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The Oyez Project: 1996 Term Decisions
U.S. Supreme Court Decisions, presented by The Oyez Project (www.oyez.org)

• Abrams v. Johnson (No. 95-1425)
  

  Did the District Court's redistricting plan violate the 1965 Voting Rights Act or Article I of the Constitution, guaranteeing "one person, one vote"?

  No, in a five-to-four decision. First, the Court held that in re-drafting the plans, the District Court had no obligation to preserve all three of the old plan's black-majority districts, if this would result in racial gerrymandering. Second, the Court supported the District Court's decision not to preserve two black-majority districts as it held that the area's black population was not sufficiently compact to sustain such a plan. Third, the Court ruled that the plan's creation of only one black-majority district would not violate the 1965 Voting Rights Act by causing a retrogression in the political position of Abrams and his fellow plaintiffs. The Court, in addition to noting Abrams' failure to meet his retrogression claim's population density requirement, found that in the last election, held under the challenged plan, all three black incumbents won re-election, two of whom while running against white candidates from white-majority districts. Finally, the Court concluded that the District Court's redistricting plan did not violate the Constitution's guarantee of "one person, one vote." In addition to finding that the plan's overall and average population deviations were acceptable, the Court held that even if these deviations were slightly "off" they must be tolerated given their six year tenure in an area which has seen significant population shifts. Accordingly, any minor errors would be best corrected by the next census rather than by judicial intervention.

• Adams v. Robertson (No. 95-1873)
  

  Does the Supreme Court of Alabama's approval of the certification and settlement of a class action lawsuit, whose class members were not afforded the right to opt out of the class or the settlement, violate the Due Process Clause of the Fourteenth Amendment?

  In a per curiam opinion, the Court dismissed the writ of certiorari as improvidently granted. The Court noted that the Alabama Supreme Court did not expressly address the question on which certiorari was granted and that the petitioners had failed to establish that they had properly presented the issue to that court. Therefore, the Court concluded that it could not reach the question presented without unbalancing our dual system of government to "disturb the finality of state judgments on a federal ground that the state court did not have occasion to consider."

• Agostini v. Felton (No. 96-552)
  

  Is the Establishment Clause violated when public school teachers instruct in parochial schools?

  No. The Court overruled its decision in Aguilar v. Felton. The Court held that there was no evidence to support its former presumption that the entrance of public school teachers into parochial schools will inevitably lead to the indoctrination of state-sponsored religion. The New York program under which public school teachers were sent into parochial schools did not provide parochial schools with any incentive, financial or other, to establish religion in order to attract public school teachers. The Court added that under its new view, only those policies which generate an excessive conflict between church and state will be deemed to violate the Establishment Clause. As such, one should no longer find that all entanglements between church and state have a distinctly positive or negative impact on religion.

• Amchem Products, Inc. v. Windsor (No. 96-270)
  

  May settlement play a role, under FRCP 23, in determining the propriety of class certification?

  Yes, but a limited one. While the court of appeals had erred by stating that settlement was not relevant to class certification determinations, the lower court had, in fact, closely examined the terms of the settlement, and remand was therefore not merited. A court considering a class for settlement need not consider whether certification would present intractable management problems at the trial stage, but the remaining requirements of FRCP 23 must be met. Here those requirements were not fulfilled. First, despite the over-arching issue of asbestos-related health problems, common issues did not predominate given the very different injuries suffered by the plaintiffs, and the fact that some class members had not yet manifested physical disease. FRCP 23(b)(3). Second, the named parties would not adequately represent the class because those currently injured had interests distinct from those who had been exposed to asbestos but had not yet exhibited any physical symptoms. FRCP 23(a)(4). In resolving the case the Court declined to reach the issue of whether the settlement proceeding was a justiciable case or controversy under Article III because, it held, determination of class certification was logically antecedent to these issues.

• Arizonans for Official English v. Arizona (No. 95-974)
  

  Was a challenge to a state's efforts to make English its official language a justiciable controversy after the state employee who mounted the challenge left her government job?

  No. In a unanimous decision, announced by Justice Ruth Bader Ginsburg, the Court held that the dispute was moot due to the previous resignation of Yniguez. The Court did not rule on the constitutionality of the article.

• Arkansas v. Farm Credit Services (No. 95-1918)
  

  Do Production Credit Associations fall within the exception in the Tax Injunction Act created by Department of Employment v. United States when they sue by themselves?

  No. In a unanimous opinion delivered by Justice Anthony M. Kennedy, the Court held that Production Credit Associations are not included within the judicial exception to the Act by virtue of their designation as instrumentalities of the United States alone. Therefore, the Court continued, PCA's may not sue in federal court for an injunction against state taxation without the United States as co-plaintiff. "The Tax Injunction Act is grounded in the need of States to administer their fiscal affairs without undue interference from federal courts," wrote Justice Kennedy, "[a]s all parties concede, respondents have a 'speedy, plain, and efficient remedy' in state court."

• Associates Commercial Corp. v. Rash (No. 96-454)
  

  Is the value of collateral, under the "cram-down" provision of the Bankruptcy Code, section 1325(a)(5)(B), determined by the "foreclosure-value" standard, or what a secured creditor could obtain through a foreclosure sale of the property?

  No. In an 8-1 opinion delivered by Justice Ruth Bader Ginsburg, the Court held that section 506(a) of the Bankruptcy Code, which governs the value of a secured claim, directs the application of the replacement-value standard when debtor, in a repayment plan under Chapter 13, has exercised the cram-down provision. Justice Ginsburg wrote that, "under [section 506(a)], the value of property retained because the debtor has exercised the [section 1325(a)(5)(B)] 'cram down' option is the cost the debtor would incur to obtain a like asset for the same 'proposed... use.'" Dissenting, Justice John Paul Stevens expressed the view that the text of 506(a) pointed to foreclosure as the proper method of valuation in the case at hand.

• Atherton v. Federal Deposit Insurance Corporation, As Receiver For City Savings, F. S. B. (No. 95-928)
  

  1) Can states apply standards of negligence that are stricter (more inclusive) than the federal standard of "gross negligence" for employees of federally-chartered banks?
  
  2) Is there a federal common law governing negligence by employees of federally-chartered banks?

  Yes and no. The unanimous Court concluded that "state law sets the standard of conduct as long as the state standard is stricter than that of the federal statute." The opinion by Justice Stephen Breyer held that the federal "gross negligence" statute was only intended to set a "floor" or minimum standard for state laws governing negligent conduct. The Court also ruled that "[t]here is no federal common law that would create a general standard of care applicable to this case."

• Auer v. Robbins (No. 95-897)
  

  Must sergeants and lieutenants in the St. Louis Police Department be paid for working overtime pursuant to the Fair Labor Standards Act of 1938?

  No. In a unanimous decision, authored by Justice Antonin Scalia, the Court ruled that sergeants and lieutenants are exempt as salaried employees from the federal Fair Labor Standards Act. The justices rejected the argument that the possibility of suspension without pay moves the officers out of the exempt category.

• Babbitt v. Youpee (No. 95-1595)
  

  Does amended Section 207 of the Indian Land Consolidation Act violate the Fifth Amendment's Just Compensation Clause?

  Yes. In an 8-1 decision, authored by Justi