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Cutter v. Wilkinson

Cutter v. Wilkinson

 

Cutter v. Wilkinson: The Background

The case of Cutter v. Wilkinson deals with the Religious Land Use and Institutionalized Persons Act of 2000. This piece of legislation prohibited government bodies from imposing substantial burdens on a prisoner’s religious exercise, unless the burden exacerbated a compelling state or local interest. The case of Cutter v. Wilkinson began when prisoners in Ohio alleged in a federal district court that prison officials violated the provisions of the Religious Land Use and Institutionalized Persons Act by failing to properly accommodate the inmates’ exercise of their non-mainstream religious beliefs.

In response to this allegation, prison officials argued that the act improperly strengthened or bolstered said religions and thus violated the First Amendment’s establishment clause, which effectively outlaws government from creating laws that favor or respect an establishment of religion. The district court ultimately rejected this argument and ruled for the inmates. This decision; however, was reversed by the Sixth Circuit Court of Appeals. Eventually the case of Cutter v. Wilkinson made its way to the United States Supreme Court.

The case of Cutter v. Wilkinson was filed by five residents of an Ohio prison. Two of these inmates including practices of Asatru, while one was regarded as a minister of the white supremacist Church of Jesus Christ Christian, one a Satanist and the fifth a Wiccan.

 

Cutter v. Wilkinson: The Question

The question surrounding the case of Cutter v. Wilkinson asked if the federal law preventing government from burdening a prisoner’s religious exercise violates the First Amendment’s establishment clause.

 

Cutter v. Wilkinson: The Decision

The decision rendered by the United States Supreme Court in Cutter v. Wilkinson stated unanimously (9 to 0 vote) that the federal law does not violate the First Amendment’s establishment clause.

The majority opinion presented in Cutter v. Wilkinson was delivered by Chief Justice Ruth Bader Ginsburg. The decision reflected the court’s ruling that on its face the Religious Land Use and Institutionalized Persons Act made a direct accommodation permitted by the First Amendment to the United States Constitution.

The Supreme Court of the United States in Cutter v. Wilkinson stated that the law was an effort to help the natural government-created burden on religious exercise that prisoners were confronted with. Moreover, the Religious Land Use and Institutionalized Persons Act did not discriminate between non-mainstream and mainstream religions. That said, the Supreme Court did point out that constitutional problems could arise if the Religious Land Use and Institutionalized Persons Act was enforced improperly and religious inmates received favored treatment or if some religious exercises and security concerns were not justly balanced. 

Estep v. United States

Estep v. United States

 

Estep v. United States: The Facts

Estep v. United States was a Supreme Court case in which the court ruled that a draft board’s refusal to classify a Jehovah’s Witness as minister is subject to judicial review. This ruling; however, must only be made following exhaustive administrative remedies.

The case of Estep v. United States began when the petitioner (Mr. Estep) was classified as IV-A, meaning a sole surviving son status. When the Selective Service Board learned of the death of the petitioner’s mother, the board reclassified him as I-A, meaning he was available for military service. The switch was based off the theory that the IV-A classification became invalid when the “family unit” was irreparably altered and no longer existed. The petitioner did not appeal the reclassification; however, he refused to report as ordered for his physical examination. Because of his refusal to show, he was classified by the army as a delinquent. He then failed to report induction as ordered and as a result was indicted for such failure. Estep’s only defense was that he was improperly denied the sole surviving son exemption.

Using this defense in the District Court system, the court held that it didn’t matter as to the exemption because Estep failed to exhaust the administrative remedies provided by the Selective Service System. In response, the Petitioner was convicted and the Court of Appeals affirmed this ruling.

 

Estep v. United States: Consequences

Following these adverse rulings, Estep asked the State and National directors of Selective Service to appeal the matter to the President of the United States. This request was ultimately refused as the local board ordered him to report for induction. Estep followed orders and was ultimately accepted by the Navy; however, he refused to be indicted, maintaining that he was exempt from service because he was an ordained minister. Regardless of this claim, Estep was indicted under the Act for refusing to submit to induction. Estep continued to defend on the grounds that as a Jehovah’s Witness he was a recognized minister of religion and he was denied exemption from service because the associated agencies acted capriciously and randomly from refusing to classify him as an IV-D.

Garrity v. New Jersey

Garrity v. New Jersey

 

Garrity v. New Jersey: Background

In June of 1961, The New Jersey State Supreme Court directed the state’s Attorney General to investigate substantial evidence and reports that pointed to “ticket fixing” in the towns of Bellmar and Barrington. Following investigation, six employees were targeted as suspicious threats. Three of these employees came from Bellmar, including a court clerk, a police officer and the town’s Police Chief, Mr. Edward Garrity. Those that were filed as suspicious in Barrington were police officers.

