Justia U.S. Supreme Court Opinion Summaries

Moore was convicted of capital murder and sentenced to death for shooting a clerk during a robbery that occurred when Moore was 20 years old. A state habeas court determined that, under Supreme Court precedent, Moore was intellectually disabled and that his death sentence violated the Eighth Amendment. The court consulted the 11th edition of the American Association on Intellectual and Developmental Disabilities clinical manual (AAIDD–11) and the 5th edition of the Diagnostic and Statistical Manual of Mental Disorders and followed the generally accepted intellectual-disability definition, considering: intellectual-functioning deficits, adaptive deficits, and the onset of these deficits while a minor. The court credited six IQ scores, the average of which (70.66) indicated mild intellectual disability. Based on testimony from mental-health professionals, the court found significant adaptive deficits in all three skill sets (conceptual, social, and practical). The Texas Court of Criminal Appeals (CCA) declined the recommendation, concluding that the habeas court should have used standards for assessing intellectual disability contained in AAMR–9 and its requirement that adaptive deficits be “related” to intellectual-functioning deficits. The Supreme Court vacated. While precedent leaves to the states “the task of developing appropriate ways to enforce” the restriction on executing the intellectually disabled, that discretion is not “unfettered,” and must be “informed by the medical community’s diagnostic framework.” When an IQ score is close to, but above, 70, courts must account for the “standard error of measurement.” The CCA overemphasized Moore’s perceived adaptive strengths—living on the streets, mowing lawns, and playing pool for money—when the medical community focuses on adaptive deficits. The CCA stressed Moore’s improved behavior in prison; clinicians caution against reliance on adaptive strengths developed in controlled settings. The CCA concluded that Moore’s record of academic failure, with a history of childhood abuse and suffering, detracted from a determination that his intellectual and adaptive deficits were related; the medical community counts traumatic experiences as risk factors for intellectual disability. The CCA also departed from clinical practice by requiring Moore to show that his adaptive deficits were not related to “a personality disorder.” View "Moore v. Texas" on Justia Law

During a traffic stop, officers searched Manuel and found a vitamin bottle containing pills. Suspecting the pills were illegal drugs, officers conducted a field test, which came back negative for any controlled substance. They arrested Manuel. At the police station, an evidence technician tested the pills and got a negative result, but claimed that one pill tested “positive for the probable presence of ecstasy.” An arresting officer reported that, based on his “training and experience,” he “knew the pills to be ecstasy.” Another officer charged Manuel with unlawful possession of a controlled substance. Relying exclusively on that complaint, a judge found probable cause to detain Manuel pending trial. The Illinois police laboratory tested the pills and reported that they contained no controlled substances. Manuel spent 48 days in pretrial detention. More than two years after his arrest, but less than two years after his case was dismissed, Manuel filed a 42 U.S.C. 1983 lawsuit against Joliet and the officers. The district court dismissed, holding that the two-year statute of limitations barred his unlawful arrest claim and that pretrial detention following the start of legal process could not give rise to a Fourth Amendment claim. The Seventh Circuit affirmed. The Supreme Court reversed. Pretrial detention can violate the Fourth Amendment when it precedes or when it follows, the start of the legal process. The Fourth Amendment prohibits government officials from detaining a person absent probable cause. Where legal process has begun but has done nothing to satisfy the probable-cause requirement, it cannot extinguish a detainee’s Fourth Amendment claim. Because the judge’s determination of probable cause was based solely on fabricated evidence, it did not expunge Manuel’s Fourth Amendment claim. On remand, the Seventh Circuit should determine the claim’s accrual date, unless it finds that the city waived its timeliness argument. View "Manuel v. Joliet" on Justia Law

