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Cases in the US

How to analyze Cases in the US
To fully understand the law with respect to business, you need to be able to read and understand court decisions. To make this task easier, you can use a method of case analysis that is called briefing. There is a fairly standard procedure that you can follow when you “brief ” any court case. You must first read the case opinion carefully. When you feel you understand the case, you can prepare a brief of it.
Although the format of the brief may vary, typically it will present the essentials of the case under headings such as those listed below.

1. Citation. Give the full citation for the case, including the name of the case, the date it was decided, and the court that decided it.
2. Facts. Briefly indicate (a) the reasons for the lawsuit; (b) the identity and arguments of the plaintiff(s) and defendant(s), respectively; and (c) the lower court’s decision—if appropriate.
3. Issue. Concisely phrase, in the form of a question, the essential issue before the court. (If more than one issue is involved, you may have two—or even more— questions here.)
4. Decision. Indicate here—with a “yes” or “no,” if possible— the court’s answer to the question (or questions) in the Issue section above.
5. Reason. Summarize as briefly as possible the reasons given by the court for its decision (or decisions) and the case or statutory law relied on by the court in arriving at its decision.

An Example of a Briefed Sample Court Case
As an example of the format used in briefing cases, we present here a briefed version of the sample court case that was presented in Chapter 1 in Exhibit 1A–3.
D.A.B.E., INC. v. CITY OF TOLEDO
United States Court of Appeals,
Sixth Circuit, 2005.
393 F.3d 692

FACTS The city of Toledo, Ohio, has regulated smoking in public places since 1987. In 2003, Toledo’s city council enacted a new Clean Indoor Air Ordinance. The ordinance restricts the ability to smoke in public places—stores, theaters, courtrooms, libraries, museums, health-care facilities, restaurants, and bars. In enclosed public places, smoking is generally prohibited except in a “separate smoking lounge” that is designated for this purpose. D.A.B.E., Inc., a group consisting of the owners of bars, restaurants, and bowling alleys, filed a suit in a federal district court, claiming that the ordinance constituted a taking of their property in violation of the Fifth Amendment to the U.S. Constitution. The plaintiffs also argued that the ordinance was preempted (prevented from taking effect) by a state statute that regulated smoking “in places of public assembly,” excluding restaurants, bowling alleys, and bars. The court ruled in favor of the city. The plaintiffs appealed to the U.S. Court of Appeals for the Sixth Circuit.

ISSUE Does the ordinance deny the plaintiffs “economically viable use of their property,” as required to prove a taking? Does a state indoor smoking statute preempt the city ordinance?

DECISION No, to both questions. The U.S. Court of Appeals for the Sixth Circuit affirmed the lower court’s ruling. The ordinance did not prevent the beneficial use of the plaintiffs’ property, because it did not categorically prohibit smoking, but only regulated it. The state indoor smoking statute did not cover the excluded businesses, and the legislature did not indicate an intent to bar a city from restricting smoking in those places.

REASON The Fifth Amendment provides that private property shall not “be taken for public use, without just compensation.” A taking occurs when an ordinance denies an owner economically viable use of his or her property. In this case, the plaintiffs alleged that they lost customers because of the ordinance. The court reasoned that the ordinance’s only effect on the plaintiffs’ businesses is to restrict the areas in which customers can smoke and the conditions under which smoking is permitted. This might “require some financial investment, but an ordinance does not effect a taking merely because compliance with it requires the expenditure of money.” Besides, the owners could elect to make other uses of their property. As for the preemption issue, a state statute takes precedence over a local ordinance when they conflict. In this case, a statute prohibits smoking in certain locations, but “it does not contain the slightest hint that the legislature intended to create a positive right to smoke in all public places where it did not expressly forbid smoking. Nothing in the [statute] is inconsistent with a local jurisdiction’s decision to impose greater limits on public smoking.”

Review of Sample Court Case
Here we provide a review of the briefed version to indicate the kind of information that is contained in each section.

CITATION The name of the case is D.A.B.E., Inc. v. City of Toledo. D.A.B.E. is the plaintiff; Toledo is the defendant. The U.S. Court of Appeals for the Sixth Circuit decided this case in 2005. The citation states that this case can be found in volume 393 the Federal Reporter, Third Series, on page 692.

FACTS The Facts section identifies the plaintiff and the defendant, describes the events leading up to this suit, the allegations made by the plaintiff in the initial suit, and (because this case is an appellate court decision) the lower court’s ruling and the party appealing this ruling. The appellant’s contention on appeal is also sometimes included here.

ISSUE The Issue section presents the central issue (or issues) decided by the court. In this case, the U.S. Court of Appeals for the Sixth Circuit considers whether the ordinance constitutes a taking in violation of the Fifth Amendment and whether a state statute preempts (or supersedes) the city ordinance.

DECISION The Decision section includes the court’s decision on the issues before it. The decision reflects the opinion of the judge or justice hearing the case. Decisions by appellate courts are frequently phrased in reference to the lower court’s decision; that is, the appellate court may “affirm” the lower court’s ruling or “reverse” it. Here, the court determined that the ordinance did not effect a taking because it did not prevent the plaintiffs’ beneficial use of their property. The statute did not preempt the ordinance because the legislature did not indicate an intent to prohibit a city from restricting smoking in places excluded from the statute. The court affirmed the lower court’s ruling.

