Facts
Plaintiff cruise passengers had filed a lawsuit in a United States district court against the defendant cruise line for injuries sustained when an Italian cruise ship, the Achille Lauro , was hijacked by terrorists. The cruise ticket included a forum selection clause which required that lawsuits against the cruise line be brought in Naples, Italy.
A plaintiff is the party who initiates a lawsuit before a court. By doing so, the plaintiff seeks a legal remedy; if this search is successful, the court will issue judgment in favor of the plaintiff and make the appropriate court order. "Plaintiff" is the term used in civil cases in most English-speaking jurisdictions, the notable exception being England and Wales, where a plaintiff has, since the introduction of the Civil Procedure Rules in 1999, been known as a "claimant", but that term also has other meanings. In criminal cases, the prosecutor brings the case against the defendant, but the key complaining party is often called the "complainant".
A lawsuit is a proceeding by a party or parties against another in the civil court of law. The archaic term "suit in law" is found in only a small number of laws still in effect today. The term "lawsuit" is used in reference to a civil action brought in a court of law in which a plaintiff, a party who claims to have incurred loss as a result of a defendant's actions, demands a legal or equitable remedy. The defendant is required to respond to the plaintiff's complaint. If the plaintiff is successful, judgment is in the plaintiff's favor, and a variety of court orders may be issued to enforce a right, award damages, or impose a temporary or permanent injunction to prevent an act or compel an act. A declaratory judgment may be issued to prevent future legal disputes.
The United States district courts are the general trial courts of the United States federal court system. Both civil and criminal cases are filed in the district court, which is a court of law, equity, and admiralty. There is a United States bankruptcy court associated with each United States district court. Each federal judicial district has at least one courthouse, and many districts have more than one. The formal name of a district court is "the United States District Court for" the name of the district—for example, the United States District Court for the Eastern District of Missouri.
The cruise line filed a motion to dismiss for lack of personal jurisdiction, based on the forum selection clause. The district court denied the motion, and the cruise line sought an interlocutory appeal of this motion. The appellate court denied the motion based on the final judgment rule, 28 U.S.C. 1291, asserting that the cruise line would have to wait until the case was decided before filing any appeals. This ruling was immediately appealed to the U.S. Supreme Court.
Personal jurisdiction is a court's jurisdiction over the parties to a lawsuit, as opposed to subject-matter jurisdiction, which is jurisdiction over the law and facts involved in the suit. If a court does not have personal jurisdiction over a party, its rulings or decrees cannot be enforced upon that party, except by comity; i.e., to the extent that the sovereign which has jurisdiction over the party allows the court to enforce them upon that party. A court that has personal jurisdiction has both the authority to rule on the law and facts of a suit and the power to enforce its decision upon a party to the suit. In some cases, territorial jurisdiction may also constrain a court's reach, such as preventing hearing of a case concerning events occurring on foreign territory between two citizens of the home jurisdiction.
The Code of Laws of the United States of America is the official compilation and codification of the general and permanent federal statutes of the United States. It contains 53 titles. The main edition is published every six years by the Office of the Law Revision Counsel of the House of Representatives, and cumulative supplements are published annually. The official version of those laws not codified in the United States Code can be found in United States Statutes at Large.
Opinion of the Court
The defendants argued that this fell under the judge-made collateral order doctrine, which allows immediate appeals of rulings that are collateral to the merits of the case, would determine it conclusively, and would not be effectively reviewable unless an immediate appeal were allowed.
The Court, in a unanimous opinion by Justice Brennan, held that the collateral order doctrine does not apply to a forum selection clause. This was not a case where the defendant was claiming a right not to be tried at all, like a sovereign immunity case, which would be disposed of before the defendant was even subject to the discovery process. Instead, the defendant was acknowledging that it could be sued, but merely disputing the appropriate forum for the suit.
Sovereign immunity, or crown immunity, is a legal doctrine by which the sovereign or state cannot commit a legal wrong and is immune from civil suit or criminal prosecution, strictly speaking in modern texts in its own courts. A similar, stronger rule as regards foreign courts is named state immunity.
Discovery, in the law of common law jurisdictions, is a pre-trial procedure in a lawsuit in which each party, through the law of civil procedure, can obtain evidence from the other party or parties by means of discovery devices such as interrogatories, requests for production of documents, requests for admissions and depositions. Discovery can be obtained from non-parties using subpoenas. When a discovery request is objected to, the requesting party may seek the assistance of the court by filing a motion to compel discovery.
Justice Scalia, concurring, wrote to express his opinion that the reason an interlocutory appeal would not stand in this case was that "the law does not deem the right important enough to be vindicated" by an interlocutory appeal.
United States appellate procedure involves the rules and regulations for filing appeals in state courts and federal courts. The nature of an appeal can vary greatly depending on the type of case and the rules of the court in the jurisdiction where the case was prosecuted. There are many types of standard of review for appeals, such as de novo and abuse of discretion. However, most appeals begin when a party files a petition for review to a higher court for the purpose of overturning the lower court's decision.
Batson v. Kentucky, 476 U.S. 79 (1986), was a case in which the United States Supreme Court ruled that a prosecutor's use of peremptory challenge in a criminal case—the dismissal of jurors without stating a valid cause for doing so—may not be used to exclude jurors based solely on their race. The Court ruled that this practice violated the Equal Protection Clause of the Fourteenth Amendment. The case gave rise to the term Batson challenge, an objection to a peremptory challenge based on the standard established by the Supreme Court's decision in this case. Subsequent jurisprudence has resulted in the extension of Batson to civil cases and cases where jurors are excluded on the basis of sex.
