Today in Supreme Court History: March 13, 1963

3/13/1963: Ernesto Miranda is arrested.

Comments

[Dan Schiavetta]

Klopfer v. North Carolina, 386 U.S. 213 (decided March 13, 1967): prosecutor can’t say “nolle prosequi” (decide not to go forward) and yet keep the defendant on a long leash; North Carolina nolle prosequi procedure, under which defendant could go where he wants but can’t move to dismiss and is subject to trial at prosecutor’s discretion, violates Sixth Amendment speedy trial right

Clyatt v. United States, 197 U.S. 207 (decided March 13, 1905): conviction for peonage (abducting debtors and forcing them to work off the debt) reversed because no showing that debtors were “returned” to peonage per the indictment (picky, picky); court also affirms that peonage statute is a valid application of Thirteenth Amendment

Fortnightly Corp. v. United Artists Television, Inc., 392 U.S. 390 (decided March 13, 1968): transmitting movies via cable TV was not “performing” them so as to violate Copyright Act (which was then amended to expand definition of “performing”, see American Broadcasting Cos. v. Aereo, Inc., 2014)

FTC v. Jantzen, Inc., 386 U.S. 228 (decided March 13, 1967): Finality Act of 1959 (changing the FTC’s procedures for enforcement of the Clayton Act) did not void existing FTC orders

United States v. Dakota-Montana Oil Co., 288 U.S. 459 (decided March 13, 1933): Congress can be said to approve of agency’s construction of a statute if it re-enacts statute without material change (here, basis of an oil depletion allowance)

Texas v. Florida, 306 U.S. 398 (decided March 13, 1939): Texas interpleads three other states to determine which state gets the estate taxes of a man whose domicile might have been in one of four states (dead man was a multimillionaire who lived all over); Court confirms Special Master’s conclusion that it was Massachusetts; opinion expounds on the nature of the Court’s original jurisdiction and concludes that it encompasses equitable devices such as interpleader

Affolder v. New York, Chicago & St. Louis R.R. Co., 339 U.S. 96 (decided March 13, 1950): under Federal Safety Appliance Act, railroad is strictly liable for failure of couplers to connect on contact (plaintiff lost his leg falling off car that he was trying to stop due to non-coupling)

Johnson v. Yellow Cab Transit Co., 321 U.S. 383 (decided March 13, 1944): on a military reservation (Fort Sill) United States law applied, not Oklahoma law prohibiting transportation into state of liquor without a license (Court orders return to Officers’ Club of liquors shipped in from Illinois)

Hipolite Egg Co. v. United States, 220 U.S. 45 (decided March 13, 1911): federal court has jurisdiction over seizing adulterated food after it has reached its destination in-state (here, cans of “preserved eggs” used for baking which were found to be tainted with boric acid -- a sign that cockroaches were around during preparation, if you ask me!)

United States v. Post, 148 U.S. 124 (decided March 13, 1893): law limiting letter carriers to eight hours a day included non-letter-carrying time (e.g., other tasks around the post office)

[JoeFromtheBronx]

I talked about Miranda recently so won't repeat.

Clyatt v. United State was one of several "peonage" rulings decided by the Supreme Court over the years. For instance, Taylor v. Georgia, 315 U.S. 25 (1942) was one of the few opinions written by Justice Byrnes.

As one summary noted:

Peonage, also called debt slavery or debt servitude, is a system where an employer compels a worker to pay off a debt with work. Legally, peonage was outlawed by Congress in 1867. However, after Reconstruction, many Southern black men were swept into peonage though different methods, and the system was not completely eradicated until the 1940s.

https://www.pbs.org/tpt/slavery-by-another-name/themes/peonage/

A statement about peonage from 1907 quotes Clyatt:

‘Not withstanding the fact that several United States Courts have held this law to be constitutional’ (said Judge Moody), ‘the Government is powerless to compel its enforcement or observance, even in the most typical and flagrant cases. We think we may truthfully say’ (continues Judge Moody), ‘that upon the decision of this case (Clyatt v. the United States) hangs the liberty of thousands of persons, mostly coloured, it is true, who are now being held in a condition of involuntary servitude, in many cases worse than slavery itself, by the unlawful acts of individuals, not only in violation of the thirteenth amendment to the constitution, but in violation of the law which we have under consideration.’

https://awpc.cattcenter.iastate.edu/2019/11/22/peonage-in-the-united-states-1907/

The fight against slavery and involuntary servitude in its many lingering forms was and, in some forms, continues to be a long, hard, and complicated fight.

