LSI - Quimbee Case Briefs Flashcards
Blanchard v. Bergeron
“REASONABLE ATTORNEY’S FEES” #legislativehistory #legislative intent
Blanchard v. Bergeron
United States Supreme Court
489 U.S. 87 (1989)
Rule of Law
Courts may rely on congressional committee reports to determine legislative intent.
Facts
Arthur Blanchard (plaintiff) sued James Bergeron and the St. Martin Parish Sheriff’s Department (defendants) under 42 U.S.C. § 1983, alleging that Blanchard had been beaten by Bergeron, a sheriff’s deputy. The jury awarded Blanchard $5,000 in compensatory damages and $5,000 in punitive damages. Blanchard then sought to recover attorney’s fees under 42 U.S.C. § 1988. The trial court awarded $7,500 to Blanchard for attorney’s fees. Bergeron appealed to the United States Court of Appeals for the Fifth Circuit, which held that the attorney’s fees were capped by the contingency-fee agreement between Blanchard and his attorney. The agreement had provided for a contingency fee of 40 percent. The Fifth Circuit accordingly modified the award to 40 percent of $10,000, or $4,000. Blanchard petitioned the United States Supreme Court for review.
Issue
May courts rely on congressional committee reports to determine legislative intent?
Holding and Reasoning (White, J.)
Yes. Courts may rely on congressional committee reports to determine legislative intent. Section 1988 allows for an award of reasonable attorney’s fees, but does not provide a definition of a reasonable fee. The legislative history of the statute refers to 12 factors for assessing a reasonable attorney’s fee under Johnson v. Georgia Highway Express, Inc., 488 F.2d 714 (5th Cir. 1974). The relevant Senate report cites to three district-court decisions that correctly apply these factors. In Johnson, the court stated that attorney’s fees should not be awarded in an amount greater than the amount agreed to by the litigant and his or her attorney. However, the three district cases cited by the Senate report do not follow this aspect of Johnson and clarify that a fee agreement is a single factor that is not determinative. Attorney’s fees should be set at a reasonable amount, which may be above or below what the litigant agreed to with his or her attorney. Generally, the reasonable amount is determined through a lodestar calculation, which is (1) the number of hours reasonably expended on the litigation, multiplied by (2) a reasonable hourly rate. If attorney’s fees in civil-rights actions could be capped based on contingency-fee agreements, then plaintiffs and lawyers might be inclined to place too much emphasis on pursuing damages rather than obtaining equitable relief. Civil-rights actions are an important tool for protecting the rights of the general public, not just the rights of an individual plaintiff. Allowing attorney’s fees to exceed agreed-upon contingency fees does not give attorneys a windfall, because the fee must still be reasonable. Therefore, an award of attorney’s fees may not be limited by a contractual agreement between a litigant and his or her attorney. Here, Blanchard’s attorney’s fees may not be capped by the contingency-fee arrangement with his attorney. Accordingly, the judgment of the court of appeals is reversed.
Concurrence (Scalia, J.)
Committee reports should not be used to determine congressional intent. Statutes must be construed according only to the words that have been enacted as part of the statute. Members of Congress are not likely to be reading through every snippet of every committee report. Even if members of Congress did read the Senate report in this case, it is unlikely that the members looked up each of the cases cited by the report. Committee reports are drafted by staff members on the committee and appear to increasingly be designed to influence the judicial construction of statutes. Committee reports are unreliable evidence of what voting members of Congress intended in enacting particular statutes. A statute should be construed in a way that is reasonable, consistent, and faithful to the statute’s apparent purpose.
Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc.
“SOURCE” #admindiscretion #delegation
Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc.
United States Supreme Court
467 U.S 837 (1984)
Rule of Law
If a statute administered by an agency is silent or ambiguous with respect to a specific issue, a reviewing court may not simply impose its own construction on the statute.
Facts
The 1977 Amendments to the Clean Air Act (CAA) required polluters in certain areas to obtain a permit from a state regulator before building any new or modified stationary sources of air pollution. The state regulator could only grant the permit if the polluter met specific requirements regarding the abatement of new pollution. The Environmental Protection Agency (EPA) promulgated a rule interpreting the term “stationary source” to include what the agency called a “bubble policy.” Under this policy, an existing plant containing several pollution-emitting devices could install or modify one piece of equipment without a permit if the alteration did not increase the total emissions from the plant. The Natural Resources Defense Council (NRDC) (plaintiff) challenged the EPA’s interpretation of the word “source.” Specifically, the NRDC argued that the word referred to each individual pollution-emitting piece of equipment, which meant that a plant would need to obtain a permit any time it created a new source of pollution or modified an existing source if the effect were to increase the pollution from the source. Finding that this interpretation best served the goals of the CAA, the court of appeals agreed with the NRDC. In reaching this decision, the court recognized that Congress had not expressed an intent regarding the applicability of the bubble concept to the permit program. The United States Supreme Court granted certiorari to review the appellate court’s decision.
