Justia U.S. Supreme Court Opinion Summaries

Oil States sued Greene's Energy for infringement of a patent relating to technology for protecting wellhead equipment used in hydraulic fracturing. Greene’s challenged the patent’s validity in court and petitioned the Patent Office for inter partes review, 35 U.S.C. 311-319. The district court issued a claim-construction order favoring Oil States; the Board concluded that Oil States’ claims were unpatentable. The Federal Circuit rejected a challenge to the constitutionality of inter partes review. The Supreme Court affirmed. Inter partes review does not violate Article III. Congress may assign adjudication of public rights to entities other than Article III courts. Inter partes review falls within the public-rights doctrine. Patents are “public franchises” and granting patents is a constitutional function that can be carried out by the executive or legislative departments without “judicial determination.’ Inter partes review involves the same basic matter as granting a patent. Patents remain “subject to [the Board’s] authority” to cancel outside of an Article III court. The similarities between the procedures used in inter partes review and judicial procedures does not suggest that inter partes review violates Article III. The Court noted that its decision “should not be misconstrued as suggesting that patents are not property for purposes of the Due Process Clause or the Takings Clause.” When Congress properly assigns a matter to adjudication in a non-Article III tribunal, “the Seventh Amendment poses no independent bar to the adjudication of that action by a nonjury factfinder.” View "Oil States Energy Services, LLC v. Greene's Energy Group, LLC" on Justia Law

Wilson was convicted of murder and sentenced to death. He unsuccessfully sought habeas relief in Georgia courts, claiming ineffectiveness of counsel during sentencing. The Georgia Supreme Court summarily denied relief. Wilson filed a federal habeas petition, raising the same ineffective-assistance claim. The district court assumed that his counsel was deficient but deferred to the state court’s conclusion that any deficiencies did not prejudice Wilson. The Eleventh Circuit affirmed. The Supreme Court reversed, rejecting the Eleventh Circuit's methodology. A federal habeas court reviewing an unexplained state-court decision on the merits should “look through” that decision to the last related state-court decision that provides a relevant rationale and presume that the unexplained decision adopted the same reasoning. The state may rebut the presumption by showing that the unexplained decision most likely relied on different grounds. The presumption is often realistic; state higher courts often issue summary decisions when they have examined the lower court’s reasoning and found nothing significant with which they disagree. The presumption also is often more efficient than requiring a federal court to imagine what might have been the state court’s supportive reasoning. The “look through” presumption is not an absolute rule and does not show disrespect for the states but seeks to replicate the grounds for the higher state court’s decision. View "Wilson v. Sellers" on Justia Law

Dimaya, a lawful U.S. permanent resident has two convictions for first-degree burglary under California law. An Immigration Judge and the Board of Immigration Appeals held that California first-degree burglary is a “crime of violence” under 18 U.S.C. 16(b), so that Dimaya was deportable under 8 U.S.C. 1229b. While Dimaya’s appeal was pending the Supreme Court held that a similar clause in the Armed Career Criminal Act (ACCA)—defining “violent felony” as any felony that “otherwise involves conduct that presents a serious potential risk of physical injury to another,” was unconstitutionally “void for vagueness” (Johnson decision). Relying on Johnson, the Ninth Circuit held that section 16(b), as incorporated into the Immigration and Nationality Act, was also unconstitutionally vague. The Supreme Court affirmed. Section 16(b) has the same two features as ACCA’s residual clause—an ordinary-case requirement and an ill-defined risk threshold—combined in the same constitutionally problematic way. The combination of “indeterminacy about how to measure the risk posed by a crime [and] indeterminacy about how much risk it takes for the crime to qualify as a violent felony,” result in “more unpredictability and arbitrariness than the Due Process Clause tolerates,” Three textual discrepancies between ACCA’s residual clause and section 16(b) do not relate to those features that Johnson found to produce impermissible vagueness or otherwise makes the statutory inquiry more determinate. View "Sessions v. Dimaya" on Justia Law

Kisela, a Tucson police officer, shot Hughes less than a minute after arriving, with other officers, at the scene where a woman had been reported to 911 as hacking a tree with a knife and acting erratically. When Kisela fired, Hughes was holding a large kitchen knife, had taken steps toward nearby woman (her roommate), and had refused to drop the knife after at least two commands to do so. Hughes matched the description given by the 911 caller. Her injuries were not life-threatening. All of the officers later said that they subjectively believed Hughes was a threat to her roommate. Hughes had a history of mental illness. Her roommate said that she did not feel endangered. Hughes sued Kisela, alleging excessive force, 42 U.S.C. 1983. The Supreme Court ruled in favor of the officer, reversing the Ninth Circuit. Even assuming a Fourth Amendment violation occurred, which “is not at all evident,” Kisela was entitled to qualified immunity. Although the officers were in no apparent danger, Kisela believed Hughes was a threat to her roommate. Kisela had mere seconds to assess the potential danger and was separated from the women by a chain-link fence. This is "far from an obvious case" in which any competent officer would have known that shooting Hughes would violate the Fourth Amendment; the most analogous Ninth Circuit precedent favors Kisela. A reasonable officer is not required to foresee judicial decisions that do not yet exist in instances where the requirements of the Fourth Amendment are far from obvious. View "Kisela v. Hughes" on Justia Law

