Alito’s first opinion; Court rules on estate dispute
In the first opinion by new Justice Samuel A. Alito, Jr., the Supreme Court on Monday unanimously struck down an evidence rule barring a criminal defendant from introducing evidence that someone else committed the crime. That ruling came in the case of Holmes v. South Carolina (04-1327).
The state had a rule that evidence alleging another person’s guilt is not allowed, if the prosecution had offered “strong” physical evidence of guilt. The state Supreme Court decided that, when the prosecution has put on a case with strong forensic evidence, providing a strong indication of guilt, evidence about a third party’s alleged culpability cannot be admitted because it does not raise a reasonable inference of innocence. Writing for the Court, Alito’s opinion said that this focuses on the strength of only one party’s evidence, and that kind of analysis cannot support a conclusioon about the strength of contrary evidence.
In a second ruling, with no dissent, the Court decided that federal courts have some authority to decide questions about rights that are tied to disputes over estates, but did make clear that probate law remains the domain of the states.That ruling came in a case involving a well-known topless dancer and model, Anna Nicole Smith. As a result of the decision, a federal court has authority to consider her claim in a bitter dispute in Texas and federal courts over the estate of her late husband, Texas tycoon J. Howard Marshall II.
Announcing the opinion, Justice Ruth Bader Ginsburg said that the “probate exception” to federal court jurisdiction “reserves to state courts the probate or annulment of a will and the administration of a decedent’s estate. It also, and most importantly, precludes federal courts from disposing of property that is in the custody of a state court. But that is the sum and substance of it. The probate exception does not bar federal courts from adjudicating matters outside those confines and otherwise within federal jurisdiction.”
Ms. Smith, whose name is Vickie Lynn Marshall, went to federal bankruptcy court to allege fraud by her former husband’s son, and ultimately won damages of $88.6 million. The son took the case to the Ninth Circuit Court, which ruled that federal courts had no jurisdiction over the case because the estate had been probated in Texas courts. The Circuit Court ordered Mrs.Marshall’s claim dismissed, in a total victory for Marshall’s son Pierce.
The case, Marshall v. Marshall (04-1544), now goes back to the Circuit Court to settle some issues that the Court said remain open. The damages verdict thus may be far from final. All members of the Court joined in the result, but Justice John Paul Stevens did not join in full in Ginsburg’s opinion. He said in a separate opinion that there should be no probate exception “that ousts a federal court of jurisdiction it otherwise possesses.”
The Court said that Mrs. Marshall’s claim in bankruptcy court “alleges the widely recognized tort of interference with a gift or inheritance.” She thus is seeking a judgment against the son, not the probate or annulment of a will, Ginsburg noted. “Under our federal system, Texas cannot render its probate courts exclusively competent to entertain a claim of that genre, the Court concluded.
(See the end of this post for more on the issues on remand of the Marshall case to the Ninth Circuit.)
In the last of three cases decided Monday, the Court limited the power of states to place a lien on Medicaid benefit payments that an individual is entitled to receive. The decision, written by Justice Stevens, came in the case of Arkansas Department of Human Services v. Ahlborn (04-1506). The case involved a woman who had received $550,000 in a settlement for her injuries in a car accident. The state had claimed that it had a right to recover the full amount of Medicaid benefits it had paid to the woman — $215,645. But the Court ruled that it could collect only $35,581.47. That amount represents the portion of the settlement award that related to medical expenses — the only part the Court said Arkansas could reclaim. The remainder of the claim, the Court said, would violate the anti-lien provisions of federal law.
The Court, in the only case granted review Monday, agreed to try again to clarify the constitutionality of a California jury instruction, a “catch-all” instruction on consideration of evidence favorable to an accused in a death penalty case. The case, one that the Court examined nine times since January before deciding to hear it, is Ornaski v. Belmontes (05-493). The Court had ruled twice before on the so-called “factor k” instruction.
Among the cases the Court refused to hear was a new appeal in the celebrated “Nuremberg Files” cases, involving anti-abortion groups’ aggressive publicity campaign against doctors who perform abortions. The denial Monday was the second in the case by the Court in the past three years. As a result, two groups, the American Coalition for Life Activists and Advocates for Life Ministries, plus 11 individuals will have to pay $4.7 million in punitive damages, plus $11 million in treble damages under the RICO law, and $526,000 in compensatory damages to two abortion clinics in Oregon and two doctors who perform abortions. The case was American Coalition, et al., v Planned Parenthood, et al. (05-1083).
Again on Monday, the Court took no action on a major affirmative action issue — whether its rulings allowing limited use of race in college admissions will apply to student assignment plans in the public elementary and secondary schools. The new cases are from Seattle, Wash. (docket 05-908), and Louisville, Ky. (05-915).
In the Marshall estate case, Justice Ginsburg’s opinion noted that two issues remain open when the case goes back to the Ninth Circuit. IThe resolution of those issues either could mean an even higher damage award for Mrs. Marshall, or the total loss of what she had won in federal court.
Ginsburg cited two unresolved issues. The one that is critical to Mrs. Marshall is a question of whether the District Court should have undertaken its own, independent review of her claim that Pierce Marshall had wrongly interfered with her gift from her late husband. If the District Court was wrong in finding that he claim was not a “core proceeding” under bankruptcy law, that could go at least some of the way to restoring the bankruptcy court verdict awarding her $474 million (compared with $88.6 million awarded by the District Court after its independent review(.
The second issue noted by Ginsburg is a claim by Pierce Marshall that Mrs. Marshall could not raise her interference claim in federal court because her claim essentially was disposed of in the Texas state court probate case. If it should turn out that her claim was precluded, that could restore Pierce’s victory in the Texas court, presumably nullifying any award to her.
The Ninth Circuit did not decide either of those issues, because it found the federal courts lacked jurisdiction to hear Mrs. Marshall’s claim. The Circuit Court also noted other issues that it was not deciding — and those issues conceivably could remain open on remand. Those include a claim of a violation of the U.S. Constitution’s Seventh Amendment, the Constitution’s full faith and credit clause, and the “Rooker-Feldman doctrine” against relitigating issues already tested in state court. It is unclear whether any or all of those issues survive the Supreme Court’s ruling Monday that the federal courts were open to hear Mrs. Marshall’s claim.