Significant U.S. Supreme Court Cases from Tennessee

Significant U.S. Supreme Court Cases from Tennessee

• Smith v. Bell, 31 U.S. 68 (1832): A husband left all his property to his wife for the rest of her life and then to his son. The son sold his right to his father's slaves and the wife remarried. The person to whom the son sold his right brought an action to recover the slaves. The Court held that the wife took only a life estate by her late husband's will in the slaves belonging to his personal estate and that the son had a vested remainder in the slaves that would come into possession on the death of the wife.

• McCutchen v. Marshall, 33 U.S. 220 (1834): Testator devised his slave to his wife during her natural life. Upon the wife’s death, the slaves were to be freed. The executor refused the appellants’ request to distribute the slaves to them, as legatee under the testator’s will, and procured their emancipation by filing a petition according to the Act of Tennessee of 1801, § 1. The Court held that the circuit court properly sustained the executor’s demurrer to appellants’ bill. Although § 1 did not confer the right of application for the emancipation of slaves to anyone except the owner, the Act authorized an executor to procure the emancipation of slaves according to the directions of the owner’s will. Thus, when an owner’s intent to free his slaves was made known by his will, the executor had a duty to use such legal means to effectuate that purpose.

• Keely v. Sanders, 99 U.S. 441 (1878): The Court upheld the tax sale of land in the insurrectionary district of Memphis after the Civil War pursuant to congressional statutes passed in 1862 and 1863 imposing a direct tax on land in insurrectionary districts. The Supreme Court ruled that the certificate of sale issued to the purchaser at the tax sale was prima facie evidence of the validity of the sale and the buyer's title. Additionally, it was error for the state courts to overturn the tax sale because state courts do not have authority to disturb the collection of federal taxes on land in insurrectionary districts.
• United States v. Harris, 106 U.S. 629 (1883): Often called the “Ku Klux Case,” this case arose from the beating of three black inmates at the Crockett County jail by the sheriff and a mob of nineteen other men. The perpetrators were charged with violating Section 2 of the Force Act of 1871, which made it a crime for two or more people to conspire to deprive another of the equal protection of the laws. The Court held that Congress lacked authority under the Fourteenth Amendment to enact the law because it was directed at the actions of private parties, not state action.
• Virginia v. Tennessee, 148 U.S. 503 (1893): This case involved a dispute between Tennessee and Virginia over the boundary between the two States. Virginia sought to change the boundary that had existed since 1803 by agreement of the legislatures of both States. The Court held that Virginia could not change the boundary line and that the 1803 agreement did not require approval of Congress under the Compact Clause.

• United States v. Shipp, 203 U.S. 563 (1906): A black man in Chattanooga who was convicted of rape by an all-white jury and sentenced to death filed a habeas petition, which eventually was pending before the Supreme Court. While the petition was pending, the jailer allowed a mob to lynch the petitioner. The jailer and others were charged with contempt. The Court held a criminal trial—the only one in the Court’s history—and ultimately convicted the jailer and others of criminal contempt.
• Jones v. Jones, 234 U.S. 615 (1914): Under Tennessee law, individuals who were born slaves were not permitted to inherit property from their siblings. The Court held that the law did not violate the Equal Protection Clause.
• Western Oil Refining Co. v. Lipscomb, 244 U.S. 346 (1917): The Court found that a privilege tax levied by the State of Tennessee against an Indiana corporation selling oil in Tennessee was a tax upon interstate commerce and therefore violated the Commerce Clause. In determining whether the commerce was intrastate or interstate, the Court emphasized that the route the barrels undertook constituted one independent journey from Illinois and Indiana to Columbia and Mount Pleasant, Tennessee. The Court found that the stop in Columbia, Tennessee prior to traveling to Mount Pleasant, Tennessee did not break the continuity of movement that originated in Illinois and Indiana.
• Tennessee Elec. Power Co. v. Tennessee Val. Authority, 306 U.S. 118 (1939): A group of private power companies sought to enjoin the federally chartered Tennessee Valley Authority (TVA) from producing and selling electric power. They contended that the federal law authorizing the TVA violated the Tenth Amendment. The Court held that the lawsuit should be dismissed. Although it was conceded that the competition from TVA would harm the private companies, the Court reasoned that the TVA was doing nothing more than competing as a supplier of electricity. There was therefore no basis for a suit in which TVA might be forced to invoke its congressional authorization.
• Trotter v. State of Tennessee, for Use and Benefit of Blount County, Tenn., 290 U.S. 354 (1933): A World War I veteran purchased land in Blount County using federal benefits that were exempt from taxation, and the veteran contended that the land should likewise be exempt from taxation. The Court held that the veteran’s land could be taxed. Although the World War Veterans’ Act exempted compensation that soldiers received from the Act from taxation, the Court reasoned that the statute did not do the same for soldiers’ money once their funds were converted into investments, such as land.
• Arkansas v. Tennessee, 310 U.S. 563 (1940): In 1821, land on the west bank of the Mississippi River (which at the time was part of the Territory of Arkansas) was cut off by a sudden change of the river’s course and became attached to the Tennessee side of the river. The Court held that the land was part of Tennessee. Tennessee had exercised dominion and jurisdiction over the lands since 1826. Arkansas did not become a State until 1836, and it had acquiesced in Tennessee’s exercise of dominion and jurisdiction.
• Nashville, C. & St. Ry. v. Browning, 310 U.S. 362 (1940): The Court held that the State’s practice of assessing different kinds of property at different fractions of market value did not violate the Fourteenth Amendment. The Court observed that States have the power to establish different classes of property for tax purposes. As long as such classifications are reasonable, different treatment for taxpayers in different tax classes raise no equal protection problem.
• Evers v. Dwyer, 358 U.S. 202 (1958): A black resident of Memphis, Tennessee, brought a class action in federal court seeking a declaration that Tennessee’s law requiring segregated seating on buses was unconstitutional. The district court dismissed the complaint on the ground that there was no “actual controversy”; the plaintiff had ridden a bus in Memphis only once, for the purpose of instituting the litigation and was therefore not “representative of a class of colored citizens who do use the buses in Memphis as a means of transportation.” The Supreme Court reversed and remanded, holding that a resident of a municipality who cannot use transportation facilities therein without being subjected by statute to special disabilities necessarily has a substantial, immediate, and real interest in the validity of the statute which imposes the disability.

