Posted on

Loving v. Virginia, 388 U.S. 1 (1967)

Facts: Loving, a white man, and Jeter, a black woman were marriage in the District of Columbia. Shortly after their marriage, the Lovings returned to Virginia and established their home. Subsequently, a grand jury indicted the Lovings with violating Virginia’s ban on interracial marriage. The Lovings plead guilty to the charge and were sentenced to one year in jail; however, the trial judge suspended the sentence on the condition that the Lovings leave Virginia and not return together for 25 years. Virginia was one of 16 states at that time which prohibited and punished interracial marriages. Virginia argued that the statute did not constitute an invidious discrimination based upon race because it punished whites and blacks equally.

Issue: Whether a Virginia statute which prevents marriage between persons on the basis of racial classification violates the Equal Protection Clause and Due Process Clause of the Fourteenth Amendment.

Procedural History: The Supreme Court of Appeals of Virginia upheld the constitutionality of the antimiscegenation statute and affirmed the convicted.

Holding: The Lovings’ convictions were reversed.

Reasoning: The state is correct that marriage is a social relation subject to the State’s police power, however, powers are limited by the commands of the Fourteenth Amendment. Racial classifications are subjected to the “most rigid scrutiny” and there is no legitimate overriding purpose independent of invidious racial discrimination. Marriage is one of the “basic civil rights of man,” fundamental to our very existence and survival.

Posted on

In re Winship, 397 U.S. 358 (1970)

Case Name: In Re Winship
Citation: 397 U.S. 358 (1970)

Facts: A juvenile court found by a preponderance of the evidence that the defendant committed larceny.

Issue: Whether the preponderance of the evidence standard applied in the juvenile court was constitutionally permissible in a criminal case.

State’s argument: The defendant’s crime was “petty” and his punishment was only that he was to be confined for one and a half years at a “training school.” The requirement of a reasonable doubt standard in lower crimes would burden district attorneys who already have an overly burdensome caseload.

Defendant’s argument: The requirement that a criminal charge be established by proof beyond a reasonable doubt dates back to our early years as a Nation. The Due Process Clause implicitly requires this standard and lowers the risk of innocent individuals being convicted of crimes they did not commit.

Holding: The Due Process Clause requires proof beyond a reasonable doubt in this case.

Reasoning: The reasonable doubt standard is “a prime instrument for reducing the risk of convictions resting on factual error.” The standard is indispensable to the respect and confidence of the community in how criminal law is applied because every individual has confidence that his government will not “adjudge him guilty of a criminal offense without convincing a proper factfinder of his guilt with utmost certainty.”

Posted on

Duncan v. Louisiana, 391 U.S. 145 (1968)

Facts: Duncan was convicted of simple battery (a misdemeanor) and was sentenced to serve 60 days in the parish prison and pay a fine of $150. Duncan sought a jury trial but was denied because the Louisiana Constitution grants jury trials only in cases in which capital punishment or imprisonment at hard labor may be imposed.

Defendant’s Argument: A trial by jury is “fundamental to the American scheme of justice” and protects against arbitrary rule, which is one of the major themes in our country’s settlement.

State’s Argument: If a right to a jury trial is granted in every criminal case, the state’s resources will be exhausted. Also, it is not wise to allow “laymen” to determine the facts because they are untrained. Furthermore, if the court holds that the 14th Amendment assures a right to a jury trial, it will “cast doubt on the integrity of every trial conducted without a jury.”

Judgment: Reversed and remanded.

Court’s Reasoning: The right to a jury trial in a criminal case is fundamental and present in the 6th Amendment. The 14th Amendment should incorporate this right because it is so “fundamental to the American scheme of justice.”

Dissent: The right to a jury trial varies from state to state. The state should be allowed to govern its own citizens and if its own citizens want the right to a jury in all criminal cases, they can seek it through the political process.

Posted on

Allgeyer v. Louisiana, 165 U.S. 578 (1897)

Case Name: Allgeyer v. Louisiana
Citation: 165 U.S. 578 (1897)

 

Issue: Whether a Louisiana law which required foreign corporations to have a place of business within the state in order to do business within the state violated the due process clause of the 14th amendment.

 

Key Facts: Louisiana had a law prohibiting a foreign corporation from doing business in the state unless it has at least one known place of business within the state and has an authorized agent in the state (“upon whom process may be served”). The defendant sent a letter through the mail notifying a current client. The insurance contract with the client was made in New York, the premiums were to be paid in New York, and, if necessary, the insurance adjustment was to be made in New York. The letter did not create a new contract but notified the insured that their current contract with the insurance company would cover their property located in Louisiana.

 

Procedural History: The supreme court of Louisiana ruled that writing the letter within the state was a violation of its law.

 

Holding: The statute violates the 14th amendment as it deprives the defendants of their liberty without due process of law. A citizen of Louisiana has the right to enter into a contract in New York with an insurance company in New York.

