Justia U.S. Supreme Court Opinion Summaries

A man was convicted in Maryland state court for the attempted murder of his girlfriend, who was shot in her apartment. The prosecution presented evidence including a homemade device that appeared to be a silencer and DNA evidence tying the defendant to that device. Witnesses testified about the defendant’s involvement in preparing the device and his motive, which stemmed from the girlfriend’s pregnancy and her threat to seek child support. Additional evidence linked the defendant to the type of firearm used in the shooting. The jury found the defendant guilty as an accessory before the fact, and he was sentenced to life in prison.After his conviction was affirmed on appeal, the defendant sought postconviction relief in Maryland state court, arguing that the prosecution failed to disclose a forensic report about a laptop, which could have impeached a key witness’s testimony regarding the defendant’s online activity. The state postconviction court granted a new trial, but the Maryland Court of Special Appeals reversed, holding that the undisclosed evidence was not material because the other evidence linking the defendant to the crime was strong enough that there was no reasonable probability of a different outcome. The Maryland Court of Appeals denied review.The defendant then sought federal habeas relief. The United States District Court granted his petition, and a divided panel of the United States Court of Appeals for the Fourth Circuit affirmed, concluding that the state court had not properly applied the correct standard for materiality under Brady v. Maryland. The Supreme Court of the United States reversed, holding that the state appellate court correctly applied the materiality standard and that, under the Antiterrorism and Effective Death Penalty Act (AEDPA), federal courts must defer to reasonable state court decisions. The Supreme Court found that a fairminded jurist could conclude the withheld evidence was not material, and therefore federal habeas relief was not warranted. View "Klein v. Martin" on Justia Law

Vista-Pro Automotive, LLC initiated bankruptcy proceedings in 2014 and brought an adversary action against Coney Island Auto Parts Unlimited, Inc. to recover $50,000 in unpaid invoices. Vista-Pro attempted to serve Coney Island by mail but allegedly did not comply with the required service rules. Coney Island did not respond, leading the Bankruptcy Court to enter a default judgment in 2015. Over the next six years, the bankruptcy trustee sought to enforce the judgment, including notifying Coney Island’s CEO of the judgment in 2016. In 2021, a marshal seized funds from Coney Island’s bank account to satisfy the judgment, prompting Coney Island to seek relief from the judgment, alleging it was void due to improper service.The United States Bankruptcy Court denied Coney Island’s motion to vacate the judgment, finding that Coney Island failed to meet the requirement under Federal Rule of Civil Procedure 60(c)(1) that such motions be brought within a “reasonable time.” The United States District Court and the United States Court of Appeals for the Sixth Circuit both affirmed this decision, agreeing that the reasonable-time limit applied to motions alleging a void judgment.The Supreme Court of the United States reviewed the case to resolve a split among lower courts over whether the reasonable-time requirement of Rule 60(c)(1) applies to motions under Rule 60(b)(4) claiming a judgment is void. The Court held that the plain language and structure of Rule 60 make the reasonable-time requirement applicable to all Rule 60(b) motions, including those asserting voidness. The Supreme Court affirmed the judgment of the Sixth Circuit, concluding that motions for relief from allegedly void judgments must be made within a reasonable time. View "Coney Island Auto Parts Unlimited, Inc. v. Burton" on Justia Law

