Supreme Court of the United States
ISSUE: Whether police authorities may lawfully enter a private property without a warrant if they have a valid cause or reason to believe that the occupants are seriously harmed or imminently threatened by any sort of injury.
SUBSTANTATIVE FACTS:
After receiving a call regarding a loud party in a residential area, the four police officers responded to investigate.
The police authorities witnessed an altercation happening in the kitchen of the house involving a juvenile and a couple of adult men.
As soon as the juvenile have freed himself from the struggle, he swung a fist and it landed on the face of one of the adults. The blow caused the victim to bleed and spitting blood into a nearby sink.
The police authorities announced their presence from the screen door, but to no avail.
The altercation ceased after the officer entered the private premises and re-announced their presence.
The respondents were arrested and charged with disorderly conduct, intoxication and contributing to the delinquency of a minor.
PROCEDURAL FACTS:
Stuart filed a petition to suppress all evidence on the grounds that the officers violated the Fourth Amendment Rights by entering the house without a warrant.
arguing that the warrantless entry Utah trial court granted the motion to suppress all evidence
Utah Court of Appeals affirmed based on prior Utah Supreme Court precedent
Birmingham City filed a petition for review
Utah Supreme Court granted the motion
Utah Supreme Court rejected affirmed and rejected Birmingham’s contentions
The Supreme Court of the United States granted Birmingham’s petition for a certiorari
HOLDING: The officer’s announcement of his presence was at least equivalent to a knock on the screen door. It was probably the only option that had even a chance of rising above the din. Under these circumstances, there was no violation of the Fourth Amendment’s knock-and-announce rule.
REASONING: The officers had all the reasons to believing that both the juvenile and the injured adult might need help. The Fourth Amendment does require police authorities to anticipate the situation to further escalate before taking actions.
JUDGEMENT: Reversed
American Needle, Inc. v. National Football League et al 560 U. S. ____ (2010)
United States Court of Appeals
ISSUE: Whether an arrangement between the teams and NFL to deny renewal of nonexclusive license is a conspiracy, that it unreasonably restrains trade.
SUBSTANTATIVE FACTS:
The NFL teams formed the National Football League Properties or NFLP in 1963 to grant license and handle the marketing of the team’s intellectual properties.
American Needle, Inc. was granted with nonexclusive licenses by NFLP
NFLP granted Reebok International Ltd. an exclusive license In December 2000, as a result of the votes of the teams to authorize NFLP.
NFLP denied the American Needle, Inc. to renew its nonexclusive license in December 2000
PROCEDURAL FACTS:
American Needle Inc. filed action alleging that the NFLP and its teams had an agreement which violates §§1 and 2 of the Sherman Act in the Northern District Court of Illinois
NFLP averred that they are not capable of conspiring in relation to §1 of the Sherman Act for the reason that they are operating as a single-unit economic enterprise
A summary judgment given by The Northern District Court of Illinois stipulating that the defendants are operating as a single entity instead of joint ventures.
The Seventh Circuit Court of Appeals affirmed that the defendants are immune from antitrust scrutiny because they are more appropriate described as a single enterprise
The United States Court of Appeals granted American Needle’s petition for a writ of certiorari
HOLDING: NFL including its 32 teams does not have the quality of a single entity that makes a unitary decision; in addition the teams do not have the characteristic that encompasses an economic power to initiate an independent action.
REASONING: NFL’s justification that they are acting as a single entity and coordinating decisions for a single purpose to suit §1 is sufficient. Therefore, the decision to grant licenses with regard to each of the team’s intellectual property involves a coordinated activity constituting the provisions of §1.
