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Constitution Class Court Cases

Terms in this set (83)

Protects a state from suits to which it did not consent
Origins in common law, which held that a king was immune from suits from his subjects on the ground that he had established the law, and, therefore, could be held accountable in courts he created
Quite early on, it appeared that the United States wouldn't adhere to this principle though - Chisholm v. Georgia (two citizens trying to collect a debt) because of this states adopted 11th amendment to their constitutions so that out of state citizens couldn't sue them.
Then Cohens v. Virginia happened and determined that citizens could sue their own states.
Then in Hans v. Louisiana after the civil war, the Court determined that Marshall's dicta was not binding and declared that citizens couldn't sue states without their consent.
People can sue their states in federal courts if it deals with federal laws though.
Then a trend started where the Court and Congress attempted to restrict sovereign immunity (Fitzpatrick v. Bitzer, Pennsylvania v. Union Gas Co)
Then in 1996 Court overruled Union Gas Co. case in Seminole Tribe of Florida v. Florida. Court decided Congress couldn't make laws that require states to give consent to being sued. Alden v. Maine pushed it even further. Congress cannot subject non consenting states to private suits for damages even in their own courts.
A break in this restricting trend occurred in 2003 -- Nevada Department of Human Resources v. Hibbs -- states are not immune from suits brought in federal court by their employees under the federal Family and Medical Leave Act of 1993 (necessary and proper clause to ensure equal employment of men and women)
Court differentiated Hibbs and Kimel
Central Virginia Community College v. Katz then allowed state to be sued federally.
Then in 2012 the Court denied someone the right to sue the state in Coleman v. Court of Appeals of Maryland (failed to show enough pattern evidence of violations of state constitution)
In countries with kings back in the day, it was assumed the king could do no harm so he had sovereign immunity
Not only has this way of thinking vanished but it is unacceptable for America
Hamilton and others argued that sovereign immunity was a common law defense, but the Supreme Court's 1793 decision in Chisholm v. Georgia thought differently
Sovereign Immunity: The Eleventh Amendment, banning a citizen of one state from suing another state in federal court, was prompted by states that wanted to dodge their war debts. Their reasoning leaned on "sovereign immunity," a principle that holds the "sovereign," any of the individual states in this case, above the law, shielding it from court action. Stevens says that this doctrine "should never have been adopted in a democracy." He notes an argument against it from the famous Justice Oliver Wendell Holmes: "It is revolting to have no better reason for a rule of law than that it was so laid down in the time of Henry IV. It is still more revolting if the grounds upon which it was laid down have vanished long since and the rule simply persists from blind imitation of the past." Since the arrival of Rehnquist, the Supreme Court has made a series of rulings that stretched sovereign immunity and weakened state compliance with national law. For example, in 1974 a Rehnquist opinion let Illinois skate on paying damages for past non-compliance with a federal law for aiding aged, blind and disabled persons. And in 1999 the Rehnquist Court, citing an unwritten state sovereignty rule imagined to be in the "plan of the [Constitutional] Convention," forbade Congress to authorize suing a state for violations of the Fair Labor Standards Act. To Stevens, striking down the sovereign immunity doctrine is a matter of simple justice. A state-owned hospital, school, or police force should not have a defense to federal claims that a private one does not. To right this wrong Stevens adds an amendment:
The Congress passed the Sherman Anti-Trust Act in 1890 as a response to the public concern in the growth of giant combinations controlling tranportation, industry, and commerce. The Act aimed to stop the concentration of wealth and economic power in the hands of the few. It outlawed "every contract, combination...or conspiracy, in restraint of trade" or interstate commerce, and it declared every attempt to monopolize any part of trade or commerce to be illegal. The E.C. Knight Company was such a combination controlling over 98 percent of the sugar-refining business in the United States.
Did Congress exceed its constitutional authority under the Commerce Clause when it enacted the Sherman Anti-Trust Act?
The Act was constitutional but it did not apply to manufacturing. Manufacturing was not commerce, declared Fuller for the majority; the law did not reach the admitted monopolization of manufacturing (in this case, refining sugar). Although American Sugar had monopolized manufacturing, the Court found no violation of the Sherman Act because the acquisition of the Philadelphia refineries involved intrastate commerce. The trust did not lead to control of interstate commerce and so "affects it only incidentally and indirectly."
To the Court, commerce is different from manufacturing and production because "commerce succeeds to manufacture, and is not a part of it." As a result, manufacturing affects interstate commerce only indirectly and Congress may not regulate it; rather, it is a local matter that is up to the states to regulate. Federal authority becomes activated only when the intrastate activity has a direct effect on interstate commerce. In the sugar trust case, Fuller concluded that the challenged monopoly of refining facilities had only a indirect effect on interstate commerce and thereof was not subject to federal regulation.
With the National Labor Relations Act of 1935, Congress determined that labor-management disputes were directly related to the flow of interstate commerce and, thus, could be regulated by the national government. In this case, the National Labor Relations Board charged the Jones & Laughlin Steel Co. with discriminating against employees who were union members.
Was the Act consistent with the Commerce Clause?
Yes. The Court held that the Act was narrowly constructed so as to regulate industrial activities which had the potential to restrict interstate commerce. The justices abandoned their claim that labor relations had only an indirect effect on commerce. Since the ability of employees to engage in collective bargaining (one activity protected by the Act) is "an essential condition of industrial peace," the national government was justified in penalizing corporations engaging in interstate commerce which "refuse to confer and negotiate" with their workers.

