Byron Raymond White

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.

criminal lawcivil rights

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.

healthcarefederal powerbusiness & regulatory

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.

free speechreligious liberty

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.

criminal lawprocedure

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.

propertyfederal powerbusiness & regulatory

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

In Pioneer Investment Services Co. v. Brunswick Associates Ltd. Partnership, the Supreme Court addressed whether a bankruptcy court could allow late filing of proofs of claim under Rule 9006(b)(1) when the delay resulted from an attorney's inadvertent failure to meet the bar date due to excusable neglect. The case arose after respondents' counsel missed the August 3, 1989, deadline for filing claims in a Chapter 11 bankruptcy because of disruptions in his practice, despite notice of the deadline. The Court held that "excusable neglect" encompasses situations involving negligence or carelessness by the attorney, not just circumstances beyond reasonable control, and affirmed the allowance of the late filings after weighing relevant equitable factors such as lack of prejudice and good faith. The decision interpreted the rule's language flexibly based on its plain meaning and precedent.

procedurebusiness & regulatory

In Bufferd v. Commissioner, a shareholder in a Subchapter S corporation claimed pass-through deductions and credits on his 1979 individual tax return that originated from the corporation's 1978-1979 return, which was filed earlier. The IRS assessed a deficiency against the shareholder more than three years after the corporate return but within three years of the individual return. The Supreme Court held that the three-year statute of limitations under 26 U.S.C. § 6501(a) for assessing tax runs from the date the shareholder's own return is filed, not the S corporation's return. The Court reasoned that the limitations period is triggered by the filing of the return of the taxpayer against whom the deficiency is assessed, as only that return allows the IRS to determine the individual's tax liability, and the corporate return lacks complete information for that purpose.

taxesbusiness & regulatory

The case concerned claims by former regional distributors of sorbothane products against manufacturers and another distributor for alleged violations of Section 2 of the Sherman Act, including monopolization, attempted monopolization, and conspiracy to monopolize, after the distributors lost their rights to sell the product. A jury found the defendants liable, and the Ninth Circuit affirmed the attempted monopolization verdict under its rule that did not require evidence of market power or specific intent. The Supreme Court reversed, holding that attempted monopolization requires proof of a dangerous probability of achieving monopoly power in a relevant market plus specific intent to monopolize, and that the Ninth Circuit's standard was inconsistent with this requirement and with decisions in other circuits.

business & regulatory

The case concerned whether a Texas jury could adequately consider mitigating evidence of a capital defendant's youth, family background, and positive character traits when deciding the death penalty under the state's special issues framework, in light of the Eighth and Fourteenth Amendments. Petitioner Gary Graham, convicted of capital murder, challenged his sentence on collateral review after the jury answered the special issues affirmatively and imposed death. The Supreme Court held that the claim was barred by Teague v. Lane because granting relief would require announcing a new rule of constitutional law not compelled by precedent such as Franklin v. Lynaugh. The Court affirmed the denial of habeas relief, distinguishing Penry v. Lynaugh as involving different mitigating factors not fully encompassed by the special issues.

criminal lawprocedure

The case concerned whether a federal district court's denial of Eleventh Amendment immunity to a Puerto Rico government instrumentality could be immediately appealed before final judgment under the collateral order doctrine. The Supreme Court held that such an order is appealable, reversing the First Circuit's dismissal for lack of jurisdiction. The Court reasoned that Eleventh Amendment immunity, like qualified immunity for officials, protects against the burdens of suit itself and would be irretrievably lost if review were postponed until after trial. It applied the Cohen v. Beneficial Industrial Loan Corp. factors, noting the immunity claim is separable from the merits, important, and effectively unreviewable later. The opinion expressed no view on whether the petitioner actually qualified for immunity.

federal powerprocedure

The case involved Edward Soldal and his family, whose trailer home was forcibly removed from a rented lot by the park owner and its employees, with assistance from Cook County sheriff's deputies, despite the absence of any court-ordered eviction. The Soldals sued under 42 U.S.C. § 1983, claiming that the deputies' involvement made the removal an unreasonable seizure violating their Fourth and Fourteenth Amendment rights. The district court granted summary judgment for lack of state action, and the Seventh Circuit, while finding state action, held that the incident was not a Fourth Amendment seizure because it did not invade privacy interests or occur during law enforcement activity. The Supreme Court reversed, ruling that a seizure of property under the Fourth Amendment occurs with any meaningful interference with possessory interests, that this protection applies in civil as well as criminal contexts, and that the trailer removal therefore implicated the Soldals' constitutional rights.

civil rightscriminal lawpropertyprocedure

The case addressed whether Mississippi had fulfilled its constitutional obligation to dismantle its former de jure segregated public university system under the Equal Protection Clause. The Supreme Court ruled that the lower courts had used an incorrect standard by requiring proof of discriminatory intent for all challenged policies; instead, states must also eliminate policies traceable to the prior segregated regime that continue to produce discriminatory effects, unless those policies are educationally justified and no less segregative alternatives are available. The Court applied this standard to Mississippi's admissions requirements, program duplication, and institutional missions, finding that several practices perpetuated racial separation and required further review on remand. It reaffirmed that the affirmative duty to desegregate applies in higher education as in elementary and secondary schools.

