Justia U.S. Supreme Court Opinion Summaries

Abercrombie refused to hire Elauf, a practicing Muslim, because the headscarf that she wore pursuant to her religious obligations conflicted with Abercrombie’s employee dress policy. The Equal Employment Opportunity Commission (EEOC) filed suit, alleging violation of Title VII of the Civil Rights Act of 1964, which prohibits a prospective employer from refusing to hire an applicant because of the applicant’s religious practice when the practice could be accommodated without undue hardship. The EEOC prevailed in the district court. The Tenth Circuit reversed, holding that failure-to-accommodate liability attaches only when the applicant provides the employer with actual knowledge of his need for an accommodation. The Supreme Court reversed and remanded. Title VII’s disparate-treatment provision requires Elauf to show that Abercrombie “fail[ed] . . . to hire” her “because of ” “[her] religion” (including a religious practice), 42 U.S.C. 2000e–2(a)(1). Rather than imposing a knowledge standard, the statute prohibits certain motives, regardless of the state of the actor’s knowledge. An employer may not make an applicant’s religious practice, confirmed or otherwise, a factor in employment decisions. Title VII allows failure-to-accommodate challenges to be brought as disparate-treatment claims and gives favored treatment to religious practices, rather than demanding that religious practices be treated no worse than other practices. View "Equal Emp't Opportunity Comm'n v. Abercrombie & Fitch Stores, Inc." on Justia Law

Barkes was arrested in 2004, for violating probation, and taken to a Wilmington Delaware Correctional Institution. During intake, a nurse who worked for the contractor providing healthcare at the Institution conducted a suicide screening, based on a model form developed by the National Commission on Correctional Health Care in 1997. Barkes disclosed that he had a history of psychiatric treatment and was on medication and that he had attempted suicide in 2003, but stated that he was not currently thinking about killing himself. Because only two risk factors were apparent, the nurse gave Barkes a “routine” referral to mental health services and did not initiate special suicide prevention measures. Barkes was placed in a cell by himself. He called his wife and told her that he was going to kill himself; she did not inform the Institution of this call. The next morning, correctional officers observed Barkes behaving normally at 10:45, 10:50, and 11:00 a.m. At 11:35 a.m., an officer discovered that Barkes had hanged himself with a sheet. His wife sued officials, alleging violation of Barkes’s constitutional right to be free from cruel and unusual punishment, by failing to supervise and monitor the private contractor. The Third Circuit held that it was clearly established that an incarcerated individual had an Eighth Amendment “right to the proper implementation of adequate suicide prevention protocols” and that there were material factual disputes. There was evidence that the screening process did not comply with NCCHC’s latest standards, as required by contract. The Supreme Court unanimously reversed, finding that the officials were entitled to qualified immunity. No Supreme Court precedent establishes a right to proper implementation of adequate suicide prevention protocols; appellate authority in 2004 suggested that such a right did not exist. Even if the Institution’s suicide screening and prevention measures had the alleged shortcomings, no precedent would have made clear to the officials that they were overseeing a system that violated the Constitution. View "Taylor v. Barkes" on Justia Law

A federal litigant who is too poor to pay court fees may proceed in forma pauperis and commence a civil action without prepaying fees or paying certain expenses, 28 U.S.C. 1915(a), but a “three strikes” provision prevents a court from granting in forma pauperis status to a prisoner who “has, on 3 or more prior occasions, while incarcerated . . . , brought an action or appeal in a court of the United States that was dismissed on the grounds that it is frivolous, malicious, or fails to state a claim upon which relief may be granted.” A state prisoner filed three federal lawsuits that were dismissed on grounds enumerated in section 1915(g). While the third dismissal was pending on appeal, he filed four additional federal lawsuits, moving to proceed in forma pauperis in each. The district court denied the motion. The Sixth Circuit and a unanimous Supreme Court affirmed. A prior dismissal on statutorily enumerated grounds is a strike, even if the dismissal is the subject of an ongoing appeal. Section 1915 describes dismissal as an action by a single court, not as a sequence of events involving multiple courts. The Court noted that a judgment normally takes effect, and its preclusive effect is immediate, despite a pending appeall. The “three strikes” provision was “designed to filter out the bad claims and facilitate consideration of the good.” To refuse to count a prior dismissal because of a pending appeal would produce a leaky filter. View "Coleman v. Tollefson" on Justia Law