A Colorado jury convicted Peña-Rodriguez of harassment and unlawful sexual contact. Following the jury’s discharge, two jurors told defense counsel that, during deliberations, Juror H.C. had expressed anti-Hispanic bias toward Peña-Rodriguez and his alibi witness. Counsel, with court supervision, obtained affidavits from the two jurors describing H.C.'s biased statements. The court acknowledged H.C.’s apparent bias but denied a motion for a new trial, stating that Colorado Rule of Evidence 606(b) generally prohibits a juror from testifying as to statements made during deliberations during an inquiry into the validity of the verdict. The Colorado Supreme Court affirmed, citing Supreme Court precedent rejecting constitutional challenges to the federal no-impeachment. The Supreme Court reversed. Where a juror makes a clear statement indicating that he relied on racial stereotypes or animus to convict a defendant, the Sixth Amendment requires that the no-impeachment rule give way. The Court noted that it has previously indicated that the rule may have exceptions for “juror bias so extreme that, almost by definition, the jury trial right has been abridged” and that racial bias, unlike the behavior in previous cases, implicates unique historical, constitutional, and institutional concerns that, unaddressed, threaten systemic injury to the administration of justice. Before the no-impeachment bar can be set aside, there must be a threshold showing that a juror made statements exhibiting overt racial bias that cast serious doubt on the fairness and impartiality of deliberations and verdict. The statement must tend to show that racial animus was a significant motivating factor in the juror’s vote to convict. The Court did not address what procedures a court must follow when deciding a motion for a new trial based on juror testimony of racial bias or the appropriate standard for determining when such evidence is sufficient to require that the verdict be set aside. View "Pena-Rodriguez v. Colorado" on Justia Law

Beckles was convicted of possession of a firearm by a convicted felon, 18 U.S.C. 922(g)(1). The court imposed a “career offender” sentencing enhancement under U.S.S.G. 4B1.1(a), finding that his offense qualified as a “crime of violence” under the residual clause. The Eleventh Circuit affirmed his sentence and the denial of post-conviction relief. In the meantime, the Supreme Court held (Johnson v. United States) that the identically worded residual clause in the Armed Career Criminal Act (ACCA), section 924(e)(2)(b), was unconstitutionally vague. The Eleventh Circuit affirmed again. The Supreme Court affirmed. The Sentencing Guidelines, including section 4B1.2(a)’s residual clause, are not subject to vagueness challenges under the Due Process Clause. Johnson held that the ACCA’s residual clause fixed, in an impermissibly vague way, a higher range of sentences for certain defendants; the advisory Guidelines do not fix the permissible range of sentences. They merely guide the exercise of a court’s discretion in choosing an appropriate sentence within the statutory range. Congress has long permitted a “wide discretion to decide whether the offender should be incarcerated and for how long.” The Guidelines have been rendered “effectively advisory” by the Supreme Court. The Guidelines do not implicate the concerns underlying vagueness doctrine: providing notice and preventing arbitrary enforcement. The statutory range, which establishes the permissible bounds of the court’s sentencing discretion, provides the required notice. The Guidelines do not invite arbitrary enforcement because they do not permit a court to prohibit behavior or to prescribe the sentencing ranges available. View "Beckles v. United States" on Justia Law

A Nevada jury convicted Rippo of first-degree murder and other offenses and sentenced him to death. During his trial, Rippo received information that the judge was the target of a federal bribery probe, and he surmised that the Clark County District Attorney’s Office, which was prosecuting him, was playing a role in that investigation. Rippo unsuccessfully moved for the judge’s disqualification. After that judge’s indictment on federal charges a different judge denied Rippo’s motion for a new trial. The Nevada Supreme Court affirmed, reasoning that Rippo had not introduced evidence that state authorities were involved in the federal investigation. State courts denied post-conviction relief, reasoning that Rippo was not entitled to discovery or an evidentiary hearing because his allegations “d[id] not support the assertion that the trial judge was actually biased.” The Supreme Court vacated the Nevada Supreme Court’s judgment, stating that due process may sometimes demand recusal even when a judge “ ‘ha[s] no actual bias.’ Recusal is required when, objectively speaking, “the probability of actual bias on the part of the judge or decision-maker is too high to be constitutionally tolerable.” View "Rippo v. Baker" on Justia Law