The petitioner was convicted of a federal crime and, after the enactment of the Mandatory Victims Restitution Act of 1996 (MVRA), was sentenced to pay $7,567.25 in restitution to his victim, even though his criminal conduct occurred before the MVRA became law. Years later, the petitioner challenged the continued obligation to pay restitution, arguing that applying the MVRA retroactively to his conduct violated the Ex Post Facto Clause of the Constitution.The United States District Court initially sentenced the petitioner under the MVRA. When the petitioner challenged the restitution order, the United States Court of Appeals for the Eighth Circuit found against him, ruling that restitution under the MVRA is not criminal punishment and thus not subject to the Ex Post Facto Clause. The Eighth Circuit’s decision rested on its interpretation that MVRA restitution was a civil remedy rather than a criminal penalty.The Supreme Court of the United States reviewed the case and reversed the Eighth Circuit’s judgment. The Supreme Court held that restitution imposed under the MVRA constitutes criminal punishment for purposes of the Ex Post Facto Clause. The Court explained that the statutory text and structure, as well as its placement in the criminal code and its role as a penalty imposed at sentencing, demonstrate that restitution under the MVRA is penal in nature. The Court further noted that only criminal defendants can be ordered to pay restitution, it is imposed in criminal proceedings, and the government, not the victim, is the adverse party. The Supreme Court remanded the case for further proceedings consistent with its ruling, allowing the Eighth Circuit to consider other arguments raised by the government. View "Ellingburg v. United States" on Justia Law

Harold Berk, while traveling in Delaware, suffered a fractured ankle and sought treatment at Beebe Medical Center, where Dr. Wilson Choy recommended a protective boot. Berk alleged that hospital staff improperly fitted the boot, worsening his injury, and that Dr. Choy failed to order an immediate follow-up X-ray, resulting in delayed treatment and the need for surgery. Berk, a citizen of another state, filed a medical malpractice suit in federal court against both the hospital and Dr. Choy under Delaware law.Delaware law requires that a medical malpractice complaint be accompanied by an affidavit of merit from a medical professional. Berk requested an extension to file this affidavit, which was granted, but ultimately failed to secure the required affidavit and instead filed his medical records under seal. The United States District Court for the District of Delaware dismissed Berk’s suit for failing to comply with Delaware’s affidavit of merit statute. The United States Court of Appeals for the Third Circuit affirmed the dismissal, finding the state law substantive and applicable in federal court because, in its view, the Federal Rules of Civil Procedure do not address the affidavit requirement.The Supreme Court of the United States reviewed the case and held that Delaware’s affidavit of merit requirement does not apply in federal court. The Court reasoned that Federal Rule of Civil Procedure 8, which governs the information a plaintiff must provide at the outset of a lawsuit, sets the standard for pleadings and does not require supporting evidence such as an affidavit. Because Rule 8 is a valid procedural rule under the Rules Enabling Act and regulates the manner and means by which claims are presented, it displaces the contrary Delaware law. The Supreme Court reversed the Third Circuit’s decision and remanded the case for further proceedings. View "Berk v. Choy" on Justia Law

After receiving a report from his ex-girlfriend that he was threatening suicide and may have shot himself, law enforcement officers in Montana responded to William Case’s home. The officers were aware of Case’s mental health and substance abuse history, as well as prior threats of suicide and confrontations with police. Upon arrival, they received further details about the phone call from Case’s ex-girlfriend, observed an empty handgun holster, a notepad resembling a suicide note, and noted Case’s lack of response to their attempts at contact. Believing Case might be injured or at risk of imminent harm, the officers entered the home without a warrant to render emergency aid. During their search, Case emerged from a closet holding an object that appeared to be a gun, prompting an officer to shoot and injure him. A handgun was found near where Case had been standing.Case was charged with assaulting a police officer and moved to suppress the evidence obtained from the warrantless entry, arguing a Fourth Amendment violation. The trial court denied the motion, finding the entry justified by emergency circumstances. A Montana jury convicted Case. On appeal, the Montana Supreme Court upheld the conviction, applying its “community caretaker doctrine” and concluding that police may enter a home for a welfare check if “objective, specific and articulable facts” lead an experienced officer to suspect peril. The court rejected the argument that probable cause was required for such an entry, distinguishing emergency aid situations from criminal investigations.The Supreme Court of the United States reviewed the case to clarify the legal standard for warrantless home entry to render emergency aid. The Court held that officers may enter a home without a warrant if they have an “objectively reasonable basis for believing” that an occupant is seriously injured or imminently threatened with such injury. It declined to require probable cause in this context and affirmed the judgment of the Montana Supreme Court, finding the officers’ entry reasonable under the Fourth Amendment. View "Case v. Montana" on Justia Law

