Question: In what year was the court case that upheld the constitutionality of the Special Division?
Context: Planned Parenthood v. Casey, 505 U.S. 833 (1992) , was a landmark United States Supreme Court case in which the constitutionality of several Pennsylvania state statutory provisions regarding abortion was challenged.  The Court's plurality opinion reaffirmed the central holding of "Roe v. Wade" stating that "matters, involving the most intimate and personal choices a person may make in a lifetime, choices central to personal dignity and autonomy, are central to the liberty protected by the Fourteenth Amendment."  The Court's plurality opinion upheld the constitutional right to have an abortion while altering the standard for analyzing restrictions on that right, crafting the "undue burden" standard for abortion restrictions.  "Planned Parenthood v. Casey" differs from "Roe," however, because under "Roe" the state could not regulate abortions in the first trimester whereas under "Planned Parenthood v. Casey" the state can regulate abortions in the first trimester, or any point before the point of viability, and beyond as long as that regulation does not pose an undue burden on women's fundamental right to an abortion.  Applying this new standard of review, the Court upheld four regulations and invalidated the requirement of spousal notification. United States v. Kagama, 118 U.S. 375 (1886), was a United States Supreme Court case that upheld the constitutionality of the Major Crimes Act of 1885.  This Congressional act gave the federal courts jurisdiction in certain cases of Indian-on-Indian crimes, even if the crimes were committed on an Indian reservation.  Kagama, a Yurok Native American (Indian) accused of murder, was selected as a test case by the Department of Justice to test the constitutionality of the Act. The Special Division is a division of the United States Court of Appeals for the District of Columbia Circuit.  28 U.S.C. § 49 (1982 ed., Supp.  V) (Title VI of the Ethics in Government Act).  It consists of three circuit court judges or justices appointed by the Chief Justice of the United States.  One of the judges must be a judge of the DC Circuit, and no two of the judges may be named to the Special Division from a particular court.  The judges are appointed for 2-year terms, with any vacancy being filled only for the remainder of the 2-year period.  Its constitutionality was upheld in Morrison v. Olson. Morrison v. Olson, 487 U.S. 654 (1988) , is a United States federal court case in which the Supreme Court of the United States decided that the Independent Counsel Act was constitutional. Goesaert v. Cleary, 335 U.S. 464 (1948), was a United States Supreme Court case in which the Court upheld a Michigan law, which prohibited women from being licensed as a bartender in all cities having a population of 50,000 or more unless their father or husband owned the establishment.  Valentine Goesaert, the plaintiff in the case, challenged the law on the ground that it infringed on the Fourteenth Amendment's Equal Protection Clause.  Speaking for the majority, Justice Felix Frankfurter affirmed the judgment of the Detroit district court and upheld the constitutionality of the state law.  The state argued that since the profession of bartending could potentially lead to moral and social problems for women, it was within the state's power to bar them from working as bartenders.  Only when the owner of the bar was a sufficiently close relative to the women bartender could it be guaranteed that such immorality would not be present. Asho people (Burmese: my ), one of the tribes of the Chin people, are native to Arakan, Magwe Special Division, Pegu Special Division, Irrawaddy Special Division and some in Yangon Special Division.  They are much influenced by the Burmese in their daily life.  They are well educated and having high profile jobs in the Myanmar government. Bank Markazi v. Peterson, 578 U.S. ___ (2016), was a United States Supreme Court case that found that a law which only applied to a specific case, identified by docket number, and eliminated all of the defenses one party had raised does not violate the separation of powers in the United States Constitution between the legislative (Congress) and judicial branches of government.  The plaintiffs in the trial court, respondents in the Supreme Court, were several parties who had obtained judgments against Iran for its role in supporting state-sponsored terrorism, particularly the 1983 Beirut barracks bombings and 1996 Khobar Towers bombing, and sought execution against a bank account in New York held, through European intermediaries, on behalf of Bank Markazi, the state-owned Central Bank of Iran.  The initial plaintiffs obtained court orders preventing the transfer of funds from the account in 2008 and initiated their lawsuit in 2010.  