Category: Supreme Court Case Briefs

Crime scene blood

Connick v. Thompson, 563 U.S. 51 (2011)

FACTS: The prosecution charged John Thompson with murder and the case proceeded to trial. A jury convicted Thompson, to which he spent 18 years in prison and 14 on death row. Before execution, Thompson’s investigator discovered the prosecution failed to disclose evidence that should have been turned over to the defense under Brady. The reviewing court determined that the evidence was exculpatory, and both of Thompson’s convictions were vacated.

PROCEDURAL HISTORY: Thompson (Respondent) sued D.A. Harry Connick (Petitioner), for damages under Rev. Stat. § 1979, 42 U.S.C. § 1983. The jury found in Respondent’s favor. The Fifth Circuit Appeals Court affirmed the jury’s decision. Petitioner filed certiorari with SCOTUS.

JUDGMENT: Reversed.

ISSUE: Whether a D.A.’s office may be held liable under § 1983 for deliberate indifference and failure to train based on a single Brady violation.

HOLDING OF THE COURT: The case did not fall within the narrow range of “single- incident” liability hypothesized in Canton as a possible exception to the pattern of violations necessary to prove deliberate indifference in § 1983 actions alleging failure to train.

RATIONALE: SCOTUS said in its review that deliberate indifference’ is a stringent standard of fault that requires proof that a municipal actor disregarded a known or obvious consequence of his action. SCOTUS understood that Louisiana courts overturned four of Petitioner’s convictions because of Brady violations. However, SCOTUS found those incidents dissimilar to the violation in the present case. Thus, they could not have put Petitioner on notice that specific training was necessary to avoid a constitutional violation. SCOTUS also found failure to train prosecutors in their Brady obligations does not fall within the narrow range of Canton’s hypothesized single- incident liability. In its opinion, § 1983 does not provide plaintiffs or courts carte blanche to micromanage local governments. In all, a mere showing that additional training would have been helpful in making difficult decisions does not establish municipal liability.

SEPARATE OPINION: (Ginsburg, Breyer, Sotomayor, & Kagan, dissenting). While the majority held the D.A. office could not be held liable in a civil rights action under 42 U.S.C. § 1983 for marginal Brady violations, the dissenters found the long-concealed prosecutorial transgressions in the case were neither isolated nor atypical. It further found the misperception and disregard of Brady’s disclosure requirements in Orleans Parish constituted deliberately indifferent conduct for which the D.A. office bears responsibility under § 1983. According to the dissenters, abundant evidence supported the jury’s finding that additional Brady training was obviously necessary to ensure that Brady violations would not occur. For instance, Petitioner misunderstood Brady. Other leaders were similarly uninformed about Brady and had not received training. Lastly, the office shirked its responsibility to keep prosecutors abreast of relevant legal developments concerning Brady requirements. All these factors point to the conclusion that prosecutors took Brady for granted, as to which undermined the integrity of Thompson’s trials.

SYNTHESIS: In Brady v. Maryland, SCOTUS reasoned that society wins not only when the guilty are convicted but when criminal trials are fair. Although it held due process requires the prosecution to turn over evidence favorable to the accused and material to his guilt or punishment, the present Court felt the lack of Brady training cannot support an inference of deliberate indifference to support a § 1983 claim. If so, any person could point to something the city ‘could have done’ to prevent the unfortunate incident, and bring a § 1983 claim.

Disabled woman

Mathews v. Eldridge, 424 U.S. 319 (1976)

FACTS: The Secretary of Health, Education, and Welfare reviewed George Eldridge’s medical reports and information. Afterwards, it informed Eldridge by letter that his disability benefits had been terminated.

PROCEDURAL HISTORY: Eldridge (Respondent) sued the Secretary of Health, Education, and Welfare (Petitioner), and challenged the constitutional validity of the administrative procedures that assesses whether there exists a continuing disability. The District Court found the administrative procedures breached Respondent’s right to procedural due process. Therefore, it issued an injunction. The Court of Appeals relied on the District Court’s opinion and affirmed.

JUDGMENT: Reversed.

ISSUE: Whether the Due Process Clause of the Fifth Amendment requires the recipient be afforded an opportunity for an evidentiary hearing prior to the termination of Social Security disability benefit payments.

HOLDING OF THE COURT: The administrative procedures fully comport with due process in the present case. Thus, an evidentiary hearing is not required prior to the termination of disability benefits.