Issue
If a statute administered by an agency is silent or ambiguous with respect to a specific issue, may a reviewing court simply impose its own construction on the statute?
Holding and Reasoning (Stevens, J.)
No. If a statute administered by an agency is silent or ambiguous with respect to a specific issue, a reviewing court may not simply impose its own construction on the statute. When a court reviews an agency’s construction of a statute, it faces two questions. First, the court must consider whether Congress directly addressed the precise question at issue. If Congress has made its intent explicit in the statutory language, then both the court and the agency must give effect to that unambiguous congressional intent. Second, however, if the court finds that the statute is silent or ambiguous regarding the specific issue, the court must consider whether the agency’s action was based on a permissible construction of the statute. An agency’s power extends to filling both implicit and explicit gaps that Congress may have left in a statute. If Congress leaves an explicit statutory gap, then this is an express delegation of authority to the agency to fill that gap by promulgating regulations. A reviewing court must give effect to those regulations unless they are arbitrary, capricious, or contrary to the statute. If the delegation of authority to the agency is not explicit but rather is implied, then the agency has the authority to fill the gap, and a reviewing court may not disturb the agency’s reasonable interpretation of the statute. This deference to the agency is based on the principle that the agency has been entrusted to administer the statute and is in the best position to balance competing interests and make the necessary policy choices based on its knowledge of the relevant subject matter. In this case, the appellate court correctly concluded that Congress did not express an intent regarding the applicability of the bubble concept to the permit program. However, it is the agency, and not the appellate court, that must determine whether using the bubble concept is appropriate within the context of the program. The reviewing court’s only role is to determine whether the agency’s decision was a reasonable one. Given the many competing interests at stake, the EPA’s use of the bubble concept was a reasonable policy choice for the agency to make, and the court must respect this decision. Accordingly, the appellate court’s judgment is reversed.
Church of the Holy Trinity v. United States
“LABOR” #absurditycanon
Church of the Holy Trinity v. United States
United States Supreme Court
143 U.S. 457 (1892)
Rule of Law
A court may look to Congress’s intent when interpreting the text of a statute.
Facts
The Alien Contract Labor Act (Act) prohibited corporations from contracting with aliens who resided outside of the United States to perform labor or service of any kind within the United States. The Church of the Holy Trinity (Holy Trinity) (defendant) was incorporated in the State of New York. Holy Trinity entered into a contract with an English citizen, E. Walpole Warren, to relocate to New York City and serve as Holy Trinity’s pastor. The United States (plaintiff) brought suit against Holy Trinity for violating the Act. The trial court found in favor of the United States. Holy Trinity appealed.
Issue
May a court look to Congress’s intent when interpreting the text of a statute?
Holding and Reasoning (Brewer, J.)
Yes. A court may look to the intent of the legislature to interpret a statute’s text. The statute’s title, the problem the legislation sought to address, the legislative history, and the generally held values at the time may aid a court in determining the legislature’s intent. In this case, the text of the Act appears to prohibit Holy Trinity’s contract with Reverend Warren. Reverend Warren is performing a labor or service by serving as Holy Trinity’s pastor. However, the title of the Act implies manual rather than professional labor. Congress enacted the Act in order to curtail the practice of importing unskilled laborers who would work for lower wages than Americans. A Senate committee report from the time of the Act’s passage shows that the committee believed labor or service would be construed as manual labor and manual service. Finally, in a religious nation, anti-religious intent cannot be imputed to lawmakers. The legislature’s intent was clearly not to prohibit churches from hiring foreign ministers. Consequently, the Act does not prohibit Holy Trinity from hiring Reverend Warren. Accordingly, the trial court’s judgment is reversed, and the case is remanded for further proceedings.
Circuit City Stores, Inc. v. Adams
“CONTRACTS OF EMPLOYMENT” #ejusdemgeneris
Circuit City Stores, Inc. v. Adams
United States Supreme Court
532 U.S. 105 (2001)
Rule of Law
If a statute contains a list of specific things followed by a general term, a court should restrict its interpretation of the general term to things of the same kind as those enumerated.
Facts
In 1995, Saint Clair Adams (plaintiff) worked as a salesman for Circuit City Stores, Inc. (Circuit City) (defendant) in California. Two years later, Adams sued Circuit City for employment discrimination in California state court. Adams’s employment contract with Circuit City contained an arbitration clause. Circuit City filed suit in district court, seeking to enjoin Adams’s state suit. Additionally, Circuit City sought to compel arbitration pursuant to the Federal Arbitration Act (FAA), 9 U.S.C. §§ 1–2. Section 2 of the FAA required the enforcement of arbitration clauses of any contract involving commerce. Section 1 of the FAA exempted the employment contracts of seamen, railroad employees, or other workers engaged in commerce. The district court found that Adams was subject to his contract’s arbitration clause, and so he could not pursue his claims in state court. The court of appeals reversed. The United States Supreme Court granted certiorari to resolve a split among the circuits.
