Justia U.S. Supreme Court Opinion Summaries

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

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

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

Andrew Fields, an inmate at the U.S. Penitentiary in Lee County, Virginia, was placed in solitary confinement by prison officials, who monitored his condition during his isolation. Fields claimed that during periodic checks, certain officials physically abused him. He filed suit in federal court against the Bureau of Prisons, the warden, and several prison officials, seeking damages for alleged excessive force in violation of the Eighth Amendment.The U.S. District Court for the Western District of Virginia dismissed Fields’s complaint, determining that there is no implied cause of action under Bivens v. Six Unknown Fed. Narcotics Agents, 403 U.S. 388 (1971), for excessive force claims by federal prison officers against inmates. The court reasoned that the Supreme Court had never recognized a damages remedy for such claims, so Fields's case arose in a new context, and a Bivens remedy was unavailable. Fields appealed, and the U.S. Court of Appeals for the Fourth Circuit reversed in relevant part. The Fourth Circuit allowed Fields’s Eighth Amendment excessive-force claim for damages to proceed, finding that no special factors counseled against extending Bivens to this context. A dissenting judge argued that precedent barred creating a new Bivens action.The Supreme Court of the United States granted certiorari and reversed the Fourth Circuit’s judgment. The Court held that recognizing a Bivens cause of action for Eighth Amendment excessive-force claims by federal prison officials is inappropriate. The Court found that this case presents a new Bivens context and that special factors, including congressional action in prisoner litigation, alternative remedial structures, and concerns about the operation of prisons, counsel against extending Bivens. The case was remanded for further proceedings consistent with this opinion. View "Goldey v. Fields" on Justia Law

The case involves three separate lawsuits filed by individuals, organizations, and states to prevent the enforcement of President Trump's Executive Order No. 14160. This order specifies conditions under which a person born in the United States is not considered a citizen. The plaintiffs argue that the order violates the Fourteenth Amendment's Citizenship Clause and the Nationality Act of 1940. District Courts in each case issued universal injunctions, preventing the order's enforcement against anyone, not just the plaintiffs. The Government sought to limit these injunctions to the plaintiffs, arguing that the courts lacked the authority to issue such broad relief.The District Courts concluded that the Executive Order was likely unlawful and issued universal preliminary injunctions. The Courts of Appeals denied the Government's requests to stay these injunctions. The Government then filed emergency applications with the Supreme Court, seeking partial stays to limit the injunctions to the plaintiffs.The Supreme Court of the United States reviewed the case and held that universal injunctions likely exceed the equitable authority granted to federal courts by Congress. The Court granted the Government's applications for partial stays, limiting the injunctions to the extent necessary to provide complete relief to each plaintiff with standing to sue. The Court emphasized that federal courts' equitable authority is confined to traditional remedies available at the time of the Judiciary Act of 1789, and universal injunctions do not have a historical precedent. The Court directed the lower courts to determine whether narrower injunctions would be appropriate. View "Trump v. CASA, Inc." on Justia Law

The case involves the Federal Communications Commission (FCC) and its universal-service contribution scheme, which requires telecommunications carriers to contribute to a fund that subsidizes communications services for underserved communities. The FCC uses a formula to determine the contribution amount, and the Universal Service Administrative Company, a private entity, assists in managing the fund and projecting financial needs.The Fifth Circuit Court of Appeals reviewed the case and found the contribution scheme unconstitutional due to a "double-layered delegation" of authority. The court expressed skepticism about Congress's delegation of power to the FCC and the FCC's delegation to the Administrator, suggesting that the combination of these delegations violated the Constitution's nondelegation doctrine.The Supreme Court of the United States reviewed the case and reversed the Fifth Circuit's decision. The Court held that the universal-service contribution scheme does not violate the nondelegation doctrine. It found that Congress provided sufficient guidance to the FCC through the Communications Act of 1934 and its amendments, which set clear policies and boundaries for the FCC's actions. The Court also determined that the FCC retained decision-making authority and that the Administrator's role was advisory, not a delegation of governmental power. The Court rejected the Fifth Circuit's combination theory, stating that the separate delegations did not compound to create a constitutional violation. View "FCC v. Consumers' Research" on Justia Law

