The Supreme Court of the United States announced decisions in four cases this morning:
DePierre v. United States, No. 09-1533: The Anti-Drug Abuse Act provides for mandatory sentences for certain drug offenses involving "cocaine base." Petitioner, convicted and given one of the mandatory sentences, contended that the statutory term only included so-called "crack" cocaine. The Court today rejected that contention, holding the term “cocaine base” as used in the statute refers generally to cocaine in its chemically basic form and not only to “crack cocaine.”
The Court's decision is available here.
Microsoft Corp. v. i4i Limited Partnership, No. 10-290: Under §282 of the Patent Act, “[a] patent shall be presumed valid” and “[t]he burden of establishing invalidity of a patent . . . shall rest on the party asserting such invalidity.” When respondent sued petitioner for infringement of a patent, petitioner asserted in a counterclaim that the patent was invalid. Over objection, the district court instructed the jury that invalidity must be proved by clear and convincing evidence. The jury found that invalidity had not been proved to that standard and that petitioner had infringed, and the court of appeals affirmed. The Court today affirmed as well, holding that §282 requires an invalidity defense to be proved by clear and convincing evidence.
The Court's decision is available here.
Talk America, Inc. v. Michigan Bell Telephone Co., No. 10-313: The Telecommunications Act of 1996 requires providers of local telephone service to share their physical networks with competitors at cost-based rates in certain ways. After the Federal Communications Commission issued a revised interpretation of the Act, respondent notified competitors that it would no longer provide "entrance facilities" at cost-based rates for "interconnection," but would instead charge higher rates. The district court ruled in respondent's favor, and the court of appeals affirmed, refusing to defer to an argument offered by the FCC as an amicus that its revised interpretation did not change the obligations regarding sharing of entrance facilities for interconnection. The Court today reversed the court of appeals and held that because the FCC advanced a reasonable interpretation of its regulations—that existing entrance facilities must be made available to competitors at cost-based rates if the facilities are to be used for interconnection—the Court would defer to the FCC’s views.
The Court's decision is available here.
Sykes v. United States, No. 09-11311: Petitioner had prior convictions for at least three felonies, including the state-law crime of “us[ing] a vehicle” to “knowingly or intentionally” “fle[e] from a law enforcement officer” after being ordered to stop. Accordingly, the district court decided that the prior convictions subjected him to the 15-year mandatory minimum prison term that the Armed Career Criminal Act provides for an armed defendant who has three prior “violent felony” convictions. Rejecting the argument that his vehicle flight felony was not “violent” within the meaning of the ACCA, the court of appeals affirmed. The Court today affirmed as well, holding that, as proscribed by the state law at issue, felony vehicle flight is a violent felony for purposes of the ACCA.
The Court's decision is available here.