Justia U.S. Supreme Court Opinion Summaries

Following a suspicious vehicle, Sergeant Darisse noticed that only one of the brake lights was working and pulled the driver over. While issuing a warning ticket for the broken light, Darisse became suspicious of the actions of the occupants and their answers to his questions. Heien, the car’s owner, gave Darisse consent to search the vehicle. Darisse found cocaine. Heien was arrested and charged with attempted trafficking. The trial court denied Heien’s motion to suppress, concluding that the faulty light gave Darisse reasonable suspicion for the stop. The North Carolina Court of Appeals reversed, holding that N. C. Gen. Stat. 20–129(g), requires only a single lamp, which Heien’s vehicle had, so that the justification for the stop was objectively unreasonable. Reversing, the state Supreme Court held that Darisse’s mistake was reasonable. The U.S. Supreme Court affirmed. The Fourth Amendment requires government officials to act reasonably, not perfectly. Reasonable suspicion arises from an understanding of both the facts and the law. Whether an officer is reasonably mistaken about the one or the other, the result is the same. Because the Fourth Amendment tolerates only objectively reasonable mistakes, an officer gains no advantage by “Ignorance of the law.” The vehicle code’s wording made it objectively reasonable to think that a faulty brake light constituted a violation. View "Heien v. North Carolina" on Justia Law

Shelby, Mississippi police officers alleged that they were fired, not for deficient performance, but because they brought to light criminal activities of an alderman. The district court entered summary judgment, rejecting their due process claims for failure to invoke 42 U. S. C. 1983. The Fifth Circuit affirmed. The Supreme Court reversed. Federal pleading rules call for “a short and plain statement of the claim showing that the pleader is entitled to relief,” Fed. Rule Civ. Proc. 8(a)(2); they do not contemplate dismissal for imperfect statement of the legal theory asserted. No heightened pleading rule requires plaintiffs seeking damages for violations of constitutional rights to invoke section 1983 expressly in order to state a claim. No qualified immunity analysis was implicated here, as the officers asserted a constitutional claim against the city only, not against any municipal officer. The complaint was not deficient in informing the city of the factual basis for the lawsuit. View "Johnson v. City of Shelby" on Justia Law

Pennsylvania State Police received a report that Zita had stolen a car and loaded handguns and might have fled to the Carman home and sent Officers Carroll and Roberts to that home. The officers parked at the far rear of the corner-lot property, and walked toward the house. They saw a sliding glass door that opened onto a ground-level deck. Carroll thought the door “looked like a customary entryway,” so he and Roberts decided to knock on it. As they stepped onto the deck, a man exited the house and “aggressively approached” them. The officers identified themselves, explained they were looking for Zita, and asked the man for his name. The man refused to answer, but turned away and appeared to reach for his waist. Carroll grabbed his arm to make sure he was not reaching for a weapon. He twisted away and fell into the yard. A woman came outside, identified herself as Karen Carman, identified the man as her husband, and stated that Zita was not there. Karen consented to a search. The officers searched the house, did not find Zita, then left. The Carmans sued under 42 U. S. C. 1983. Carroll argued that his entry was lawful under the “knock and talk” exception to the warrant requirement, which he contended, allows officers to knock on someone’s door, so long as they stay “on those portions of [the] property that the general public is allowed to go on.” The Carmans responded that a normal visitor would have gone to their front door. The jury returned a verdict for Carroll. The Third Circuit reversed. The Supreme Court reversed, holding that Carroll was entitled to qualified immunity. The Court declined to address whether an officer may conduct a “knock and talk” at any entrance that is open to visitors or only the front door, but stated that Carroll may reasonably have concluded that he was allowed to knock on any door that was open to visitors. View "Carroll v. Carman" on Justia Law

In 2005, Smith’s wife was killed at home by a blow to the head from a log roller. The home appeared to have been ransacked. Jewelry was missing. Smith was charged with first-degree murder. The prosecution presented evidence that he was unfaithful for many years, that his wife was threatening a divorce, and that he told an employee that “the ‘only way’ … out of their marriage was ‘to die’.” Smith’s DNA was found on the murder weapon, duct tape found near the body, and a matchstick that may have been used to burn the body. The missing jewelry was discovered in the trunk of Smith’s car, wrapped in duct tape from the same roll as pieces found near the body. Smith claimed that he could not have delivered the fatal blow due to surgery weeks before the murder. The prosecution successfully requested an aiding-and-abetting instruction and argued that even if he had not delivered the fatal blow, he could be convicted. The jury did not specify which theory it adopted. The California Court of Appeal affirmed, rejecting an assertion that Smith had inadequate notice of the aiding-and-abetting theory. The California Supreme Court denied his petition for review. The Ninth Circuit affirmed the district court’s grant of habeas relief, stating that the information charging first degree murder was initially sufficient, because under California law, aiding and abetting is the same substantive offense as perpetrating the crime, but that Smith’s Sixth Amendment and due process right to notice were violated because the prosecution (until it sought an aiding-and-abetting instruction) had tried the case on the theory that Smith himself had delivered the fatal blow. The Supreme Court reversed. When a state prisoner seeks federal habeas relief on the ground that a state court, in adjudicating a claim on the merits, misapplied federal law, a federal court may grant relief only if the state court’s decision was “contrary to, or involved an unreasonable application of, clearly established Federal law, as determined by the Supreme Court of the United States,” 28 U. S. C. 2254(d)(1). The Ninth Circuit relied only on its own precedent in this case. View "Lopez v. Smith" on Justia Law

