| Venue: | SCOTUS |
| Facts: | Plaintiffs allege violation of some SEC rules. There's a new law, 15 U.S.C. § 78aa-1, that allows reinstatement of claims dismissed as time barred after 6/19/91. |
| Posture: | Dismissed as time-barred in August 1991. In 1992, the plaintiffs ask for this to be re-instated. Motion denied. Affirmed on appeal, cert granted. |
| Issue: | Does the requirement that federal courts reopen final judgments in private civil actions under the Securities Exchage act contravene either the due process clause (5A) or the separation of powers? |
| Holding: | Yes. Affirmed. |
| Rule: | The federal judiciary has the power not merely to review cases, but to decide them, subject only to review by superior Aritcle III courts, and a judgment conclusively resolves a case because the nature of judicial power is to render dispositive judgments. |
| Reasoning: | Retroactive legislation like this undoes settled judgments; that's
a usurpation of the judiciary's powers, so Congress can't do it.
Congress can't declare by legislation that the law as interpreted in a case is now something different than it was, because it's the judiciary's job to say what the law is. Separation of powers is a structural safeguard, a prophylactic device. It can't be relaxed, or it'll be overrun altogether. |
| Dicta: | Breyer, concurring: congress is trying to apply, as well as make,
the law here.
Stevens, dissenting: Lampf denied an aggrieved class some rights, and congress was just trying to mend that. They do that with statutes all the time-- here is with a judge-made rule, but the concept is the same. The three branches aren't absolutely independent, and we shouldn't be cavalier about frontal assaults on congress's enactments. |