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Following are case highlights for the topic areas of Redistricting, Religious Freedom, and RICO. To access other case highlights for the 2005-2006 Term or previous terms, or to return to the main Case Highlights page, use the Topic Area menu to the right.

REDISTRICTING



REDISTRICTING
League of United Latin American Citizens v. Perry
Docket No. 05-204
Reversed in part and Remanded: U.S. District Court for the Eastern District of Texas

Argued: March 1, 2006
Decided: June 28, 2006
For Case Analysis: See ABA Preview 265

Did the Texas Legislature's statewide redistricting in 2003 constitute unconstitutional political gerrymandering?

No. Although the redrawing of one district's lines amounted to vote dilution in violation of §2 of the Voting Rights Act of 1965, there was no showing of legally impermissible use of political classification with respect to the statewide redistricting.

From the opinion by Justice Kennedy (joined in part by Chief Justice Roberts and Justices Souter, Ginsburg and Alito):

In sum, we disagree with appellants' view that a legislature's decision to override a valid, court-drawn plan mid-decade is sufficiently suspect to give shape to a reliable standard for identifying unconstitutional political gerrymanders. We conclude that appellants have established no legally impermissible use of political classifications. For this reason, they state no claim on which relief may be granted for their statewide challenge.

Dissenting in part: Justice Stevens (Joined by Justice Breyer)
Dissenting in part: Justice Souter (joined by Justice Ginsburg)
Dissenting in part: Justice Breyer
Dissenting in part: Chief Justice Roberts (joined by Justice Alito)
Dissenting in part: Justice Scalia) (joined by Justice Thomas and joined in part by Chief Justice Roberts and Justice Alito)

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RELIGIOUS FREEDOM



RELIGIOUS FREEDOM
Gonzales et al. v. O Centro Espirita Beneficente Unias Do Vegetal et al.
Docket No. 04-1084
Affirmed: The Tenth Circuit

Argued: November 1, 2005
Decided: February 21, 2006
For Case Analysis: See ABA Preview 52

Does the government have a compelling state interest in prohibiting sacramental use of hoasca tea for the purposes of seeking a preliminary injunction, under the terms of the Religious Freedom Restoration Act (RFRA) of 1993?

No. The Court ruled that the courts below did not err in holding that the government failed to demonstrate a compelling interest in barring a small religious group from the sacramental use of hoasca tea, which contains a hallucinogenic controlled substance.

From the opinion by Chief Justice Roberts (for a unanimous Court):

Under RFRA, the Federal Government may not, as a statutory matter, substantially burden a person's exercise of religion, "even if the burden results from a rule of general applicability." §2000bb-1(a). The only exception recognized by the statute requires the Government to satisfy the compelling interest test—to "demonstrat[e] that application of the burden to the person—(1) is in furtherance of a compelling government interest; and (2) is the least restrictive means of furthering that compelling governmental interest." §2000bb-1(b).

Taking no part in the decision or consideration of the case: Justice Alito

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RICO



RICO
Anza, et al. v. Ideal Steel Supply Corp.
Docket No. 04-433
Reversed in part; Vacated in part: The Second Circuit

Argued: March 27, 2006
Decided: June 5, 2006
For Case Analysis: See ABA Preview 346

Is a competitor "injured in his business or property by reason of a violation" of the Racketeer Influenced and Corrupt Organizations Act when the alleged predicate acts of racketeering activity were mail fraud but the competitor was not the party defrauded and did not rely on the alleged fraudulent behavior?

No. Under Holmes v. Securities Investor Protection Corporation (1992), proximate cause requires "some direct relation between the injury asserted and the injurious conduct alleged."

From the opinion by Justice Kennedy (joined by Chief Justice Roberts and Justices Stevens, Scalia, Souter, Ginsburg, and Alito; and joined in part by Justice Thomas):

Section 1962(c) … forbids conducting or participating in the conduct of an enterprise's affairs through a pattern of racketeering activity. … The RICO violation alleged by Ideal is that the Anzas conducted National's affairs through a pattern of mail fraud and wire fraud. The direct victim of this conduct was the State of New York, not Ideal. It was the State that was being defrauded and the State that lost tax revenue as a result. …To be sure, Ideal asserts it suffered its own harms when the Anzas failed to charge customers for the applicable sales tax. The cause of Ideal's asserted harms, however, is a set of actions (offering lower prices) entirely distinct from the alleged RICO violation (defrauding the State).

Concurring: Justice Scalia
Concurring in part and dissenting in part: Justice Thomas
Concurring in part and dissenting in part: Justice Breyer

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RICO
Mohawk Industries, Inc. v. Williams, et al.
Docket No. 05-465
Vacated: The Eleventh Circuit

Argued: April 26, 2006
Decided: June 5, 2006
For Case Analysis: See ABA Preview 364

Can a defendant corporation and its agents constitute an "enterprise" under the Racketeer Influenced and Corrupt Organizations Act, in light of the settled rule that a RICO defendant must "conduct" or "participate in" the affairs of some larger enterprise and not just its own affairs?

The writ of certiorari is dismissed as improvidently granted.

From the per curiam order:

Section 1962(c) … forbids conducting or participating in the conduct of an enterprise's affairs through a pattern of racketeering activity. … The RICO violation alleged by Ideal is that the Anzas conducted National's affairs through a pattern of mail fraud and wire fraud. The direct victim of this conduct was the State of New York, not Ideal. It was the State that was being defrauded and the State that lost tax revenue as a result. …To be sure, Ideal asserts it suffered its own harms when the Anzas failed to charge customers for the applicable sales tax. The cause of Ideal's asserted harms, however, is a set of actions (offering lower prices) entirely distinct from the alleged RICO violation (defrauding the State).

The judgment is vacated, and the case remanded to the United States Court of Appeals for the Eleventh Circuit for further consideration in light of Anza v. Ideal Steel Supply Corp. [2006].

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