The legal principle or standard that a court uses to resolve the issues presented in a case.
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Common Examples
6
Erie Balance in Diversity Suit
Roland Rhodes, a citizen of State A, sues Redline Automotive, a State B corporation, in federal court over a contract dispute. No federal statute or rule directly addresses whether a particular evidentiary presumption is substantive or procedural. The court weighs the state's interest in uniform application of its presumption against the federal system's interest in efficient administration and decides to apply federal practice.
Most Significant Relationship Test
Rosalind Reed, domiciled in State X, contracts to sell land located in State Y to Raven Logistics. The parties dispute which state's law governs their interests in the land. The court evaluates the purposes of each state's property rules, the parties' justified expectations, and the states' relative interests before selecting the state with the most significant relationship to the transaction and the land.
Raymond Ramos, a testator domiciled in State P, leaves land in State Q to a charity. State Q's rule limits charitable bequests while State P has no such limit. The court examines the purpose behind State Q's restriction and the parties' connections to each state to decide whether State Q's rule should apply to the particular issue.
Temporary Takings Claim
Rosa Ruiz owns parcels near Lake Tahoe. A regional agency imposes two-year moratoria on development while studying environmental impacts. Ruiz claims a categorical taking under Lucas. The court applies the rule that temporary restrictions on use do not constitute a total deprivation of all economically viable use and therefore evaluates the claim under the Penn Central factors instead.
Tahoe-Sierra Preservation Council, Inc. v. Tahoe Regional Planning Agency535 U.S. 302
In the early 1980s, the Tahoe Regional Planning Agency imposed two moratoria on development in the Lake Tahoe Basin. The first, Ordinance 81-5, took effect on August 24, 1981, and lasted until August 26, 1983. The second, Resolution 83-21, ran from August 27, 1983, to April 25, 1984. Together these measures prohibited virtually all development on sensitive lands for a total of 32 months while TRPA developed a comprehensive land-use plan.
Lake Tahoe's exceptional water clarity had begun to deteriorate due to increased land development starting in the late 1950s and early 1960s. Runoff from impervious surfaces on steeper slopes and stream environment zones carried nutrients that promoted algae growth. In response, California and Nevada, along with the federal government, amended the Tahoe Regional Planning Compact in 1980 to require TRPA to establish environmental threshold carrying capacities and adopt a regional plan.
The 1980 Compact amendment directed TRPA to adopt thresholds within 18 months and a plan within a year thereafter. It also included a finding that temporary halts on development were necessary to preserve the region's capacity for future development consistent with the ultimate plan. TRPA enacted Ordinance 81-5 in June 1981 after concluding it could not meet the original deadlines, and later adopted Resolution 83-21 when no plan was in place by August 1983.
Petitioners, including the Tahoe-Sierra Preservation Council representing about 2,000 owners and a class of approximately 400 individual owners of vacant lots purchased before 1980 primarily for building single-family homes, filed parallel actions in federal courts in Nevada and California shortly after the 1984 plan was adopted. The suits were consolidated in the District of Nevada. The District Court found that the moratoria constituted categorical takings under Lucas because they temporarily deprived owners of all economically viable use. The Ninth Circuit reversed that determination.
The Ninth Circuit held that the temporary nature of the regulations meant no categorical taking had occurred and that Penn Central analysis applied, though petitioners had not challenged the District Court's Penn Central findings. The Supreme Court granted certiorari to address whether the moratoria effected per se takings.
Raphael Rivera is charged with murdering a witness who had given statements to police. The prosecution seeks to introduce the witness's prior statements. The court applies the rule that forfeiture by wrongdoing requires proof the defendant acted with intent to prevent the witness from testifying and therefore excludes the statements because that intent is not shown.
Giles v. California554 U.S. 353 (2008)
On September 29, 2002, Dwayne Giles shot his ex-girlfriend Brenda Avie six times outside the garage of his grandmother’s house.
Giles’ niece heard the two speaking in conversational tones before Avie yelled “Granny” several times and a series of gunshots sounded. Giles’ niece and grandmother ran outside and saw Giles standing near Avie with a gun in his hand. Avie had not been carrying a weapon. Giles fled the scene and was apprehended by police about two weeks later.
Three weeks before the shooting, Avie spoke to a police officer responding to a domestic-violence report. Avie, who was crying, told the officer that Giles had accused her of having an affair, grabbed her by the shirt, lifted her off the floor, choked her, punched her in the face and head, and threatened her with a folding knife. At trial, prosecutors sought to introduce these statements. Over Giles’ objection, the trial court admitted them under California Evidence Code section 1370.
Giles testified that he had acted in self-defense. He described Avie as jealous and violent, said she had threatened to kill him and his new girlfriend on the day of the shooting, and claimed she charged at him before he fired. A jury convicted Giles of first-degree murder. While Giles’ appeal was pending, the Supreme Court decided Crawford v. Washington. The California Court of Appeal held that admission of Avie’s statements did not violate the Confrontation Clause because Giles had forfeited his confrontation right by committing the murder. The California Supreme Court affirmed on the same ground. The U.S. Supreme Court granted certiorari.
Rita Russell, a lawful permanent resident, pleads guilty to a drug offense on counsel's advice that never mentions deportation risk. After conviction she faces removal. The court applies the rule that counsel must advise a noncitizen client that a conviction may carry adverse immigration consequences and finds the representation constitutionally deficient.
Padilla v. Kentucky130 S. Ct. 1473, 1485 (2010)
Jose Padilla, a native of Honduras, has been a lawful permanent resident of the United States for more than forty years and served in the U.S. Armed Forces during the Vietnam War. He faced criminal charges in Kentucky after being arrested for transporting a large amount of marijuana in his tractor-trailer.
Before entering a guilty plea to the drug distribution charges, Padilla's counsel did not advise him that the conviction would trigger deportation proceedings. Counsel instead told him that he did not have to worry about his immigration status because he had lived in the country so long. Padilla relied on that advice when he pleaded guilty and later alleged that he would have insisted on going to trial if he had received accurate information.
In postconviction proceedings Padilla claimed that his attorney's erroneous advice about deportation constituted ineffective assistance. The Supreme Court of Kentucky denied relief without holding an evidentiary hearing, treating deportation as a collateral consequence outside the protection of the Sixth Amendment.
The United States Supreme Court granted certiorari to review whether federal law imposed on counsel an obligation to advise Padilla that his guilty plea would result in removal from the country.
What does the 'rule applied' section of a case brief contain?
It states the legal principle or standard the court uses to decide the issues presented. The section identifies the doctrine or test that governs the outcome once the facts and question presented are clear.
…and § 1332 diversity jurisdiction were conditioned on the same jurisdictional-amount limitation, the same nonaggregation
rule applied
under both heads of federal jurisdiction. But cf. ante , at 562. The Court added, however, that "Congress ha[d] exempted major areas of federal-question jurisdiction from any…