Case Brief

Complete case brief of Nix v. Williams. You will see an example of a case brief in your Week 7 Packet, along with a separate document with helpful hints for how to brief a case. The Nix case can be found here: supreme.justia.com/us/467/431/case.html

In a nutshell, the case brief is an explanation of what the court decided in the case and why. See the attached worksheet as well as the resources under Case Brief for information and examples. I expect the following sections:

Case citation
Facts
Procedural History
Legal Issues
Decision of the Court
Legal Analysis (should be the longest section)

Please remember that if you cut and paste something from the internet into your assignment, that is plagiarism and you will receive a 0 for the assignment and be reported to the school. A brief should not have footnotes and all citations should be in-text. Please submit to Turnitin

Please submit all Assignments as a single word document

Example of a CaseBrief:

Case Citation:         Delahanty v. Hinckley, 564 A.2d 758 (D.C. 1989).

Parties:                   Thomas and Jean Delahanty, Plaintiffs / Appellants

                                John Hinckley, Defendant / Appellee

Facts: Thomas Delahanty was seriously injured when John Hinckley attempted to assassinate President Ronald Reagan.  John Hinckley used a “Saturday Night Special” in the assassination attempt that was manufactured by R. G. Industries, a subsidiary of Roehm. 

Procedural History:  Appellants filed suit in U.S. District Court for the District of Columbia against John Hinkley, R.G. Industries, the gun manufacturer, Roehm, the manufacturer’s foreign parent company, and individual officers of Roehm, for injuries Appellant Thomas Delahanty suffered when Hinkley attempted to assassinate President Ronald Reagan. The District Court dismissed appellants’ complaint against R.G. Industries, Roehm, and individual officers of Roehm for failure to state a claim. On appeal, the U.S. Court of Appeals for the District of Columbia Circuit certified the question of whether, in the District of Columbia, “manufacturers and distributors of Saturday Night Specials may be strictly liable for injuries arising from these guns’ criminal use” to the District of Columbia Court of Appeals.

Issue: Whether established theories of tort law in the District of Columbia provide a cause of action against gun manufacturers and distributors for injuries arising from the guns' criminal uses?

Holding:  No. There is no basis under the law of the District of Columbia for holding the gun manufacturer and its officers liable for John Hinckley’s criminal use of the gun.

Reasoning: Appellants advanced the following three theories in support of their position:

1.  Strict liability for sale of defective product

The court rejected this theory of liability because appellants put on no evidence that the weapon Hinkley purchased and later used in the assassination attempt was in any way defective. Rather, appellants argued that the manufacturers had a duty to warn of the dangers of criminal misuse of the gun. The court found this argument unpersuasive, pointing out that a manufacturer has no duty to warn because the dangerous nature of guns self-evident.

2.  Strict liability for abnormally dangerous activity

Appellants argued that the manufacturer should be held liable because the Saturday Night Special is “inherently and abnormally dangerous with no social value. The “abnormally dangerous activity” doctrine had never been applied to gun manufacturers in the District of Columbia.  The Court rejected this application of the doctrine, since selling weapons is not an abnormally dangerous activity “in and of itself.”  In response to appellants’ reliance on Kelly v. R.G. Industries, 304 Md. 124, 497 A.2d 1143 (1985), the court stated that it is not just cheap guns that may potentially by used to commit crimes, and that the Maryland legislature had specifically overridden the Kelly decision.

3.  Negligence

While the general rule is that no tort liability exists for harm resulting from the criminal acts of third parties, an exception sometimes comes in to play when a special relationship exists between parties.  Examples of such “special” relationships include landlord / tenant, hospital / patient, and school / student relationships.  The court declined to extend this special relationship status to gun manufacturers and sellers / gun purchaser, as Appellants neither argued that any special relationship existed, nor suggested any way that gun manufacturers could prevent their gun purchasers from misusing the purchased gun for criminal acts.

Decision: 

The court certified the answer back to the U.S. Court of Appeals for the District of Columbia that there was no theory of liability in the District of Columbia under which the gun manufacturer and its officers could be held liable for Hinckley’s criminal misuse of the gun.

Comment: This case gives a good example of how appellate courts may certify issues to other courts (either lower or in different jurisdictions) for opinions.  In this case, the U.S. Circuit Court of Appeals for the District of Columbia (federal appellate court) certified the issue to a Washington D.C. court because it presented a question of local law, not federal law.  

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