• Baker v. Carr, 369 U.S. 186 (1962): Tennessee voters brought suit against state officials alleging that the State’s legislative apportionment violated the Equal Protection Clause by weighing votes unequally. The Court held that the suit did not present a political question and was justiciable.
• Watson v. City of Memphis, 373 U.S. 526 (1963): Black residents of Memphis sued the city in federal court seeking an injunction directing the immediate desegregation of municipal parks and other city owned facilities from which they were excluded. The Court held that the city could not further delay desegregation unless it presented constitutionally cognizable reasons for postponement and found that the city had failed to carry its burden.
• Goss v. Board of Ed. of City of Knoxville, Tenn., 373 U.S. 683 (1963): The Court ruled that a provision in a school desegregation plan that entitled a student, solely on the basis of his race and the racial composition of his school, to leave his current school where he was a racial minority, to attend a formally segregated school where he was a member of the racial majority, would inevitably lead toward the segregation of students based on race, and thereby violated Brown v. Board of Education, 349 U.S. 294 (1954).
• Monroe v. Board of Comm’rs of City of Jackson, Tenn., 391 U.S. 450 (1968): The Court held that a desegregation plan known as “free transfer,” which allowed students the option of attending a school of their choice after registering at an assigned school, had been implemented on a discriminatory basis and would inevitably lead to segregation. It therefore did not satisfy the school board’s duty to convert the school system from a racially segregated system to a nondiscriminatorysystem. The Court ordered the school board to formulate a new desegregation plan.

Marchetti v. United States, 390 U.S. 39 (1968): The petitioner in this case was convicted of several federal offenses for failing to pay a federal tax on wagering. Petitioner’s wagering activities also subjected him to potential state and federal criminal prosecution because both Tennessee and the federal government prohibited wagering. The Court held that requiring petitioner to pay the occupational tax violated his privilege against self-incrimination.

Citizens to Preserve Overton Park, Inc. v. Volpe, 401 U.S. 402 (1971): Two federal statutes prohibited the Secretary of Transportation from authorizing the use of federal funds to finance the construction of highways through public parks if a “feasible and prudent” alternative route exists. If no alternative route is available, the statutes allowed the Secretary to approve construction through parks only if there has been “all possible planning” to minimize harm to the park. A group of private citizens and local and national conservation organizations contended that the Secretary had violated the federal statutes by authorizing expenditure of federal funds to construct an interstate through Overton Park in Memphis. The Court first held that the petitioners were entitled to judicial review because the Secretary’s decision was not one that was committed to agency discretion. The Court also held that the Secretary’s decision must be reviewed first to determine whether the Secretary had acted within the scope of his statutory authority, then under arbitrary and capricious review, and finally to determine whether he had followed the necessary procedural requirements. The Court reasoned that the Secretary was not required to make formal findings to support his authorization of funding but remanded for consideration of the necessary factors based on the full administrative record.