Before being questioned the six state employees were read their rights: the individuals were told that anything said may be used during a criminal proceeding; the individuals had the privilege to refuse to answer any question if the answer would be used against them in the court of law; and a refusal to answer such questions would be cause for removal from office.

Each of the suspected employees answered the questions posed by the government. Some of these answers were used during the trial, which ultimately resulted in their convictions for conspiracy to obstruct their respective town’s administration of traffic laws.

The employees, following their conviction, appealed arguing that their statements were coerced and thus in direct violation of the Fifth and Fourteenth Amendments to the United States Constitution. These convictions, which were upheld by the state Supreme Court, were again appealed where they were retried in the United States Supreme Court.

 

Garrity v. New Jersey: The Question

The issue in Garrity v. New Jersey asked the question of whether a State, contrary to the requirements laid forth by the Fourteenth Amendment, can use the threat of discharge to secure self-incriminating evidence against an employee of a state body.

 

Garrity v. New Jersey: The Decision

The United States Supreme Court in Garrity v. New Jersey ultimately reversed the decision rendered by the New Jersey Supreme Court. As a result of the decision laid forth in Garrity v. New Jersey all employees of the case saw their convictions overturned.

The reasoning behind the United States’ Supreme Court ruling in Garrity v. New Jersey was as follows:

·         Garrity v. New Jersey states that the threat of removal from a public office renders the resulting statements involuntary. As a result, said statements are inadmissible in the state criminal proceedings

·         Garrity v. New Jersey states that coercion is present if the choice given to petitioners revolves around either a forfeiture of their jobs or the delivery of self-incriminating evidence.

·         The option to lose their means of income and livelihood or to pay the penalties associated with self-incrimination is the direct opposite of free choice to remain silent or speak out

·         Policemen, like all state employees, are not relegated to a lesser or watered-down version of constitutional rights

·         The protection of the individual under the fourteenth amendment to the United States Constitution against coercion is affirmed through the ruling of Garrity v. New Jersey. This protection extends to statements obtained under threat of removal from office.

 

Harris v. McRae

Harris v. McRae

 

Harris v. McRae: The Background

In 1965, the United States Congress established the Medicaid Program through the passing of Title XIX of the Social Security Act. The purpose of Medicaid was to provide federal financial assistance to states that opted to reimburse certain costs of medical care for the less fortunate. Starting in 1976, the U.S. Congress passed several versions of the “Hyde Amendment.” These amendments severely limited the use of federal dollars to reimburse abortion costs under the Medicaid Program.

The case of Harris v. McRae starts with Cora McRae, a pregnant Medicaid Recipient, who challenged the Amendment and took action against Patricia Harris, the then acting Secretary of Health and Human Services.

 

Harris v. McRae: The Question

The question revolving around Harris v. McRae dealt with the Amendment and whether or not it violated the patient’s right to privacy, the Due Process Clause of the Fifth Amendment and/or the Religion Clause of the First Amendment to the United States Constitution.

 

Harris v. McRae: The Decision

The decision of Harris v. McRae was a 5 to 4 split decision in favor of Harris. The court ruled that the Amendment did not violate the aforementioned rights. The Supreme Court in Harris v. McRae ruled that states participating in the Medicaid program were not required to fund medically necessary abortions under Title XIX of the Social Security Act. The Court ruled that a woman’s freedom of choice does not carry with it an entitlement to the financial resources to avail herself of the wide range of protected choices.

The court in Harris v. McRae ruled that because the Equal Protection Clause was not a definitive source of substantive rights and because impoverished conditions did not qualify as a suspected classification the Amendments did not violate the Fifth Amendment to the United States Constitution. Lastly, the case of Harris v. McRae held that the coincidence of the funding regulations of the statute with tenets of the Church did not constitute an establishment of religion.

The case of Harris v. McRae held that states participating in the Medicaid program were not required to fund medically necessary abortions under the Act. As a result of this ruling, the courts in Harris v. McRae, ruled that the Hyde Amendment did not violate the Establishment Clause of the First Amendment or the Fifth Amendment to the United States Constitution. 

Hill v. Wallace

Hill v. Wallace

 

Hill v. Wallace: Background

The case of Hill v. Wallace was a landmark United States Supreme Court decision that effectively overturned the legal of the Future Trading Act of 1921.

The Future Trading Act of 1921 was a piece of legislation that imposed a 20 cent per bushel tax on grain futures that were explicitly not regulated nor registered by the United States Department of Agriculture. The Future Trading Act of 1921 was intended to impose regulations on futures exchanges and contracts. The case of Hill v. Wallace deemed the act unconstitutional in 1921.

