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United States Constitutional Law
United States Supreme
Court Case Summaries
 April 25, 2000
 

United States constitutional Law
United States Supreme Court Case Summaries
April 25, 2000

U.S. Supreme Court Opinions
Case Summaries - April 25, 2000

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INTELLECTUAL PROPERTY LAW

NELSON v. ADAMS USA, INC., et al. (4/25/00 - No. 99-502)
Certiorari to the United States Court of Appeals for the Federal Circuit
Argued March 27, 2000--Decided April 25, 2000
Ohio Cellular Products Corporation (OCP) sued respondent Adams USA, Inc.
(Adams), for patent infringement. The District Court dismissed OCP's claim
and ordered OCP to pay Adams' costs and attorney fees. In awarding costs and
fees, the court determined that petitioner Nelson, president and sole
shareholder of OCP, had deceitfully withheld from the United States Patent
and Trademark Office prior art that rendered OCP's patents invalid, and that
this behavior constituted inequitable conduct chargeable to OCP. Fearing
that OCP might be unable to pay the fee, Adams moved under Rule 15 of the
Federal Rules of Civil Procedure to amend its pleading to add Nelson,
personally, as a party from whom fees could be collected. Adams also asked
the court, under Rule 59(e), to amend the judgment to make Nelson
immediately liable for the fee award.  The District Court granted Adams'
motion in full.
Held: The District Court erred in amending the judgment immediately upon
permitting amendment of the pleading. Due process, as reflected in Rule 15
as well as Rule 12, required that Nelson be given an opportunity to respond
and contest his personal liability for the fee award after he was made a
party and before the entry of judgment against him. Pp. 4-11.
175 F. 3d 1343, reversed and remanded.
Ginsburg, J., delivered the opinion for a unanimous Court.
To read the full text of this opinion, go to:
http://laws.findlaw.com/us/000/99-502.html 
INTELLECTUAL PROPERTY LAW: NELSON v. ADAMS USA, INC., et al. (4/25/00 - No. 99-502-USACL)


CRIMINAL LAW

EDWARDS, WARDEN v. CARPENTER (4/25/00 - No. 98-2060)
Certiorari to the United States Court of Appeals for the Sixth Circuit
Argued February 28, 2000--Decided April 25, 2000
Respondent pleaded guilty while maintaining his innocence to Ohio murder and
robbery charges in exchange for the prosecutor's agreement that the plea
could be withdrawn if the death penalty was imposed. The Ohio Court of
Appeals affirmed his conviction and sentence of imprisonment, and he did not
appeal to the Ohio Supreme Court. After pursuing state postconviction relief
pro se, respondent, represented by new counsel, petitioned the Ohio Court of
Appeals to reopen his direct appeal, claiming that his original appellate
counsel was constitutionally ineffective in failing to challenge the
sufficiency of the evidence supporting his conviction and sentence. The
court dismissed the application as untimely under Ohio Rule of Appellate
Procedure 26(B), and the Ohio Supreme Court affirmed. Respondent then filed
a federal habeas petition, raising, inter alia, the
sufficiency-of-the-evidence claim, and alleging that his appellate counsel
was constitutionally ineffective in not raising that claim on direct appeal.
Held: A procedurally defaulted ineffective-assistance claim can serve as
cause to excuse the procedural default of another habeas claim only if the
habeas petitioner can satisfy the "cause and prejudice" standard with
respect to the ineffective-assistance claim itself. The procedural default
doctrine and its attendant "cause and prejudice" standard are grounded in
comity and federalism concerns, Coleman v. Thompson, 501 U. S. 722, 730
http://caselaw.findlaw.com/cgi-bin/getcase.pl?navby=case&court=US&vol=501&in
vol=722&pageno=730, and apply whether the default occurred at trial, on
appeal, or on state collateral attack, Murray v. Carrier, 477 U. S. 478
http://caselaw.findlaw.com/cgi-bin/getcase.pl?navby=case&court=US&vol=477&in
vol=478, 490-492. Thus, a prisoner must demonstrate cause for his
state-court default of any federal claim, and prejudice therefrom, before
the federal habeas court will consider that claim's merits. 501 U. S., at
750
http://caselaw.findlaw.com/cgi-bin/getcase.pl?navby=case&court=US&vol=501&pa
ge=750. Counsel's ineffectiveness in failing properly to preserve a claim
for state-court review will suffice as cause, but only if that
ineffectiveness itself constitutes an independent constitutional claim.
Carrier, supra, at 488-499. The comity and federalism principles underlying
the doctrine of exhaustion of state remedies require an
ineffective-assistance claim to be presented to the state courts as an
independent claim before it may be used to establish cause for a procedural
default. Carrier, supra, at 489. The doctrine's purposes would be frustrated
if federal review were available to a prisoner who had presented his claim
in state court, but in such a manner that the state court could not, under
its procedural rules, have entertained it. Pp. 4-7.
163 F. 3d 938, reversed and remanded.
Scalia, J., delivered the opinion of the Court, in which Rehnquist, C. J.,
and O'Connor, Kennedy, Souter, Thomas, and Ginsburg, JJ., joined. Breyer,
J., filed an opinion concurring in the judgment, in which Stevens, J.,
joined.
To read the full text of this opinion, go to:
http://laws.findlaw.com/us/000/98-2060.html 
CRIMINAL LAWEDWARDS, WARDEN v. CARPENTER (4/25/00 - No. 98-2060)-USACL

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United States Supreme Court Case Summaries 04-25-2000
April 25, 2000INTELLECTUAL PROPERTY LAW NELSON v. ADAMS USA, INC.,
USACL