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Supreme court cases 2002-2003 term.

Each year the United States Supreme Court is asked to review a multitude of cases covering a variety of legal topics. The 2002-2003 Supreme Court session was no different. The justices decided several cases of interest to law enforcement officers and management. The Court decided two cases involving confessions. Three Americans with disabilities cases were decided: one dealing with the definition of a major life function; one concerning reasonable accommodation; and one dealing with a direct threat to a disabled person's own health. A First Amendment speech case was decided, as well as a Title VII case involving the required proof in a mixed-motive sexual discrimination case.

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Chavez v. Martinez, 123 S. Ct. 1994 (May 27, 2003)

The U.S. Supreme Court decided that a police officer's failure to give Miranda warnings, coupled with coercive questioning of a defendant, did not violate the defendant's privilege against self-incrimination under the Fifth Amendment. The Court stated that the privilege is not violated until the government tries to use the offending statement against a defendant in a criminal case. However, the Court did not decide whether the officer's actions in this case violated the due process clause of the Fourteenth Amendment.

Martinez was questioned by Sergeant Chavez while in an emergency room, suffering from gunshot wounds inflicted by another police officer. Martinez was in severe pain and believed he was about to die when he admitted using heroin and stealing a police officer's gun. Chavez never advised Martinez of his Miranda rights. Martinez was never charged with any crime.

Martinez later filed a Title 42, Section 1983, U.S. Code lawsuit against Chavez for violating his Fifth Amendment privilege against self-incrimination and his Fourteenth Amendment substantive due process right to be free from coercive questioning. The district court and the U.S. Circuit Court of Appeals for the Ninth Circuit held that Chavez was not entitled to qualified immunity because he obtained the statements coercively. The fact that the government never tried to use the statements in a criminal trial was irrelevant to these courts. The Supreme Court reversed.

The Supreme Court held that compulsive questioning alone, unrelated to a criminal case, does not violate the Fifth Amendment self-incrimination clause. The phrase "criminal case" in the self-incrimination clause, at the very least requires initiation of legal proceedings and does not encompass the entire criminal investigatory process, including police interrogations. Statements compelled by police interrogation may not be used against a defendant in a criminal case. Martinez was never made to be a "witness" against himself because his statements never were admitted as testimony against him in a criminal case.

The Court also concluded that Chavez's failure to read Miranda warnings to Martinez did not violate Martinez's constitutional rights. The majority agreed that a simple Miranda violation was not a violation of a "core" Fifth Amendment right and, therefore, could not support a Section 1983 civil action, requiring an actual violation of a constitutional right.

The Court did not resolve the question of whether or not Chavez's questioning violated Martinez's substantive due process rights under the Fourteenth Amendment. That issue was remanded to the Ninth Circuit for additional proceedings. In an opinion dated July 30, 2003, the Ninth Circuit ruled that Chavez's coercive interrogation of Martinez violated his clearly established due process rights under the Fourteenth Amendment.

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Kaupp v. Texas, 123 S. Ct. 1843 (May 5, 2003) (per curiam)

In this case, a 17-year-old murder suspect was awakened by at least three officers at 3 a.m. One officer told the boy, "we need to go and talk," to which the boy responded, "Okay." The boy was led away in handeuffs, wearing only his underwear, taken to the scene of the crime where the victim's body had just been recovered, and then taken to the police station. All parties agree that the police, at this point, did not have probable cause to arrest the young man. At the station, the youth was given his Miranda rights. After a brief interrogation, he confessed to some involvement in the murder. He unsuccessfully challenged the use of his confession, alleging that his unlawful arrest tainted his subsequent confession. The boy was given a 55-year sentence.

On appeal, Texas courts affirmed the conviction. They reasoned that the boy's response of "Okay" indicated consent, that his failure to protest was a waiver of rights, and that his transport to the station in handcuffs was simply routine.

The Court vacated the conviction. It concluded that a 17-year-old boy being awakened late at night, taken to the police station in handcuffs in his underwear, and interrogated, is indistinguishable from a traditional arrest. Because the boy was arrested without probable cause, his subsequent confession must be suppressed absent evidence of intervening events sufficient to purge the taint of the unlawful seizure. In the Court's view, the fact that Miranda rights were given was not sufficient to purge the taint in this circumstance.

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Toyota Motor Mfg. v. Williams, 122 S. Ct. 681 (January 8, 2002)

Williams, a former Toyota employee, suffered from carpal tunnel syndrome, preventing her from performing tasks associated with certain types of manual jobs that require gripping tools and repetitive work with her hands and arms extended at or above shoulder level for extended periods of time. After several attempts to find jobs she could do, Toyota eventually fired her, citing her poor attendance record. She sued Toyota under the Americans With Disabilities Act (ADA), alleging that Toyota failed to accommodate her disability.