RATIONALE: While the lower courts found due process requires an evidentiary hearing prior to termination, SCOTUS disagreed because of the private and governmental interests at stake. In its view, due process is not a technical conception with a fixed content unrelated to time, place and circumstances. SCOTUS also reasoned that due process requires (1) the private interest that will be affected by the official action, (2) the risk of an erroneous deprivation of such interest through the procedures used, and the probable value of additional or substitute procedural safeguards, (3), the Government’s interest, the function involved, and the fiscal and administrative burdens that the additional or substitute procedural requirement would entail.

SCOTUS did agree with the lower courts that procedures needed to be tailored to “the capacities and circumstances of those who are to be heard,” and that recipients of benefits must be given a meaningful opportunity to present their case, as in Goldberg v. Kelly. However, in the present case, SCOTUS recognized that the local SSA office offered the Respondent assistance in the completion of his questionnaire. The Respondent was also given an opportunity to submit additional evidence or arguments, which enabled him to challenge the accuracy of information in his file and the agency’s tentative conclusions. Based on these facts, SCOTUS reasoned the potential value of an evidentiary hearing or oral presentation before the decision-maker was inconsequential.

DISSENT: (Brennan, J., Marshall, J.) The Justices in the dissent agreed with the lower courts that Eldridge must be afforded with an evidentiary hearing of the type required for welfare beneficiaries under Title IV of the Social Security Act prior to termination of benefits. However, the dissidents felt SCOTUS did not need to consider whether a recipient suffers only a limited deprivation that stem from a discontinuance of disability benefits. It also felt the argument raised in regard to a worker who could still seek other forms of public assistance, but has been placed in the untenable position of having been denied disability benefits, was irrelevant for SCOTUS to consider. In all, the dissidents believed the legislative determination to provide disability benefits, without any prerequisite determination of need by the recipient, presumed the need at issue.

SYNTHESIS: Eldridge relied exclusively upon Goldberg v. Kelly, which established a right to an “evidentiary hearing” prior to termination of welfare benefits. SCOTUS then went back to its past decisions and found it spoke sparingly about the requisite procedures. In Sniadach v. Family Finance Corp., it was silent. In Fuentes v. Shevin, SCOTUS said a determination needed to be more than an ex parte proceeding before a court clerk. Although SCOTUS held in Bell v. Burson, that due process required only a pre-revocation hearing, it reasoned that it “need not take the form of a full adjudication of the question of liability.”

In the examination of these cases, SCOTUS pointed out that a recipient’s sole interest is the uninterrupted receipt of benefits pending final administrative decision on their claim. In the event a recipient’s benefits are terminated, and they prevail on their claim, retroactive relief is provided to them. Given this fact, SCOTUS found the Respondent’s potential injury was similar in nature to Goldberg, and Sniadach, but that an evidentiary hearing was not required prior to the termination of disability benefits.

Gas stove

Fuentes v. Shevin, 407 U.S. 67 (1972)

FACTS: Margarita Fuentes purchased a gas stove and stereophonic phonograph from the Firestone Tire and Rubber Company. Although Firestone retained title to the merchandise, Mrs. Fuentes was entitled to possession contingent she did not default on her installment payments. Firestone claimed Mrs. Fuentes had defaulted on her payment and instituted an action in a small-claims court for repossession of the property. After Mrs. Fuentes received a summons, Firestone obtained a writ of replevin, which ordered a sheriff to seize the property at once.

PROCEDURAL HISTORY: Mrs. Fuentes (Plaintiff) sued Firestone (Defendant) in a federal district court, and challenged the constitutionality of Florida’s prejudgment replevin procedures under the Due Process Clause of the Fourteenth Amendment. Plaintiff sought declaratory and injunctive relief against continued enforcement of the procedural provisions of the state statutes that authorize prejudgment replevin.

JUDGMENT: Vacated and remanded.

ISSUE: Whether Florida and Pennsylvania’s statutory procedures violate the Fourteenth Amendment’s guarantee that no State shall deprive any person of property without due process of law.

HOLDING OF THE COURT: The Florida and Pennsylvania prejudgment replevin provisions deprives Plaintiffs’ of property without due process of law, and deny the right to a prior opportunity to be heard before property are taken from their possessor.

RATIONALE: The Court relied on Goldberg v. Kelly’s rationale, in that, an opportunity for a hearing must be provided before the deprivation at issue takes effect. The Court further said procedural due process means ‘[p]arties whose rights are to be affected are entitled to be heard. In order that they may enjoy that right, they must first be notified.’ Moreover, the right to notice and be heard ‘must be granted at a meaningful time and in a meaningful manner.’