[Dan Schiavetta]

More generally "specific performance" of a contract to do work has never been ordered, even if both sides are guilty of a breach. because it looks like peonage.

[Bored Lawyer]

Michael Mann and his lawyers were sanctioned for presenting false evidence to the jury in his defamation trial.

Here, the Court finds, by clear and convincing evidence, that Dr. Mann, through Mr. Fontaine and Mr. Williams, acted in bad faith when they presented erroneous evidence and made false representations to the jury and the Court regarding damages stemming from loss of grant funding. Specifically, the Court finds that Mr. Fontaine and Mr. Williams knowingly violated the rules of professional conduct in eliciting testimony and offering evidence related to (1) the post-publication unfunded grant amounts depicted in Exhibit 517A, and as reproduced in Exhibit 117, and (2) the post-publication funded grant amounts in Exhibit 116. The Court does not reach this decision lightly.

https://www.dropbox.com/scl/fi/yixcqfv4h1idp1xt5elo7/2025.03.12-Order-Granting-Def-s-Sanctions-Mots.pdf?rlkey=yqactvu9h9bpwlyp6q2taaj7h&e=2&st=lc9jyq5c&dl=0

Query what further professional sanctions these lawyers will suffer.

Mann's credibility is now in tatters. Wonder if he regrets bringing the suit.

[Stupid Government Tricks]

You might enjoy this.

https://wattsupwiththat.com/2025/03/06/michael-e-mann-responds-parody/

[SRG2]

It's a good thing that science doesn't depend on single individuals for authority

[Bob from Ohio]

"Query what further professional sanctions these lawyers will suffer. "

They don't work for Trump so none.

[A Japanese Student]

"Lady Chatterley's Lover" Case (Grand Bench, decided March 13, 1957): Defined "obscenity"; obscenity is a question of law, not fact; artistic works can be obscene; obscenity is not protected by freedom of speech; upheld conviction of translator (the work was published in full, 40 years later, by defendant's son) (the test is that the work is immoral, stimulates the sexual desire, is harmful to one's sense of shame; 1980 ruling limited its scope by adopting first prong of Miller test (the work, when taken as a whole, appeals to the prurient interest); the police definition of obscenity, which is less ambiguous, is that uncensored depictions of genitals is obscene)

Theft Case (Second Petty Bench, decided March 13, 1953): When a witness is examined out-of-court in the presence of defense counsel, detained defendant need not be present

Disqualification from Candidacy Case (First Petty Bench, decided March 13, 1997): Held constitutional Public Office Elections Act provision disqualifying the candidate from running for the same district for 5 years after voter bribery conviction of organized campaign manager (even if the candidate is not involved)

Siberia Prisoners of War Case (First Petty Bench, decided March 13, 1997): Former prisoners of war cannot claim compensation from the Government for claims waived under Japan-USSR Joint Declaration

Tosa High School Lightning Strike Case (Second Petty Bench, decided March 13, 2006): High school and athletic association liable for injuries caused by lightning strike during a soccer match (okay, who decided it would be a good idea to play soccer during a thunderstorm?)

[CJColucci]

I have heard, but have been unable to verify, that Mr. Miranda got into more legal trouble late in life and was going to trial. When people realized he was that Ernesto Miranda, prospective jurors were asked if they would hold that against him.

[JoeFromtheBronx]

He was dead in less than five years from his release from prison, so that must have been a somewhat narrow window.

[SMP0328]

From Wikipedia's Ernesto Miranda article:

The Supreme Court invalidated Miranda's conviction, which was tainted by the use of the confession that had been obtained through improper interrogation. The state of Arizona retried him. At the second trial, his confession was not introduced into evidence, but he was convicted again, on March 1, 1967, based on testimony given by his estranged common-law wife. He was sentenced to 20 to 30 years in prison.

Miranda was paroled in 1972. After his release, he started selling autographed Miranda warning cards for $1.50. Over the next few years, Miranda was arrested numerous times for minor driving offenses and eventually lost his license. He was arrested for the possession of a gun but the charges were dropped. However, because this violated his parole, he was sent back to Arizona State Prison for another year before being released.

Miranda was stabbed to death in a bar fight on January 31, 1976. The man who was charged with his murder invoked his rights under Miranda and then fled to Mexico; he's never been located by police since then.

[The Margrave of Azilia]

There's a movie out about the woman whom Miranda raped.

https://www.rottentomatoes.com/m/mirandas_victim/reviews