Today in Supreme Court History: January 14

Wong Sun v. United States, 371 U.S. 471 (decided January 14, 1963): the leading “fruit of the poisonous tree” case, where statements made after unlawful entry as to drug sale were excluded, as well as heroin seized; but voluntary confession made when defendant went to police station several days later was admissible because the “taint” was sufficiently “attenuated” (facts too complicated to summarize here)

Mississippi ex rel. Hood v. AU Optronics Corp., 571 U.S. 161 (decided January 14, 2014): defendant can’t automatically remove class action brought by State suing on behalf of its citizens (alleged illegal price-fixing as to LCD screens) because citizens are not specifically named; Class Action Fairness Act (allowing removal) requires at least 100 named claimants

Daimler AG v. Bauman, 571 U.S. 117 (decided January 14, 2014): The Court here to everybody’s surprise all but obliterates traditional general (or “doing business in state”) jurisdiction, departing from the International Shoe “fairness” standard and in effect striking down dozens of state jurisdictional statutes.  It holds that it’s a violation of Due Process to sue a business anywhere except 1) its state of incorporation, 2) its main place of business, or 3) where the conduct sued upon happened (in other words, only where it’s “at home”).  Here, former Argentina citizens alleged that Daimler (actually its subsidiary, Mercedes Benz, but the Court treats them as the same) delivered labor leaders up for torture by reporting them to the Argentina dictatorship.  Sotomayor concurs as to lack of jurisdiction but on the grounds that there are obvious better forums, such as Germany (following the Court’s standard reasoning in such situations since Asahi, 1987) and points out that the Court went beyond the arguments presented to it and its holding is a gift to big business.  (I.e., if something you buy in Oregon injures you due to the Virginia manufacturer’s design defect, you have to go to Virginia to sue.)  Opinion by Ginsburg.

Oregon v. Ice, 555 U.S. 160 (decided January 14, 2009): not a Sixth Amendment violation to have a judge (not a jury) find facts necessary to impose consecutive (instead of concurrent) sentences (here, finding that there were two incidents of burglary and sexual abuse of 11-year-old girl)

Herring v. United States, 555 U.S. 135 (decided January 14, 2009): evidence found during arrest was admissible even though warrant for the arrest had been recalled; the arresting officer due to a recordkeeping error had not been told about it