BLAW 378 Exam 2: Case Majorities
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Church of the Holy Trinity v. U.S. (1892): church hires English pastor
ISSUE: Does a ban on importing aliens to perform "labor or service of any kind" cover a church hiring a rector?
HELD: No.
WHY: Within the letter, not the spirit. The "evil" was cheap manual contract labor. The title says "labor," the committee report expected a manual-labor reading, and "we are a religious people."
RULE: "A thing may be within the letter of the statute and yet not within the statute, because not within its spirit."
Bob Jones University v. U.S. (1983): discriminatory private schools
ISSUE: Can the IRS deny 501(c)(3) tax exemption to racially discriminatory schools?
HELD: Yes (Burger).
WHY: "Charitable" carries the common-law rule that a charity can't violate public policy. Read with 170 and 501(i) (whole act). Congress let the IRS rule stand for 12 years while 13 bills to overturn it died (acquiescence).
RULE: Look past the literal text when following it would defeat the statute's plain purpose.
TVA v. Hill (1978): snail darter vs. Tellico Dam
ISSUE: Does ESA 7 stop a nearly finished dam that would wipe out an endangered fish's habitat?
HELD: Yes. Dam enjoined (Burger).
WHY: The text is plain and "admits of no exceptions." Agencies must "insure" their actions don't jeopardize a species. Continued funding is not an implied repeal.
RULE: Clear text controls even when the result is expensive. Fixing it is Congress's job.
U.S. v. Locke (1985): filed on December 31
ISSUE: Is a filing due "prior to December 31" on time if filed on Dec. 31?
HELD: No. Claims forfeited (Marshall).
WHY: Plain text. Congress may have meant end of year, but courts don't rewrite deadlines.
RULE: No "carte blanche to redraft statutes" because Congress could have been clearer. Harsh is not the same as absurd.
General Dynamics v. Cline (2004): workers aged 40 to 49 lose retiree benefits
ISSUE: Does the ADEA bar favoring older workers over younger workers who are also 40+?
HELD: No (Souter).
WHY: In ordinary usage, "age discrimination" means against the older. Legislative history (Labor Secretary report, hearings) shows Congress targeted bias against older workers.
RULE: Read words in their social context, not at their broadest dictionary meaning.
U.S. v. Kirby (1868): sheriff arrests mail carrier for murder
ISSUE: Did a sheriff "obstruct the passage of the mail" by arresting the carrier on a murder warrant?
HELD: No.
WHY: A literal reading leads to an absurd result. The legislature is presumed to intend sensible exceptions (the surgeon who "drew blood in the streets," the prisoner fleeing a burning jail).
RULE: "General terms should be so limited … as not to lead to injustice, oppression, or an absurd consequence."
Green v. Bock Laundry (1989): arm torn off in dryer
ISSUE: FRE 609 protected only the "defendant" from prejudicial impeachment. Does that cover civil plaintiffs?
HELD: No. "Defendant" means criminal defendant, so a civil witness's felonies come in (Stevens).
WHY: Read literally, civil defendants are protected and civil plaintiffs aren't, which is absurd. Drafting history shows the concern was criminal defendants.
RULE: Absurdity lets the court fix the text; legislative history picks which fix.
Smith v. U.S. (1993): gun traded for cocaine
ISSUE: Is trading a gun for drugs "uses … a firearm"?
HELD: Yes (O'Connor).
WHY: Ordinary meaning of "use" is "to employ" or "derive service from" (Webster's, Black's). 924(d) treats guns "used in" trades as covered (whole act).
RULE: Undefined words get their ordinary, natural meaning, not only their most typical use.
Muscarello v. U.S. (1998): gun in locked glove compartment
ISSUE: Does "carries a firearm" cover a gun locked in the glove compartment of your vehicle?
HELD: Yes (Breyer).
WHY: Dictionaries, the Bible, Robinson Crusoe, Moby Dick, and news usage all say you "carry" things in vehicles.
RULE: Ordinary meaning can be proven with dictionaries and common usage. Lenity applies only to "grievous" ambiguity.
McBoyle v. U.S. (1931): stolen airplane
ISSUE: Is an airplane a "motor vehicle" ("automobile … motor cycle, or any other self-propelled vehicle not designed for running on rails")?
HELD: No (Holmes).
WHY: "Vehicle" calls up the popular picture of something on land. Every listed item runs on land (ejusdem generis). Fair warning points to lenity.