The trial court ruled that she was not disabled under the ADA. The U.S. Circuit Court of Appeals for the Sixth Circuit reversed, finding that Williams' impairments substantially limited her major life activity of performing manual tasks, even though it was determined that she could perform household chores and personal hygiene.

The U.S. Supreme Court reversed, holding that the circuit court did not apply the proper standard to determine whether Williams was disabled under the ADA because it analyzed only a limited class of manual tasks. In the Supreme Court's view, the Sixth Circuit failed to consider whether Williams's impairments prevented or restricted her from performing tasks that are of central importance to most people's daily lives.

The Court stated that to qualify as disabled under the ADA, a plaintiff must prove not only a physical or mental impairment, but also that the impairment limits, in a substantial way. a major life activity: walking, seeing, hearing, or, in this case, performing manual tasks. The Court noted that Equal Employment Opportunity Commision (EEOC) regulations define "substantially limited" as an inability to perform a major life activity that the average person in the general population can perform or a significant restriction on the condition, manner, or duration of the performance of the activity, as compared to the general population. Williams' inability to do repetitive work with her hands and arms extended at or above shoulder level did not substantially limit her major life activity of performing manual tasks. She still could do such common tasks as brushing her teeth, washing her face, bathing, tending her garden, and doing laundry. Consequently, Williams' impairment, while real, was not substantial enough to qualify as a disability under the ADA.

Chevron USA, Inc. v. Echazabal, 122 S. Ct. 2045 (June 6, 2002)

In this case, the Court unanimously upheld an EEOC regulation that permits an employer to refuse to hire a disabled worker if that worker's disability poses a direct threat to his own health, even though it poses no threat to the health or safety of others.

Echazabal worked for an independent contractor doing work at a Chevron plant. Twice Chevron offered Echazabal a job if he could pass the company's physical examination. Each time, the exam showed that he suffered from a liver abnormality or damage caused by hepatitis C. Doctors advised that the condition would worsen through continued exposure to toxins at the job site. Each time, Chevron withdrew its employment offer and, finally, asked the contractor employing him to reassign him to a job without exposure to the toxins or to remove him from the job site altogether. The contractor laid off Echazabal. Echazabal filed suit, alleging that Chevron violated the ADA by refusing to hire him and barring him from the job site because of a disability.

The U.S. Circuit Court of Appeals for the Ninth Circuit ruled in favor of the worker. The Ninth Circuit stated that the statutory language of the ADA permits an employer to deny employment to anyone whose disability would jeopardize others in the workplace, but forbids an employer from denying employment to individuals whose disability threatens only themselves. The U.S. Supreme Court reversed.

The Court stated that the ADA's purpose is to prevent employers from making employment decisions regarding disabled individuals based upon untested or pretextual stereotypes Employers' concern regarding lawsuits by workers harmed on the job site is real, not the result of stereotypical thinking. Consequently, refusal to hire a worker whose disability could cause that worker harm is permissible.

US Airways v. Barnett, 122 S. Ct. 1516 (April 29, 2002)

In this ADA case, an employer refused to accommodate a disabled employee by reassigning him to another job because another nondisabled employee had seniority rights to that job. The Supreme Court held that an accommodation that conflicts with a legitimate seniority system is ordinarily not reasonable. However, the employee remains free to present evidence of special circumstances that makes a seniority rule exception reasonable in the particular case.

Barnett, a US Airways employee, injured his back while working as a cargo handler. He invoked seniority rights and was transferred to a less physically demanding job in the mailroom. This position opened again to seniority-based employee bidding, and nondisabled employees senior to Barnett planned to bid for his position. US Airways refused to accommodate his disability by allowing him to remain in the mailroom, and he lost his job. He then filed suit under the ADA, claiming that US Airways discriminated against him on the basis of his disability by not accommodating him. The district court granted the company summary judgment, ruling that making an exception to the seniority rules would work a hardship on both US Airways and its employees who relied on the system. The U.S. Circuit Court of Appeals for the Ninth Circuit reversed, holding that the seniority system was merely a factor in the undue hardship analysis and that a case-by-case analysis is required to determine whether any particular assignment would constitute an undue hardship.

The Supreme Court took a middle-of-the-road position on this issue. It ruled that seniority systems normally prevail against a reasonable accommodation argument because such systems allow for consistent, uniform treatment of employees by employers. The disabled employee, however, is free to show that special circumstances warrant the requested accommodation because circumstances might alter the important expectations of a seniority system. The court of appeals judgment was vacated and the case remanded for further proceedings.