During the 2022-2023 school year, the Montgomery County Board of Education introduced LGBTQ+-inclusive storybooks into the public school curriculum for kindergarten through fifth grade. Initially, the Board allowed parents to opt their children out of this instruction, consistent with its guidelines for respecting religious diversity. However, the Board later rescinded this opt-out policy, citing disruptions and potential social stigma for students who opted out. A group of parents from diverse religious backgrounds, who believe the curriculum undermines their religious teachings on sexuality and gender, filed a lawsuit seeking to reinstate the opt-out option.The United States District Court for the District of Maryland denied the parents' request for a preliminary injunction, dismissing their reliance on Wisconsin v. Yoder and characterizing their claim as an objection to school indoctrination. The court held that the curriculum did not violate the Free Exercise Clause. A divided panel of the Fourth Circuit affirmed, finding insufficient evidence that the storybooks coerced students to change their views or act contrary to their faith.The Supreme Court of the United States reversed the Fourth Circuit's decision, holding that the parents are entitled to a preliminary injunction. The Court found that the Board's policies substantially interfere with the religious development of the children and impose a burden on religious exercise similar to that in Yoder. The Court concluded that the parents are likely to succeed on the merits of their claim, suffer irreparable harm without relief, and that an injunction is in the public interest. The Board must notify parents in advance when the books will be used and allow their children to be excused from that instruction. View "Mahmoud v. Taylor" on Justia Law

In 2023, Texas enacted H.B. 1181, which requires commercial websites publishing sexually explicit content to verify that visitors are 18 or older. The law aims to prevent minors from accessing such content, with violations resulting in injunctions and civil penalties. Representatives of the pornography industry challenged the law, claiming it was unconstitutional under the First Amendment as it hindered adults' access to protected speech.The District Court granted a preliminary injunction, finding that the law was subject to strict scrutiny and that Texas had not shown it was narrowly tailored or the least restrictive means to achieve its goal. The court suggested that encouraging parents to use content-filtering software would be a less restrictive alternative.The U.S. Court of Appeals for the Fifth Circuit vacated the injunction, holding that the law was a regulation of the distribution of materials obscene to minors and only incidentally affected adults' privacy. The court applied rational-basis review, concluding that the age-verification requirement was rationally related to the government's interest in preventing minors' access to pornography.The Supreme Court of the United States reviewed the case and held that H.B. 1181 triggers intermediate scrutiny because it only incidentally burdens adults' protected speech. The Court found that the law advances important governmental interests in shielding children from sexual content and is adequately tailored to that interest. The Court affirmed the Fifth Circuit's judgment, concluding that H.B. 1181 is a constitutionally permissible exercise of Texas's authority to prevent minors from accessing sexually explicit content. View "Free Speech Coalition, Inc. v. Paxton" on Justia Law

The case involves two separate lawsuits filed in the United States District Court for the Southern District of New York under the Antiterrorism Act of 1990 (ATA). The plaintiffs, American citizens injured or killed in terror attacks, sued the Palestine Liberation Organization (PLO) and Palestinian Authority (PA). The plaintiffs alleged that the PLO and PA engaged in conduct that triggered jurisdiction under the Promoting Security and Justice for Victims of Terrorism Act (PSJVTA), which deems these entities to have consented to personal jurisdiction in ATA cases under certain conditions.The United States District Court for the Southern District of New York found evidence that the PLO and PA engaged in conduct sufficient to satisfy the PSJVTA's jurisdictional predicates. However, the court ruled that exercising jurisdiction under the PSJVTA was unconstitutional. The Second Circuit Court of Appeals affirmed this decision, holding that the PSJVTA could not establish personal jurisdiction over the PLO or PA consistent with constitutional due process requirements.The Supreme Court of the United States reviewed the case and held that the PSJVTA's personal jurisdiction provision does not violate the Fifth Amendment's Due Process Clause. The Court reasoned that the statute reasonably ties the assertion of jurisdiction over the PLO and PA to conduct involving the United States and implicating sensitive foreign policy matters within the prerogative of the political branches. The Court reversed the Second Circuit's judgment and remanded the case for further proceedings consistent with its opinion. View "Fuld v. Palestine Liberation Organization" on Justia Law