Issue
If a statute contains a list of specific things followed by a general term, should a court restrict its interpretation of the general term to things of the same kind as those enumerated?
Holding and Reasoning (Kennedy, J.)
Yes. If a statute makes a list of specific things that concludes with a more general term, a court should restrict its interpretation of the general term to things similar to those on the list. Under the canon of construction ejusdem generis, a court should interpret a general term that follows a specific list as referring only to things of the same kind. A catch-all term at the end of a list indicates the legislature’s intent to reach additional items in the nature of those specified. Here, § 1 specifically exempts from arbitration the contracts of seamen, railroad employees, or any other class of workers engaged in commerce. Because the phrase “or any other class of workers engaged . . . in commerce” follows the specific categories of “seamen” and “railroad employees,” the phrase’s meaning is limited to the employment contracts of transportation workers. In Allied-Bruce Terminix Companies, Inc. v. Dobson, 513 U.S. 265 (1995), this court interpreted the phrase “involving commerce” in § 2 to have the broadest possible scope. Although similar to § 2, the phrases “in commerce” and “engaged . . . in commerce” of § 1 are terms of art with narrower scope. Finally, there is little relevant legislative history to further inform the interpretation of § 1. Consequently, § 1 of the FAA exempts the employment contracts of transportation workers only. Therefore, Adams must pursue his employment discrimination claim in arbitration. The judgment of the court of appeals is reversed.
Dissent (Souter, J.)
In Allied-Bruce, the Court held that the FAA’s coverage, described in § 2 with the phrase “involving commerce,” was coextensive with the reach of the Commerce Clause. The Commerce Clause had expanded significantly between the time the FAA was enacted in 1925 and the Allied-Bruce decision in 1995. Our interpretation of “involving commerce” allowed the coverage of the FAA to grow in step with the growth of the Commerce Clause. The exemption in § 1 of the employment contracts for workers “engaged . . . in commerce” is language similarly elastic to the phrase “involving commerce.” It is incoherent for the majority to limit the FAA’s § 1 exemptions to their meaning from 1925 but expand the FAA’s § 2 coverage to mirror the growth of the Commerce Clause. Additionally, the majority has misapplied ejusdem generis. Congress had already carefully fitted the FAA to the special circumstances of seamen and railroad workers. Section 1 lists seamen and railroad employees in order to emphasize and make certain that they will not be subjected to arbitration clauses.
Continental Can Company, Inc. v. Chicago Truck Drivers, Helpers and Warehouse Workers Union
“SUBSTANTIALLY ALL” #legislativehistory
Continental Can Company, Inc. v. Chicago Truck Drivers, Helpers and Warehouse Workers Union
United States Court of Appeals for the Seventh Circuit
916 F.2d 1154 (1990)
Rule of Law
A court may not look to legislative history inserted after a statute’s passage when interpreting the text of the statute.
Facts
Continental Can Company, Inc. (Continental Can) (plaintiff) was a contributor to a pension fund consisting of the pooled assets of multiple employers. A majority of these assets were contributed by employers in the trucking business. Federal statute 29 U.S.C. § 1383(d)(2) exempted a pension fund from withdrawal liability if substantially all the fund’s contributions were made by employers in the trucking industry. Continental Can brought suit seeking an exemption for its pension fund from withdrawal liability under § 1383(d)(2).
Issue
May a court look to legislative history inserted after a statute’s passage when interpreting the text of the statute?
Holding and Reasoning (Easterbrook, J.)
No. A court may not look to legislative history inserted after a statute’s passage when interpreting the text of the statute. Statements made after the enactment of a law, or “subsequent legislative history,” are not truly legislative history. This is because these kinds of statements offer no view of the process by which the law was passed. A law’s post-enactment commentary lacks persuasiveness, because it is not debated or voted upon, in contrast to a law’s actual text. In this case, the contemporaneous legislative history of § 1383(d)(2) shows that legislators understood the phrase “substantially all” to refer to at least 85 percent. Eighty-five percent is the special legal meaning of “substantially all” throughout the tax code. After § 1383(d)(2) had been voted into law, the statute’s author expressed his intention that substantially all meant a majority, or at least 50.1 percent. Continental Can’s pension fund received a majority of its contributions from trucking-industry employers, but not 85 percent. Consequently, Continental Can’s pension fund is not eligible for special treatment under the statute, because the fund’s contributions are not substantially all from employers in the trucking industry.
Corning Glass Works v. Brennan
“ANY OTHER REASON OTHER THAN SEX” #legislative history
Corning Glass Works v. Brennan
United States Supreme Court
417 U.S. 188 (1974)
Rule of Law
A court may look to legislative history in order to define industry terms of art when interpreting a statute.
