Wednesday, December 20, 2006

Supreme Court Cases

MARBURY v. MADISON (1803)
In
Marbury v. Madison, the U.S. Supreme Court asserted its power to review acts of Congress and invalidate those that conflict with the Constitution.

During the first two administrations, President George Washington and President John Adams appointed only Federalist Party members to administration and judiciary positions. When Thomas Jefferson won the 1800 election, President Adams, a Federalist, proceeded to rapidly fill the judiciary bench with members of his own party, who would serve for life during "good behavior." In response, Jeffersonian Republicans repealed the Judiciary Act of 1800, which had created several new judgeships and circuit courts with Federalist judges, and threatened impeachment if the Supreme Court overturned the repeal statute.

Although President Adams attempted to fill the vacancies prior to the end of his term, he had not delivered a number of commissions. Thus, when Jefferson became President, he refused to honor the last-minute appointments of President John Adams. As a result, William Marbury, one of those appointees, sued James Madison, the new Secretary of State, and asked the Supreme Court to order the delivery of his commission as a justice of the peace.

The new chief justice,
John Marshall, understood that if the Supreme Court issued a writ of mandamus (i.e., an order to force Madison to deliver the commission), the Jefferson administration would ignore it, and thus significantly weaken the authority of the courts. On the other hand, if the Court denied the writ, it might well appear that the justices had acted out of fear. Either case would be a denial of the basic principle of the supremacy of the law. Instead, Marshall found a common ground where the Court could chastise the Jeffersonians for their actions while enhancing the Supreme Court's power. His decision in this case has often been hailed as a judicial tour de force.

Basically, he declared that Madison should have delivered the commission to Marbury; however, he ruled that the Court lacked the power to issue writs of mandamus. While a section of the
Judiciary Act of 1789 granted the Court the power to issue writs of mandamus, the Court ruled that this exceeded the authority allotted the Court under Article III of the Constitution and was therefore null and void. So, while the case limited the court's power in one sense, it greatly enhanced it in another by ultimately establishing the court's power to declare acts of Congress unconstitutional. Just as important, it emphasized that the Constitution is the supreme law of the land and that the Supreme Court is the arbiter and final authority of the Constitution. As a result of this court ruling, the Supreme Court became an equal partner in the government.

DRED SCOTT v. SANFORD (1857):
Dred Scott, a slave, was taken by his owner, Sanford, into northern federal territory. Scott felt that he was free because of the Missouri Compromise of 1820, which excluded slavery from specified portions of United States territories. When he came back to Missouri, Scott sued his owner for his freedom. The Supreme Court of the United States ruled that slaves were property, not citizens and, therefore, Dred Scott was not entitled to use the courts. The Court also said that Congress had no power to prohibit slavery in the territory and that the Missouri Compromise was unconstitutional.

PLESSY v. FERGUSON (1896):
Plessy purchased a first class ticket on the East Louisiana Railway. Plessy, who was racially mixed (one-eighth black and seven-eighths Caucasian), was a United States citizen and a resident of the state of Louisiana. He took a seat in the coach where only whites were permitted to sit. He was told by the conductor to leave the coach and to find another seat on the train where non-whites were permitted to sit. Plessy did not move and was ejected by force from the train. Plessy was sent to jail for violating the Louisiana Act of 1890, which required railway companies to provide “separate but equal” accommodations for white and black races. Plessy argued that this law was unconstitutional. The Supreme Court of the United States held that the Louisiana Act, which stated that “all railway companies were to provide equal but separate accommodations for white and black races” did not violate the Constitution. The law did not violate the Fourteenth Amendment, which gave all blacks citizenship, and forbade states from passing any laws which would deprive blacks of their constitutional rights. The Court believed that “separate but equal” was the most reasonable approach considering the social prejudices which prevailed at the time.

BROWN v. BOARD OF EDUCATION (1954)
On May 17, 1954, the United States Supreme Court handed down a landmark decision on segregation in public elementary schools. That case, which consolidated a number of matters on appeal from Kansas, South Carolina, Virginia and Delaware, was titled Brown v. Board of Education. Like in Sweatt and McLaurin, the Court here considered criteria beyond the physical facilities and other tangible assets of black and white schools. So, even if the black schools and white schools had substantially equal buildings, curricula, classroom materials, teacher qualifications and salaries, the separate schools still possibly did not offer equal educational opportunities. Turning to the effect of segregation on school children, the Court noted that to separate black children from others of similar age and qualifications solely because of their race generates a feeling of inferiority as to their status in the community that may affect their hearts and minds in a way unlikely ever to be undone.
In the field of public education the doctrine of "separate but equal" has no place. Separate educational facilities are inherently unequal.
This sense of inferiority affects their motivation to learn and, thus, has a tendency to retard their educational and mental development and to deprive them of some of the benefits they would receive in a racially integrated school system. The Court then held that segregation in public schools was unconstitutional and rejected any language in Plessy that ran contrary to this. So, in this century of change, people once enslaved were unshackled and set free. People once isolated were integrated into society. People once looked down upon returned to lead. And, these leaders guided not just themselves but the entire nation to a better place. A place where people have never been freer. A place where justice has never been fairer. And, a place where the promise of America has never been finer.

