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T.V.A. v. Hill
endangered fishes case :open_mouth:
used: leg. history…
T.V.A. v. Hill
- endangered fishes case :open_mouth:
- used: leg. history + intent of congress to support textualist "plain meaning" of the text
- courts should always start with interpretting the plain meaning of the text
Purposivist
Church of Holy Trinity v. US
- no foreign workers law
- courts looked at purpose and intent of congress
- congress meant, "manual labor" not all foreign workers
Train v. Colorado Public Interest Research Group Inc.
- EPA has authority to regulate nuclear waste?
- Court focused on legislative history, looked at house committee report
- Colloquy in Senate floor btwn two senators, affirming that no changes were to be made to Atomic Energy Comm. (AEC)'s reg. control
Textualist
W.V. University Hospitals Inc. v. Casey
- "Expert Witness" fees count as "Attorney's Fees"?
- Used leg. history to support plain meaning, other laws during the same era used more specific language
- If the two fees aren't distinct, then dozens of statutes that make distinction would be reduntant" (Rule against Surplusage)
- Narrow reading of text to affirm congressional supremacy
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Semantic Canons
Ejusdem Generis canon
McBoyle v. US.
- Is a plane a vehicle?
- law listed "running on land" vehicles, no mention of flying
- If flying vehicles were meant congress would have applies broader language
- Court also applied rule of lenity. Where facts should be read in favor of the defendant if the law is unsure/ambigious
People v. Smith
- Is a firearm a "dangerous weapon?"
- list: "dagger, dirk, stilleto..."
- rifle is not, "same kind as those enumerated"
Expressio Unius
Silvers v. Sony Pictures Entertainment
- writer (but not owner) sues for copyright infringement of movie
- Law never explicitly said writer can't sue, only said owner could sue.
- court said that any persons omitted from law are understood to be exclusions
Rule against Surplusage
Circuit City v. Adams
- Arbitration case
- "seamen, railroad workers, and any other class of worker"
- Ejusdem Generis is linked strongly w/ Rule of Surplusage
- Dissent: Congress added extra words out of an Abundance of Caution (Abundati cautela)
Substantive Canons
Rule of Lenity
- "statute should be read narrowly to give criminal/defendant fair notice"
- Applied in McBoyle case b/c planes shouldn't be applied to ambiguous law about vehicles
- Applied in People v. Smith b/c rifles aren't stabbing weapons
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- Graph shows most general case in the middle (starting with the Hill case) to most specific cases at the edges.
- Bolded words in the case summary show unique aspects that might come in handy when figuring out when to bring up during the midterm.
Color meaning:
- brown: cases
- yellow: questions that narrow focus
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