Facts
Because Pennsylvania’s state labor laws at one time prohibited employers from employing women for night shifts, Corning Glass Works (Corning) (defendant) wound up employing exclusively men as inspectors for its night shifts at its plants. Corning employed exclusively women as inspectors for its day shifts. Subsequently, Corning implemented a higher wage for working its night shifts than it did for working its day shifts, creating a pay differential between its female day-shift inspectors and its male night-shift inspectors. The Equal Pay Act (EPA), 29 U.S.C. § 206(d)(1), mandated that men and women receive equal pay for equal work performed under similar working conditions. Brennan (plaintiff), the United States Secretary of Labor, sued Corning, seeking to enjoin Corning from violating the EPA.
Issue
May a court look to legislative history in order to define industry terms of art when interpreting a statute?
Holding and Reasoning (Marshall, J.)
Yes. When interpreting a statute, a court may look to the statute’s legislative history in order to understand terms of art used in the industry that the statute regulates. Statutory text that appears vague to the layperson may, in fact, have specific industry meanings. In this case, the EPA requires that employers pay the sexes equally for equal work performed under similar working conditions. Time of day may appear to be relevant to comparisons in working conditions. However, the EPA’s legislative history shows that industry representatives feared the government would second-guess established job-evaluation plans. To assuage these concerns, Congress amended the EPA to incorporate language specific to industry job-evaluation plans. The EPA’s legislative history shows that “working conditions” is one such term, drawn from four standard components used in industry job-evaluation plans. The legislative history further includes testimony that the evaluation metric of working conditions is comprised of a worker’s surroundings and hazards. By this definition, here, Corning’s female and male inspectors receive unequal pay for work performed under similar working conditions. Whether working a day or night shift, the inspectors’ surroundings and hazards are the same. Consequently, Corning is in violation of the EPA.
Dissent (Burger, C.J.)
The majority’s opinion emphasizes one piece of the EPA’s legislative history, but a different piece shows that one of the statute’s sponsors considered differences in shifts relevant to the analysis of working conditions. Taking shift differences under consideration could justify paying female day-shift workers less than male night-shift workers.
Exxon Mobil Corp. v. Allapattah
AMOUNT IN CONTROVERSY REQUIREMENT #legislativehistory
Exxon Mobil Corp. v. Allapattah
United States Supreme Court
545 U.S. 546 (2005)
Rule of Law
Where other elements of diversity jurisdiction are present and at least one named plaintiff satisfies the amount-in-controversy requirement, the court may exercise jurisdiction over other plaintiffs who might otherwise be properly joined but who do not allege damages which reach the jurisdictional amount.
Facts
The United States Supreme Court consolidated two cases to resolve a split in the circuits regarding amount-in-controversy in diversity cases. The first case, Exxon Mobil Corp. v. Allapattah (2005), involved a class action of 10,000 Exxon dealers who brought suit against Exxon, alleging that the company was overcharging them for fuel. Some of the dealers’ damages did not rise to the amount required for diversity jurisdiction, but the district court and the United States Court of Appeals for the Eleventh Circuit allowed joinder, holding that the unnamed members of a class action suit were not all required to meet the amount-in-controversy requirement, so long as at least one plaintiff did. The second case involved a nine-year-old girl who sued Starkist based on the unusually serious injuries she endured when she cut herself on a tuna can. She attempted to join her parents as plaintiffs as well, but the district court held that none of the parties had damages to the level of the jurisdictional amount. On appeal, the Court of Appeals for the First Circuit found that while the parents’ damages were below the jurisdictional amount and therefore could not be properly joined, the girl’s damages were sufficient. The United States Supreme Court granted certiorari to resolve the split.
Issue
When other elements of diversity jurisdiction are present and at least one named plaintiff satisfies the amount-in-controversy requirement, may the court exercise jurisdiction over other plaintiffs who might otherwise be properly joined but who do not allege damages which reach the jurisdictional amount?
Holding and Reasoning (Kennedy, J.)
Yes. Where other elements of diversity jurisdiction are present and at least one named plaintiff satisfies the amount-in-controversy requirement, the court may exercise jurisdiction over other plaintiffs who might otherwise be properly joined but who do not allege damages which reach the jurisdictional amount. It is well-settled that federal courts are courts of limited jurisdiction. Although diversity jurisdiction is available to parties from different states, to prevent flooding of the federal courts, jurisdiction is limited to cases that exceed a fixed amount of money. Federal courts may also exercise supplemental jurisdiction over issues related to a case or controversy over which the court already properly has jurisdiction. Here, this court must decide, based on this settled law, whether under §1367 the court may exercise jurisdiction over other plaintiffs who might otherwise be properly joined, but who do not allege damages which reach the jurisdictional amount. This Court finds that they can. A failure for some claimants to meet the amount-in-controversy requirement does not affect the claims the way that, for example, allowing a case to stay in federal court when diversity jurisdiction were destroyed would. Furthermore, some parties must be joined as indispensable parties under Rule 19; to hold that the case-in-controversy requirement forbids this joinder would be illogical. The holding of the Court of Appeals for the Eleventh Circuit is affirmed, and the holding of the Court of Appeals for the First Circuit is reversed and the case remanded.
Dissent (Ginsburg, J.)