Sheehan lived in a group home for individuals with mental illness. After Sheehan threatened to kill her social worker, San Francisco dispatched officers to escort Sheehan to a facility for evaluation and treatment. When the officers entered Sheehan’s room, she grabbed a knife and threatened them. They retreated and closed the door. Concerned about what Sheehan might do, and without considering whether they could accommodate her disability, the officers reentered. Sheehan, knife in hand, again confronted them. After pepper spray proved ineffective, the officers shot Sheehan multiple times. Sheehan sued under the Americans with Disabilities Act, 42 U.S.C. 12132 and 42 U.S.C. 1983. The Ninth Circuit held that the ADA applied and that the officers were not entitled to qualified immunity. The Supreme Court dismissed certiorari as to whether the ADA “requires law enforcement officers to provide accommodations to an armed, violent, and mentally ill suspect in the course of bringing the suspect into custody,” because, instead of arguing that the ADA does not apply when an officer faces an armed and dangerous individual, San Francisco argued only that Sheehan was not “qualified” for an accommodation, because she “pose[d] a direct threat to the health or safety of others,” which could not “be eliminated by a modification of policies, practices or procedures, or by the provision of auxiliary aids or services.” The lower courts did not address that question. The officers are entitled to qualified immunity from liability for injuries suffered by Sheehan. Their use of force was also reasonable. Any Fourth Amendment right involving accommodation of a disability, even assuming it exists, was not clearly established. View "City & Cnty. of San Francisco v. Sheehan" on Justia Law

Grady was convicted in North Carolina of a second degree sexual offense in 1997 and of taking indecent liberties with a child in 2006. After he served his sentence, the state held a hearing to determine whether he should be subjected to satellite-based monitoring (SBM) as a recidivist sex offender, N. C. Gen. Stat. 14–208.40(a)(1), 14– 208.40B. Grady argued that the program, under which he would be forced to wear tracking devices at all times, would violate his Fourth Amendment rights. State courts rejected his arguments. The Supreme Court, per curiam, vacated, holding that the state conducts a search when it attaches a device to a person’s body, without consent, for the purpose of tracking that individual’s movements. Although the North Carolina monitoring program is civil in nature, the government’s purpose in collecting information does not control whether the method of collection constitutes a search. The Fourth Amendment prohibits only unreasonable searches. The case was remanded to allow North Carolina courts to examine whether the monitoring program is reasonable, when properly viewed as a search. View "Grady v. North Carolina" on Justia Law

Donald, Liggins, Moore, Saine, and Zaya decided to rob a drug dealer (Makki). Donald, Moore, and Liggins drove to Makki’s home. Moore and Donald entered. Liggins waited in the car. McGinnis, a drug runner, was present, and dropped to the floor. He heard a scuffle and gunshots. After Moore and Donald left, he found Makki, dying. Moore and Donald returned to the car. Donald stated that he had stolen $320 and that Moore had accidentally shot him. Donald later went to a hospital for the wound. Weeks later, the state charged Donald with first-degree felony murder and two counts of armed robbery. Liggins and Zaya pleaded guilty. Donald was tried with Moore and Saine. His defense was that he was present, but did not participate. The court admitted a chart chronicling phone calls from the day of the crime among Moore, Saine, and Zaya. Donald’s attorney did not object, saying: “it does not affect me.’” When the trial resumed after a recess, Donald’s counsel was not in the courtroom. Ten minutes later, the lawyer returned. The judge informed him that “we only were discussing the telephone chart.” The attorney replied, “I had no dog in the race and no interest in that.” Donald was convicted. Michigan courts rejected his claim that his attorney’s absence during the phone call testimony denied him effective assistance of counsel. The federal district court granted habeas relief. The Sixth Circuit affirmed, based on the Supreme Court’s “Cronic” holding that courts may presume unconstitutional prejudice if a defendant “is denied counsel at a critical stage of his trial.” The Supreme Court, per curiam, reversed. The state court’s decision could not be “contrary to” any Supreme Court holding; no holding addresses counsel’s absence during testimony that is irrelevant within the defendant’s own theory of the case. A fair-minded jurist could conclude that a presumption of prejudice is not warranted by counsel’s short absence during testimony about other defendants, irrelevant to the defendant’s theory. View "Woods v. Donald" on Justia Law

