Lamb's Chapel v. Center Moriches Union Free School District
Jun 07, 1993
OUTCOME: Judgment for Plaintiffs
In this action, Center Moriches denied Lamb's Chapel's application to use its facilities after school hours to show a film series on family life issues. The school's denial was based on the religious ...perspective of the film series. Injunctive relief was denied in the trial court, and that decision affirmed by the Second Circuit. On certiorari, the Supreme Court found the exclusion of the film series violated the prohibition on viewpoint-based discrimination.
Civil rights
Jayne Bray v. Alexandria Women's Health Center
Jan 13, 1993
OUTCOME: Reversed in part, vacated in part, remanded
Several abortion clinics, and organizations that supported the operation of such clinics, sued, under 42 USCS 1985(3)--which provides a cause of action for damages, if two or more persons conspire for ...the purpose of (1) depriving, either directly or indirectly, any person or class of persons of equal protection of the laws or equal privileges and immunities under the laws, or (2) preventing or hindering the constituted authorities of any state or territory from giving or securing the equal protection of the laws--and under state law, to enjoin the conduct of demonstrations at abortion clinics in the Washington, D.C., metropolitan area by an association and individuals who organized, in various parts of the country, antiabortion demonstrations in which participants trespassed on, and obstructed general access to, the premises of abortion clinics.
The United States District Court for the Eastern District of Virginia (1) held that the demonstration organizers had violated 1985(3) by conspiring to deprive women seeking abortions of their right, under the Federal Constitution, to interstate travel; (2) upheld the clinics' and their supporters' pendent state-law claims of trespass and public nuisance; (3) as relief on the federal and state claims, enjoined the demonstration organizers from trespassing on, or obstructing access to, abortion clinics in specified Virginia counties and cities in the Washington, D.C., metropolitan area; and (4) ordered the demonstration organizers to pay the attorneys' fees and costs of the clinics and their supporting organizations, pursuant to 42 USCS 1988's authorization of orders requiring such payments to prevailing parties (726 F Supp 1483).
The United States Court of Appeals for the Fourth Circuit affirmed the District Court judgment (914 F2d 582).
On certiorari, the Supreme Court reversed in part, vacated in part, and remanded the case for further proceedings.
In an opinion by Scalia, J., joined by Rehnquist, Ch. J., and White, Kennedy, and Thomas, JJ., it was held that
(1) the first--"deprivation"--clause of 1985(3) did not provide a federal cause of action against the demonstration organizer, because it was not shown that (a) a class-based, invidiously discriminatory animus lay behind the obstruction of the abortion clinics, since (i) "women seeking abortion" is not a class qualifying for protection under 1985(3), and (ii) the demonstration organizers' opposition to abortion did not reflect an animus against women in general, where a purpose directed specifically at women as a class was not shown, or (b) the demonstration organizers' intent was to interfere with rights protected against private encroachment, where (i) a conspiracy to violate the right, under the Constitution, of interstate travel was not shown, and (ii) deprivation of the right to an abortion, under the Constitution, cannot, for purposes of 1985(3), be the object of a purely private conspiracy;
(2) the Supreme Court would not find a violation of the second--"hindrance"--clause of 1985(3), because (a) the issue whether the hindrance clause was violated was not properly before the Supreme Court, and (b) at any rate, it was not clear that a violation of the hindrance clause could be established, since (i) the hindrance clause claim seemed to require class-based animus, and (ii) it had not been concluded in the Federal District Court below that impeding law enforcement was the purpose of the antiabortion protests; and
(3) the abortion clinics and their supporters were not entitled to an award of attorneys' fees and costs.