This Court is mistaken in reading § 1367 so broadly, and its reading ignores the fact that Congress did not intend to so expand federal jurisdiction with § 1367’s enactment. Instead, the court should read the statute as requiring plaintiffs to first meet the original jurisdiction requirement, that is, the amount-in-controversy requirement, before supplemental jurisdiction may be authorized. The reading the court propounds discards an established history of the doctrine of supplemental jurisdiction.
Food and Drug Administration v. Brown & Williamson Tobacco Corp.
“DRUGS” #Chevron? #anti-novelty
Food and Drug Administration v. Brown & Williamson Tobacco Corp.
United States Supreme Court
529 U.S. 120 (2000)
Rule of Law
The FDA does not have authority to regulate tobacco products.
Facts
In 1996, the Food and Drug Administration (FDA) issued a rule prohibiting the marketing of tobacco products to young people. The FDA claimed it had authority to regulate tobacco products because they were drugs within the meaning of the Food, Drug, and Cosmetic Act (FDCA). This position was a change from the FDA’s prior position that it did not have jurisdiction to regulate tobacco products. Tobacco companies challenged the rule on grounds that the structure and history of the FDCA did not permit the FDA to regulate tobacco products.
Issue
Does the FDA have authority to regulate tobacco products?
Holding and Reasoning (O’Connor, J.)
No. The FDA does not have authority to regulate tobacco products. This issue involves an administrative agency’s construction of a statute (the FDCA) and so the analysis is governed by Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc., 467 U.S. 837 (1984). Under Chevron, a reviewing court first examines whether Congress has directly spoken on the exact question at issue. If Congress has done so, then the court needs to give effect to the clear, expressed intent of Congress. However, if Congress has not specifically addressed the question, a reviewing court must adhere to the agency’s construction of the statute if it is permissible. Here, Congress has directly spoken on the issue and indicated that the FDA does not have authority to regulate tobacco products. Congress’s intent must be given effect. Congress did not intend for the FDA to have jurisdiction over tobacco products because Congress enacted six separate pieces of legislation since 1965 concerning tobacco products and their effect on public health. These pieces of legislation do not involve the FDA. In light of the FDA’s position during the same period that it did not have jurisdiction over tobacco products, the statutes are evidence that Congress understood that the FDA did not have jurisdiction.
Dissent (Breyer, J.)
I believe that the language of the FDCA establishes that the FDA does have the authority to regulate tobacco products. The FDCA’s general purpose is to protect public health, which indicates cigarettes should be included within its scope. I do not find that Congress’s passage of six pieces of tobacco legislation leads to the conclusion that Congress understood that the FDA did not have jurisdiction over tobacco products. The majority’s arguments against jurisdiction do not counter the strong jurisdiction-supporting arguments of the FDCA’s language and purpose.
Gregory v. Ashcroft
“EMPLOYEES” #statesovreignty #federalism
Gregory v. Ashcroft
United States Supreme Court
501 U.S. 452 (1991)
Rule of Law
A statute should not be construed in a manner that would alter the usual constitutional balance between the states and the federal government, unless Congress’s intent to do so is unmistakably clear in the language of the statute.
Facts
Judge Ellis Gregory Jr. and several other Missouri state judges (plaintiffs) sued the State of Missouri (defendant), seeking a declaration that a provision of the Missouri constitution imposing a mandatory retirement age of 70 years for state judges violated the Age Discrimination in Employment Act (ADEA), 29 U.S.C. §§ 621-34. The trial court dismissed the lawsuit, finding that judges were not included within the definition of employees under the ADEA. The state judges appealed, and the court of appeals affirmed. The state judges then petitioned the United States Supreme Court for review.
Issue
Should a statute be construed in a manner that would alter the usual constitutional balance between the states and the federal government?
Holding and Reasoning (O’Connor, J.)
No. A statute should not be construed in a manner that would alter the usual constitutional balance between the states and the federal government, unless Congress’s intent to do so is unmistakably clear in the language of the statute. The Constitution establishes a system of dual sovereignty between the states and the federal government. The states generally possess a sovereignty that is concurrent with that of the federal government, subject to the limitations imposed by the Supremacy Clause. This structure assures a decentralized government and also serves as a check on the abuses of governmental power. While Congress may enact legislation through the Supremacy Clause to override the will of the states, Congress does not exercise this power lightly where legislation involves areas traditionally regulated by the states. Therefore, a statute will not be interpreted to upset the usual constitutional balance of federal and state powers without an unmistakably clear intent in the language of the statute. Here, Missouri’s constitutional provision regarding the qualifications of Missouri state judges represents a decision of the most fundamental sort for a sovereign entity. The authority of the people of the states to determine the qualifications of the most important governmental officials lies at the heart of representative government. This authority will not be disturbed without clear congressional intent to do so. The ADEA prohibits an employer from specifying a mandatory retirement age for employees who are over 40 years old. State and local governments are included in the definition of employers. The definition of an employee excludes elected officials, appointed individuals on the staff of an elected official, and appointees on the policymaking level. Missouri state judges are appointed by the state governor and subject to retention elections. Judges make common-law decisions and exercise supervisory authority over the state bar, and appellate judges also supervise inferior courts and establish rules of procedure. Therefore, Missouri state judges are arguably appointees on the policymaking level. The statutory exclusion of appointees on the policymaking level from the definition of employees appears next to two other types of individuals who have a close working relationship with elected officials. However, the exclusion should not be interpreted to apply only to appointees who have a close working relationships with elected officials, as that interpretation leaves the exclusion without additional meaning. It is at least ambiguous whether Congress intended appointed judges to be included as employees. Therefore, the ADEA should not be interpreted in a way that intrudes upon traditional state governmental functions, and the state may set a mandatory retirement age for judges. Accordingly, the judgment of the court of appeals is affirmed.