Hill v. Wallace: The Particulars

The Supreme Court case of Hill v. Wallace was argued on January 11th of 1922 and decided on May 15th of 1922. The Act’s purpose, in essence, was to regulate the business of the grain trade. The act imposed heavy penalties on the sales of grain for future delivery to boards and their members. It was ruled in Hill v. Wallace that the Act cannot be sustained as an exercise of Congress’ taxing powers because neither the related regulations nor the tax itself met the provisions of the Commerce Clause.

The case of Hill v. Wallace was filed by eight members of the Board of Trade of Chicago. This board sued the government, specifically the Secretary of Agriculture, the Commissioner of the Internal Revenue Service, the Collector of Internal Revenue for the First District of the State, the United States District Attorney for the Northern District of Illinois and the Board of Trade of the City of Chicago.

The suit charges that the Act violates the Constitution of the United States because it deprived the members of the Board of their property without adhering to the due process clause. Moreover, the board claimed that the Act attempted to regulate commerce, specifically commerce between entities and persons contracting within the state with regards to the sale or purchase of grains. And lastly, the case of Hill v. Wallace argued that the Act violates the Tenth Amendment to the United States Constitution by impeding the right of the state to provide for and regulate the maintenance of grain exchanges within borders.

Hill v. Wallace: Consequences

The Grain Futures Act was passed shortly after the ruling of Hill v. Wallace. The Grain futures act created a system of government regulation that was intended to grow into a network of stock market and commodities regulations. The bill was intended to be an essential element of commercial regulation as independent investors depended on the commissions spawned from Grain Futures contracts. The legislation intended to provide oversight to the markets, specifically the futures and commodities markets, to prevent theft and fraudulent dealings.

McKaskle v. Wiggins

McKaskle v. Wiggins

 

McKaskle v. Wiggins: Summary

The case of McKaskle v. Wiggins is a landmark case of the United States Supreme Court in which the legal system considered the role of standby lawyers in a criminal trial where the defendant conducted his or her own defense. In this particular matter, the defendant claimed his Six Amendment right to present his own case in a criminal matter was directly violated by the presence of a court-appointed standby lawyer.

McKaskle v. Wiggins: The Specifics

Carl Wiggins was on trial for Robbery and opted to defend himself before the court law. Mr. Wiggin’s defense strategy proved futile as he was convicted and sentenced to life in prison. This conviction was eventually overturned on the technicality that the conviction was defective. The case went to re-trial where Wiggins formally requested counsel for the second trial. In this case, the trial court appointed a standby lawyer to assist Wiggins if needed. Wiggins ultimately defended himself and asked that the standby lawyer be barred from interjecting in the legal matter. That said, Wiggins changed his mind several times regarding the standby lawyer’s role. Wiggins would sometimes would request or allow the standby lawyer’s participation in the trial.

Wiggins was once again convicted for robbery. Following his conviction, Wiggins requested a new trial on the grounds that his standby lawyer had interfered with his presentation of his own defense tactic. The motion was denied by the trial court but Wiggins filed a habeas petition in the Federal District Court. In this appeal, Wiggins claimed that the standby lawyer's ’conduct deprived him of his rights guaranteed by the United States Constitution. The rights that Wiggins brought up revolved the guarantee that he was allowed to conduct his own defense. The Federal Court agreed that his standby counsel should not interfere without permission but found that Wiggins’ attorney had not violated this relationship and had maintained proper actions while under trial.

This district ruling was ultimately reversed by the Court of Appeals. The court of Appeals held that Wiggins’ Sixth Amendment right to represent oneself was violated by the intrusive participation of the court-appointed standby lawyer.

McKaskle v. Wiggins: The Decision

In a split 6-3 decision the court in McKaskle v. Wiggins found that Wiggins’ right to present his own defense was not formally violated. The court ruled this way because Wiggins was allowed to make his own appearances as he wanted and that his standby lawyer’s unsolicited involvement was held within reason.

The ruling of McKaskle v. Wiggins was delivered by Judge Sandra Day O’Conner. The decision in McKaskle v. Wiggins was based on federal and state laws which preserved a defendant’s right to self-representation as guaranteed in a previous court case. Self-representation, as defined by the law, includes certain specific liberties for a defendant to have his own opinion heard.

McKaskle v. Wiggins set an important precedent for the boundaries on the behavior of standby lawyers by refining the position taken in the previous case (Faretta v. California)  concerning the role of said counsel.