• Dunn v. Blumstein, 405 U.S. 330 (1972): Tennessee required residence in the State for one year and in the county for three months as prerequisites for voting. The Court held that these durational residency requirements violated the Equal Protection Clause because the requirements were not necessary to achieve Tennessee’s interests in protecting the purity of the ballot box and ensuring a knowledgeable electorate.
• Nashville Gas Co. v. Satty, 434 U.S. 136 (1977): The Court held that an employer’s policy of denying accumulated seniority to employees returning from pregnancy leave constitutes sex discrimination in violation of Title VII. The Court remanded the case to determine whether the employer’s policy of not awarding sick-leave pay to its pregnant employees, when such pay was granted to employees with nonoccupational disabilities other than pregnancy, was a pretext to effect invidious discrimination.
• Tennessee Valley Authority v. Hill, 437 U.S. 153 (1978): The Court affirmed an injunction granted by the Sixth Circuit that prevented the TVA from completing construction of the Tellico Dam in order to protect against the extinction of the snail-darter. The Court found that the Endangered Species Act’s legislative history revealed a congressional decision to give endangered species priority over the “primary missions” of federal agencies.
• McDaniel v. Paty, 435 U.S. 618 (1978): The Court held that a Tennessee constitutional provision barring ministers from serving as delegates to the Tennessee constitutional convention violated the Free Exercise Clause of the First Amendment, because it conditioned a minister’s right to free exercise on the surrender of his right to seek office.
• Pickett v. Brown, 462 U.S. 1 (1983): The Court invalidated a Tennessee statute that imposed a two-year limitations period on paternity and support suits filed on behalf of children born out of wedlock. The Court concluded that the statute violated the Equal Protection Clause because it treated children born out of wedlock differently from children born to married parents and was not substantially related to a legitimate state interest.

Tennessee v. Garner, 471 U.S. 1 (1985): A Tennessee statute provided that if, after a police officer has given notice of an intent to arrest a criminal suspect, the suspect flees or forcibly resists, “the officer may use all the necessary means to effect the arrest.” A Memphis police officer shot and killed a fleeing suspect even though the officer was “reasonably sure” the suspect was unarmed. The suspect’s father sued the officer under 42 U.S.C. §1983 alleging, among other things, that the officer’s actions violated the Fourth Amendment. The Court held that the Tennessee statute violated the Fourth Amendment to the extent it authorized the use of deadly force against an unarmed, nondangerous fleeing suspect. The Court reasoned that, under the Fourth Amendment’s reasonableness requirement, deadly force may only be used if it is necessary to prevent the escape and the officer has probable cause to believe that the suspect poses a significant threat of violence to the officer or the community.

• Williamson County Regional Planning Comm’n v. Hamilton Bank of Johnson City, 473 U.S. 172 (1985): The Court held that the Fifth Amendment does not require that just compensation be paid in advance of, or contemporaneously with, a taking. If a State provides an adequate procedure for seeking just compensation, the property owner cannot claim a violation of the Just Compensation Clause until it has used the procedure and been denied just compensation.
• Brandon v. Holt, 469 U.S. 464 (1985): The Court held that a lawsuit filed under 42 U.S.C. § 1983 against the Director of the Memphis Police Department in his official capacity was a suit against the City of Memphis. The City was not allowed to assert a qualified immunity defense because that defense was available only to officials sued in their individual capacities.
• Burson v. Freeman, 504 U.S. 191 (1992): The Court upheld the constitutionality of Tennessee’s statute forbidding the solicitation of votes and the display or distribution of campaign materials within 100 feet of entrances to polling places. After subjecting the statute to exacting scrutiny because it amounted to a content-based restriction on speech, the Court held that the statute was narrowly drafted to serve a compelling state interest. The Court also noted that the statute did not completely block out the presence of political messages.
• Harris v. Forklift Systems, Inc., 510 U.S. 17 (1993): The Court reversed the Sixth Circuit’s dismissal of an employee’s claim of gender harassment under Title VII. The Court held that (1) to be actionable as “abusive work environment” harassment, conduct need not seriously affect an employee’s psychological well-being or lead the plaintiff to suffer injury, (2) the standard for proving an objectively hostile or abusive environment is one that a reasonable person would find hostile or abusive—as well as the victim's subjective perception that the environment is abusive, and (3) whether an environment is “hostile” or “abusive” can only be determined by looking at the totality of the circumstances, not just one single factor.
• McKennon v. Nashville Banner Publ’g Co., 513 U.S. 352 (1995): The Court held that an employee is not precluded from recovering under the Age Discrimination in Employment Act (ADEA) when, after the employee’s discharge, the employer discovers evidence of wrongdoing that would have given the employer legitimate grounds to discharge the employee. The Court also concluded that, as a general rule, neither reinstatement nor front pay is an appropriate remedy in such cases.
• Richardson v. McKnight, 521 U.S. 399 (1997): The Court held that prison guards employed by a private firm are not entitled to a qualified immunity from suits brought by prisoners under 42 U.S.C. §1983. The Court reasoned that there was no firmly rooted tradition of immunity applicable to privately employed prison guards, and allowing privately employed prison guards to assert qualified immunity would not further the purposes of immunity.
• Rogers v.