Engblom v Carey (Landmark Court Decisions in America)💬🏛️✅

Summary

The 1982 case 'Doe v. L. Paul' is a significant legal decision by the U.S. Court of Appeals for the Second Circuit, addressing the Third Amendment's prohibition against quartering soldiers in private homes without consent. The case arose from a 1979 strike by New York State correction officers, during which National Guardsmen occupied employee housing. The court ruled that the Third Amendment applies to state authorities and extends to anyone with a legal right to exclude others from their residence, not just homeowners. Despite the ruling, the case was ultimately decided in favor of the state due to qualified immunity.

Takeaways

• 🏛️ The case 'Doe v. Lader' was a significant court decision by the United States Court of Appeals for the Second Circuit, focusing on the Third Amendment.
• ⚖️ The Third Amendment was invoked to challenge the quartering of National Guardsmen in employee housing during a correction officers' strike in New York.
• 🛡️ The court established that the National Guardsmen are considered 'soldiers' under the Third Amendment.
• 🏢 The decision affirmed that the Third Amendment applies to both state and federal authorities, indicating it is incorporated against the states.
• 🏡 The ruling expanded the scope of the Third Amendment, protecting not just homeowners but anyone with a legal expectation of privacy and the right to exclude others.
• 📜 The court held that the correctional officers' occupancy was protected under tenancy laws, thus falling under the Third Amendment's protection.
• 📊 The case was remanded to the district court, which decided in favor of the defendants due to qualified immunity as state agents.
• 👨‍⚖️ Judge Kaufman dissented, arguing that the officers' occupancy was under employee housing rules and that prison residency circumstances should override Third Amendment protections.
• 🌪️ The script suggests the Third Amendment could be relevant in the 21st century, such as in cases of natural disasters where the National Guard might need to quarter in private homes.
• ⚔️ Even in a state of war, the Third Amendment would require that National Guardsmen be housed in a manner prescribed by law, emphasizing the importance of consent from homeowners.

Q & A

What is the significance of the 'in bloom V carry 677 F point to D 957 to' case?

The case is significant as it is the only notable court decision based on a direct challenge under the Third Amendment to the United States Constitution, which deals with the quartering of soldiers in private homes.

Which court decided the 'in bloom V carry 677 F point to D 957 to' case?

The case was decided by the United States Court of Appeals for the Second Circuit.

What was the background of the case?

The case was initiated by a 1979 strike by New York State correction officers, during which National Guardsmen were activated to perform some duties and were housed in employee housing, leading to the eviction of striking employees.

Who were the petitioners in the case?

The petitioners were Mary Annie Emblem and Charles E. Palmer, two of the evicted correction officers at Mid-Orange Correctional Facility.

What were the legal claims made by the petitioners?

The petitioners claimed violations of the Due Process Clause of the Fourteenth Amendment and the Third Amendment.

What was the district court's decision regarding the petitioners' claims?

The district court found for the defendants and dismissed the suit.

What were the three important holdings established by the Court of Appeals for the Second Circuit?

The court held that: 1) National Guardsmen qualify as soldiers under the Third Amendment; 2) the Third Amendment applies to state as well as federal authorities; and 3) the protection of the Third Amendment extends beyond homeowners to anyone with a legal expectation of privacy and a right to exclude others.

How did the majority in the Court of Appeals rule on the Third Amendment claim?

The majority held that the correctional officers' occupancy was protected under the legal rules of tenancy and thus was covered by the Third Amendment.

What was the final outcome of the case after it was remanded to the district court?

The case was decided in favor of the defendants at the district court level due to the principle of qualified immunity for state agents, as they did not knowingly act illegally in the absence of previous precedents.

What was Judge Kaufman's dissenting opinion regarding the Third Amendment protection?

Judge Kaufman maintained that the officers' occupancy was covered under the lesser protection of employee housing and that the special circumstances of residency in prison grounds superseded Third Amendment protection.

How might the Third Amendment be relevant in the 21st century according to the script?

The Third Amendment could be relevant in situations where, during a major natural disaster, the National Guard is activated and decides to house its staff in private dwellings without the owner's consent, which would be prohibited by the Third Amendment.