The Texas university medical center has an agreement with Parkland Memorial Hospital, requiring the Hospital to offer vacant staff physician posts to University faculty members. A physician of Middle Eastern descent, both a University faculty member and a Hospital staff physician, claimed that Levine, one of his University supervisors, was biased against him because of his religion and ethnic heritage. He complained to Fitz, Levine’s super¬visor. He wanted to continue working at the Hospital without also being on the University faculty. He resigned his teaching post and sent a letter to Fitz and others, stating that he was leaving because of Levine’s harassment. Fitz, wanting public exoneration for Levine, objected to the Hospital’s job offer, which was then withdrawn. The doctor sued, claiming that Levine’s harassment resulted in his constructive discharge from the University, in violation of 42 U.S.C. 2000e–2(a), and that Fitz’s efforts to prevent his hiring were in retaliation for complaining about that harassment, in violation of section 2000e–3(a). A jury agreed on both claims. The Fifth Circuit vacated as to the constructive-discharge claim, but affirmed with respect to retaliation, reasoning that retaliation claims under 2000e–3(a) require only a showing that retaliation was a motivating factor for the adverse employment action, not its but-for cause. The Supreme Court vacated and remanded. Title VII retaliation claims must be proved according to traditional principles of but-for causation, not the lessened causation test stated in section 2000e–2(m). Title VII’s anti-retaliation provision appears in a different section from its status-based discrimination ban and uses the term “because,” indicating that retaliation claims require proof that desire to retaliate was the but-for cause of the challenged employment action. The Court noted that retaliation claims are made with “ever¬increasing frequency” and that lessening the standard could contribute to the filing of frivolous claims. View "Univ. of TX. SW Med. Ctr. v. Nassar" on Justia Law

Under Title VII (42 U.S.C. 2000e–2(a)(1)), an employer’s liability for workplace harassment may depend on the status of the harasser. If the harassing employee is the victim’s co-worker, the employer is liable only if it was negligent in controlling working conditions. If the harasser is a “supervisor,” however, and the harassment culminates in a tangible employment action, the employer is strictly liable. If there was no tangible employment action, the employer may escape liability by establishing that the employer exercised reasonable care to prevent and correct harassing behavior and that the plaintiff unreasonably failed to take advantage of preventive or corrective opportunities provided by the employer. Vance, an African-American woman, sued her employer, BSU, alleging that a fellow employee, Davis, created a racially hostile work environment in violation of Title VII. The district court entered summary judgment, holding that BSU was not vicariously liable for Davis’ alleged actions because Davis, who could not take tangible employment actions against Vance, was not a supervisor. The Seventh Circuit and Supreme Court affirmed. An employee is a "supervisor" for purposes of vicarious liability under Title VII only if empowered by the employer to take tangible employment actions against the victim. A definition that draws a sharp line between co-workers and supervisors, with the authority to take tangible employment actions as the defining characteristic of a supervisor, can be readily applied. Supervisor status will often be discerned before or soon after litigation commences and is likely to be resolved as a matter of law before trial. This definition will not leave employees unprotected against harassment by co-workers who possess some authority to assign daily tasks and accounts for the fact that many modern organizations have abandoned a hierarchical management structure in favor of giving employees overlapping authority with respect to assignments. View "Vance v. Ball State Univ." on Justia Law

Without being placed in custody or receiving Miranda warnings, the defendant voluntarily answered questions about a murder. He fell silent when asked whether ballistics testing would match his shotgun to casings found at the murder scene. At trial in Texas state court, over defendant’s objection, the prosecution used his failure to answer as evidence of guilt. Defendant was convicted and state courts of appeals affirmed. The Supreme Court affirmed, reasoning that the defendant did not expressly invoke the Fifth Amendment privilege in response to the question. A witness who desires the protection of the privilege must claim it at the time he relies on it. A defendant need not take the stand and assert the privilege at trial, but there is no comparable unqualified right not to speak during a police interview. Failure to invoke the privilege must be excused if governmental coercion makes its forfeiture involuntary, but this defendant agreed to accompany officers to the station and was free to leave at any time. Neither silence nor official suspicion is sufficient by itself to relieve a witness of the obligation to expressly invoke the privilege and they do not do so together. The Court rejected arguments that reliance on the Fifth Amendment privilege is the most likely explanation for silence in a case like this, stating that such silence is “insolubly ambiguous,” and that it would be unfair to require a suspect unschooled in the particulars of legal doctrine to do anything more than remain silent in order to invoke his “right to remain silent.” View "Salinas v. Texas" on Justia Law

