Section 8 housing assistance contracts, violated the Due Process Clause by impairing private developers' contractual rights to automatic annual rent increases based on published factors. The Supreme Court held that the Act did not abrogate the respondents' contract rights in a manner that violated due process. The core reasoning was that the contracts themselves included an overall limitation clause preventing material differences between assisted and unassisted rents, and the statutory amendment clarified rather than altered the existing terms by explicitly permitting such studies to enforce that limit, consistent with the original statutory framework allowing either formula-based or market-based adjustments.
The case involved a wrongful death lawsuit brought by Lizzie Easterwood against CSX Transportation after her husband was killed in a train-truck collision at a Georgia grade crossing, alleging negligence for inadequate warning devices and excessive train speed under state law. The Supreme Court affirmed the lower court's ruling that federal regulations under the Federal Railroad Safety Act preempted the excessive speed claim but did not preempt the inadequate warning devices claim. The core reasoning was that the Secretary of Transportation's speed regulations for different track classes covered the subject matter of the speed claim, triggering preemption under the Act's express clause, while the federal grade crossing improvement programs and regulations did not fully cover or preempt state-law duties regarding warning devices. The Court rejected implied conflict preemption for the warning devices claim.
federal powertorts & liabilitybusiness & regulatory