Outlines

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🏛️ Third Amendment Court Case: In Bloom v. Carey

In Bloom v. Carey was a pivotal court case decided by the United States Court of Appeals for the Second Circuit in 1982. It was the first significant legal challenge based on the Third Amendment of the U.S. Constitution, which prohibits the quartering of soldiers in private homes without the owner's consent during peacetime. The case arose from a 1979 strike by New York State correction officers, during which the National Guard was activated to perform their duties. Striking employees were evicted from their housing, which was then used to accommodate the National Guard. Two of these officers, Mary Annie Emblem and Charles E. Palmer, sued the state of New York and Governor Hugh L. Carey, alleging violations of the Due Process Clause of the Fourteenth Amendment and the Third Amendment. The District Court dismissed the suit, but the Court of Appeals found that the National Guardsmen qualified as soldiers under the Third Amendment, that the amendment applies to state authorities, and that its protection extends to anyone with a legal expectation of privacy in their residence. The case was remanded to the District Court, which ruled in favor of the defendants due to qualified immunity. Judge Kaufman dissented, arguing that the officers' occupancy was protected by the lesser standard of employee housing and that their residency in prison grounds should have superseded Third Amendment protection. The case highlights the potential relevance of the Third Amendment in modern scenarios, such as natural disasters, where the National Guard might be activated and potentially violate private property rights without the owner's consent.

Keywords

💡Third Amendment

The Third Amendment to the United States Constitution prohibits the quartering of soldiers in private homes without the owner's consent during peacetime. In the video, this amendment is central to the court case discussed, where correction officers were evicted from their housing to accommodate National Guardsmen during a strike, raising a direct challenge under the Third Amendment.

💡United States Court of Appeals for the Second Circuit

This is a federal court that hears appeals from the district courts within its jurisdiction, which includes New York, Connecticut, and Vermont. In the context of the video, it is the court that decided the case involving the Third Amendment, establishing important legal precedents regarding the amendment's application.

💡National Guardsmen

The National Guard is a reserve military force in the United States, which can be activated by state governments or the federal government. In the video, National Guardsmen were activated to perform duties during a correction officers' strike, leading to the use of employee housing and raising constitutional issues.

💡Due Process Clause

The Due Process Clause of the Fourteenth Amendment to the U.S. Constitution ensures that the government must respect all legal rights, procedures, and safeguards that are owed to an individual. In the video, correction officers claimed a violation of the Due Process Clause, but the court dismissed this claim.

💡Legal Expectation of Privacy

This concept refers to an individual's reasonable expectation of privacy within their residence. The video discusses how the Third Amendment's protection extends to anyone with a legal expectation of privacy, not just homeowners, which was a significant holding in the case.

💡Qualified Immunity

Qualified immunity is a legal doctrine that shields government officials from being held personally liable for actions performed in their official capacity unless they violated clearly established rights. In the video, the court found that the state agents were covered by qualified immunity since they did not knowingly act illegally without precedent.

💡Mid-Orange Correctional Facility

This is a correctional facility in New York where some of the events leading to the court case took place. During the strike by correction officers, National Guardsmen were activated at this facility, and the subsequent use of employee housing became a legal issue.

💡Incorporation against the States

This legal concept refers to the idea that certain provisions of the U.S. Constitution apply not only to the federal government but also to state governments. The video explains that the Third Amendment's protections are incorporated against the states, meaning states cannot violate these rights.

💡Legal Rules of Tenancy

These are the laws governing the rights and obligations of landlords and tenants. The video discusses how the correctional officers' occupancy in the rooms was covered under these rules, making it protected under the Third Amendment.

💡Concurring and Dissenting Opinion

In legal contexts, a concurring opinion agrees with the decision of the court but offers different reasoning, while a dissenting opinion disagrees with the court's decision. In the video, Judge Kaufman concurred with part of the decision but dissented on other parts, offering an alternative view on the case.

💡Hurricane Katrina

Hurricane Katrina was a major natural disaster in the United States, and the video uses it as an example of a situation where the Third Amendment could become relevant in modern times. It discusses a hypothetical scenario where the National Guard might need to quarter soldiers in private homes without consent during disaster relief efforts.

Highlights

The case was a direct challenge under the Third Amendment to the U.S. Constitution.