Davila, under indictment on tax fraud charges, wrote to the district court, expressing dissatisfaction with his court-appointed attorney, whom, he claimed, simply advised him to plead guilty. Davila requested new counsel. A magistrate held an in camera hearing with Davila and his attorney, but no representative of the prosecution, and told Davila that he would not get another court-appointed attorney and that his best course, given the strength of the prosecution’s case, was to plead guilty. More than three months later, Davila pleaded guilty to a conspiracy charge in exchange for dismissal of 33 other charges. He stated under oath that he was not forced or pressured to enter the plea and did not mention the hearing. Before sentencing, Davila moved to vacate his plea and dismiss the indictment, asserting that he had entered the plea to force the prosecution to acknowledge errors in the indictment. The district judge denied the motion, finding the plea knowing and voluntary. Davila did not mention the in camera hearing. The Eleventh Circuit held that the magistrate’s violation of Federal Rule of Criminal Procedure 11(c)(1), prohibiting court participation in plea discussions, required automatic vacatur. The Supreme Court vacated, noting that both Rule 11 and Rule 52(a), governing trial court error in general, allow for harmless error. Vacatur of the plea is not in order if the record shows no prejudice to Davila’s decision to plead guilty. Rule 11(c)(1) was adopted as a prophylactic measure, not one impelled by the Due Process Clause or any other constitutional requirement, so its violation does not belong in the highly exceptional category of structural errors (denial of counsel of choice or denial of a public trial) that trigger automatic reversal because they undermine the fairness of the entire criminal proceeding. The Court noted that three months elapsed between the in camera meeting and Davila’s appearance before the district judge who examined and accepted his guilty plea after an "exemplary" Rule 11 colloquy. View "United States v. Davila" on Justia Law

Peugh was convicted of bank fraud for conduct that occurred in 1999-2000. Under the 1998 Sentencing Guidelines, his sentencing range was 30 to 37 months, but the 2009 Guidelines yielded a range of 70 to 87 months. The district court rejected an ex post facto claim and sentenced Peugh to 70 months in prison. The Seventh Circuit affirmed. The Supreme Court reversed, holding that sentencing a defendant to a longer term, under Guidelines promulgated after the commission of the criminal acts, violates the Ex Post Facto Clause. The Court rejected the government’s argument that the Sentencing Guidelines lack sufficient legal effect to have the status of “law” within the meaning of the Ex Post Facto Clause. The existence of discretion does not displace the constitutional protections.View "Peugh v. United States" on Justia Law

Department of Health and Human Services (HHS) regulations implementing the 2010 Patient Protection and Affordable Care Act (ACA) require that employers’ group health plans furnish preventive care and screenings for women without cost sharing requirements, 42 U.S.C. 300gg–13(a)(4). Nonexempt employers must provide coverage for 20 FDA-approved contraceptive methods, including four that may have the effect of preventing a fertilized egg from developing. Religious employers, such as churches, are exempt from the contraceptive mandate. HHS has effectively exempted religious nonprofit organizations; an insurer must exclude contraceptive coverage from such an employer’s plan and provide participants with separate payments for contraceptive services. Closely held for-profit corporations sought an injunction under the 1993 Religious Freedom Restoration Act (RFRA), which prohibits the government from substantially burdening a person’s exercise of religion even by a rule of general applicability unless it demonstrates that imposing the burden is the least restrictive means of furthering a compelling governmental interest, 42 U.S.C. 2000bb–1(a), (b). As amended by the Religious Land Use and Institutionalized Persons Act of 2000 (RLUIPA), RFRA covers “any exercise of religion, whether or not compelled by, or central to, a system of religious belief.” The Third Circuit held that a for-profit corporation could not “engage in religious exercise” under RFRA and that the mandate imposed no requirements on corporate owners in their personal capacity. The Tenth Circuit held that the businesses are “persons” under RFRA; that the contraceptive mandate substantially burdened their religious exercise; and that HHS had not demonstrated that the mandate was the “least restrictive means” of furthering a compelling governmental interest.The Supreme Court ruled in favor of the businesses, holding that RFRA applies to regulations that govern the activities of closely held for-profit corporations. The Court declined to “leave merchants with a difficult choice” of giving up the right to seek judicial protection of their religious liberty or forgoing the benefits of operating as corporations. Nothing in RFRA suggests intent to depart from the Dictionary Act definition of “person,” which includes corporations, 1 U.S.C.1; no definition of “person” includes natural persons and nonprofit corporations, but excludes for-profit corporations. “Any suggestion that for-profit corporations are incapable of exercising religion because their purpose is simply to make money flies in the face of modern corporate law.” The Court rejected arguments based on the difficulty of ascertaining the “beliefs” of large, publicly traded corporations and that the mandate itself requires only insurance coverage. If the plaintiff companies refuse to provide contraceptive coverage, they face severe economic consequences; the government failed to show that the contraceptive mandate is the least restrictive means of furthering a compelling interest in guaranteeing cost-free access to the four challenged contraceptive methods. The government could assume the cost of providing the four contraceptives or could extend the accommodation already established for religious nonprofit organizations. The Court noted that its decision concerns only the contraceptive mandate, not all insurance-coverage mandates, e.g., for vaccinations or blood transfusions. View "Burwell v. Hobby Lobby Stores, Inc." on Justia Law