The Court was also in full agreement that only ‘extraordinary situations’ can justify the postponement of notice and opportunity to be heard. For example, an important governmental or general public interest, a special need for prompt action, or necessary circumstances where a government official initiates the seizure.

SYNTHESIS: The District Courts relied on Sniadach v. Family Finance Corp and Goldberg v. Kelly to reject the appellants’ constitutional claims. It reasoned that the property defendants seized from the plaintiffs were not absolute necessities of life. Therefore, plaintiffs did not enjoy a right to be heard. However, the U.S. Supreme Court made clear in Bell v. Burson, a driver’s license suspension case, that an important interest entitles one to a fair hearing before a deprivation occurs, and the protection of procedural due process of law.

The U.S. Supreme Court then looked to the Florida and Pennsylvania statutes, and found, both statutes gave no opportunity for a prior hearing and no prior notice to the plaintiffs. In Florida, a person will be given a hearing after the owner seizes the property. However, in Pennsylvania, the law does not require a hearing on the merits, as it relates to possession of the replevied property. The holding from Bell is similar to Fuentes’ case because a temporary, nonfinal deprivation of property, as with the driver’s license suspension in Bell, is nonetheless a ‘deprivation’ in the terms of the Fourteenth Amendment. Indeed, GoldbergSniadach, nor Bell held the most basic due process requirements is limited to the protection of only a few types of property interests.

Say No to War - Guantanamo Bay

Hamdi v. Rumsfeld, 542 U.S. 507 (2006)

FACTS: The U.S. Government detained Yaser Esam Hamdi on allegations that he participated in Taliban conflict. Government officials then transferred Hamdi from Guantanamo Bay and held him in a Virginia naval brig.

PROCEDURAL HISTORY: Hamdi (Petitioner) sued the U.S. Government (Respondent) under the Fifth and Fourteenth Amendments for violation of due process. The district court agreed with Petitioner, that the Mobbs Declaration did not support his detention. Respondent appealed the decision. The Fourth Circuit reversed. Petitioner then filed a writ of certiorari with SCOTUS.

JUDGMENT: Vacated and remanded.

ISSUE: Whether the President’s detention of citizens who qualify as enemy combatants violates the Fifth and Fourteenth Amendments right to due process.

HOLDING OF THE COURT: Detained citizens who seek to challenge the Government’s enemy combatant classification must receive notice and be given a fair opportunity to rebut the assertion before an impartial decision-maker.

RATIONALE: Independent review of enemy combatant classification are not burdensome as to eclipse a citizen’s right to challenge the Government’s position and to be heard by an impartial decision-maker.

SYNTHESIS: In Fuentes v. Shevinthe Court said individuals are entitled to notice and the opportunity to be heard when their rights are affected. Then in Mathews v. Eldridge, the Court laid out the necessary procedure to ensure that citizens are not deprived of procedural due process (private interest vs. governmental interests vs. functions). Based on these two cases, the Court found the Petitioner’s incommunicado detention violated procedural due process.

DISSENT: (Thomas, J., dissenting) The Judiciary does not have the aptitude to question the validity of an enemy combatant status. Justice Thomas was of the opinion that the majority misapplied the Eldridge framework. If it were applied ‘correctly’ the Court would have reached a different conclusion.

African American boy.

Tolan v. Cotton, 134 S. Ct. 1861 (2014)

FACTS: Robert Tolan was unarmed on his parents’ front porch approximately 15 to 20 feet away from police sergeant, Jeffrey Cotton. Cotton shot Tolan in the chest and punctured his right lung.

PROCEDURAL HISTORY: Tolan (Petitioner) sued Cotton (Respondent) for excessive force in violation of the Fourth Amendment. Cotton moved for summary judgment and the district court granted the motion. Tolan appealed but the Fifth Circuit affirmed. Tolan then filed a petition of certiorari. SCOTUS granted the petition.

JUDGMENT: Vacated and remanded.

ISSUE: Whether the lower court failed to view the evidence and facts at summary judgment in the light most favorable to Petitioner.

HOLDING OF THE COURT: Courts must follow the fundamental principle that at the summary judgment stage, reasonable inferences should be viewed in light most favorable to the non-moving party.