The Third Amendment prohibits soldiers from being quartered in any house without the owner's consent during peacetime.

The case involved a 1979 strike by New York State correction officers.

National guardsmen were activated to perform duties of striking employees.

Striking employees were evicted from employee housing, which was then used to house the National Guard.

Two evicted officers filed a lawsuit against the state of New York and its Governor.

The lawsuit claimed violations of the Due Process Clause and the Third Amendment.

The District Court dismissed the suit, leading to an appeal to the Second Circuit.

Judge Walter R. Mansfield wrote the decision for the Second Circuit.

The Court affirmed the dismissal of the due process claim.

The Court established that national guardsmen qualify as soldiers under the Third Amendment.

The Third Amendment applies to both state and federal authorities.

The Third Amendment's protection extends to anyone with a legal expectation of privacy in their residence.

The majority held that the correctional officers' occupancy was protected under the Third Amendment.

The case was remanded to the District Court, which decided in favor of the defendants due to qualified immunity.

Judge Kaufman dissented, arguing that the officers' occupancy was covered under employee housing protections.

The Third Amendment could be relevant in the 21st century, such as in the case of natural disasters and the activation of the National Guard.

Housing National Guard personnel in private dwellings without consent would be prohibited by the Third Amendment, even in a declared war.

Transcripts

in bloom V carry 677 F point to D 957 to

D sir 1982 on-ramp 572 F sub 44

Sdn Y 1982 aft per curiam 724 m point to

D 28 to D sir 1983 was a court case

decided by the United States Court of

Appeals for the Second Circuit it is the

only significant court decision based on

a direct challenge under the third

amendment to the United States

Constitution which states that no

soldier shall in time of peace be

quartered in any house without the

consent of the owner background the case

was initiated by a 1979 strike by New

York State correction officers while the

officers were on strike some of their

duties were performed by national

guardsmen who were activated at mid

orange correctional facility and other

facilities striking employees were

evicted from employee housing which was

then used to house some of the National

Guard two of the evicted officers at Mid

orange CF Mary Annie emblem and Charles

E Palmer subsequently filed suit in the

United States District Court for the

Southern District of New York against

the state of New York and its Governor

Hugh L Kerry petitioners asserted

violation of the Due Process Clause of

the Fourteenth Amendment and violation

of the third Amendment the district

court found four defendants and

dismissed the suit petitioners then

appealed to the Court of Appeals for the

Second Circuit decision

rendered on May 3rd 1982 the decision

was written for the court by Judge

Walter our Mansfield it began by

affirming the district court's dismissal

of the due process claim it then turned

to petitioners third Amendment claim

because of the lack of any prior third

Amendment jurisprudence this decision

established three important holdings

never / not previously articulated one

that the national guardsmen qualify as

soldiers under the third amendment to

that the third amendment applies to

state as well as federal authorities ie

is incorporated against the states and

three that the protection of the third

amendment extends beyond homeowners that

is those only with a fee simple

arrangement but includes anyone who

within their residence has a legal

expectation of privacy and a legal right

to exclude others from entry into the

premises the majority held that the

correctional officers occupancy in the

rooms was covered under the legal rules

of tenancy and was therefore protected

under the third amendment the case was

remanded to district court where it was

decided in the defendants favor due to

the principle that as agents of the

state the defendants were covered by a

qualified immunity unless they knowingly

acted illegally in the absence of

previous precedents on this issue the

standard of knowing illegality was not

met concurring in part and dissenting in

part judge serving our Kaufman

maintained that the officers occupancy

was covered under the lesser protection

of employee housing and that the special

circumstances of residency in prison

grounds superseded third amendment

protection while viewed as an 18th

century anachronism by many others state

that the third amendment could come into

play in the 21st century in a situation

where a geographic region is struck by a

major natural disaster such as Hurricane

Katrina the National Guard is activated

and sent into the area and arbitrarily

decides to house its command and support

staffs in private dwellings regardless

of the owners wishes citing the national

emergency

absent the consent of the owner or a

declaration of war by Congress this

would be prohibited by the third

amendment even in the latter case war

the guardsmen still would need to be

housed in a manner to be prescribed by

law please subscribe and thanks for

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