The Pregnancy Discrimination Act specifies that Title VII’s prohibition against sex discrimination applies to discrimination “because of or on the basis of pregnancy, childbirth, or related medical conditions,” 42 U.S.C 2000e(k), and that employers must treat “women affected by pregnancy . . . the same for all employment-related purposes . . . as other persons not so affected but similar in their ability or inability to work.” Young, a UPS driver, became pregnant; her doctor advised that she should not lift more than 20 pounds. UPS required drivers to lift up to 70 pounds. UPS told Young that she could not work while under a lifting restriction. Young filed a disparate-treatment claim of discrimination, identifying UPS policies that accommodated workers who were injured on the job, were covered by the Americans with Disabilities Act, or had lost Department of Transportation certifications. UPS argued that, since Young did not fall within those categories, it had not discriminated on the basis of pregnancy, but had treated her as it treated all “other” relevant “persons.” The district court granted UPS summary judgment. The Fourth Circuit affirmed. The Supreme Court vacated. Disparate treatment law normally allows an employer to implement policies that are not intended to harm members of a protected class if the employer has a nondiscriminatory, nonpretextual reason. A pregnant worker can make a prima facie case of disparate treatment by showing that she sought and was denied accommodation and that the employer did accommodate others “similar in their ability or inability to work.” The employer may then try to establish “legitimate, nondiscriminatory” reasons, other than that it is more expensive or less convenient to accommodate pregnant women. If the employer offers a reason, the plaintiff may show that it is pretextual. The plaintiff may survive a motion for summary judgment by providing sufficient evidence that the employer’s policies impose a significant burden on pregnant workers, and that the employer’s “legitimate, nondiscriminatory” reasons are not sufficiently strong to justify the burden. The plaintiff can create a genuine issue of material fact as to “significant burden” with evidence that the employer accommodates a large percentage of nonpregnant workers while failing to accommodate a large percentage of pregnant workers. Young created a genuine dispute as to whether UPS provided more favorable treatment to some employees whose situation cannot reasonably be distinguished from hers. View "Young v. United Parcel Service, Inc." on Justia Law

In 2012 Alabama redrew the boundaries of its 105 House and 35 Senate districts to minimize each district’s deviation from precisely equal population and avoid retrogression with respect to racial minorities’ “ability to elect their preferred candidates of choice” under the Voting Rights Act, 52 U.S.C. 10304(b), by maintaining roughly the same black population percentage in existing majority-minority districts. The district court rejected an equal protection claim of “racial gerrymander.” The Supreme Court vacated. Analysis of the racial gerrymandering claim as referring to the state “as a whole,” rather than district-by-district, was erroneous. Showing that race-based criteria did not significantly affect the drawing of some districts did not defeat a claim that such criteria predominantly affected the drawing of others. The objectors’ claimed that individual majority-minority districts were racially gerrymandered, and those districts must be reconsidered. There was “strong, perhaps overwhelming, evidence that race did predominate as a factor” with respect to one district. An equal population goal is not a “traditional” factor in determining whether race “predominates,” but is taken as a given. The district court and the Alabama legislature relied upon a mechanically numerical view as to what counts as forbidden retrogression and asked how to maintain the present minority percentages in majority-minority districts. The Act does not require maintenance of a particular numerical minority percentage. It requires the jurisdiction to maintain a minority’s ability to elect a preferred candidate of choice. View "Alabama Legislative Black Caucus v. Alabama" on Justia Law

