John Clay v. Sun Insurance Office, Ltd. | |
---|---|
Argued March 22–23, 1960 Decided June 13, 1960 | |
Full case name | Clay v. Sun Insurance Office, Ltd. |
Citations | 363 U.S. 207 ( more ) |
Court membership | |
| |
Case opinions | |
Majority | Frankfurter |
Dissent | Black, Douglas |
John Clay v. Sun Insurance Office, Ltd. | |
---|---|
Argued April 28, 1964 Decided May 18, 1964 | |
Full case name | Clay v. Sun Insurance Office, Ltd. |
Citations | 377 U.S. 179 ( more ) |
Court membership | |
| |
Case opinions | |
Majority | Douglas |
Dissent | none |
Clay v. Sun Insurance Office, Ltd., 363 U.S. 207 (1960) and 377 U.S. 179 (1964), was a conflict of laws case that was twice heard by the Supreme Court of the United States, with an initial decision remanding the case for further proceedings in 1960, and a final resolution in 1964. [1]
Plaintiff, while living in Illinois, bought an insurance policy from a company headquartered in the United Kingdom. The policy included a clause requiring that insured's seeking to sue on an insurance claim must do so within twelve months. The plaintiff later moved to Florida, which has five year statute of limitations for lawsuits brought on contracts. The plaintiff suffered a loss in Florida, and sued in Florida to recover under the policy. The District Court applied Florida law and allowed recovery. [1]
The United States Court of Appeals for the Fifth Circuit reversed, citing Home Insurance Co. v. Dick . [2] [1]
The case was appealed to the United States Supreme Court, which first considered it in 1960, noting that the circuit court of appeals could not "make a competent guess" about how the Florida courts would construe an insurance statute. The court observed that the Florida legislature had passed a statute allowing the federal courts to certify questions of state law to the Florida Supreme Court, but that the Florida courts had not yet made a rule establishing procedures under the statute. After this decision, various states began to adopt statutes or rules allowing for the certification of questions of state law to state courts. [3] The Supreme Court remanded Clay to the Fifth Circuit for reconsideration in an opinion drawing dissents from Justices Black and Douglass. After further litigation before the Court of Appeals, the case was again appealed to the Supreme Court in 1964, this time obtaining a final resolution.
On appeal in 1964, the Supreme Court considered whether the contacts between the defendant insurance company and the forum state of Florida were sufficient to avoid a violation of Fourteenth Amendment due process or of the Full Faith and Credit Clause. Justice Douglas, writing for the unanimous court, found that Home Insurance Co. v. Dick was distinguishable based on the absence of contacts between the claimant in that case and the state in which the lawsuit was brought. [1] However, because insurance contracts are transitory, insurers must expect policy holders to move to other states, and for the policies to be subject to the laws of those states. The insurer in Clay's case did business throughout the United States, and had no particular affinity for the laws of Illinois, while Clay had ample contacts with Florida sufficient to satisfy Fourteenth Amendment due process or Full Faith and Credit. [1]
Conflict of laws in the United States is the field of procedural law dealing with choice of law rules when a legal action implicates the substantive laws of more than one jurisdiction and a court must determine which law is most appropriate to resolve the action. In the United States, the rules governing these matters have diverged from the traditional rules applied internationally. The outcome of this process may require a court in one jurisdiction to apply the law of a different jurisdiction.
In the United States, removal jurisdiction allows a defendant to move a civil action or criminal case filed in a state court to the United States district court in the federal judicial district in which the state court is located. A federal statute governs removal.
Sáenz v. Roe, 526 U.S. 489 (1999), was a landmark case in which the Supreme Court of the United States discussed whether there is a constitutional right to travel from one state to another. The case was a reaffirmation of the principle that citizens select states and not the other way round.
Insurance bad faith is a tort unique to the law of the United States that an insurance company commits by violating the "implied covenant of good faith and fair dealing" which automatically exists by operation of law in every insurance contract.
Plaut v. Spendthrift Farm, Inc., 514 U.S. 211 (1995), was a landmark case about separation of powers in which the Supreme Court of the United States held that Congress may not retroactively require federal courts to reopen final judgments. Writing for the Court, Justice Scalia asserted that such action amounted to an unauthorized encroachment by Congress upon the powers of the judiciary and therefore violated the constitutional principle of separation of powers.