 

Reasoning: Any act by the state legislature to prevent a contract such as this (or the mailing  of a notification within the state of Louisiana) is an improper and illegal interference with the conduct of the citizen. Although the citizen resides in the state, his right to contract outside the state is beyond the jurisdiction of the state.
Liberty means not only the right of the citizen to be free in the enjoyment of all his faculties; to be free to use them in all lawful ways; to live and work where he will; to earn his livelihood by any lawful calling; to pursue any livelihood or vocation; and for that purpose to enter into all contracts which may be proper, necessary, and essential to his carrying out to a successful conclusion the purposes above mentioned.
Posted on

Lochner v. New York, 198 U.S. 45 (1905)

Case Name: Lochner v. New York
Citation: 198 U.S. 45 (1905)

 

Issue: Whether the New York law which limited bakery worker hours violated the 14th amendment.

 

Facts: Lochner was convicted of a misdemeanor for violating a New York law that limited the hours he could work in a bakery. The law limited bakery workers to 60 hours per week or 10 hours per day.

 

Holding: The law interferes with the right of contact between an employer and employees.

 

Reasoning: The state has police powers: safety, health, morals, and general welfare of the public and this statute does not fall within any of those. The right to purchase or sell labor is part of the “liberty” protected by the 14th amendment. Justice Peckham goes on with a list of horribles argument stating that if we allow this law then states will be able to do whatever they want because they can always say their law relates to their police power.

 

Justice Holmes dissent: State laws may regulate life in many ways which me might find “injudicious” or “tyrannical” and interfere with the liberty to contract. But so do school laws, the post office, and taxes.

 

Justice Harlan’s dissent: Legislation should never be “disregarded or held invalid unless it be, beyond question, plainly and palpably in excess of legislative power.” This statute was enacted to protect bakery employees and does not apply to all kinds of businesses. It was designed to protect the health of these workman because breathing the air is not healthy. The court should sustain the statute because it has not be shown that it was plainly and palpably inconsistent with the Federal Constitution.
Posted on

Muller v. Oregon, 208 U.S. 412 (1908)

Case Name: Muller v. Oregon
Citation: 208 U.S. 412 (1908)

 

Issue: Whether an Oregon act that limited the amount of hours a woman could work interfered with the right to contract under the 14th amendment.

 

Facts: Oregon had an act that limited the hours a woman could work in a mechanical establishment, factory, or laundry. The defendant was convicted of violating this act in a laundry. Attorney Louis Brandeis wrote a 113 page brief (known as the Brandeis brief ) that detailed how long hours are dangerous for women because of “(a) the physical organization of women, (b) her maternal functions, (c) the rearing and education of the children, and (d) the maintenance of the home.”

 

Holding: The act is not in conflict with the Federal Constitution.

 

Reasoning: Although the general right to contract is protected by the 14th amendment, “liberty is not absolute and extending to all contracts” and a state may restrict an individual’s power of contract. Here, the court took into account woman’s physical structure and the performance of maternal functions. Legislation protecting women, who are in a class by themselves, may be sustained even when like legislation for men may not be sustained.
Posted on

Nevvia v. New York, 291 U.S. 502 (1934)

Case Name: Nevvia v. New York
Citation: 291 U.S. 502 (1934)

 

Issue:Whether the creation of the New York Milk Control Board, which had the power to set minimum and maximum prices for milk, violated a retailer’s right to due process under the 14th amendment.

 

Facts: New York created a Milk Control Board which had the power to “fix minimum and maximum retail prices” for a quart of milk. The purpose of the Milk Control Board was to protect farmers who were receiving less for their milk than the cost of production.
Nebbia, the owner of a grocery store sold two quarts and a 5 cent loaf of bread for 18 cents and was convicted of violating the Milk Board’s order. Nebbia contends that the enforcement of the law denied him due process under the 14th Amendment.

 

Holding: Upheld price regulations for milk. As far as due process is concerned, “and in the absence of other constitutional restriction a state is free to adopt whatever economic policy may reasonably be deemed to promote public welfare, and to enforce that policy by legislation adapted to its purpose.”

 

Reasoning: Milk is an essential item of our diet and is also need of safeguards because it cannot be stored long and is an excellent medium for the growth of bacteria. The cost of production increases because of the safeguards needed in the production of milk. If producers do not receive a reasonable return, it is very likely they will not take the proper safeguards.

 

Posted on

West Coast Hotel Co. v. Parrish, 300 U.S. 379 (1937)

Case Name: West Coast Hotel Co. v. Parrish
Citation: 300 U.S. 379 (1937)

 

Issue: Whether the Washington minimum wage law violates the Due Process Clause of the 14th Amendment.

 

Facts: Minimum wage law created by the state of Washington. Elsie Parrish was a chambermaid and sued to recover the difference between her wages and the state minimum wage ($14.50 per week of 48 hours). The hotel alleged that the minimum wage regulation is a deprivation of freedom of contract.

 

Holding: The minimum wage law was upheld and found to be within the state’s legislative power.

 

Reasoning: The Court believed that this subject should receive “fresh consideration” from previous decisions. The Constitution does not speak of “freedom of contract” but it does speak of “liberty and prohibits the deprivation of liberty without due process of law.”
The state is able to protect the public interest and “what can be closer to the public interest than the health of women and their protection from unscrupulous and overreaching employers?” The requirement of a minimum wage is an admissible means to the end of protecting women. The Court also discussed the “evils” of current employment conditions of women in sweatshops and how they have unequal bargaining power so freedom of contract is really a misnomer.

