judicial administration

In October 1966, nineteen-year-old Gary Duncan stopped his car on Highway 23 in Plaquemines Parish, Louisiana, after seeing his two younger Negro cousins talking with four white boys near a formerly all-white high school that had recently experienced racial incidents. Duncan approached the group, spoke with the white boys, encouraged his cousins to leave, and was about to drive away when a dispute arose over whether he had slapped or merely touched one of the white boys on the elbow. At his trial in the Twenty-fifth Judicial District Court of Louisiana, the white boys and a white onlooker testified that Duncan had slapped Herman Landry, while Duncan and his cousins testified that he had only touched the boy. The trial judge found Duncan guilty of simple battery beyond a reasonable doubt. Under Louisiana law, simple battery is a misdemeanor punishable by a maximum of two years' imprisonment and a three-hundred-dollar fine. Duncan requested a jury trial, but the trial judge denied the request because the Louisiana Constitution provides for jury trials only in cases where capital punishment or imprisonment at hard labor may be imposed. Duncan was convicted by the judge alone and sentenced to sixty days in the parish prison and a fine of one hundred fifty dollars. Duncan sought review in the Supreme Court of Louisiana, which denied his application for a writ of certiorari. He then petitioned the United States Supreme Court pursuant to 28 U.S.C. § 1257(2), alleging that the denial of a jury trial violated his rights under the Sixth and Fourteenth Amendments. The Supreme Court noted probable jurisdiction and set the case for argument along with a related case.

In March 1944 petitioner Fisher, the janitor at the library of the Cathedral of Saint Peter and Saint Paul in Washington, D.C., killed librarian Catherine Cooper Reardon inside the library building between eight and nine o'clock on the morning of March 1. Reardon had complained a few days earlier to the verger about Fisher's care of the premises, and the verger had informed Fisher of the complaint. Fisher and Reardon were alone in the library at the time of the homicide. Fisher testified that Reardon spoke insulting words about his work, after which he slapped her impulsively. He ran up a flight of steps toward an exit but turned back, seized a stick of firewood, struck her, and when the stick broke choked her to silence. He then dragged her to a lavatory and left the body to clean up some spots of blood on the floor outside. While Fisher was doing this cleaning up, the victim started hollering again. Fisher then took out his knife and stuck her in the throat. After that he dragged her body down into an adjoining pump pit, where it was found the next morning. Fisher's accounts of the events varied. His original confession made no reference to insulting words from Reardon. His written confession mentioned them, and his trial testimony amplified their effect on him. In the written confession he admitted his main reason for assaulting her was that she had reported him for not cleaning the floor. The Deputy Coroner testified that the knife wound was not deep and only went through the skin. Defense psychiatrists testified that Fisher was a psychopathic personality of a predominantly aggressive type, mentally somewhat below average, with minor stigmata of mental subnormalcy, and that he was unable by reason of a deranged mental condition to resist the impulse to kill. The prosecution introduced competent evidence that Fisher was capable of understanding the nature and quality of his acts. All evidence offered by the defense was received by the trial court. Fisher was tried in the District Court of the United States for the District of Columbia on an indictment charging killing by choking and strangling with deliberate and premeditated malice. The jury returned a verdict of guilty on the first count, and the court imposed a sentence of death. The United States Court of Appeals for the District of Columbia affirmed the judgment and sentence.

Parklane Hosiery Company, Inc., and eleven of its officers and directors issued a proxy statement in connection with a merger between Parklane and another corporation. Leo Shore, a stockholder of Parklane, filed a class action on behalf of stockholders in the United States District Court for the Eastern District of New York against Parklane and the individual defendants. The complaint alleged that the proxy statement was false and misleading in violation of sections 14(a), 10(b), and 20(a) of the Securities Exchange Act of 1934 and related SEC rules. The complaint sought damages for the class, rescission of the merger, and recovery of costs. Before Shore’s action came to trial, the Securities and Exchange Commission filed a separate suit against the same defendants in the United States District Court for the Southern District of New York. The SEC complaint alleged that the proxy statement that had been issued by Parklane was materially false and misleading in essentially the same respects as those that had been alleged in the respondent's complaint. After a four-day trial, the District Court found that the proxy statement was materially false and misleading in the respects alleged, and entered a declaratory judgment to that effect. The court permanently enjoined the defendants from further violations of the securities laws and ordered them to offer rescission to shareholders who had tendered shares. The defendants did not appeal this judgment. Shore then moved for partial summary judgment in the Eastern District of New York action, asserting that the defendants were collaterally estopped from relitigating the issues resolved against them in the SEC action. The District Court denied the motion on the ground that application of collateral estoppel would deny the defendants their Seventh Amendment right to a jury trial. The Court of Appeals for the Second Circuit reversed, holding that a party who has had issues of fact determined against him after a full and fair opportunity to litigate in a nonjury trial is collaterally estopped from obtaining a subsequent jury trial of these same issues of fact. Because of an intercircuit conflict with the Fifth Circuit’s decision in Rachal v. Hill, the Supreme Court granted certiorari.

On October 29, 1958, at approximately 5:45 a.m., thirteen Chicago police officers entered the apartment of James Monroe and his family without a search warrant or arrest warrant. The officers roused the Monroes from bed using flashlights and forced them at gunpoint to stand naked in the living room while ransacking every room, emptying drawers, and ripping mattress covers. Detective Pape struck Mr. Monroe several times with his flashlight and called him "nigger" and "black boy." Other officers hit and kicked several of the children and pushed them to the floor. Mr. Monroe was then taken to the police station and detained on open charges for ten hours. During this period he was interrogated about a murder, exhibited in lineups, and not permitted to call his family or attorney, although he was not brought before a magistrate despite their availability. He was released without any criminal charges being filed against him. The complaint alleged that these actions occurred under color of the statutes, ordinances, regulations, customs, and usages of Illinois and Chicago, and that the City had no rules or controls over its police officers, permitting them to act without restraint. The Monroes claimed deprivations of rights under the Fourth and Fourteenth Amendments and sought compensatory and punitive damages from the officers and the City. The district court dismissed the complaint for failure to state a claim upon which relief could be granted. The Court of Appeals for the Seventh Circuit affirmed the dismissal, and the Supreme Court granted certiorari to review the judgment.