Strauder v. West Virginia, 100 U.S. 303 (1880), was a United States Supreme Court case about racial discrimination and United States constitutional criminal procedure. Strauder was the first instance where the Supreme Court reversed a state court decision denying a defendant's motion to remove his criminal trial to federal court pursuant to Section 3 of the Civil Rights Act of 1866.
A forum selection clause in a contract with a conflict of laws element allows the parties to agree that any disputes relating to that contract will be resolved in a specific forum. They usually operate in conjunction with a choice of law clause which determines the proper law of the relevant contract.
Carnival Cruise Lines, Inc. v. Shute, 499 U.S. 585 (1991), was a case in which the Supreme Court of the United States held that United States federal courts will enforce forum selection clauses so long as the clause is not unreasonably burdensome to the party seeking to escape it.
The Speedy Trial Act of 1974, establishes time limits for completing the various stages of a federal criminal prosecution.
Mitchell v. Forsyth, 472 U.S. 511 (1985), was a United States Supreme Court case deciding on the issue of immunity of cabinet officers from suits from individuals.
The Double Jeopardy Clause of the Fifth Amendment to the United States Constitution provides: "[N]or shall any person be subject for the same offence to be twice put in jeopardy of life or limb..." The four essential protections included are prohibitions against, for the same offense:
Burnham v. Superior Court of California, 495 U.S. 604 (1990), was a United States Supreme Court case addressing whether a state court may, consistent with the Due Process Clause of the Fourteenth Amendment, exercise personal jurisdiction over a non-resident of the state who is served with process while temporarily visiting the state. All nine justices unanimously agreed that this basis for personal jurisdiction—known as "transient jurisdiction"—is constitutionally permissible. However, the Court failed to produce a majority opinion, as the members were sharply divided on the reasons for the decision, reflecting two fundamentally different approaches to how due-process issues are to be analyzed. Justice Scalia wrote the lead opinion, joined in whole or part by three other Justices. Justice Brennan wrote an opinion joined by three other Justices. Justices White and Stevens wrote separate opinions.
Douglas v. California, 372 U.S. 353 (1963), was a case before the United States Supreme Court.
Mohawk Industries, Inc. v. Carpenter, 558 U.S. 100 (2009), is a United States Supreme Court case in which the Court held that disclosure orders adverse to attorney–client privilege do not qualify for immediate appeal under the collateral order doctrine.
Ludwig v. Massachusetts, 427 U.S. 618 (1976), was a case in which the Supreme Court of the United States held that the Massachusetts two-tier court system did not deprive Ludwig of his U.S. Const., Amend. XIV right to a jury trial and did not violate the double jeopardy clause of the U.S. Const., Amend. V.
United States v. Valenzuela-Bernal, 458 U.S. 858 (1982), is a United States Supreme Court case that determined the constitutionality of deporting aliens who might give testimony in criminal alien smuggling prosecutions. Because deporting alien witnesses might take away a testimony that would be both “material and favorable” to the defendant, it gives rise to a potential motion from the defense to dismiss the indictment under the Compulsory Process Clause of the Sixth Amendment and the Due Process Clause of the Fifth Amendment.
SEC v. Rajaratnam, 622 F.3d 159, is a United States Court of Appeals for the Second Circuit case in which defendants Raj Rajaratnam and Danielle Chiesi appealed a discovery order issued by a district court during a civil trial against them for insider trading filed by the Securities and Exchange Commission (SEC). The district court compelled the defendants to disclose to the SEC the contents of thousands of wiretapped conversations that were originally obtained by the United States Attorney's Office (USAO) and were turned over to the defendants during a separate criminal trial.
Stewart Organization, Inc. v. Ricoh Corp., 487 U.S. 22 (1988), is a United States Supreme Court case in which the Court further refined the test for determining whether federal courts sitting in diversity must apply state law as opposed to federal law under the Erie doctrine. The question in Stewart was whether the federal venue transfer statute, 28 U.S.C. § 1404(a), occupied the field or whether Alabama law's unfavorable stance towards forum-selection clauses should instead be applied. The Court held that the federal statute governed the District Court's decision whether to give effect to the forum-selection clause.
Atlantic Marine Construction Co., Inc. v. United States District Court for the Western District of Texas, 571 U.S. 49 (2013), was United States Supreme Court decision dealing with the enforcement of forum selection clauses.
Whitewood v. Wolf is the federal lawsuit that successfully challenged the Pennsylvania Marriage Laws, as amended in 1996 to ban same-sex marriage. The district court's decision in May 2014 held that the Marriage Laws violated the Due Process and Equal Protection clauses of the United States Constitution. Same-sex couples immediately sought and received marriage licenses and the decision was not appealed. One county clerk sought repeatedly without success to intervene to defend the law.
Burks v. United States, 437 U.S. 1 (1978), is a United States Supreme Court decision that clarified both the scope of the protection against double jeopardy provided by the Fifth Amendment to the United States Constitution and the limits of an appellate court's discretion to fashion a remedy under section 2106 of Title 28 to the United States Code. It established the constitutional rule that where an appellate court reverses a criminal conviction on the ground that the prosecution failed to present sufficient evidence to prove the defendant's guilt beyond a reasonable doubt, the Double Jeopardy Clause shields the defendant from a second prosecution for the same offense. Notwithstanding the power that appellate courts have under section 2106 to "remand the cause and direct the entry of such appropriate judgment, decree, or order, or require such further proceedings to be had as may be just under the circumstances," a court that reverses a conviction for insufficiency of the evidence may not allow the lower court a choice on remand between acquitting the defendant and ordering a new trial. The "only 'just' remedy" in this situation, the Court held, is to order an acquittal.