ROE v. WADE (1973)
Facts
A Texas woman sought to terminate her pregnancy. However, a Texas law made it a crime to procure or attempt an abortion except when the mother’s life would be in danger if she remained pregnant. Ms. Roe challenged the Texas law on the grounds that the law violated her right of personal liberty given in the Fourteenth Amendment and her right to privacy protected by the Bill of Rights.
Issue
Whether state law which bans or regulates abortion violates a woman’s right to privacy or personal choice in matters of family decisions or marriage.
Opinion
The Supreme Court of the United States decided that states could regulate abortions only in certain circumstances but otherwise women did have a right to privacy and reproductive autonomy. The Court divided a woman’s pregnancy into three time periods: 1) during the first trimester (the first three months of pregnancy), states may not interfere with a woman’s decision to have an abortion; 2) during the second trimester, states could regulate abortions, but only if such regulation was reasonably related to the mother’s health; and, 3) during the third trimester, which occurs after the fetus (unborn child) reaches viability (the stage at which it can survive outside the mother’s body), states may regulate absolutely and ban abortions altogether in order to protect the unborn child. The woman’s right to privacy was held to be a fundamental right which could only be denied if a compelling state interest existed. Once the fetus reaches a “viable” stage of development, such a compelling point is reached because the unborn child is now given constitutional protection.


Gideon v. Wainwright (1963)
Facts
Clarence Earl Gideon was arrested in 1961, and charged with breaking and entering a pool hall with intent to commit petty larceny (a felony). He did not have enough money for a lawyer and asked that one be appointed to defend him. The judge denied the request, saying that under Florida state law, counsel can be appointed only in a capital offense. Gideon was sentenced to five years in prison. He then filed a writ of certiorari (petition of appeal) to the Supreme Court of the United States, asking for a case review. The Court granted Gideon’s request and appointed Abe Fortas to represent him.
Issue
Whether the state of Florida violated Gideon’s Sixth Amendment right to counsel, made applicable to the states by the Fourteenth Amendment, by not providing him with the assistance of counsel for his criminal defense.
Opinion
The Court ruled unanimously in Gideon’s favor, and held that the Fourteenth Amendment included state as well as federal defendants. The Court said that all states must provide an attorney in all felony and capital cases for people who cannot afford one themselves. Through the Fourteenth Amendment due process clause, the Sixth Amendment guarantee of the right to counsel applies to the states. [Gideon was retried in Florida and found not guilty.]

Miranda v. Arizona (1966)
Facts
Ernesto Miranda was convicted of rape and kidnapping. His conviction was based in part on incriminating statements he made to the police while they interrogated him. At no time during the questioning did the police inform Miranda that he did not have to talk to them or that he had the right to a lawyer when being questioned by police.
Issue
Whether the state of Arizona violated the constitutional rights of Miranda under the Fifth, Sixth, and Fourteenth Amendments when they interrogated him without advising him of his constitutional right to remain silent.
Opinion
The Supreme Court of the United States, in a 5-4 decision, ruled that the police were in error. The Court held that the police must inform suspects that they have the right to remain silent, that anything they say may be used against them, and that they have the right to counsel before the police may begin to question those held in custody.
[Miranda established the “Miranda Warning” which police now use prior to interrogation of persons arrested.]

Furman v. Georgia (1972)
Facts
William Henry Furman, a 26 year old African American, attempted to burglarize a home in Georgia. When the homeowner awoke and attempted to stop him, Mr. Furman tried to escape. He tripped and dropped his gun, which went off, killing the homeowner. At the trial, Mr. Furman was found guilty of murder, despite a claim of mental incompetence. Under Georgia statute, the jury had the option of recommending the death penalty or life imprisonment. Mr. Furman was sentenced to death. His lawyer argued the Georgian death penalty law was excessively cruel and: (1) made rehabilitation impossible; (2) imprisonment was an available alternative; and (3) the death penalty was imposed almost exclusively on poor people and black persons.
Issue
Whether Mr. Furman’s death sentence was a violation of the Eighth Amendment’s Cruel and Unusual Punishment Clause and the Equal Protection and Due Process Clause of the Fourteenth Amendment.
Opinion
In a 5-4 decision the Supreme Court of the United States struck down all existing state death penalty laws. The justices reasoned these death penalty laws left almost unlimited discretion to the judges or juries in deciding the sentence. The majority of the justices agreed that almost all those convicted in capital trials were black or poor or both, which they found “capriciously selective.” The Court did not declare capital punishment a violation of the Eighth Amendment’s “Cruel and Unusual Punishment” clause. Instead, it declared the existing death penalty laws violated the due process clause of the Fourteenth Amendment.