Engblom v Carey (Landmark Court Decisions in America)💬🏛️✅
Summary
TLDRThe 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
🏛️ 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.
Mindmap
Keywords
💡Third Amendment
💡United States Court of Appeals for the Second Circuit
💡National Guardsmen
💡Due Process Clause
💡Legal Expectation of Privacy
💡Qualified Immunity
💡Mid-Orange Correctional Facility
💡Incorporation against the States
💡Legal Rules of Tenancy
💡Concurring and Dissenting Opinion
💡Hurricane Katrina
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
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