REASON The Reason section includes references to the relevant laws and legal principles that the court applied in arriving at its conclusion in the case. The relevant law here included the Fifth Amendment, the state indoor smoking statute, and the principles derived from judicial interpretations and applications of those laws. This section also explains the court’s application of the law to the facts in this case.

Analyzing Case Problems
In addition to learning how to brief cases, students of business law and the legal environment also find it helpful to know how to analyze case problems. Part of the study of business law and the legal environment usually involves analyzing case problems, such as those included in this text at the end of each chapter.

For each case problem in this book, we provide the relevant background and facts of the lawsuit and the issue before the court. When you are assigned one of these problems, your job will be to determine how the court should decide the issue, and why. In other words, you will need to engage in legal analysis and reasoning. Here we offer some suggestions on how to make this task less daunting. We begin by presenting a sample problem:
While Janet Lawson, a famous pianist, was shopping in Quality Market, she slipped and fell on a wet floor in one of the aisles. The floor had recently been mopped by one of the store’s employees, but there were no signs warning customers that the floor in that area was wet. As a result of the fall, Lawson injured her right arm and was unable to perform piano concerts for the next six months. Had she been able to perform the scheduled concerts, she would have earned approximately $60,000 over that period of time. Lawson sued Quality Market for this amount, plus another $10,000 in medical expenses. She claimed that the store’s failure to warn customers of the wet floor constituted negligence and therefore the market was liable for her injuries. Will the court agree with Lawson? Discuss.

Understand the Facts
This may sound obvious, but before you can analyze or apply the relevant law to a specific set of facts, you must clearly understand those facts. In other words, you should read through the case problem carefully—more than once, if necessary—to make sure you understand the identity of the plaintiff(s) and defendant(s) in the case and the progression of events that led to the lawsuit.
In the sample case just given, the identity of the parties is fairly obvious. Janet Lawson is the one bringing the suit; therefore, she is the plaintiff. Quality Market, against whom she is bringing the suit, is the defendant. Some of the case problems you may work on have multiple plaintiffs or defendants. Often, it is helpful to use abbreviations for the parties. To indicate a reference to a plaintiff, for example, the pi symbol— —is often used, and a defendant is denoted by a delta— —a triangle.
The events leading to the lawsuit are also fairly straightforward. Lawson slipped and fell on a wet floor, and she contends that Quality Market should be liable for her injuries because it was negligent in not posting a sign warning customers of the wet floor.
When you are working on case problems, realize that the facts should be accepted as they are given. For example, in our sample problem, it should be accepted that the floor was wet and that there was no sign. In other words, avoid making conjectures, such as “Maybe the floor wasn’t too wet,” or “Maybe an employee was getting a sign to put up,” or “Maybe someone stole the sign.” Questioning the facts as they are presented only adds confusion to your analysis.

Legal Analysis and Reasoning
Once you understand the facts given in the case problem, you can begin to analyze the case. The IRAC method is a helpful tool to use in the legal analysis and reasoning process. IRAC is an acronym for Issue, Rule, Application, Conclusion. Applying this method to our sample problem would involve the following steps:
1. First, you need to decide what legal issue is involved in the case. In our sample case, the basic issue is whether Quality Market’s failure to warn customers of the wet floor constituted negligence. As discussed in Chapter 4, negligence is a tort—a civil wrong. In a tort lawsuit, the plaintiff seeks to be compensated for another’s wrongful act. A defendant will be deemed negligent if he or she breached a duty of care owed to the plaintiff and the breach of that duty caused the plaintiff to suffer harm.
2. Once you have identified the issue, the next step is to determine what rule of law applies to the issue. To make this determination, you will want to review carefully the text of the chapter in which the problem appears to find 2 1 the relevant rule of law. Our sample case involves the tort of negligence, covered in Chapter 7. The applicable rule of law is the tort law principle that business owners owe a duty to exercise reasonable care to protect their customers (“business invitees”). Reasonable care, in this context, includes either removing—or warning customers of—foreseeable risks about which the owner knew or should have known. Business owners need not warn customers of “open and obvious” risks, however. If a business owner breaches this duty of care (fails to exercise the appropriate degree of care toward customers), and the breach of duty causes a customer to be injured, the business owner will be liable to the customer for the customer’s injuries.
3. The next—and usually the most difficult—step in analyzing case problems is the application of the relevant rule of law to the specific facts of the case you are studying. In our sample problem, applying the tort law principle just discussed presents few difficulties. An employee of the store had mopped the floor in the aisle where Lawson slipped and fell, but no sign was present indicating that the floor was wet. That a customer might fall on a wet floor is clearly a foreseeable risk. Therefore, the failure to warn customers about the wet floor was a breach of the duty of care owed by the business owner to the store’s customers.
4. Once you have completed step 3 in the IRAC method, you should be ready to draw your conclusion. In our sample case, Quality Market is liable to Lawson for her injuries, because the market’s breach of its duty of care caused Lawson’s injuries.

The fact patterns in the case problems presented in this text are not always as simple as those presented in our sample problem. Often, for example, there may be more than one plaintiff or defendant. There also may be more than one issue involved in a case and more than one applicable rule of law. Furthermore, in some case problems the facts may indicate that the general rule of law should not apply. For example, suppose a store employee advised Lawson not to walk on the floor in the aisle because it was wet, but Lawson decided to walk on it anyway. This fact could alter the outcome of the case because the store could then raise the defense of assumption of risk (see Chapter 4). Nonetheless, a careful review of the chapter should always provide you with the knowledge you need to analyze the problem thoroughly and arrive at accurate conclusions.