Downes v. Bidwell

Downes v. Bidwell

 

Downes v. Bidwell: The Background

Downes v. Bidwell is a Landmark Supreme Court Case that, in addition to several other Supreme Court cases, made up what is known as the Insular Cases. Rendered in the first several years of the twentieth century, these famous cases determined that full constitutional rights were not necessarily granted to individuals living in American territories.

Downes v. Bidwell is regarded as one of the most prominent insular cases. In this matter, the United States Supreme Court established that the United States of America was not just a nation of states and territories, but a nation of states and potentially permanent territories. Although the nation had always possessed territories, they were perpetually assumed to be transitional phases as areas under the sovereignty of the United States.

The case of Downes v. Bidwell was a landmark case in which the United States Supreme Court decided whether territories were subject to the protections and provisions offered under the Constitution of the United States. The resulting decision in Downes v. Bidwell narrowly held that the Constitution of the United States did not necessarily apply to territories. Instead, the congress of the United States maintained jurisdiction to create laws within territories in certain circumstances, including revenue that would not be allowed by the Constitution for proper states within the union.

 

Downes v. Bidwell: Background

The case of Downes v. Bidwell specifically concerned a merchant named Samuel Downes. Mr. Downes owned the S.B. Downes & Company which imported oranges into the port of New York from the newly acquired territory of Puerto Rico. Downes was required to pay import duties on these goods. In response, he sued George Bidwell, who was the customs inspector for the port of New York, on the grounds that as a territory of the United States, such duties fell under the jurisdiction of article 1, Section 8 of the United States Constitution which provides that all imposts, duties and excises must be uniform throughout the nation. Since this particular duty on oranges did not exist for other parts of the United States, he argued that it should not be placed for Puerto Rican goods.

 

Downes v. Bidwell: The Decision

The United States Supreme Court decided, in a five to four decision, that newly annexed territories were not officially part of the United States for purposes of the United States Constitution in the matter of administrative matters and revenues. However, the Court noted that the Constitutional rights guaranteed were applicable to all. Territories were therefore due the full protections of the United States Constitution only when the US Congress incorporates them as an essential part of the nation.

 

United States v. Cruikshank

United States v. Cruikshank

 

What is United States v. Cruikshank?

United States v. Cruikshank was a landmark Supreme Court case that was decided during the height of Reconstruction in the South. To render a decision, the Court opted for a precise reading of the Fourteenth Amendment and refused to expand federal jurisdiction.

The case of United States v. Cruikshank revolved around a horrific event in which an armed white mob in Louisiana attacked and murdered over one hundred African-Americans during a contested gubernatorial election. During the ruckus, three white men—who were deemed the ring leaders of the murderous mob—were brought to trial and convicted under the Federal Enforcement Act of 1870, which made it a felony to interfere with any citizen’s constitutional rights. In response to the conviction, the three white ring leaders appealed under what the deemed to be faulty indictments.

The intended effect of Reconstruction was to expand federal power in the South following the close of the Civil War. To bolster federal influence, a number of methods and Acts employed to carry out Reconstruction were deemed unconstitutional. The Courts were thus sensitive to these actions and were prepared to impede these attempts of expansion.

 

United States v. Cruikshank: The Ruling

Because of the environment, all nine justices agreed that the indictments brought forth in United States v. Cruikshank were, in fact, illegitimate. As brought under the Enforcement Act, the indictments failed to allege the denial of federal rights, including the Right to assemble and the right to bear arms.

Ultimately, the local court placed the responsibility of trying and subsequently punishing the offenders in the state of Louisiana. The outcome of United States v. Cruikshank ultimately did nothing to stern the racial tension and violence of the Reconstructions period.

 

United States v. Cruikshank: The Influence

United States v. Cruikshank is viewed as a fundamental United States Supreme court ruling in United States constitutional law and one of the first to deal with the application of the Bill of Rights to state governments.

The Supreme Court in United States v. Cruikshank overturned the convictions of the defendants in the case. The Court, when making this decision, did not incorporate the Bill of Rights to the states and ruled that the First Amendment right to Assembly was not meant to limit the powers of the states in respect to their own citizens. Moreover, the ruling stated that the Second Amendment had no other effect than to restrict the powers of the federal government.

The Enforcement Act, which was designed to allow Federal enforcement and the prosecution of racist groups, the ruling in United States v. Cruikshank held that the Equal Protection and Due Process Clauses applied only to state action.

The short term effects of United States v. Cruikshank saw Southern blacks being abused by increasingly hostile state governments, who did little to protect them. When Democrats regained office in the late 1870s, legislation was passed making elections and voter registration more complicated. These laws effectively  stripped a large percentage of blacks from voting. 

Rostker v. Goldberg

Mickie Most

Chisholm v. Georgia