RATIONALE: The lower courts failed to determine whether Respondent’s actions violated established law. The lower courts also failed to properly credit evidence and draw factual inferences in Petitioner’s favor. SCOTUS made clear that to resolve the questions of qualified immunity at summary judgment, courts should engage in a two-pronged inquiry. First, courts must look at the evidence from the lens of the injured party, and ask whether an officer’s conduct violated a federal right. Second, courts should ask whether the right was “clearly established” at the time of the constitutional violation.

CONCURRENCE: (Alito, J., Scalia, J, concurring) The issue to be determined is whether the relevant evidence is viewed in light most favorable to the non-moving party. Relevant evidence should also support a judgment against summary judgment. While they disagreed, in part, with SCOTUS’ characterization of the evidence, they agreed Petitioner’s case had genuine issues of material fact and that, summary judgment should not have been granted.

Abestos on the job site.

Celotex Corp. v. Catrett, 477 U.S. 317 (1986)

FACTS: Myrtle Catrett alleged her husband’s exposure to Celotex Corporation’s asbestos products resulted in his death.

PROCEDURAL HISTORY: Catrett (Respondent) sued Celotex (Petitioner) for strict liability, negligence, and breach of warranty. The district court granted Petitioner’s summary judgment motion. Respondent appealed. The appeals court reversed the decision of the district court. Petitioner filed certiorari. SCOTUS granted the petition to resolve the conflict.

JUDGMENT: Reversed and remanded.

ISSUE: Whether the Petitioner sufficiently demonstrated the Respondent lacked evidence to establish elements of their case at trial.

HOLDING OF THE COURT: A party cannot move for summary judgment with a conclusory assertion that plaintiffs have no evidence to prove their case.

RATIONALE: The standard for granting summary judgment is similar to the directed verdict standard. Fed. R. Civ. P. 50(a). In SCOTUS’ view, lower courts must construe Rule 56 with due regard of individual asserting the claims and defenses that will eventually be tried by a jury. The rule must also be construed with due regard for the individual in opposition that those claims and defenses have no factual basis.

CONCURRENCE: (White, J., concurring) A plaintiff does not have to initiate any discovery or reveal their witnesses or evidence unless the court orders or they are required to do so by discovery rules. According to Justice White, it is the defendant who must negate a plaintiff’s basis for the suit.

DISSENT: (Brennan, J.; The Chief Justice; Blackmun, J., dissenting) The Dissenters felt the Court did not explain what the requirement is for the party who claims a non-moving party cannot prove their case, and then moves for summary judgment. Be that it may, the Dissenters felt Celotex failed to both, provide affirmative evidence and attack the Respondent’s evidence. Because Celotex failed to discharge its burden of production under Rule 56, the district court erred when it granted summary judgment.

Haddle v. Garrison, 525 U.S. 121 (1998)

FACTS: Federal agents investigated Jeanette Garrison (et al.) for Medicare fraud. Michael A. Haddle, an at-will employee of Garrison, cooperated in the investigation. Haddle was also set to testify against Garrison at a grand jury. However, Haddle claims Garrison terminated his employment to deter him from testifying at the criminal trial.

PROCEDURAL HISTORY: Haddle (Petitioner) sued Garrison (Respondents) for conspiracy to deter cooperation in a criminal trial and, conspiracy to retaliate for his attendance before a grand jury. Petitioner also asserted damages under 42 U.S.C. § 1985(2) and other state claims. The district court granted the Respondents motion to dismiss pursuant to Fed. R. Civ. P. 12(b)(6). The appeals court affirmed. SCOTUS granted certiorari.

JUDGMENT: Reversed and remanded.

ISSUE: Whether a plaintiff states a claim for damages when he alleges his employer was provoked by § 1985(2), to conspire to terminate his at-will employment.

HOLDING OF THE COURT: SCOTUS held a claim for relief is stated under §1985(2) when a third-party interferes with an employee’s at-will employment relationship.

RATIONALE: SCOTUS said nothing in § 1985(2) requires a plaintiff to suffer an injury to their “constitutionally protected property interest” before they can claim damages under § 1985(2). Petitioners allegation that Respondents interfered with his at-will employment meets the definition of intentional interference with contractual relations.

Incommunicado Detention

Ashcroft v. Iqbal, 556 U.S. 662 (2009)

FACTS: The Federal Bureau of Investigation (FBI) detained and arrested Javaid Iqbal on criminal charges. Iqbal claims Robert Mueller and John Ashcroft’s carceral policies discriminates against him on the basis of his national origin, race, and religious beliefs. Iqbal further claims jailors assaulted him and violated his right to bodily integrity.