After the 2010 census, the Virginia Legislature drew new lines for 12 state legislative districts, to ensure that each district would have a black voting-age population of at least 55%. Voters challenged the redistricting under the Equal Protection Clause. As to 11 districts, the district court concluded that the voters had not shown that race was the predominant factor motivating the legislature’s decision, reasoning that race predominates only where there is an “actual conflict between traditional redistricting criteria and race.” As to District 75, the court found that race did predominate, but the use of race was narrowly tailored to a compelling state interest--avoiding violation of the Voting Rights Act. The Supreme Court vacated in part, stating that the proper inquiry concerns the actual considerations that provided the essential basis for the lines drawn, not post hoc justifications. A legislature could construct a plethora of potential maps that look consistent with traditional, race-neutral principles, but if race is the overriding reason for choosing a map, race still may predominate. Challengers may establish racial predominance without evidence of an actual conflict. A holistic analysis is necessary to give the proper weight to districtwide evidence, such as stark splits in the racial composition of populations moved into and out of a district, or the use of a racial target. The judgment regarding District 75 is consistent with the basic narrow tailoring analysis; the state’s interest in complying with the Voting Rights Act was a compelling interest and the legislature had sufficient grounds to determine that the race-based calculus it employed was necessary to avoid violating the Act. View "Bethune-Hill v. Virginia State Board of Elections" on Justia Law

Buck was convicted of murder; under Texas law, the jury could impose a death sentence only if it found unanimously, beyond a reasonable doubt, that Buck was likely to commit future acts of violence. Buck’s attorney called a psychologist, Dr. Quijano, who had been appointed to evaluate Buck. While concluding that Buck was unlikely to be a future danger, Quijano stated, in his report and testimony, that Buck was statistically more likely to act violently because he is black. The jury returned a sentence of death. In his first post-conviction proceeding, Buck did not argue ineffective assistance of counsel. In the meantime, the Supreme Court vacated the judgment in a case in which Quijano had testified that Hispanic heritage weighed in favor of a finding of future dangerousness. The Texas Attorney General then identified six cases in which Quijano had testified and, in five cases, consented to resentencing. Buck’s second state habeas petition, alleging ineffective assistance, was dismissed for failure to raise the claim in his first petition. Buck sought federal habeas relief (28 U.S.C. 2254). His claim was held procedurally defaulted. The Supreme Court subsequently issued holdings (Martinez and Trevino) under which Buck’s claim could have been heard, had he demonstrated that state post-conviction counsel was constitutionally ineffective in failing to raise a claim that had some merit. The Fifth Circuit affirmed rejection of Buck’s motion to reopen, finding that Buck had not established extraordinary circumstances or ineffective assistance. The Supreme Court reversed. The question was not whether Buck had shown that his case is extraordinary; it was whether jurists of reason could debate that issue. No competent defense attorney would introduce evidence that his client is liable to be a future danger because of his race. There is a reasonable probability that Buck was sentenced to death in part because of his race, a concern that supports Rule 60(b)(6) relief. The Court rejected, as waived, the state’s argument that Martinez and Trevino did not apply. View "Buck v. Davis" on Justia Law

Two women called 911 to report Daniel as a “‘drunk driver’” on a highway near Santa Fe, then followed Daniel with their bright lights on. Daniel, feeling threatened, pulled over at an off-ramp to confront them. After a nonviolent encounter, Daniel drove to a secluded house where he lived with his brother, Samuel. Officer Truesdale interviewed the women at the off-ramp and obtained Daniel’s license plate number. The dispatcher identified the brothers’ address. Truesdale was joined by Officers White and Mariscal. The three agreed there was insufficient probable cause for arrest, but decided to speak with Daniel. White remained behind in case Daniel returned. Truesdale and Mariscal drove separately, less than a half mile, to the address, without flashing lights. They approached the house in a covert manner, found Daniel’s pickup truck, and spotted two men moving inside the residence. They radioed White, who left the off-ramp to join them. At approximately 11 p.m., the brothers became aware of their presence and yelled, “‘Who are you?’” and “‘What do you want?’” Mariscal and Truesdale laughed and responded: “‘Hey, (expletive), we got you surrounded. Come out or we’re coming in.’” Truesdale shouted: “‘Open the door, State Police, open the door.’” Mariscal yelled: “‘Open the door, open the door.’” The brothers heard, “We’re coming in” and did not hear the officers identify themselves. They armed themselves and yelled, “We have guns.” Truesdale positioned himself behind the house and shouted “‘Open the door, come outside.’” White, walking toward the house, heard “We have guns,” drew his gun and took cover behind a stone wall. Mariscal took cover behind a truck. Daniel fired two shotgun blasts from the back door while screaming loudly. Seconds later, Samuel opened a window and pointed a handgun in White’s direction. Mariscal fired at Samuel but missed. “‘Four to five seconds’” later, White shot and killed Samuel. In a suit under 42 U.S.C. 1983, the district court denied the officers summary judgment on the defense of qualified immunity. The Tenth Circuit affirmed. The Supreme Court vacated. Officer White did not violate clearly established law. The Court declined to consider whether a reasonable jury could infer that White witnessed the other officers’ deficient performance and should have realized that corrective action was necessary before using deadly force because neither lower court addressed that argument. The Court expressed no opinion on whether Truesdale and Mariscal are entitled to qualified immunity. View "White v. Pauly" on Justia Law