"That power is plenary and may be exerted to protect interstate commerce "no matter what the source of the dangers which threaten it.""

A couple months earlier Roberts voted the opposite way even though cases nearly identical
It affects commerce so it counts -- expansive view
Effects of manufacturing do fall under commerce
McReynolds dissents: Questioned Congress's power to control this under commerce clause, wonders where power to regulate will stops, remember all those other cases, 10th amendment stops this
Court Packing Plan failed: Cases along with public opinion leads to 10-8 decision from Judiciary Committee to strike down FDR's plan
Evidence that Roberts did not in fact switch to save the Court: Sick of hardline conservatism, just following public opinion, decided case before FDR's court packing plan went Public
People didn't vote for New Deal they voted for anything but Hooverism
FDR would have appointed a southern Democrat anyway so it would have taken a while even if he did get an appointment opportunity in his first year

While judicial resistance angered New Deal loyalists during FDR's first term, it emphasized to the larger public that the Democrat's initiative raised questions far beyond the ordinary competence of elites in Washington to resolve; and that it was up to the People to decide whether the traditional values elaborated by the conservative Justices were worth preserving
The reality was more complex - By casting their ballots for FDR, most Americans were certainly voting against Hoover and all he stood for; but what they were voting for was a lot less clear
Hoover's election marked a shift to the Progressive wing of the Republican Party that had been shunted to the sidelines by Harding and Coolidge
Hooverism -- states and local concern but Republican values kept feds out of it
Historically speaking, it was the Republicans, not the Democrats whose heroes included proponents of national power like Lincoln and (Theodore) Roosevelt -- Democrat President Grover Cleveland confronted Panic of 1893 with conservative action, more conservative than Hoover's
People like Paul Douglas (later a liberal Democrat from Illinois) urged the organization of a new party in 1932
If FDR didn't get nominated or didn't respond the way he did we could have ended up with another 1860s era of many political parties and the democrats would have failed to handle the Great Depression mirroring Grover Cleveland again
The First Wave:
FDR passed National Industrial Recovery Act (NIRA), signed into law less than four months after the inauguration
The act did not try to cure a particular abuse of the free market system -- as the Interstate Commerce Act had focused on railroad monopolies or the Pure Food and Drug Act on health risks
It proposed to abolish market capitalism and replace it with a corporatist structure under Presidential leadership
Henceforward each industry would legislate its own code of economic life--in which the interests of organized labor, no less than organized capital, would be represented
The NIRA was set to expire unless Congress renewed it
Returning to the people:
Republicans lost more seats and the only ones who remained were progressive republicans
It was Supreme Court resistance that forced him to sober second thought: Would the People really support him if he made the 1936 election into a mandate for the NIRA?
Not corporatism, but nationalism, would serve as his watchword
FDR went silent after that first press conference for the rest of his first term as the Court continued to strike down his New Deal Legislation
It was far more important for the President to come up with well defined alternative to the NIRA
He needed to win a mandate with his second "New Deal"
FDR urged congress to not adjourn over the summer -- they created: The Wagner Labor Act, Social Security Act, and Public Utility Holding Company Act
The San Antonio Metropolitan Transit Authority (SAMTA), the main provider of transportation in the San Antonio metropolitan area, claimed it was exempt from the minimum-wage and overtime requirements of the Fair Labor Standards Act. SAMTA argued that it was providing a "traditional" governmental function, which exempted it from federal controls according to the doctrine of federalism established in National League of Cities v. Usery (1976). Joe G. Garcia, an employee of SAMTA, brought suit for overtime pay under Fair Labor Standards Act.
Did principles of federalism make the San Antonio Metropolitan Transit Authority immune from the Fair Labor Standards Act?
In a 5-to-4 decision, the Court held that the guiding principles of federalism established in National League of Cities v. Usery were unworkable and that SAMTA was subject to Congressional legislation under the Commerce Clause. The Court found that rules based on the subjective determination of "integral" or "traditional" governmental functions provided little or no guidance in determining the boundaries of federal and state power. The Court argued that the structure of the federal system itself, rather than any "discrete limitations" on federal authority, protected state sovereignty.