RULE: Criminal laws must give "fair warning … in language that the common world will understand."
O'Connor v. Oakhurst Dairy (1st Cir. 2017): missing Oxford comma
ISSUE: In "packing for shipment or distribution" (no serial comma), is "distribution" its own exempt activity?
HELD: Ambiguous, so the delivery drivers win overtime.
WHY: No Oxford comma vs. parallel gerunds ("distribution" isn't an -ing word like the rest). Maine's wage law is remedial, so ties go to workers.
RULE: Grammar and punctuation are evidence of meaning. Ambiguity in a remedial statute favors the people it protects.
Leatherman v. Tarrant County (1993): Section 1983 pleading
ISSUE: Can courts demand heightened pleading for Section 1983 claims against cities?
HELD: No.
WHY: FRCP 9(b) requires particularity only for fraud and mistake. Naming those two excludes everything else.
RULE: Expressio unius: listing some things implies the omitted ones were left out on purpose.
Yates v. U.S. (2015): undersized fish thrown overboard
ISSUE: Are fish a "tangible object" under Sarbanes-Oxley 1519 ("record, document, or tangible object")?
HELD: No (Ginsburg plurality, Alito concurring).
WHY: Neighbors "record" and "document" store information (noscitur, ejusdem generis). Title is about records. SOX targets financial fraud (whole act). "Makes a false entry in" fits records, not fish. Surplusage and lenity.
RULE: Context can narrow a broad word. "Tangible object" means objects used to record or preserve information.
U.S. v. Bass (1971): felon possessing guns
ISSUE: Does "in commerce or affecting commerce" modify "possesses," or only "transports"?
HELD: All three verbs. The government must prove a commerce link (Marshall).
WHY: Real ambiguity, so lenity applies. Reading it broadly would federalize ordinary state crimes without a clear statement. Surplusage.
RULE: Before choosing the harsher reading, Congress must speak "in language that is clear and definite."
Skilling v. U.S. (2010): Enron CEO, honest-services fraud
ISSUE: What does fraud depriving another of "the intangible right of honest services" cover?
HELD: Only bribes and kickbacks. Skilling's conduct wasn't covered (Ginsburg).
WHY: A broader reading would be unconstitutionally vague (due process). Congress clearly meant at least bribes and kickbacks.
RULE: Constitutional avoidance: choose the plausible reading that avoids a serious constitutional problem.
Gregory v. Ashcroft (1991): mandatory retirement for state judges
ISSUE: Does the ADEA bar Missouri's age-70 retirement rule for appointed state judges?
HELD: No (O'Connor).
WHY: Choosing state judges is a core state power. It's unclear whether judges are "appointee[s] on the policymaking level," and the ADEA doesn't plainly cover them.
RULE: Federalism clear statement: Congress must be unmistakably clear before intruding on core state functio
Does "labor or service of any kind" cover a church hiring a pastor?
NO. Spirit over letter.
Can the IRS deny tax exemption to racially discriminatory schools?
YES. Purpose + acquiescence.
Does the ESA stop a nearly finished dam to save the snail darter?
YES. Plain text, no exceptions.
Is a filing due "prior to December 31" on time if filed Dec. 31?
NO. Plain text; harsh isn't absurd.
Does the ADEA protect workers in their 40s against favoritism toward older workers?
NO. Ordinary usage + legislative history.
Does arresting a mail carrier for murder "obstruct the passage of the mail"?
NO. Absurdity.
Does FRE 609's "defendant" include civil defendants?
NO, criminal only. Absurdity + legislative history.
Is trading a gun for drugs "using" a firearm?
YES. Ordinary meaning + whole act.
Is a gun in your glove compartment "carried"?
YES. Dictionaries + common usage.
Is an airplane a "motor vehicle"?
NO. Ejusdem generis + lenity.
With no Oxford comma, is "distribution" exempt from overtime?
NO, drivers win. Grammar + remedial purpose.
Can courts require heightened pleading for Section 1983 claims against cities?
NO. Expressio unius.
Is a fish a "tangible object" under Sarbanes-Oxley?
NO. Noscitur + ejusdem generis.
Does "in commerce or affecting commerce" apply to possession too?
YES. Lenity + federalism.
Does honest-services fraud reach beyond bribes and kickbacks?
NO. Constitutional avoidance.
Does the ADEA cover appointed state judges?
NO. Federalism clear statement.