The Supreme Court of the United States announced decisions in two cases today:
Integrity Staffing Solutions, Inc. v. Busk, No. 13-433: Petitioner Integrity Staffing Solutions, Inc. required its employees, warehouse workers who retrieved inventory and packaged it for shipment, to undergo an antitheft security screening before leaving the warehouse each day. Busk, a warehouse worker, filed this putative class action for, inter alia, alleged violations of the Fair Labor Standards Act. The District Court dismissed the complaint for failure to state a claim, but the Ninth Circuit reversed. Today, the Court reversed, holding that these security screenings are noncompensable postliminary activities under the Fair Labor Standards Act of 1938, 29 U.S.C. §201 et seq., as amended by the Portal-to-Portal Act of 1947, 29 U.S.C. §251 et seq.
The Court's decision is available here.
Warger v. Shauers, No. 13-517: Petitioner Gregory Warger brought a negligence suit in federal court against respondent Randy Shauers for injuries in a motor vehicle accident. The jury returned a verdict for Shauers, after which one juror contacted Warger’s counsel, stating, and later providing in an affidavit, that the jury foreperson had revealed during deliberations that her daughter had been at fault in a fatal motor vehicle accident, and that a lawsuit would have ruined her daughter’s life. Warger then moved for a new trial, arguing that the jury foreperson had deliberately lied during voir dire about her impartiality and ability to award damages. The District Court denied the motion, holding that Federal Rule of Evidence 606(b) barred the affidavit, and the Eighth Circuit affirmed. The Court today affirmed, holding that Rule 606(b), which provides that certain juror testimony regarding what occurred in a jury room is inadmissible “[d]uring an inquiry into the validity of a verdict,” applies to juror testimony during a proceeding in which a party seeks to secure a new trial on the ground that a juror lied during voir dire.
The Court's decision is available here.
The Supreme Court of the United States granted review in three cases last Friday:
Commil USA v. Cisco Systems, Inc., No. 13-896: Whether the Federal Circuit erred in holding that a defendant’s belief that a patent is invalid is a defense to induced infringement under 35 U.S.C. §271(b).
Walker v. Sons of Confederate Vets, 14-144: (1) Do the messages and symbols on state-issued specialty license plates qualify as government speech immune from any requirement of viewpoint neutrality? (2) Can a State that rejects a specialty license plate defend itself against a charge of “viewpoint discrimination” if the State has never issued or approved a license plate bearing a different viewpoint on the subject matter of the rejected license plate.
Brumfield v. Cain, 13-1433: (1) Whether a state court that considers the evidence presented at a petitioner's penalty phase proceeding as determinative of the petitioner's claim of mental retardation under Atkins v. Virginia, 536 U.S. 304 (2002), has based its decision on an unreasonable determination of facts under 28 U.S.C. §2254(d)(2). (2) Whether a state court that denies funding to an indigent petitioner who has no other means of obtaining evidence of his mental retardation has denied petitioner his "opportunity to be heard," contrary to Atkins and Ford v. Wainwright, 477 U.S. 399 (1986), and his constitutional right to be provided with the "basic tools" for an adequate defense, contrary to Ake v. Oklahoma, 470 U.S. 68 (1985).