The defendant committed a series of robberies, one of which involved the fatal shooting of a victim by an accomplice. He was charged with Hobbs Act robbery, using a firearm during a crime of violence under 18 U.S.C. §924(c)(1)(A)(i), and causing death during that firearm use under 18 U.S.C. §924(j). A jury found him guilty on all counts, and the District Court sentenced him to a lengthy prison term, merging the sentences for the firearm offenses. After subsequent appellate proceedings, including reconsideration in light of Supreme Court decisions, the District Court resentenced the defendant, ultimately merging the convictions related to the firearm offenses.On appeal, the United States Court of Appeals for the Second Circuit addressed whether the defendant could be convicted under both §924(c)(1)(A)(i) and §924(j) for the same act. The Second Circuit held that, notwithstanding the overlap between the two provisions and the Blockburger v. United States test indicating they are the same offense, Congress had authorized cumulative punishments for both. The appellate court relied in part on its reading of Supreme Court precedent and statutory language concerning consecutive sentences, instructing the District Court to impose separate convictions and sentences for each provision.The Supreme Court of the United States reviewed the case and held that Congress did not clearly authorize convictions under both §§924(c)(1)(A)(i) and (j) for a single act that violates both provisions. The Court found that the Blockburger presumption—that Congress does not intend to punish the same offense under two statutes—applies, and no statutory text, structure, or legislative history overcame that presumption. As a result, a single act violating both provisions may yield only one conviction. The Supreme Court reversed the relevant part of the Second Circuit’s judgment and remanded the case for further proceedings consistent with its opinion. View "Barrett v. United States" on Justia Law

Illinois law provides that election officials must count mail-in ballots postmarked or certified no later than election day, as long as those ballots are received within two weeks after election day. Congressman Michael Bost and two other political candidates filed suit against the Illinois State Board of Elections and its executive director, asserting that counting ballots received after election day violates federal statutes that set a single election day for federal offices. The plaintiffs alleged that the challenged law would require them to expend additional campaign resources, potentially harm their reputations, and deprive them of a fair electoral process. Congressman Bost, in particular, claimed he would need to extend campaign activities and monitoring efforts for two additional weeks, incurring costs and risking a reduction in his margin of victory.The United States District Court for the Northern District of Illinois dismissed the case, concluding that the plaintiffs lacked standing. The United States Court of Appeals for the Seventh Circuit affirmed, reasoning that the injuries alleged—such as increased campaign costs and potential reputational harm—were speculative or voluntarily incurred. The Seventh Circuit emphasized that Congressman Bost had won his prior election with a significant margin and found the plaintiffs’ injuries to be neither concrete nor particularized enough to support standing.The Supreme Court of the United States reviewed the case and held that Congressman Bost, as a candidate for office, does have standing to challenge the rules governing vote counting in his election. The Court reasoned that candidates possess a concrete and particularized interest in the integrity and legality of the electoral process, which is distinct from the generalized interest of voters. The judgment of the Seventh Circuit was reversed and the case remanded for further proceedings. View "Bost v. Illinois Bd. of Elections" on Justia Law