Aetna Health Inc. v. Davila, 542 U.S. 200 (2004), was a United States Supreme Court case in which the Court limited the scope of the Texas Healthcare Liability Act (THCLA). The effective result of this decision was that the THCLA, which held Case Management and Utilization Review decisions by Managed Care entities like CIGNA and Aetna to a legal duty of care according to the laws of The State of Texas could not be enforced in the case of Health Benefit plans provided through private employers, because the Texas statute allowed compensatory or punitive damages to redress losses or deter future transgressions, which were not available under ERISA § 1132. The ruling still allows the State of Texas to enforce the THCLA in the case of Government-sponsored (Medicare, Medicaid, Federal, State, Municipal Employee, etc., Church-sponsored, or Individual Health Plan Policies, which are saved from preemption by ERISA. The history that allows these Private and Self-Pay Insurance to be saved dates to the "Interstate Commerce" power that was given the federal Government by the Supreme Court. ERISA, enacted in 1974, relied on the "Interstate Commerce" rule to allow federal jurisdiction over private employers, based on the need of private employers to follow a single set of paperwork and rules for pensions and other employee benefit plans where employers had employees in multiple states. Except for private employer plans, insurance can be regulated by the individual states, and Managed Care entities making medical decisions can be held accountable for those decisions if negligence is involved, as allowed by the Texas Healthcare Liability Act.
Bell v. Maryland, 378 U.S. 226 (1964), provided an opportunity for the Supreme Court of the United States to determine whether racial discrimination in the provision of public accommodations by a privately owned restaurant violated the Equal Protection and Due Process Clauses of the 14th Amendment to the United States Constitution. However, due to a supervening change in the state law, the Court vacated the judgment of the Maryland Court of Appeals and remanded the case to allow that court to determine whether the convictions for criminal trespass of twelve African American students should be dismissed.
In United States law, the federal government as well as state and tribal governments generally enjoy sovereign immunity, also known as governmental immunity, from lawsuits. Local governments in most jurisdictions enjoy immunity from some forms of suit, particularly in tort. The Foreign Sovereign Immunities Act provides foreign governments, including state-owned companies, with a related form of immunity—state immunity—that shields them from lawsuits except in relation to certain actions relating to commercial activity in the United States. The principle of sovereign immunity in US law was inherited from the English common law legal maxim rex non potest peccare, meaning "the king can do no wrong." In some situations, sovereign immunity may be waived by law.
Tolling is a legal doctrine that allows for the pausing or delaying of the running of the period of time set forth by a statute of limitations, such that a lawsuit may potentially be filed even after the statute of limitations has run. Although grounds for tolling the statute of limitations vary by jurisdiction, common grounds include:
In the law of the United States, a certified question is a formal request by one court from another court, usually but not always in another jurisdiction, for an opinion on a question of law.
Stop the Beach Renourishment v. Florida Department of Environmental Protection, 560 U.S. 702 (2010), was a United States Supreme Court case in which the Court held that the Florida Supreme Court did not effect an unconstitutional taking of littoral property owners' rights to future accretions and to contact the water by upholding Florida's beach renourishment program.
South Carolina v. Catawba Indian Tribe, Inc., 476 U.S. 498 (1986), is an important U.S. Supreme Court precedent for aboriginal title in the United States decided in the wake of County of Oneida v. Oneida Indian Nation of New York State (1985). Distinguishing Oneida II, the Court held that federal policy did not preclude the application of a state statute of limitations to the land claim of a tribe that had been terminated, such as the Catawba tribe.
O'Gorman & Young, Inc. v. Hartford Fire Ins. Co., 282 U.S. 251 (1931), was a case in which the United States Supreme Court held that a state statute limiting the commissions allowable by insurers against loss by fire to local agents will be deemed a valid exercise of the police power in the absence of facts showing it to be unreasonable.
King v. Burwell, 576 U.S. 473 (2015), was a 6–3 decision by the Supreme Court of the United States interpreting provisions of the Patient Protection and Affordable Care Act (ACA). The Court's decision upheld, as consistent with the statute, the outlay of premium tax credits to qualifying persons in all states, both those with exchanges established directly by a state, and those otherwise established by the Department of Health and Human Services.
In Brenner v. Scott and its companion case, Grimsley v. Scott, a U.S. district court found Florida's constitutional and statutory bans on same-sex marriage unconstitutional. On August 21, 2014, the court issued a preliminary injunction that prevented that state from enforcing its bans and then stayed its injunction until stays were lifted in the three same-sex marriage cases then petitioning for a writ of certiorari in the U.S. Supreme Court–Bostic, Bishop, and Kitchen–and for 91 days thereafter. When the district court's preliminary injunction took effect on January 6, 2015, enforcement of Florida's bans on same-sex marriage ended.
Home Insurance Co. v. Dick, 281 U.S. 397 (1930), was one of the earliest conflict of laws cases in which the United States Supreme Court held that the U.S. Constitution imposes certain limitations on the ability of states to apply their own law to events occurring in other states.
Watson v. Employers Liability Assurance Corp., 348 U.S. 66 (1954), was a conflict of laws case decided by the Supreme Court of the United States.
Allstate Insurance Co. v. Hague, 449 U.S. 302 (1981), was a conflict of laws case decided by the United States Supreme Court.
Sun Oil Co. v. Wortman, 486 U.S. 717 (1988), was a conflict of laws case decided by the United States Supreme Court.
The Supreme Court of the United States handed down eight per curiam opinions during its 2014 term, which began October 6, 2014 and concluded October 4, 2015.