Bank Markazi raised several defenses against the execution against the account, including that the account was not an asset "of" the bank, but rather an asset of its European intermediary, under both New York state property law and §201(a) of the Terrorism Risk Insurance Act.  In response to concerns that existing laws were insufficient for the account to be used to settle the judgments, Congress included a section within a 2012 bill, codified after enactment as 22 U.S.C. § 8772, that identified the pending lawsuit by docket number, applied only to the assets in the identified case, and essentially abrogated every legal basis available to Bank Markazi to prevent the plaintiffs from executing their claims against the account.  Bank Markazi then argued that § 8772 was an unconstitutional breach of the separation of power between the legislative and judicial branches of government, because it effectively directed a particular result in a single case without changing the generally applicable law.  The United States District Court for the Southern District of New York and, on appeal, the United States Court of Appeals for the Second Circuit both upheld the constitutionality of § 8772 and cleared the way for the plaintiffs to execute their judgments against the account, which held about $1.75 billion in cash. Santosky v. Kramer, 455 U.S. 745 (1982) , is a Supreme Court case involving the burden of proof for the revocation of parental rights.  The case arose when the Ulster County, New York Department of Social Services sought to revoke John Santosky II and Annie Santosky's parental rights to their three children.  Under Section 622 of the New York State Family Court Act, the state was permitted to revoke parental rights to a natural child if, after a fair preponderance of the evidence, a court found "permanent neglect."  The New York State Family Court found such neglect by using the "fair perponderance" standard.  The Appellate Division of the New York Supreme Court upheld the constitutionality of the burden of proof used. Clark v. Arizona, 548 U.S. 735 (2006) , is a United States Supreme Court case in which the Court upheld the constitutionality of the insanity defense used by the State of Arizona.  The ruling affirmed the murder conviction of a man with paranoid schizophrenia, for the killing of a police officer.  The man had argued that his inability to understand the nature of his acts at the time they were committed should be a sufficient basis for showing he lacked the requisite mental state required as an element of the charged crime.  The Court upheld Arizona's restriction of admissible mental health evidence only to the issue of insanity.  Arizona does not allow mental health evidence to show that the defendant did not possess the required mental intent level necessary to satisfy an element of the crime.  The evidence is only admissible if used to show that the defendant was insane at the time of the crime's commission.  In this case, the defendant knew right from wrong so he could not qualify under Arizona's insanity defense. Prior to the landmark ruling "United States v. Windsor", the constitutionality of banning same-sex marriage was upheld by the Eighth Circuit in "Citizens for Equal Protection v. Bruning".  After the "Windsor" ruling, many same-sex marriage bans were struck down by lower courts.  The Tenth, Fourth, Seventh, and Ninth circuits all ruled that same-sex marriage bans were unconstitutional.  The cases that made it to these circuit courts originated in district courts which for the most part also struck down same-sex marriage bans.  When a circuit court struck down a state's same-sex marriage ban, it did not directly strike down same-sex marriage bans in other states within the circuit.  However, it paved the way for same-sex marriage bans to be struck down in the entire circuit due to the precedent it set for district courts within the circuit to follow.  In some states, same-sex marriage was already legal before a federal circuit court ruled on the matter.  The Sixth Circuit ruled that same-sex marriage bans were not unconstitutional and reversed the district court rulings that struck down same-sex marriage bans.  Since this was the only circuit court to rule this way post-"Windsor", this created a circuit split which ultimately led to the Supreme Court of the United States deciding to resolve the issue once and for all.  They ruled that same-sex marriage bans violate the constitution in the landmark ruling "Obergefell v. Hodges" which was the consolidated case that covered each state in the Sixth Circuit.  Some circuit courts have not ruled on the constitutionality of same-sex marriage bans at all.  Many circuit courts had pending same-sex marriage cases, but decided to hold off on litigation until the Supreme Court ruled on the matter.
Answer: 1988