 

Another policy reason: The exploitation of workers also casts a direct burden upon the community for their support. Taxpayers are called to pay additional wages to the workers in order for them to meet the bare cost of living. Shouldn’t the manufacturer pay for these costs directly because they are receiving the benefit of selling goods in the marketplace?
The Court overruled Adkins stating that it “was a departure from the true application of the principles governing the regulation by the state of the relation of employer and employed.”
Posted on

Williamson v. Lee Optical of Oklahoma, Inc., 348 U.S. 483 (1955)

Case Name: Williamson v. Lee Optical of Oklahoma, Inc.
Citation: 348 U.S. 483 (1955)

Facts: An Oklahoma law made it unlawful for any person who is not a licensed optometrist or ophthalmologist to fit lenses for someone or replace lenses unless they received a written prescription from an Oklahoma licensed optometrist or ophthalmologist. The goal of this law was to forbid opticians from fitting or duplicating lenses without a prescription.

 

Procedural Posture: The District Court held the Oklahoma law unconstitutional under the Due Process Clause of the 14th Amendment. The District Court did concede that the state has police power to regulate the examination of the eyes but did not agree that a state could require a prescription just “to take old lenses and place them in new frames and then fit the completed spectacles to the face of the eyeglass wearer.” It held that this requirement was not “reasonably and rationally related to the health and welfare of the people.”

 

Holding: The law was upheld. “The day is gone when this Court uses the Due Process Clause of the 14th Amendment to strike down state laws.”

 

Reasoning: This law may be a needless requirement; however, it is for the legislature, not the courts, to balance the advantages and disadvantages of these requirements. “The law need not be in every respect logically consistent with its aims to be constitutional. It is enough that there is an evil at hand for correction,” and [that the legislation was a] rational way to correct it.”
Quoting Chief Justice Waite in Munn v. State of Illinois, “For protection against abuses by legislature the people must resort to the polls, not to the courts.”
Posted on

BMW of North America, Inc. v. Gore, 517 U.S. 559 (1996)

Case Name: BMW of North America, Inc. v. Gore

Citation: 517 U.S. 559 (1996)

Issue: Whether a $2 million punitive damages award to the purchaser of one car exceeds the constitutional limit created by the Due Process Clause of the 14th Amendment which prohibits a State from imposing a “grossly excessive” punishment on a tortfeasor.

 

Facts: Gore purchased a BMW sports sedan for forty thousand dollars from an authorized BMW dealer in Alabama. Nine months later, he found his car had been repainted by BMW and sued for suppression of a material fact and asked for $500,000 in compensatory and punitive damages.
BMW acknowledged that it had a nationwide policy that if a car was damaged in the course of manufacturing and the cost of repairing the damage exceeded 3 percent of the car’s retail price, the car would be sold as used. If the repair cost did not exceed 3 percent of the suggested retail price, it would be sold as new without advising the dealer that any repairs had been made. The cost of repainting Gore’s car was only 1.5 percent of the retail price.
Gore asserted that the repainted car was worth less than a car which had not been refinished. He showed $4,000 of actual damages. For punitive damages, Gore introduced evidence of BMW selling 983 refinished cars since 1983 (only 14 were sold within Alabama) without disclosing that the cars had been repainted.

 

Procedural Posture: The jury returned a verdict for $4,000 in compensatory damages and $4 million in punitive damages. The Alabama Supreme Court rejected BMW’s claim that this exceeded the constitutionally permissible amount but did find the jury miscalculated the damages and held that “a constitutionally reasonable punitive damages award in this case is $2 million.”

 

Holding: The punitive damage award was grossly excessive and exceeds the constitutional limit.

 

Reasoning: Gore argued that the large punitive damages award was necessary to induce BMW to change the nationwide policy that it adopted in 1983. However, by attempting to alter BMW’s nationwide policy, Alabama would be infringing on the policy choices of other states. One state cannot impose economic sanctions on violators of its laws with the “intent of changing the tortfeasor’s lawful conduct in other States.”
In addition, the Court gave three guideposts for reviewing punitive damages:
  1. the degree of reprehensibility of the defendant’s misconduct,
  2. the ratio of punitive damages to actual damages (here it is 500 to 1 which does not bear a “reasonable relationship.”), and
  3. the difference between punitive damages awarded by the jury and civil penalties authorized or imposed in comparable cases (here, Alabama’s Legislature authorizes a maximum $2,000 penalty of $2,000 through its Deceptive Trade Practices Act. In Alabama, there were only 14 violations).

 

Scalia’s Dissent (Thomas joined): The Constitution does not make excessive punitive damages any concern of the Court. There is no federal guarantee (even in the 14th Amendment) that a damages award actually be reasonable. “By today’s logic, every dispute as to evidentiary sufficiency in a state civil suit poses a question of constitutional moment, subject to review in this Court. That is a stupefying proposition.