Thursday, November 14, 2013

Pierce County, Washington v. Guillen case brief

Pierce County, Washington v. Guillen case brief summary
537 U.S. 129 (2003)

Respondent survivors sued in state court to compel petitioner county to turn over federal highway safety data. While the appeal was pending, the survivors filed a tort claim. The county refused discovery. The survivors appealed. The consolidated cases proceeded to the Washington Supreme Court, which declared that a grant of privilege to the information exceeded Congress' powers, so was not binding on the states. Certiorari was granted.

The data was gathered pursuant to a federal highway safety program. After the inception of the program, due to the states' concerns that such data could ostensibly be used to impose liability upon them, Congress legislated a statutory privilege for the information.


  • The Court held that, as the decision below did not constitute final judgment with respect to the tort action, and none of the Cox Broadcasting exceptions applied, it had no jurisdiction over that claim. 
  • However, under the first Cox exception, the state court's ruling on the federal privilege issue was "conclusive" and the outcome of further proceedings preordained, so the Court had jurisdiction to hear that issue. 
  • Title 23 U.S.C.S. § 409 protected only information compiled or collected for 23 U.S.C.S. § 152 purposes, and did not protect information compiled or collected for purposes unrelated to § 152, as held by the agencies that compiled or collected that information. 
  • As the legislation was aimed at improving safety in the channels of commerce and increasing protection for the instrumentalities of interstate commerce, it properly fell within Congress' Commerce Clause power.
The Court reversed the judgment of the state court and remanded for further proceedings.

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