Nevada Department of Human Resources v. Hibbs, 123 S. Ct. 1972 (May 27, 2003)

A state employee sought leave to care for his ailing wife under the Family Medical Leave Act (FMLA), which entitles an eligible employee to take up to 12 weeks of unpaid leave annually to care for "serious health conditions" of an employee's spouse, child, or parent. Twelve weeks of intermittent leave was granted, but when informed that the leave was exhausted and told to report back to work, the employee failed to return and was terminated. Section 2617(a)(2) of the FMLA allows an individual to seek both equitable relief and monetary damages "against any employer (including a public agency)." that "interfered with, restrained, or denied the exercise of" FMLA rights. The employee sued the department and two of its officers, alleging a violation of the act.

The district court summarily dismissed the suit, finding that the suit was barred by the Eleventh Amendment and that the plaintiff's Fourteenth Amendment rights were not violated. The U.S. Circuit Court of Appeals for the Ninth Circuit reversed, and the U.S. Supreme Court agreed to hear the case.

The Court held that Congress acted within its power under Section 5 of the Fourteenth Amendment in abrogating states' Eleventh Amendment immunity to suits alleging violations of Title 29. Section 2612(a)(1)(c), U.S. Code of the FMLA. State employees may recover monetary damages in federal court for a state's failure to comply with the family-care provision of the FMLA.

The Court ruled that the Constitution generally does not provide for federal jurisdiction over suits against nonconsenting states. Congress, however, may abrogate Eleventh Amendment immunity in federal court if it makes its intention to do so unmistakably clear in the language of the statute and acts pursuant to a valid exercise of its power under section 5 of the Fourteenth Amendment. The Court found that in this case, Congress clearly abrogated states' immunity under the FMLA. Congress was trying to deal with past state gender discrimination in implementing the FMLA. Congress' chosen remedy, the family leave provision of the FMLA is "congruent and proportional to the targeted violation and can be understood as responsive to, or designed to prevent, unconstitutional behavior."

Virginia v. Hicks 123 S. Ct. 2191 (June 16, 2003)

In a unanimous decision, the Court reversed a ruling by the Virginia Supreme Court that a state housing agency's policy of authorizing the police to serve notice on any person lacking a "legitimate business or social purpose" for being on the premises and to arrest for trespassing any person who remains or returns after having been so notified was an unconstitutionally overbroad First Amendment violation. In this case, the defendant was convicted of trespassing on the premises of a low-income housing development owned and operated by the Richmond Redevelopment and Housing Authority (RRHA). This conviction was based on the defendant's violation of written notice barring his return to RRHA property due to prior trespass convictions.

The Court held that the state housing agency's trespass policy did not violate the First Amendment's over breadth doctrine because neither the basis for the barment sanction, a prior trespass, nor its purpose, preventing future trespasses, implicates the First Amendment. The Court explained that the regulation did not prohibit a substantial amount of protected speech in relation to its many legitimate applications. Both the notice barment rule and the legitimate business or social purpose rule apply to all persons, not just to those seeking to engage in expression. The Court explained that an over breath challenge rarely succeeds against a law that is not specifically directed at speech or conduct associated with speech. In this instance, any application of the RRHA's policy that violates the First Amendment can be remedied through as-applied litigation.

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Desert Palace v. Costa, 123 S. Ct. 2148 (June 9, 2003)

A former female warehouse worker and heavy equipment operator sued her former employer for gender discrimination and sexual harassment under Title VII. The worker, the only female on the job site, had problems with company management and coworkers, all of which were male, which led to escalating disciplinary sanctions and to her ultimate termination. The U.S. District Court for the District of Nevada dismissed the harassment claim and entered judgment on the jury verdict in favor of the employee on the discrimination claim.

A U.S. Circuit Court of Appeals for the Ninth Circuit panel agreed with the employer's argument that the worker had not provided "direct evidence" that sex was a motivating factor in the employer's decision. The en banc court reinstated the judgment. The court concluded that Title VII does not impose any special evidentiary requirement. It decided that if a worker proves by a preponderance of evidence that sex was a motivating factor in the employer's decision or action, the worker is entitled to damages, even when the employer also is motivated by lawful reasons, unless the employer can demonstrate that it would have treated the worker similarly had gender played no role.

The U.S. Supreme Court affirmed the Ninth Circuit, holding that direct evidence of discrimination is not required for a worker to obtain a mixed-motive jury instruction under Title VII. Title VII of the 1964 Civil Rights Act does not require that a plaintiff make a heightened showing through direct evidence. If Congress intended to require heightened proof requirements in mixed-motive cases, it would have included language to that effect in the act.

By MICHAEL J. BULZOMI, J.D.
COPYRIGHT 2004 Federal Bureau of Investigation
No portion of this article can be reproduced without the express written permission from the copyright holder.
Copyright 2004, Gale Group. All rights reserved. Gale Group is a Thomson Corporation Company.

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Title Annotation:Legal Digest
Author:Bulzomi, Michael J.
Publication:The FBI Law Enforcement Bulletin
Geographic Code:1USA
Date:Apr 1, 2004
Words:2755
Previous Article:Web-based resources.
Next Article:The bulletin notes.
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