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Supreme Court rules Title VII protects employees from retaliatory discharge

[JURIST] The US Supreme Court [official website; JURIST news archive] on Wednesday decided six cases. The Court ruled [opinion, PDF] unanimously in Crawford v. Nashville and Davidson County [Cornell LII backgrounder; JURIST report] that Title VII of the 1964 Civil Rights Act [text] protects a government employee against being fired for cooperating with an internal sexual harassment probe against a superior. The issue came before the court in a case where a payroll employee in the Nashville school system was interviewed as part of an investigation into harassment claims against a high-ranking official in the system, and the employee alleged that the official later fired her in retaliation for statements she made against him. Reversing a US Court of Appeals for the Sixth Circuit dismissal of the lawsuit [opinion, PDF], the court held that the Title VII protections extended to the employee even though she was not the originator of the sexual harassment claims being investigated. Writing the opinion of the court, Justice David Souter reasoned that failing to provide such employees protection would undermine the purpose of the Act:

The appeals court’s rule would thus create a real dilemma for any knowledgeable employee in a hostile work environment if the boss took steps to assure a defense under our cases. If the employee reported discrimination in response to the enquiries, the employer might well be free to penalize her for speaking up. But if she kept quiet about the discrimination and later filed a Title VII claim, the employer might well escape liability, arguing that it “exercised reasonable care to prevent and correct [any discrimination] promptly” but “the plaintiff employee unreasonably failed to take advantage of ... preventive or corrective opportunities provided by the employer.”
The Court also ruled [opinion, PDF] unanimously in Kennedy v. Plan Administrator for DuPont Savings and Investment Plan [Cornell LII backgrounder; JURIST report] that the Qualified Domestic Relations Order (QDRO) provision [text; DOL backgrounder] of the Employee Retirement Income Security Act (ERISA) is the exclusive means by which to waive one's right to a divorcing spouse's pension benefits. Justice Souter wrote the opinion of the court, affirming a decision [text] by the US Court of Appeals for the Fifth Circuit that the provision precluded the recognition of a woman's waiver of rights to her former husband's pension in a divorce proceeding.

The Court ruled [opinion, PDF] unanimously in United States v. Eurodif [Cornell LII backgrounder; JURIST report] that the reimportation of uranium enriched abroad may be subject to federal anti-dumping laws prohibiting the sale of certain goods below market value. The question before the court was whether, under 19 U.S.C. § 1673 [text], the Commerce Department [official website] could impose addition duties on the uranium because it was a good, or could not because its foreign enrichment was a service. Reversing a US Court of Appeals for the Federal Circuit decision [PDF text], Justice Souter again wrote for the majority, reasoning that, because the Commerce Department had acted reasonably when it initially ruled the transaction a sale of goods, its decision should stand.

The Court ruled [opinion, PDF] unanimously in Arizona v. Johnson [Cornell LII backgrounder; JURIST report] that the Fourth Amendment [Cornell LII backgrounder] does permit a police officer to search a vehicle passenger during a routine traffic stop if he believes the passenger may be armed and dangerous but has no justifiable reason to believe that a crime is being committed. In this case, Johnson, a passenger in a car, was frisked during a traffic stop. The officer suspected Johnson of gang affiliation, and upon pat-down she discovered a handgun and marijuana. At trial, Johnson was convicted of possession of the gun and marijuana, but the Arizona Court of Appeals Division Two [official website] overturned his conviction [opinion, PDF], finding that the evidence should have been excluded under the Fourth Amendment. Justice Ruth Bader Ginsburg wrote the opinion of the court and, reversing the lower court's decision, held that such searches were lawful as long the did not unreasonably extend the length of the stop.

The Court ruled [opinion, PDF] unanimously in Van De Kamp v. Goldstein [Cornell LII backgrounder; JURIST report] that two Los Angeles County supervising prosecutors have absolute immunity from liability for failing to establish a system that would have instructed a prosecutor to disclose at trial that a jailhouse witness received a lighter sentence in exchange for perjured testimony that wrongly convicted a suspect of murder. Thomas Goldstein, the respondent in the case, was convicted in 1980 of murder on the testimony of a jailhouse informant who committed perjury when he testified that he had not received any benefit for obtaining a confession from Goldstein. Goldstein spent 24 years in prison and was released in 2004 after he filed a federal habeas corpus suit, which was affirmed by the Ninth Circuit Court of Appeals [official website]. Reversing the lower court's decision, Justice Stephen Breyer wrote the court's opinion, and reasoned that even though granting the supervising prosecutors absolute immunity may deny some defendants compensation, the protection was necessary for the efficient administration of justice.

Finally, the Court issued [opinion, PDF] a unanimous per curiam opinion in Nelson v. United States, in which the court again vacated a sentence imposed on a man convicted of distributing cocaine because a lower court misapplied Federal Sentencing Guidelines [materials]. The court held that even though the lower court had not interpreted the guidelines as mandatory, it did, erroneously, presume them to be reasonable.

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