Concurrence (White, J.)
The majority imposes a plain-statement rule upon Congress’s statute even when the statute clearly applies to the states. The plain-statement rule has not previously been expanded this far, and the application of this rule is unclear. The majority seems to indicate that the rule would apply to all state-governmental functions, not just functions that go to the heart of representative government. Additionally, this expanded rule is unnecessary to decide the present case. A simple interpretation of the statute is sufficient to determine that state judges are not included as employees. State judges are appointees that are on the policymaking level.
Gustafson v. Alloyd Company, Incorporated
“PROSPECTUS” #nosciturasociis?
Gustafson v. Alloyd Company, Incorporated
United States Supreme Court
513 U.S. 561 (1995)
Rule of Law
A prospectus is a document describing an offering of securities held out to the public.
Facts
Gustafson (defendant), McLean and Butler were the sole shareholders of Alloyd Company, Inc. (plaintiff). In 1989, Gustafson sold the company to Wind Point Partners. The parties’ sales contract stated that revenue figures from the previous year would be used to value Alloyd. When Wind Point discovered that the revenue figures were incorrect, it brought suit against Gustafson under § 12(2) of the Securities Act of 1933, arguing that the sales contract was a prospectus, and that the incorrect revenue figures were a misstatement creating liability on the part of Gustafson. The district court ruled in favor of Gustafson. The court of appeals vacated the district court’s judgment and remanded the case. The United States Supreme Court then granted certiorari.
Issue
Will a document be considered a prospectus if it is an offering of securities held out to the public?
Holding and Reasoning (Kennedy, J.)
Yes. The sales contract in this matter is not a prospectus because it was not a document that was held out to the public. A prospectus is a document describing an offering of securities held out to the public. In reading the language of § 12(2) it is apparent that a prospectus is a document that is intended for wide distribution. In this case, the sales contract in question was not meant for wide distribution. The only parties involved were Gustafson and Wind Point. Since the contract was not intended to be distributed to the public, it is not a prospectus as defined by § 12(2). Thus, the judgment of the court below is reversed and remanded for judgment consistent with this opinion.
Dissent (Thomas, J.)
The term “prospectus” is defined elsewhere in the Securities Act of 1933. The act defines a prospectus as a document meant to describe an initial offering. The majority attempts to inject its personal opinions on the definition of prospectus by deviating from the definition already provided by the act.
Dissent (Ginsburg, J.)
Any alteration of the definition of prospectus provided by the Securities Act of 1933 should be left to Congress. Furthermore, the legislative history of the act supports a definition of prospectus that includes private offerings as well.
Riggs v. Palmer
ELMER’S MURDERER/HEIR #absurdity
Riggs v. Palmer
Court of Appeals of New York
115 N.Y. 506 (1889)
Rule of Law
When interpreting a statute, a court may depart from the statute’s clear text in order to avoid an absurd result.
Facts
On August 13, 1880, Francis Palmer created a will dividing his estate among his daughters, Mrs. Riggs and Mrs. Preston (plaintiffs), and his grandson, Elmer Palmer (defendant). Elmer knew the terms of the will. In 1882, Elmer murdered his grandfather by poisoning him. Elmer was convicted of murder and began serving his sentence. The plaintiffs brought suit to annul the parts of the will under which Elmer inherited, alleging that Elmer’s crime rendered his inheritance void. The trial court dismissed the plaintiffs’ suit. The plaintiffs appealed.
Issue
When interpreting a statute, may a court depart from the statute’s clear text in order to avoid an absurd result?
Holding and Reasoning (Earl, J.)
Yes. Where enforcing a statute creates absurd or unreasonable consequences, a court may interpret the statute in a way that effects the lawmakers’ intentions. Here, New York’s Statute of Wills is clear regarding who may inherit from an estate. Because Palmer is the beneficiary of a validly executed will, the law allows him to inherit his grandfather’s estate. However, a murderer may not reasonably inherit from the man he murdered. The intention of the lawmakers was to ensure that a will’s beneficiaries receive the property they were given, but the lawmakers cannot have intended to ensure the inheritance of a person who kills to secure and hasten his inheritance. This would be an absurd outcome. Consequently, the statute does not apply to this will, and Palmer does not inherit his grandfather’s estate. Judgment is entered for the plaintiffs.