civil rights

The case involved Taco Cabana suing Two Pesos for infringing its restaurant trade dress under Section 43(a) of the Lanham Act by copying a festive Mexican motif with bright colors, murals, and patio features. A jury found the trade dress inherently distinctive and nonfunctional but without secondary meaning in the market, yet still ruled it protected and created a likelihood of confusion. The Supreme Court affirmed, holding that inherently distinctive trade dress qualifies for protection under the Lanham Act without needing to prove secondary meaning. The core reasoning was that the Act protects unregistered marks and trade dress that identify the source of goods or services to prevent unfair competition, applying the same standards used for registered trademarks.

business & regulatory

The case involved a mother, a Missouri citizen, suing her ex-husband and his companion, Louisiana citizens, in federal district court under diversity jurisdiction for monetary damages based on alleged sexual and physical abuse of her children. The district court dismissed the complaint, relying on the domestic relations exception to diversity jurisdiction and Younger abstention principles, and the court of appeals affirmed. The Supreme Court held that a narrow domestic relations exception exists, rooted in historical precedent like Barber v. Barber, but does not bar federal courts from hearing tort actions for damages that do not involve core issues like divorce, alimony, or child custody decrees. The Court also ruled that Younger abstention did not apply absent any pending state proceeding, reversing the dismissal and remanding the case.

family lawproceduretorts & liability

Morgan v. Illinois concerned whether a trial court in a capital murder case must permit questioning of potential jurors during voir dire about whether they would automatically impose the death penalty if the defendant is convicted. The Supreme Court held that the Due Process Clause requires such inquiry to ensure an impartial jury, reversing the Illinois Supreme Court's decision upholding the conviction. The core reasoning is that jurors who would always vote for death regardless of mitigating factors are biased, akin to those who would never impose death being excluded under Witherspoon v. Illinois, and the jury must be capable of considering both aggravating and mitigating evidence in the sentencing phase.

criminal lawcivil rightsprocedure

The case concerned a challenge by a Hawaii voter to the state's election laws, which made no provision for write-in voting and effectively banned it, claiming this violated rights under the First and Fourteenth Amendments by limiting the ability to vote for candidates not on the ballot. The Supreme Court affirmed the Ninth Circuit's ruling that the ban was constitutional. The Court reasoned that while voting is fundamental, it is not absolute, and not every burden on voting rights triggers strict scrutiny; instead, the severity of the burden must be weighed against the state's interests in regulating elections. Hawaii's overall election scheme provided easy access to the ballot through other means, and the write-in prohibition was justified by the state's regulatory authority without impermissibly restricting expression or association.

electionsfree speech

The case concerned an Alabama law that imposed an additional $72-per-ton fee on hazardous waste generated outside the state and disposed of at a commercial facility in Alabama, while exempting in-state waste from the fee. Chemical Waste Management challenged the fee after the Alabama Supreme Court upheld it. The U.S. Supreme Court reversed, holding that the fee violated the Commerce Clause. The Court reasoned that the fee was facially discriminatory against interstate commerce and that the state had not shown it was the least discriminatory means to serve its asserted health and safety purposes, given the availability of nondiscriminatory alternatives.

environmentfederal powerbusiness & regulatory

In Foucha v. Louisiana, the case concerned a Louisiana law allowing a person found not guilty by reason of insanity to be committed to a mental institution and held indefinitely based solely on a finding of dangerousness, even after any mental illness had resolved. The Supreme Court held that this scheme violated the Due Process Clause because, unlike civil commitment proceedings, it permitted continued confinement of a sane individual without requiring proof of mental illness. The core reasoning was that due process demands both mental illness and dangerousness for involuntary commitment to a psychiatric facility, and the state's burden-shifting approach after an insanity acquittal impermissibly allowed detention based on dangerousness alone once sanity was restored.

criminal lawcivil rights

The case concerned a Cuban immigrant convicted after a nolo contendere plea to manslaughter in Oregon state court who later sought federal habeas corpus relief, alleging his plea was invalid because an interpreter had failed to accurately convey the mens rea element. State courts rejected the claim after a hearing, but the Ninth Circuit held that an evidentiary hearing was required in federal court under the deliberate-bypass standard of Townsend v. Sain unless the petitioner himself had deliberately bypassed state procedures. The Supreme Court reversed, overruling that aspect of Townsend and holding that the cause-and-prejudice standard governs whether a federal court must hold a hearing when material facts were not developed in state postconviction proceedings. The Court reasoned that comity and concerns for orderly administration of justice require the stricter cause-and-prejudice test, consistent with recent procedural-default cases, rather than the more lenient deliberate-bypass rule.

criminal lawprocedurefederal power