The Oyez Project: 2002 Term Decisions
U.S. Supreme Court Decisions, presented by The Oyez Project (www.oyez.org)

• Abdur'Rahman v. Bell (No. 01-9094)
  

  Does a Federal Rule of Civil Procedure 60(b) motion, filed in a habeas corpus proceeding to inform the federal courts of a state court's interpretation of state procedural laws, constitute a "successive" habeas corpus petition?

  In a per curiam opinion, the writ of certiorari was dismissed as improvidently granted. Justice John Paul Stevens dissented. Justice Stevens argued that the Court of Appeals plainly erred when it characterized Abdur'Rahman's Rule 60(b) motion as an application for a second or successive habeas petition and denied relief for that reason.

• American Insurance Association v. Garamendi (No. 02-722)
  

  Did California's passage of the HVIRA interfere with the federal government's sovereignty over foreign affairs established by Article I of the Constitution?

  Yes. In a 5-4 opinion delivered by Justice David H. Souter, the Court held that California's HVIRA interferes with the president's ability to conduct the nation's foreign policy and is therefore preempted. The Court reasoned that an exercise of state power that concerns foreign relations must yield to the Federal Government's policy or that generally there is executive authority to decide what policy should be implemented. Based on an account of related international negotiations, the Court found sufficiently clear conflict between HVIRA and the President's foreign policy. "The basic fact is that California seeks to use an iron fist where the President has consistently chosen kid gloves," wrote Justice Souter. Justice Ruth Bader Ginsburg, joined by Justices John Paul Stevens, Antonin Scalia, and Clarence Thomas, dissented, arguing that no executive agreement or other formal expression of foreign policy expressly disapproved of state disclosure laws like California's HVIRA.

• Archer v. Warner (No. 01-1418)
  

  Does the Bankruptcy Code cover a debt embodied in a settlement agreement that settled a creditor's earlier claim "for money...obtained by...fraud?"

  Yes. In a 7-2 opinion delivered by Justice Stephen G. Breyer, the Court held that a debt for money promised in a settlement agreement accompanied by the release of underlying tort claims can amount to a debt for money obtained by fraud, within the nondischargeability statute's terms. "We conclude that the Archers' settlement agreement and releases may have worked a kind of novation, but that fact does not bar the Archers from showing that the settlement debt arose out of 'false pretences, a false representation, or actual fraud,' and consequently is nondischargeable," wrote Justice Breyer. Justice Clarence Thomas, with whom Justice John Paul Stevens joined, dissented.

• Barnhart v. Peabody Coal Co. (No. 01-705)
  

  Is the assignment of beneficiaries, under Coal Industry Retiree Health Benefit Act of 1992, valid if the assignment was made after the Act's October 1, 1993 deadline?

  Yes. In a 6-3 opinion delivered by Justice David H. Souter, the Court held that the Commissioner's initial assignments made after October 1, 1993, are valid despite their untimeliness. The Court reasoned that a statute directing official action needed more than a mandatory "shall" before the grant of power would be read to expire when the job was supposed to be completed. Moreover, Justice Souter noted that the Act was designed to assign the greatest number of beneficiaries and read the statutory date as a spur to prompt action. Justice Antonin Scalia dissented, in which Justices Sandra Day O'Connor and Clarence Thomas joined. Justice Thomas also filed a separate dissenting opinion. Both read the Act has establishing a clear deadline for the expiration of the Commissioner's authority.

• Beneficial National Bank v. Anderson (No. 02-306)
  

  Does the NBA require that any suits involving charges of excessive interest be heard in federal rather than state court?

  Yes. In a 7-2 opinion delivered by Justice John Paul Stevens, the Court held that the National Bank Act preempted the state-law claim and provided the exclusive cause of action for usury claims against national banks. Thus, the claim arose under federal law. The Court reasoned that the provisions of the Act create a federal remedy for overcharges that is exclusive, even when a state complainant relies entirely on state law. "Because [sections of the Act] provide the exclusive cause of action for such claims, there is, in short, no such thing as a state-law claim of usury against a national bank," wrote Justice Stevens. Justice Antonin Scalia, joined by Justice Clarence Thomas, dissented.

