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Supreme Court rules in federal immunity, sentencing, discrimination cases

[JURIST] The US Supreme Court [official website] on Wednesday handed down decisions in four cases, including Dolan v. U.S. Postal Service [Duke Law backgrounder; JURIST report], where the Court ruled that a Pennsylvania woman could sue the US Postal Service for injuries she sustained after slipping on a pile of mail that was left on her porch rather than in her mail box. Barbara Dolan sued, arguing that the mail had negligently been left on the porch but the lower courts dismissed the case [opinion, PDF], ruling that the claim was barred under the Federal Tort Claims Act (FTCA) [text]. The Supreme Court reversed the decision, holding that FTCA's postal exception, which bars claims arising out of "the negligent transmission of letters or postal matter," is limited in scope and does not apply to this case. Read the Court's opinion [text], per Justice Kennedy, along with a dissent [text] from Justice Thomas. AP has more.

In Oregon v. Guzek [Duke Law backgrounder; JURIST report], the Court held that states may limit the evidence that a convicted defendant may provide at sentencing to evidence that was introduced at the original trial. The Court also held that it has not interpreted "the Eighth Amendment as providing such a defendant the right to introduce at sentencing evidence designed to cast 'residual doubt' on his guilt...." The Court was considering an appeal of an Oregon Supreme Court ruling [text], which held that Randy Lee Guzek should have been allowed to introduce "alibi evidence" during the sentencing phase, even though that evidence was not introduced at trial. Read the Court's opinion [text], per Justice Breyer, along with a concurrence from Justice Scalia, who was joined by Justice Thomas. AP has more.

In Arbaugh v. Y & H Corp. [Duke Law backgrounder], the Court ruled that the employee threshold requirement in Title VII of the 1964 Civil Rights Act [text; EEOC backgrounder] "does not circumscribe federal-court subject-matter jurisdiction." Jenifer Arbaugh had sued a New Orleans restaurant for sexual discrimination and won a $40,000 judgment. On appeal, the company argued that it did not have 15 employees, the threshold requirement for Title VII to apply, and the district court ruled that it lacked subject matter jurisdiction and reversed the jury verdict. The US Court of Appeals for the Fifth Circuit upheld that decision [opinion, PDF] but the Supreme Court reversed the appeals court, holding that the number of employees "relates to the substantive adequacy of Arbaugh's Title VII claim, and therefore could not be raised defensively late in the lawsuit." Read the Court's unanimous opinion [text], per Justice Ginsburg.

Finally, in Domino's Pizza v. McDonald [Duke Law backgrounder; JURIST report], the Court held that a Nevada businessman could not sue Domino's Pizza [corporate website] for racial discrimination because he did not have an individual contract with the company. McDonald alleged that Domino's refused to honor its construction contracts with McDonald's company because he is black, but the Court reversed the Ninth Circuit's decision [text] and ruled that McDonald, as an individual, did not have a contractual relationship with Domino's and therefore could not bring a claim under Section 1981 [text]. Read the Court's unanimous opinion [text], per Justice Scalia. AP has more. All four cases were argued before Justice Samuel Alito was confirmed to the Court and he did not participate in any of the cases.

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