Court returned to the expansive approach to the commerce clause power that characterized Perez case. Court would generally trust Congress to make appropriate use of its commerce power as log as it is not interfering with an individual right or liberty, such as the first amendment -- but not the 10th. Made it clear that the Court would not hold Congress to a higher standard just because the law was aimed at states rather than the private sector. States should look to the political process, not the Court (or 10th amendment) to protect their interests as long as Congress is constitutional exercising its power.
Alfonzo Lopez, a 12th grade high school student, carried a concealed weapon into his San Antonio, Texas high school. He was charged under Texas law with firearm possession on school premises. The next day, the state charges were dismissed after federal agents charged Lopez with violating a federal criminal statute, the Gun-Free School Zones Act of 1990. The act forbids "any individual knowingly to possess a firearm at a place that [he] a school zone." Lopez was found guilty following a bench trial and sentenced to six months' imprisonment and two years' supervised release.
Is the 1990 Gun-Free School Zones Act, forbidding individuals from knowingly carrying a gun in a school zone, unconstitutional because it exceeds the power of Congress to legislate under the Commerce Clause?
Yes. The possession of a gun in a local school zone is not an economic activity that might, through repetition elsewhere, have a substantial effect on interstate commerce. The law is a criminal statute that has nothing to do with "commerce" or any sort of economic activity.

For first time since New Deal battles, Court invalidated a federal statute as falling outside the authority granted to Congress by the commerce clause. Warning to Congress that it must justify its legislation by showing the relationship between the activities regulated and interstate commerce. Had Congress explicitly demonstrated that it was responding to the negative impact school violence has on the economy, they asserted, it is likely that the Court would have found no fault with the law. More of a detour and not a full scale retreat from the commerce clause power. Some viewed t as a sweeping blow, a signal that the Court was restricting commerce power.
Brief Fact Summary. The Respondent, Morrison (Respondent), was sued under part of the Violence Against Women Act of 1994 (Act), which penalized crimes of violence motivated by gender. Now Respondent argues this section of the Act is beyond the scope of Congress' power to regulate commerce.
Does Congress have the authority to enact the Violence Against Women Act of 1994 under either the Commerce Clause or Fourteenth Amendment?
No. In a 5-4 opinion delivered by Chief Justice William H. Rehnquist, the Court held that Congress lacked the authority to enact a statute under the Commerce Clause or the Fourteenth Amendment since the statute did not regulate an activity that substantially affected interstate commerce nor did it redress harm caused by the state. Chief Justice Rehnquist wrote for the Court that [i]f the allegations here are true, no civilized system of justice could fail to provide [Brzonkala] a remedy for the conduct of...Morrison. But under our federal system that remedy must be provided by the Commonwealth of Virginia, and not by the United States." Dissenting, Justice Stephen G. Breyer argued that the majority opinion "illustrates the difficulty of finding a workable judicial Commerce Clause touchstone." Additionally, Justice David H. Souter, dissenting, noted that VAWA contained a "mountain of data assembled by Congress...showing the effects of violence against women on interstate commerce."
By the same 5-4 vote as occurred in Lopez and using the same reasoning, the Supreme Court struck down the Violence Against Women Act
4 months later in Jones v. United States, Court said a man who threw molotov cocktail into his cousin's house was a private matter and couldn't be regulated
The opinions in Lopez, Morrison, and Jones, taken together with other Rehnquist Court federalism and taxation decisions, provide some indication of the Court's modified commerce clause jurisprudence