• Black & Decker Disability Plan v. Nord (No. 02-469)
  

  Under ERISA, are companies required to defer to the decision of a disability claimant's personal physician?

  No. In a unanimous opinion delivered by Justice Ruth Bader Ginsburg, the Court held that plan administrators are not obliged to accord special deference to the opinions of treating physicians. The Court reasoned that the Court of Appeals erroneously applied a "treating physician rule" because nothing in ERISA gave rise to such a rule. Justice Ginsburg wrote, "courts have no warrant to require administrators automatically to accord special weight to the opinions of a claimant's physician; nor may courts impose on plan administrators a discrete burden of explanation when they credit reliable evidence that conflicts with a treating physician's evaluation."

• Boeing Co. v. United States (No. 01-1209)
  

  Was Boeing Co. required to take into account expenses incurred for R&D in accordance with applicable Treasury regulations in calculating its "combined taxable income" for purposes of determining taxation with respect to its domestic international sales corporation and foreign sales corporation?

  Yes. In a 7-2 opinion delivered by Justice John Paul Stevens, the Court held that section 1.861-8(e)(3) is a proper exercise of the Secretary of the Treasury's rulemaking authority. The Court reasoned that the general regulation classifying all R&D as an indirect cost attributable to all export sales was not arbitrary as it provided consistent treatment for costs items used in computing domestic taxable income and combined taxable income. Justice Stevens wrote that the rule's "allocation of R&D expenditures to all products in a category even when specifically intended to improve only one or a few of those products is no more tenuous than the allocation of a chief executive officer's salary to every product that a company sells even when he devotes virtually all of his time to the development of an Edsel." Justice Clarence Thomas filed a dissenting opinion, in which Justice Antonin Scalia joined.

• Borden Ranch v. United States Army Corps of Engineers (No. 01-1243)
  

  Does deep plowing ranchland to plant deep-rooted crops constitute the "addition" of a "pollutant" from a "point source" so as to fall within the regulation of the Clean Water Act? Is deep plowing ranchland which is farmable in its natural state to plant deep-rooted crops statutorily exempt from regulation under the Act's exemption for any discharge from "normal farming...activities such as plowing?" Does the Act's civil penalty section authorize assessing the maximum daily penalty for each time a plow crosses a seasonal drainage feature, without regard to the number of days when such activity occurred?

  In a per curiam opinion, the Court affirmed the judgment of the appeals court by an equally divided vote. Justice Anthony M. Kennedy took no part in the consideration or decision of this case.

• Branch v. Smith (No. 01-1437)
  

  Did the District Court properly enjoin the Mississippi state court's proposed congressional redistricting plan and properly fashion its own congressional reapportionment plan?Did the District Court properly enjoin the Mississippi state court's proposed congressional redistricting plan and properly fashion its own congressional reapportionment plan?

  Yes. In a plurality opinion delivered by Justice Antonin Scalia, the Court held, 9-0, that the District Court properly enjoined enforcement of the state-court plan that lacked the required timely preclearance. The Court also held, 7-2, that the federal court properly fashioned its own congressional reapportionment plan, which drew the requisite single-member districts rather than directing at-large elections, under 2 USC section 2c. Regarding the second holding, Justice Scalia, joined by Chief Justice William H. Rehnquist and Justices Anthony M. Kennedy and Ruth Bader Ginsburg, reasoned that the provision for at-large elections under 2 USC section 2a(c) was subject to the requirement under section 2c that single-member districts must be drawn whenever possible. Justice John Paul Stevens, with whom Justices David H. Souter and Stephen G. Breyer joined, concluded that section 2c impliedly repealed section 2a(c). Justice Sandra Day O'Connor, with whom Justice Clarence Thomas joined, disagreed with the plurality's