Dissent (Gray, J.)
The legislature comprehensively regulates the disposition of property. State statutes iterate the circumstances in which a will may be altered or revoked after a testator’s death. By implication, a will may not be altered or revoked under any other circumstances. The facts of this case do not meet any of the statutory requirements to alter a will. Additionally, Palmer’s criminal act is not relevant to whether he should inherit his grandfather’s estate. Palmer was tried and punished for his crime, and he does not need to be further penalized.
Rice v. Santa Fe Elevator Corporation
WAREHOUSE REGULATION #preemption #federalism
Rice v. Santa Fe Elevator Corporation
United States Supreme Court
331 U.S. 218 (1947)
Rule of Law
When resolving a conflict between state and federal law, a court should assume that subjects traditionally regulated by state law are not superseded by federal statute, unless Congress has asserted its express purpose to do so.
Facts
The Rice partnership (Rice) (plaintiff) was in the grain business. Rice was a customer of the Santa Fe Elevator Corporation (Santa Fe) (defendant). Santa Fe operated public grain warehouses in Illinois. Rice brought suit against Santa Fe for certain violations of Illinois state law which were administered by the Illinois Commerce Commission (ICC). Santa Fe sought to have the case dismissed, alleging that the United States Warehouse Act (USWA) superseded the ICC’s authority.
Issue
When resolving a conflict between state and federal law, should a court assume that subjects traditionally regulated by state law are not superseded by federal statute, unless Congress has asserted its express purpose to do so?
Holding and Reasoning (Douglas, J.)
Yes. If state and federal laws conflict, a court should assume that areas traditionally regulated by state law are not superseded by federal statute, unless Congress has asserted its express purpose to do so. Courts should apply a presumption against federal preemption of state law. In this case, the USWA, as it was enacted in 1916, subordinated federal law to state law in the field of warehouse operation. When the USWA was amended in 1931, Congress gave the federal government exclusive jurisdiction over licensing the operators of grain warehouses. Because grain warehousing involves interstate commerce, under the Commerce Clause, the federal government could choose to regulate the entire field of grain storage. In determining whether Congress intended this degree of federal regulation, the presumption is that subjects historically regulated by the state are not superseded by federal statute, unless Congress indicates its express intent to do so. Here, however, Congress’s goals in enacting the USWA would be defeated by allowing nonconflicting Illinois regulations to supplement the USWA. Consequently, the USWA supersedes the regulations of the ICC. Santa Fe’s motion to dismiss is granted.
Dissent (Frankfurter, J.)
The majority erred in finding that the USWA nullified Illinois’s state regulations regarding grain storage. Illinois’s state laws regulating warehouses do not conflict with the USWA’s licensing powers. Further, only a clear expression of intent to supersede state law should convince the Court that Congress wished to sweep away extensive state regulations.
Nix v. Hedden
“TOMATOES” #ordinarymeaning #technicalmeaning
Nix v. Hedden
United States Supreme Court
149 U.S. 304 (1893)
Rule of Law
When interpreting a statute, a court should use the ordinary, rather than specialized, meaning of the statute’s words.
Facts
In 1886, Nix (plaintiff) imported tomatoes from the West Indies to New York City. Hedden (defendant), the collector of the Port of New York, collected import duties on the tomatoes in accordance with the Tariff Act of 1883 (Act). The Act imposed a duty on vegetables but exempted fruits. In 1887, Nix brought suit to recover the duties he had paid on the tomatoes, claiming that because tomatoes were fruits, the tomatoes should not have been subject to the tariff. The federal circuit court held in favor of Hedden. The United States Supreme Court accepted a writ of error.
Issue
When interpreting a statute, should a court use the ordinary, rather than specialized, meaning of the statute’s words?
Holding and Reasoning (Gray, J.)
Yes. Where a statute’s words have both ordinary and specialized meanings, a court should interpret the statute using the words’ ordinary meanings. Although words may have different meanings in different communities, a court should assume that statutes are written in the language of ordinary people. Here, the vegetables taxed under the Act would commonly be understood to include tomatoes. While a tomato is botanically a fruit, ordinary people refer to tomatoes as vegetables. Tomatoes are eaten at dinner, like other vegetables. Fruits are eaten for dessert. Fruits and vegetables do not have any special meaning in the lexicon of trade and commerce. Consequently, tomatoes are vegetables for purposes of the Act, and Hedden therefore properly charged duties on Nix’s tomatoes. Accordingly, the judgment of the circuit court is affirmed.
National Labor Relations Board v. Catholic Bishop of Chicago
“EMPLOYER” #constitutionalqavoidance
National Labor Relations Board v. Catholic Bishop of Chicago
United States Supreme Court
440 U.S. 490 (1979)
Rule of Law
A statute should not be construed in a manner that will raise serious questions under the Constitution, unless Congress has clearly expressed an affirmative intent that the statute be interpreted in that manner.