PROCEDURAL HISTORY: Iqbal (Respondent) brought a class action suit against Ashcroft (Petitioners) for racial discrimination. The district court denied Petitioners’ motion to dismiss. Before the final judgment of the case, Petitioners brought an appeal before the Second Circuit. The appeals court affirmed the district court’s decision.

JUDGMENT: Reversed and remanded.

ISSUE: Whether Respondent’s complaint met the Twombly standard to survive a motion to dismiss.

HOLDING OF THE COURT: SCOTUS held Respondent did not plead enough facts in his complaint to state a claim against Petitioners for discrimination.

RATIONALE: Respondent failed to show Petitioners intended to discriminate against him based on a protected characteristic. Although Rule 9 reduces the pleading standard for discriminatory intent, plaintiffs cannot plead the plain elements of a cause of action. If so, this would circumvent the function of Rule 8.

SYNTHESIS: Under the flexible ‘plausibility standard,’ as stated in Twombly, a plaintiff must delineate their factual allegations for them to be plausible. However, SCOTUS found the present case to be dissimilar from Twombly, as the doctrine of respondeat superior does not apply to Bivens and § 1983 claims. Thus, a plaintiff’s complaint should delineate how a government official, individually, violated their constitutional right.

High speed internet

Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007)

FACTS: William Twombly and Lawrence Marcus (Respondents) argues Bell Atlantic Corporation (Petitioners) conspired to prevent access to Respondents’ telephone and high speed internet services markets. Respondents also argue the Petitioners violated § 1 of the Sherman Act when they impeded competition and, allotted markets and customers to each other.

PROCEDURAL HISTORY: Respondents sued Petitioners for violations of the Sherman Act. The district court dismissed Respondents’ complaint for failure to state a claim upon which relief can be granted. Respondents appealed to the Second Circuit and, it reversed the district court’s decision. Petitioners appealed to the SCOTUS and it granted certiorari.

JUDGMENT: Reversed and remanded.

ISSUE: What must a plaintiff plead in order to state a claim under § 1 of the Sherman Act?

HOLDING OF THE COURT: Plaintiffs must follow 9(b)-(c)of the Fed. R. Civ. P. and, particularize their factual allegations.

RATIONALE: While the appeals court found plaintiffs do not have to plead plus factors for an antitrust claim to persist, SCOTUS stated under Rule 8(a)(2), plaintiffs must show they are entitled to relief. According to SCOTUS’ rationale, if a plaintiff’s complaint includes blind assertions disguised as factual allegations, a plaintiff is not entitled to relief. Rule 9(b)-(c).

SYNTHESIS: While the Conley Court stated a plaintiff’s complaint need only have a short statement and give defendants fair notice, the Twombly Court disagreed. In fact, it criticized, questioned, and overturned Conley’s “no set of facts” language. In SCOTUS’ view, the plaintiff should expound on the facts, not their legal right to bring suit.

Conley v. Gibson, 355 U.S. 41 (1957)

Conley v. Gibson, 355 U.S. 41 (1957)

FACTS: Railroad companies in Texas and New Orleans (“Railroads”) terminated several of its African American employees. Although the Railroads claimed the action it took was due to retrenchment, it hired Caucasians to fill the vacant positions. The Railroads further demoted African Americans in senior positions and, rehired them in lower positions.

PROCEDURAL HISTORY: The African American employees (Petitioners) sued the Brotherhood of Railway and Steamship Clerks (Respondents) for discrimination. Respondents filed a motion to dismiss the complaint for failure to state a claim for which could be granted. The District Court granted Respondent’s motion. The Fifth Circuit affirmed the decision. SCOTUS granted certiorari.

JUDGMENT: Reversed and remanded.

ISSUE: Whether the Federal Rules requires one to detail the facts upon which they base their claim.

HOLDING OF THE COURT: The Federal Rules only require a plaintiff to give ‘a short and plain statement of the claim, which gives the defendant fair notice and grounds for those claims.

RATIONALE: The Court examined Rule 8(f), which states ‘all pleadings shall be so construed as to do substantial justice.’ In the Court’s view, not only did the Petitioners’ complaint have a short statement, but it also gave the Respondents fair notice. The Court also reasoned that pleadings are not a ‘game of skill,’ and that mistakes in pleadings cannot determine the merits of a case.

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