Court ends up following Lopez and determines that gender related crimes aren't economic -- if we decided this it would lead to everything being related to the economy
In contrast to Lopez there were congressional findings about the impacts of gender related violence --- wrong type of connection found
Aggregate non-economic activity can't be regulated
In 1996 California voters passed the Compassionate Use Act, legalizing marijuana for medical use. California's law conflicted with the federal Controlled Substances Act (CSA), which banned possession of marijuana. After the Drug Enforcement Administration (DEA) seized doctor-prescribed marijuana from a patient's home, a group of medical marijuana users sued the DEA and U.S. Attorney General John Ashcroft in federal district court.
The medical marijuana users argued the Controlled Substances Act - which Congress passed using its constitutional power to regulate interstate commerce - exceeded Congress' commerce clause power. The district court ruled against the group. The Ninth Circuit Court of Appeals reversed and ruled the CSA unconstitutional as it applied to intrastate (within a state) medical marijuana use. Relying on two U.S. Supreme Court decisions that narrowed Congress' commerce clause power - U.S. v. Lopez (1995) and U.S. v. Morrison (2000) - the Ninth Circuit ruled using medical marijuana did not "substantially affect" interstate commerce and therefore could not be regulated by Congress.

Does the Controlled Substances Act (21 U.S.C. 801) exceed Congress' power under the commerce clause as applied to the intrastate cultivation and possession of marijuana for medical use?

No. In a 6-3 opinion delivered by Justice John Paul Stevens, the Court held that the commerce clause gave Congress authority to prohibit the local cultivation and use of marijuana, despite state law to the contrary. Stevens argued that the Court's precedent "firmly established" Congress' commerce clause power to regulate purely local activities that are part of a "class of activities" with a substantial effect on interstate commerce. The majority argued that Congress could ban local marijuana use because it was part of such a "class of activities": the national marijuana market. Local use affected supply and demand in the national marijuana market, making the regulation of intrastate use "essential" to regulating the drug's national market. The majority distinguished the case from Lopez and Morrison. In those cases, statutes regulated non-economic activity and fell entirely outside Congress' commerce power; in this case, the Court was asked to strike down a particular application of a valid statutory scheme.

Although the deacon still allows federal agents to prosecute medical marijuana cases, Obama administration announced that it would no longer prosecute such cases if the individuals involved are compliant with state law.

Raich demonstrates that Lope, Morrison, and Jones should not be seen as a wholesale repudiation of commerce clause jurisprudence -- the production of commercially viable items, when considered in the aggregate, has a sufficiently substantial relationship with interstate commerce to trigger the use of congressional regulatory authority. But when congress under the commerce clause attempts to regulate noneconomic activity (gun possession, rape, or arson) without showing that the regulation is a necessary part of a broader regulation of interstate commerce, it may impermissibly infringe on powers reserved for the states
Expanding the Powers to Tax and Spend: FDR's threat led to change in Court. Butler gets overturned soon after in 1936.

