The Supreme Court of the United States announced decisions in three cases this morning:
Astra USA, Inc. v. Santa Clara County, No. 09-1273: The Public Health Services Act imposes ceilings on prices drug manufacturers may charge for medications sold to specified health care facilities, including public hospitals and community health centers. The question presented was whether those facilities, though accorded no right to sue for overcharges under the statute itself, could nonetheless sue allegedly overcharging manufacturers as third-party beneficiaries of the pricing agreements between the federal government and the manufacturers. The Court today held that such suits are incompatible with the statutory regime.
The Court's decision is available here.
Connick v. Thompson, No. 09-571: Petitioner filed suit against a district attorney’s office under 42 U. S. C.
§1983, alleging that the failure of a prosecutor to turn over exculpatory evidence to the defense in petitioner's criminal trial (a so-called "Brady violation") was caused by the office’s deliberate indifference to an obvious need to train prosecutors to avoid such constitutional violations. The lower court held petitioner did not need to show a pattern of similar Brady violations to prove deliberate indifference when he could demonstrate that the need for training was obvious. The Court today held that a district attorney’s office may not be held liable under §1983 for failure to train its prosecutors based on a single Brady violation.
The Court's decision is available here.
Tolentino v. New York, No. 09-11556: The Court dismissed "as improvidently granted" (and without other comment) the writ of certiorari it had issued in this case, which it had granted to decide whether pre-existing identity-related governmental documents, such as motor vehicle records, obtained as the direct result of police action violative of the Fourth Amendment, were subject to the exclusionary rule. The dismissal means the lower court decision stands, but does not amount to Supreme Court precedent.