In this case, a federal prisoner pleaded guilty in 2008 to charges including conspiracy and attempted Hobbs Act robbery, as well as using a firearm during a “crime of violence” under 18 U.S.C. §924(c). The firearm conviction carried a mandatory 10-year consecutive sentence. After later Supreme Court decisions—United States v. Davis (which invalidated the residual clause of §924(c) as unconstitutionally vague) and United States v. Taylor (which held that attempted Hobbs Act robbery does not qualify as a “crime of violence” under the elements clause)—the validity of the petitioner’s §924(c) conviction was called into doubt.The petitioner first sought relief in federal district court in 2016, but was denied because at that time, Eleventh Circuit precedent still considered attempted Hobbs Act robbery a crime of violence under the elements clause. After Davis, the petitioner sought authorization from the United States Court of Appeals for the Eleventh Circuit to file a second or successive motion under 28 U.S.C. §2255(h), but the court denied authorization, finding he could not make a prima facie case for relief based on then-current precedent. After Taylor, he again sought authorization, but the Eleventh Circuit denied or dismissed his requests, relying on 28 U.S.C. §2244(b)(1) to bar claims previously presented and holding that Taylor did not announce a new constitutional rule. The petitioner’s efforts for rehearing and for certification of the controlling question to the Supreme Court were also denied.The Supreme Court of the United States held that the certiorari bar in §2244(b)(3)(E) does not apply to federal prisoners seeking leave to file a second or successive motion under §2255(h), so the Court had jurisdiction. The Court further held that §2244(b)(1)’s bar on previously presented claims applies only to state prisoners’ habeas applications under §2254, not to federal prisoners’ §2255 motions. The Court vacated the Eleventh Circuit’s decision and remanded for further proceedings. View "Bowe v. United States" on Justia Law

Jeremiah Sweeney was involved in a late-night argument with neighbors over stolen marijuana, during which he fired a gun, missing his intended targets but fatally striking a bystander some distance away. At trial, a key issue was whether Sweeney could have been the shooter given his location and the trajectory of the bullet. After the prosecution rested, a juror independently visited the crime scene and reported his findings to the rest of the jury, leading to his dismissal and the continuation of deliberations with the remaining eleven jurors. Sweeney was convicted of second-degree murder and other charges.His convictions were upheld by a Maryland appellate court on direct appeal. Sweeney then pursued postconviction relief in Maryland state court, arguing his trial counsel was ineffective for not seeking to question the rest of the jury about possible prejudice following the dismissed juror’s unauthorized crime-scene visit. The state court denied relief. Sweeney repeated this claim in a federal habeas petition before the United States District Court, which also denied relief, finding that the state court's application of Strickland v. Washington was not objectively unreasonable.The United States Court of Appeals for the Fourth Circuit reversed, not on the ineffective assistance claim Sweeney asserted, but on the grounds that a series of failures deprived him of his constitutional rights, and ordered a new trial. The Supreme Court of the United States held that the Fourth Circuit erred by granting relief on a claim that Sweeney had never raised, thus violating the principle of party presentation. The Supreme Court reversed the Fourth Circuit’s judgment and remanded the case, instructing the lower court to address only the ineffective-assistance claim Sweeney actually raised. View "Clark v. Sweeney" on Justia Law

A child reported sexual abuse by her father following a weekend visit, which led to criminal charges against him. At trial, the prosecution requested that a screen be placed between the child witness and the defendant during her testimony, citing a Mississippi statute that mandated such a screen in child-abuse cases. The defendant objected, contending that the statute’s mandatory requirement could not override his Sixth Amendment right to confront his accuser face to face unless the court made a case-specific finding that such a procedure was necessary to protect the witness.The trial court granted the State’s motion, reasoning that the statutory mandate left no discretion, and the defendant was subsequently convicted by a jury. On appeal, the Mississippi Supreme Court acknowledged that the trial court did not make a case-specific finding of necessity but upheld the procedure, distinguishing Supreme Court precedents and holding that the statutory requirement was sufficient authority for the use of the screen.The Supreme Court of the United States reversed the decision of the Mississippi Supreme Court. The Court held that under the Sixth Amendment, a defendant’s right to confront witnesses may not be denied based solely on a statute or generalized findings of necessity. Instead, a trial court must hear evidence and make a case-specific finding of necessity before permitting screening of a child witness. The Court remanded the case, allowing the Mississippi Supreme Court to consider whether the constitutional error was harmless beyond a reasonable doubt, consistent with the harmless-error standard. View "Pitts v. Mississippi" on Justia Law