U.S. Supreme Court Case Summaries: June 24, 2008

U.S. Supreme Court

Federal Preemption

NLRA

Chamber of Commerce of the U.S. v. Brown

No. 06-939

Certiorari to the Ninth Circuit

Background: Organizations whose members do business with California sued the California Attorney General to enjoin enforcement of a law that prohibits employers who receive state grants or more than $10,000 in state program funds per year from using the funds "to assist, promote or deter union organizing." The district court granted the plaintiffs partial summary judgment, holding that the National Labor Relations Act preempts the law because it regulates employer speech about union organizing under circumstances in which Congress intended free debate. The Ninth Circuit reversed, concluding the Congress did not intend to preclude states from imposing restrictions on the use of their own public funds.

Ruling: The court reverses and holds that the California law is preempted by the NLRA. Although the NLRA contains no express preemption provision, the court has held preemption necessary to implement federal labor policy in which Congress intended particular conduct to be unregulated because it is to be controlled by "the free play of economic forces."

Sixth Amendment

Self-Representation

Indiana v. Edwards

No. 07-208

Certiorari to the Supreme Court of Indiana

Background: The trial court in this criminal prosecution found Edwards suffered from schizophrenia and concluded that, although it appeared he was competent to stand trial, he was not competent to defend himself. The defendant was charged with attempted murder and other crimes for a shooting during his attempt to steal a pair of shoes. His mental condition became the subject of three competency proceedings and two self-representation requests. He was represented by appointed counsel at trial and convicted on two counts. Indiana's intermediate appellate court ordered a new trial, agreeing with Edwards that the trial court's refusal to permit him to represent himself deprived him of his constitutional right of self- representation under the Sixth Amendment. The Indiana Supreme Court affirmed.

Ruling: The court rules that the Constitution does not forbid states from insisting on a defendant's representation by counsel for those competent enough to stand trial but suffer from mental illness and are not competent to conduct trial proceedings by themselves.

Age Discrimination

Pension Plans

Kentucky Retirement Systems v. EEOC

No. 06-1037

Certiorari to the Sixth Circuit

Background: Kentucky's state retirement plan for hazardous position workers calculates normal retirement benefits based on actual years of service. The plan calculates disability benefits by adding to an employee's actual years of service the number of years an employee would have had to continue working in order to become eligible for normal retirement benefits, adding no more than the number of years the employee previously worked. The plaintiff, who continued working after becoming eligible for retirement at age 55, became disabled. He retired at age 61 and filed an age discrimination complaint with the EEOC after the plan based his pension on his actual years of service without imputing any additional years. The EEOC filed suit against Kentucky, arguing the plan failed to impute years solely because Lickteig became disabled after age 55. The district court granted Kentucky summary judgment, holding the EEOC could not establish age discrimination, but the Sixth Circuit ultimately reversed on the grounds that the plan violated the Age Discrimination in Employment Act of 1967.

Ruling: The court finds Kentucky's system does not illegally discriminate against workers who become disabled after becoming eligible for retirement based on age.

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