Frost helped associates commit armed robberies in Washington, generally as the driver. Frost admitted involvement, but claimed he acted under duress. Frost’s lawyer planned to argue both that the state failed to meet its burden of proof and that Frost acted under duress. The judge insisted that the defense choose between the arguments, explaining that state law prohibited simultaneously contesting the elements of the crime and presenting the affirmative defense of duress. Frost’s lawyer limited his summation to duress. The jury convicted Frost of robbery, attempted robbery, burglary, and assault. The Washington Supreme Court affirmed, rejecting the trial court’s view that state law prohibited Frost from both contesting liability and arguing duress and stating that this improper restriction qualified as a trial error (reviewable for harmlessness) rather than a structural error (requiring automatic reversal). Because the jury heard taped confessions and Frost’s confession on the witness stand, the court held that any error was harmless beyond a reasonable doubt. The district court dismissed his habeas petition; the Ninth Circuit, en banc, reversed. A unanimous Supreme Court reversed. Under the Antiterrorism and Effective Death Penalty Act, the petition could be granted only if the state court decision “was contrary to, or involved an unreasonable application of, clearly established Federal law, as determined by the Supreme Court of the United States,” or “was based on an unreasonable determination of the facts in light of the evidence presented in the State court proceeding,.” 28 U. S. C. 2254(d). No Supreme Court case clearly requires placing improper restriction of closing argument in these narrow categories. The trial court did not prohibit the defense from arguing that the prosecution failed to prove the elements of the crime. Reasonable minds could disagree whether requiring the defense to choose between alternative theories. View "Glebe v. Frost" on Justia Law

In 1999, Christeson was convicted of three counts of capital murder and sentenced to death. The Missouri Supreme Court affirmed Christeson’s conviction and sentence and denial of his post-conviction motion for relief. Under the one-year limitations period imposed by the Antiterrorism and Effective Death Penalty Act, 28 U. S. C. 244(d)(1), Christeson’s federal habeas petition was due on April 10, 2005. Nine months before that deadline, the court appointed attorneys Horwitz and Butts to represent Christeson, 18 U. S. C. 599(a)(2). The attorneys subsequently acknowledged that they failed to meet with Christeson until six weeks after his petition was due. There is no evidence that they communicated with him at all. They finally filed the petition 117 days late. The district court dismissed; the Eighth Circuit denied a certificate of appealability. Christeson, who has severe cognitive disabilities, relied entirely on his attorneys, and may not have known of the dismissal. About seven years later, the attorneys contacted attorneys Merrigan and Perkovich to discuss Christeson’s case. Christeson’s only hope for merits review was to move under FRCP60(b) to reopen final judgment on the ground that AEDPA’s statute of limitations should have been equitably tolled. Horwitz and Butts would not file that motion, premised on their own malfeasance. In 2014, Merrigan and Perkovich unsuccessfully moved to substitute counsel. The Eighth Circuit dismissed, reasoning that they were not authorized to file on Christeson’s behalf. The Missouri Supreme Court set an October 29, 2014 execution date. The district court denied a second motion as untimely, stating that Horwitz and Butts had not “abandoned” Christeson, and reasoning that allowing the motion would permit “‘abusive’” delays in capital cases. The Eighth Circuit affirmed. The Supreme Court stayed execution and reversed, stating that the denials contravened its 2012 decision, Martel v. Clair, concerning the “interests of justice” standard, and noting the obvious conflict of interest with respect to the original attorneys. View "Christeson v. Roper" on Justia Law