The Steward Machine Company challenged the validity of a tax imposed by the Social Security Act. The Act established a federal payroll tax on employers; however, if employers paid taxes to a state unemployment compensation fund (created by the states subject to federal standards), they were allowed to credit those payments toward the federal tax.
Did the Act arbitrarily impose taxes in violation of the Fifth Amendment or subvert principles of federalism?
In a 5-to-4 decision, the Court held that the tax under the Social Security Act was a constitutional exercise of congressional power. The Court found that the tax was uniform throughout the states and did not coerce the states in contravention of the Tenth Amendment. The Court took note of recent unemployment statistics from the years 1929 to 1936, maintaining that "[i]t is too late today for the argument to be heard with tolerance that in a crisis so extreme the use of the moneys of the nation to relieve the unemployed and their dependents is a use for any purpose narrower than the promotion of the general welfare. . .The nation responded to the call of the distressed."

The Social Security cases also firmly established that the thing and spending powers are to be broadly construed. If the Congress decides that the general welfare of the United States demands a program requiring the use of these final powers, the Supreme Court likely will find it constitutionally valid unless parts of the law violate specific provisions of the Constitution. Congress has used the spending authority to expand great the role of the federal government.
Over the six decades since Williamson v. Lee Optical the Court has continued to reject substantive due process attacks on state and local economic regulatory policies, giving wide latitude to the legislative branch in determining what is reasonable economic policy
The Court has used the due process clauses to improve the essential fairness of the judicial system

After purchasing a new vehicle from an authorized Alabama BMW dealership, Ira Gore, Jr. discovered that his new vehicle had been repainted. He sued BMW's American distributor (BMW), alleging that it committed fraud by failing to inform him that his car had been repainted. The Alabama Circuit Court entered judgment, following a jury verdict, awarding Gore $4,000 in compensatory damages and $4 million in punitive damages. On appeal from the trial judge's denial of BMW's post-trial petition to set aside the punitive damages as 'grossly excessive,' the Alabama Supreme Court ruled that the punitive damages were not so excessive as to violate BMW's Fourteenth Amendment right to due process. Due to a jury calculation error, however, the Alabama Supreme Court reduced Gore's punitive damage award to $2 million. BMW appealed to the Supreme Court.
Assuming that Gore's punitive damage award was grossly excessive, does the Fourteenth Amendment's due process clause protect BMW from paying the award?
Yes. In a 5-to-4 decision, the Court held that while a state may impose punitive damages to further its interest in deterring unlawful conduct, the Fourteenth Amendment's due process clause prohibits states from imposing grossly excessive punishments on tort-feasors. In the present case, the punitive damage's excessive nature is indicated by the 500 to 1 ratio between the jury's punitive and actual damage awards, the relatively insignificant amount of damage, and the lack of statutory fines that remotely parallel the present award's magnitude. BMW's due process rights were also violated because it could not have possibly anticipated, nor did it receive fair notice, that it might face such a severe punishment.
In BMW v. Gore the justices directly applied concepts of substantive due process to jury awards and concluded that grossly excessive awards violate the essential fairness guarantees of the 14th amendment
New London, a city in Connecticut, used its eminent domain authority to seize private property to sell to private developers. The city said developing the land would create jobs and increase tax revenues. Susette Kelo and others whose property was seized sued New London in state court. The property owners argued the city violated the Fifth Amendment's takings clause, which guaranteed the government will not take private property for public use without just compensation. Specifically, the property owners argued taking private property to sell to private developers was not public use. The Connecticut Supreme Court ruled for New London.
Does a city violate the Fifth Amendment's takings clause if the city takes private property and sells it for private development, with the hopes the development will help the city's bad economy?
No. In a 5-4 opinion delivered by Justice John Paul Stevens, the majority held that the city's taking of private property to sell for private development qualified as a "public use" within the meaning of the takings clause. The city was not taking the land simply to benefit a certain group of private individuals, but was following an economic development plan. Such justifications for land takings, the majority argued, should be given deference. The takings here qualified as "public use" despite the fact that the land was not going to be used by the public. The Fifth Amendment did not require "literal" public use, the majority said, but the "broader and more natural interpretation of public use as 'public purpose.'"

Implicates judicial restraint -- hey, let the states decide -- if they think it will help economy let them make that choice it's not our choice -- citizens should vote differently if they don't like it