Today in Supreme Court History: March 20

Calder v. Jones, 465 U.S. 783 (decided March 20, 1984): California court had jurisdiction to hear suit by well-known California plaintiff (actress Shirley Jones -- she was great in “Elmer Gantry”) for alleged libel in Florida newspaper with national circulation (National Enquirer) concerning her life in California (article stated that her husband, Marty Ingels -- “I’m Dickens, He’s Fenster” -- had driven her to drink -- case settled with a printed apology)

Cyan, Inc. v. Beaver County Employees Retirement Fund, 583 U.S. 416 (decided March 20, 2018): Construing Securities Litigation Uniform Standards Act of 1998, intended to tighten up how class action 1933 Securities Act violation plaintiffs can proceed in federal court, the Court holds that it doesn’t prevent plaintiffs from suing in state court. What? (Yes, you can run amok with federal law class actions, so long as you bring them in state court!)

Mayo Collaborative Services v. Prometheus Laboratories, 566 U.S. 66 (decided March 20, 2012): device that recorded metabolism levels and issued warnings as to “too low” or “too high” was not patentable; metabolism levels are just “phenomena of nature”

Coleman v. Court of Appeals of Maryland, 566 U.S. 30 (decided March 20, 2012): What if your claim is against the court itself? Here, an employee of the Court of Appeals of Maryland (that state’s highest court) went to federal court, claiming that his bosses violated the Family Medical Leave Act of 1993 by not giving him paid time off for a serious medical condition. But . . . the Court holds suit barred by the Eleventh Amendment, and Congress via the Fourteenth Amendment has not provided exception. Splintered opinion. Guy’s out of luck, I suppose -- he can’t very well sue in state court.

Wisconsin v. City of New York, 517 U.S. 1 (decided March 20, 1996): Secretary of Commerce had discretion to not use statistical method of correcting 1990 Census undercounts (this was a Republican administration, not surprisingly)

International Primate Protection League v. Administrators of Tulane Educational Fund, 500 U.S. 72 (decided March 20, 1991): 28 U.S.C. §1442(a)(1) gives the right to remove to federal court to “[a]ny officer of the United States or any agency thereof, or person acting under him, [in a suit challenging] any act under color of such office. . . .” The Court here holds that this statute gives the right to remove to federal officers but not to federal agencies. (Statute was then reworded to give agencies themselves the right to remove.) (At issue was a state suit brought by animal rights groups against National Institute of Health for euthanizing monkeys.)

Salve Regina College v. Russell, 499 U.S. 225 (decided March 20, 1991): Rhode Island federal judges are not entitled to special deference as to their interpretation of R.I. law. The First Circuit, like any other circuit, has to review de novo. (Plaintiff, booted from nursing program for being overweight, won a jury verdict with the trial judge guessing that the R.I. Supreme Court would hold that she had “substantially performed” so as to support breach of contract claim.)

Chauffers, Teamsters and Helpers, Local No. 391 v. Terry, 494 U.S. 558 (decided March 20, 1990): This is the boring case upon which I based my even more boring law review article (which the editors wisely decided not to print). Plaintiff sued union for breach of duty of fair representation. Entitled to trial by jury under the Seventh Amendment because action was “at common law” (as opposed to in equity). It got my interest because Brennan and Marshall were on opposite sides. Legal vs. equitable factors were “in equipoise”, but plaintiff had to show breach of the collective bargaining agreement to proceed, which is breach of contract, which is at law, therefore, jury trial. Zzzzzzz . . .

Hayes v. Florida, 470 U.S. 811 (decided March 20, 1985): fingerprints obtained at police station after defendant was threatened with arrest if he didn’t go were products of illegal search and therefore inadmissible

Winston v. Lee, 470 U.S. 753 (decided March 20, 1985): surgery to extract bullet fired by victim was unreasonable search under Fourth Amendment; surgery was hazardous and bullet was not critical evidence (victim was shopkeeper who was allegedly shot by defendant and, being himself armed, shot back)