Facts
The National Labor Relations Board (NLRB) (defendant) exercised jurisdiction over lay faculty members at two groups of religious high schools owned by the Catholic Bishop of Chicago and the Diocese of Fort Wayne-South Bend, Inc. (plaintiffs). The NLRB certified certain unions as the bargaining agents for these teachers and ordered the schools to bargain with those unions. Additionally, charges of unfair labor practices were filed against the schools under the National Labor Relations Act, 29 U.S.C. §§ 151-69. At a hearing before the NLRB, the schools argued that the challenged practices were mandated by the schools’ religious creeds and that the NLRB could not exercise jurisdiction over church-operated schools. The NLRB disagreed and ordered the schools to cease the challenged practices and enter into collective-bargaining agreements with the unions. The schools challenged the NLRB’s order in the United States Court of Appeals for the Seventh Circuit. The court of appeals held in favor of the schools and declined to enforce the order. The NLRB petitioned the United States Supreme Court for review.
Issue
Should a statute be construed in a manner that will raise serious questions under the Constitution?
Holding and Reasoning (Burger, C.J.)
No. A statute should not be construed in a manner that will raise serious questions under the Constitution, unless Congress has clearly expressed an affirmative intent for the statute to be interpreted in that manner. This rule has been applied to avoid serious constitutional questions that would arise from certain constructions of statutes. See, e.g., Machinists v. Street, 367 U.S. 740 (1961). This rule is known as the doctrine of constitutional avoidance. In this case, the NLRB relies on the definition of an employer under § 152(2) of the National Labor Relations Act (the Act). This definition includes every type of employer, with eight exceptions. However, applying the Act to allow the NLRB to exercise jurisdiction over church-operated schools presents a significant risk of infringing upon the First Amendment. Teachers have a unique and critical role in fulfilling the mission of a church-operated school. The complaints of unfair labor practices will force the NLRB to inquire into the religious creeds of the schools. This inquiry may impinge upon the rights guaranteed by the Free Exercise Clause and Establishment Clause of the First Amendment. The NLRB will also be called upon to determine the terms and conditions of employment for teachers in church-operated schools. This mandatory bargaining process will impede the autonomy of the management of the schools and compromise the religious purposes being pursued by the schools. Therefore, serious First Amendment questions will arise out of the NLRB’s exercise of jurisdiction over teachers in church-operated schools. For this reason, the Act will only be interpreted to apply to teachers in church-operated schools if Congress has clearly expressed an affirmative intention to do so. Here, it is clear that Congress has given no consideration to church-operated schools. The only two relevant amendments to the Act deal with whether nonprofit hospitals should be covered by the Act. There is no clear expression of Congress’s intent to include teachers employed by church-operated schools under the jurisdiction of the NLRB. Therefore, the NLRB may not exercise jurisdiction over church-operated schools. The judgment of the court of appeals is affirmed.
Dissent (Brennan, J.)
Statutes should be construed to avoid unnecessary constitutional decisions. However, any construction of the statute here is fairly possible. The text of the statute at issue is very broad. It is not common for Congress to include explicit expressions of congressional intent in such broadly inclusive statutes. The legislative history shows that Congress rejected an amendment to the statute that would have created the exact exception that is adopted by the majority.
McBoyle v. United States
“VEHICLE” #ruleoflenity
McBoyle v. United States
United States Supreme Court
283 U.S. 25 (1931)
Rule of Law
An airplane is not a “vehicle” within the meaning of the National Motor Vehicle Theft Act.
Facts
McBoyle (defendant) was convicted of transporting an airplane from Illinois to Oklahoma that he knew was stolen. McBoyle was sentenced to three years imprisonment and ordered to pay a $2,000 fine in violation of the National Motor Vehicle Theft Act (the act). McBoyle appealed and his judgment of conviction was affirmed. The United States Supreme Court granted certiorari to determine whether an airplane is a “vehicle” under the act.
Issue
Is an airplane a “vehicle” within the meaning of the National Motor Vehicle Theft Act?
Holding and Reasoning (Holmes, J.)
No. Section 2 of the act provides that a “motor vehicle” shall include “an automobile, automobile truck, automobile wagon, motor cycle, or any other self-propelled vehicle not designed for running on rails.” In everyday language, the word “vehicle” calls up a picture of something moving on land. Although airplanes were well known in 1919 when the act was passed, they were not mentioned in the reports or in Congressional debates when the act was discussed and subsequently passed. The act enumerates a number of different forms of motor vehicles without any sort of reference to any kind of aircraft. Although it is likely McBoyle did not consider the text of the act prior to committing his acts, it is reasonable that a fair warning should be given to the world in language that any layperson would understand regarding the consequences of crossing the line of the law. When a rule of conduct is laid down in words that evokes a picture of vehicles moving on land and not in the air, the act’s application to aircraft should not be assumed if the legislature did not expressly state so. The judgment of conviction is reversed.
