Highlights of the Supreme Court's 2000-2001 Term
During the past term the Supreme Court ruled on:
Alcohol, Tobacco, and Controlled Substances
- Medical Marijuana - U.S. v. Oakland
Cannabis Buyers' Cooperative (May 14, 2001)
California passed a law allowing seriously ill people the ability to
obtain and use marijuana for medical purposes. The Oakland Cannabis Buyers'
Cooperative (Cooperative) is an organization established to help distribute
marijuana to qualified people. The Court ruled that the Cooperative violated
the Controlled
Substances Act's prohibition on distributing a Schedule I controlled
substance, marijuana, because there is no medical necessity exception
for Schedule I controlled substances. Further
references.
- State Tobacco Ad Regulations - Lorillard Tobacco
v. Reilly (June 28, 2001)
The Court invalidated Massachusetts's regulations of outdoor and point-of-sale
advertising for cigarettes as being pre-empted by the FCLAA and invalidated
the outdoor advertising and school zone advertising regulations of smokeless
tobacco and cigars as unconstitutional. Further
references.
Criminal Procedure
- Highway Checkpoints for Drugs - City of Indianapolis
v. Edmond (November 28, 2000)
The Court found highway checkpoint programs with the primary purpose
of detecting evidence of ordinary criminal wrongdoing to be violative
of the Fourth
Amendment. Without some measure of individualized suspicion, only
a limited line of exceptions exists to the Fourth Amendment's prohibition
of suspicionless seizures, such as a sobriety checkpoint with the primary
purpose of removing drunk drivers from the roadways (Michigan
Dept. of State Police v. Sitz) and checkpoints with the primary purpose
of intercepting illegal aliens (US
v. Martinez). Checkpoints with the primary purpose of detecting the
presence of illegal drugs, which is ordinary criminal wrongdoing, do
not fit the limited exception. Further
references.
- Warrantless Seizure - Illinois v.
McArthur (February 20, 2001)
A woman notified the police that her husband had marijuana in his home.
Upon his exiting the home and standing on the front porch, police kept
him from reentering unaccompanied until a search warrant could be obtained.
The Court upheld the warrantless seizure because the police had probable
cause to believe the home contained evidence of a crime and had a reasonable
belief that the evidence would be destroyed if Respondent entered the
home unaccompanied. Furthermore, the police reconciled the demands of
personal privacy with their law enforcement needs and imposed a minimal
intrusion on Respondent's personal privacy. Further
references.
- Warrantless Arrest for a Misdemeanor - Atwater v.
Lago Vista (April 24, 2001)
Petitioner, upon failing to secure her children and herself with a safety
belt in violation of Texas law, was arrested, without a warrant, by an
officer who witnessed the violation. The warrantless arrest for such
a violation is expressly authorized by Texas statute. The Court upheld
the arrest, even though the officer could have fined the woman instead,
because the Fourth
Amendment does not forbid a warrantless arrest based upon probable
cause even when the offense is minor. Further
references.
- Heat Sensing Police Surveillance - Kyllo v. US (June
11, 2001)
The Fourth
Amendment is violated when "the Government uses a device [without
a warrant] that is not in general use, to explore details of a private
home that would previously have been unknowable without physical intrusion." Specifically,
the Court disallowed the warrantless use of a thermal imaging device
to determine whether a home was radiating abnormal heat, because such
a use is a search under the Fourth Amendment. Further
references.
Civil Rights
- Disparate-Impact Regulations - Alexander v.
Sandoval (April 24, 2001)
The Court determined that the disparate-impact regulations, promulgated
by the Department of Justice under Title VI of the Civil Rights Act of
1964 § 602 to effectuate § 601's prohibition on discrimination by recipients
of federal funds, cannot be enforced by private citizens. Only Congress
can create private rights of action under federal law. Section 602 does
not contain such a granting clause. Furthermore, the granting clause
present in § 601 does not apply to § 602 because the regulations developed
under §602 forbid a greater amount of conduct than Congress prohibited
under § 601. Further
references.
Copyright
- Electronic Publications - New York Times
Co. v. Tasini (June 25, 2001)
The Court determined that § 201(c) of the Copyright Act does not allow
print publishers to release freelance writers' articles that appeared
within the print publishers' publications, without the authors' permission,
to electronic databases for publishing. The Court ruled that because
the articles are distributed standing alone, without the context of the
original publication, they are not "revisions" within the context
of § 201(c), and their publication in an electronic database must be
approved by the copyright holder, the author. Further
references.
Disability Law
- Private Right of Action Against States Under the ADA - Bd. of Trustees
v. Garrett (February 21, 2001)
By a vote of 5 to 4, the Court overruled Congress's explicit abrogation
of States' immunity from suit under Title I of the ADA.
Congress's abrogation power stems solely from § 5 of the Fourteenth
Amendment; otherwise the Eleventh
Amendment bars states from suits brought by individuals. The Court
could not find enough evidence in the legislative record to support the
ADA as proper § 5 legislation. Furthermore, there was no evidence of
a pattern of irrational state discrimination in the employment of the
disabled. Therefore, Congress did not have the power to abrogate States'
sovereign immunity, and state employees cannot recover damages from the
State for failure to comply with the ADA. Further
references.
- ADA Requires Golf Carts for Disabled Persons in the PGA - PGA Tour, Inc.
v. Martin (May 29, 2001)
A large majority of the Court determined that the Americans with Disabilities
Act (ADA) requires the PGA to allow disabled persons the use of golf
carts during qualification rounds for the PGA Tour. The Court reasoned
that the golf courses utilized by the Tour were public, thus subject
to the ADA requirements, and the use of carts by disabled persons, who
are otherwise qualified, does not "fundamentally alter" the nature of
the sport. Further references.
Equal Protection
- Presidential Election - Bush v. Gore (December
12, 2000)
By one vote, the Court ended the presidential election of 2000 by overturning
the Florida Supreme Court and ending the manual recounts of thousands
of "undervotes" in the state. The Court determined that the mechanisms
implemented to conduct the recount did not satisfy equal protection and
that the Florida courts did not have the time to implement alternative
means which would recount the votes in compliance with equal protection. LII
Backgrounder on Election 2000.
- Citizenship of Children Born Abroad to Unwed Parents - Nguyen v. INS (June
11, 2001)
Consistent with the equal protection guarantee of the Fifth
Amendment, the Court validated a citizenship law that treats children
born out of wedlock to non-citizen mothers abroad differently from children
born out of wedlock to non-citizen fathers abroad. The disparate treatment
based on sex is valid because of the differences in proving legitimate
familial ties between a child and either parent. Further
references.
First Amendment Rights (Speech, Press, Assembly, Religion)
- Religious Groups Using Schools - Good News Club
v. Milford Central School (June 11, 2001)
The Court decided that public elementary schools, like public high schools
and colleges, may not deny a religious group after-school access to school
facilities if the group's activities otherwise fall within the guidelines
defining the school's limited public forum. Further
references.
- Political Party Election Funding - FEC v. Colorado
Republican Fed. Campaign Comm. (June 25, 2001)
The Court found that political parties' First
Amendment rights are not violated when their coordinated expenditures
are limited. Unlike truly independent expenditures, which receive First
Amendment protection, coordinated expenditures are functionally contributions,
which do not receive full First Amendment protection. Further
references.
Real Property
- Regulatory Takings - Palazzolo v.
Rhode Island (June 28, 2001)
The Court ruled that passing title to land, which is regulated at the
time of title transfer, does not bar a takings claim against the state.
The new owner may have had notice as to the regulations and their impact
on the land; however, there is no "expiration date on the Takings
Clause" of the Constitution. Further
references.