Texas House Bill 2 (2013) required that a “physician performing or inducing an abortion . . . must, on the date [of service], have active admitting privileges at a hospital . . . not further than 30 miles from the” abortion facility, and that the facility meet the state’s “minimum standards . . . for ambulatory surgical centers.” As a basis for enjoining enforcement, the district court found: as enforcement of the admitting-privileges requirement began, the number of abortion facilities dropped from about 40 to about 20, so that the number reproductive-age women living more than 50 miles from a clinic doubled and the number living more than 200 miles away increased about 2,800%; the number of facilities would drop to seven or eight if the surgical-center provision took effect; before H.B. 2’s passage, abortion was extremely safe with very low rates of complications and virtually no deaths; abortion was safer than many more common procedures not subject to the same level of regulation; and the cost of compliance with the surgical-center requirement would likely exceed $1.5 million-$3 million per clinic. The Fifth Circuit reversed, citing res judicata. The Supreme Court reversed: the constitutional claims are not barred by res judicata. This as-applied, post-enforcement challenge rests upon factual developments that occurred after an earlier facial challenge, once enforcement started and several clinics closed. Both of the challenged requirements place a substantial obstacle in the path of women seeking a previability abortion and constitute an undue burden on abortion access. Courts must consider the burdens a law imposes on abortion access together with the benefits those laws confer. The state’s evidence did not show how the law advanced its legitimate interest in protecting women’s health when compared to prior law, which required providers to have a “working arrangement” with doctors who had admitting privileges and required abortion facilities to meet extensive health and safety requirements that were policed by inspections. View "Whole Woman’s Health v. Hellerstedt" on Justia Law

The University of Texas at Austin’s undergraduate admissions system offers admission to all students who graduate in the top 10% of their Texas high school class, as required by the Texas Top Ten Percent Law. It fills the remainder of its freshman class, about 25%, by combining an applicant’s “Academic Index” (SAT score and high school academic performance) with a “Personal Achievement Index,” a holistic review containing numerous factors, including race. The University adopted the system in 2004, after a year-long-study of its admissions process—undertaken following two Supreme Court decisions—led it to conclude that its prior race-neutral system did not reach its goal of providing the educational benefits of diversity. Fisher was denied admission to the 2008 freshman class. She alleged that the University’s consideration of race disadvantaged her and other Caucasian applicants, in violation of the Equal Protection Clause. On remand for application of the strict scrutiny standard, the Fifth Circuit again affirmed summary judgment in the University’s favor. The Supreme Court affirmed. The race-conscious admissions program is lawful under the Equal Protection Clause. The compelling interest that justifies consideration of race in college admissions is not an interest in enrolling a certain number of minority students, but an interest in obtaining “the educational benefits that flow from student body diversity.” The University articulated concrete and precise goals—e.g., ending stereotypes, promoting “cross-racial understanding,” preparing students for “an increasingly diverse workforce and society,” and cultivating leaders with “legitimacy in the eyes of the citizenry” and gave a “reasoned, principled explanation” for its decision. The University’s conclusion that race-neutral programs had not achieved its diversity goals was supported by significant statistical and anecdotal evidence, while consideration of race has had a meaningful, but limited, effect on freshman class diversity. That race consciousness played a role in a small portion of admissions decisions is a hallmark of narrow tailoring, not evidence of unconstitutionality. The Top Ten Percent Plan had more of an impact on Fisher’s chances of admission. The Court noted the University’s continuing obligation to satisfy the strict scrutiny burden by periodically reassessing the program and by tailoring it to ensure that race plays no greater role than necessary to meet its compelling interests. View "Fisher v. Univ. of Tex. at Austin" on Justia Law