Ayestas was convicted of murder and sentenced to death in a Texas state court. He secured new counsel; his conviction and sentence were affirmed on appeal. A third legal team sought, unsuccessfully, state habeas relief, claiming ineffective assistance of trial counsel but not counsel’s failure to investigate petitioner’s mental health and substance abuse. His fourth legal team raised that failure in a federal habeas petition. The court found the claim procedurally defaulted because it had never been raised in state court. The case was remanded for reconsideration in light of Martinez, in which the Supreme Court held that a prisoner seeking federal habeas relief could overcome the procedural default of a trial-level ineffective-assistance claim by showing that the claim is substantial and that state habeas counsel was ineffective in failing to raise it, and Trevino's extension of that holding to Texas prisoners. The Fifth Circuit affirmed the denial of his motion for funding to develop his claim (18 U.S.C. 3599(f)). A unanimous Supreme Court vacated, first holding that the denial was a judicial decision, requiring the application of a legal standard and subject to appellate review, rather than an administrative decision. The Fifth Circuit did not apply the correct legal standard in requiring that applicants show a “substantial need” for the services. Section 3599 authorizes funding for the “reasonably necessary” services of experts, investigators, and the like; it requires the court to determine, in its discretion, whether a reasonable attorney would regard the services as sufficiently important. The court also required “a viable constitutional claim that is not procedurally barred,” which is too restrictive after Trevino. An argument that funding is never “reasonably necessary” where a habeas petitioner seeks to present a procedurally defaulted ineffective-assistance claim that depends on facts outside the state-court record may be considered on remand. View "Ayestas v. Davis" on Justia Law

After a 2004 conviction, Rodriguez, a Mexican citizen and a lawful U.S. permanent resident, was detained under 8 U.S.C. 1226 while the government sought his removal. In 2007, Rodriguez sought habeas relief, claiming that he was entitled to a bond hearing to determine whether his continued detention was justified, alleging that 8 U.S.C. 1225(b), 1226(a), and 1226(c) do not authorize “prolonged” detention without an individualized bond hearing at which the government proves by clear and convincing evidence that detention remains justified. The Ninth Circuit affirmed the entry of an injunction. The Supreme Court reversed; the sections do not give detained aliens the right to periodic bond hearings. “Read most naturally,” sections 1225(b)(1) and (b)(2) mandate detention of applicants for admission until immigration officers have finished considering the asylum application or until removal proceedings have concluded, without imposing a time limit or reference to bond hearings. There is a specific provision authorizing temporary parole “for urgent humanitarian reasons or significant public benefit,” implying that there are no other circumstances under which section 1225(b) detainees may be released. Section 1226(c)’s language allows aliens to be released “only if ” the Attorney General decides that certain conditions are met. Nothing in the section supports the imposition of periodic bond hearings nor does it hint that the length of detention before the bond hearing must be considered in determining whether an alien should be released. On remand, the Ninth Circuit should consider the merits of Rodriguez’s constitutional arguments in the first instance. View "Jennings v. Rodriguez" on Justia Law

A federal grand jury indicted Class for possessing firearms in his locked jeep, which was parked on the grounds of the U.S. Capitol in Washington, D. C.; 40 U.S.C. 5104(e)(1) provides that “An individual . . . may not carry . . . on the Grounds or in any of the Capitol Buildings a firearm.” After the court rejected his Second Amendment and Due Process claims, Class pleaded guilty. His plea agreement said nothing about the right to challenge on direct appeal the constitutionality of the statute. The Court of Appeals held that Class, by pleading guilty, had waived his constitutional claims. The Supreme Court reversed. A guilty plea, alone, does not bar a federal criminal defendant from challenging the constitutionality of his statute of conviction on direct appeal. Where the claim implicates “the very power of the State” to prosecute the defendant, a guilty plea cannot by itself bar it. Class's claims do not contradict the terms of the indictment or the plea agreement and can be resolved based on the record. Class challenged the government’s power to criminalize his (admitted) conduct and to constitutionally prosecute. Federal Rule of Criminal Procedure 11(a)(2), which governs “conditional” guilty pleas, does not say whether it sets forth the exclusive procedure for a defendant to preserve a constitutional claim following a guilty plea and does not apply to this situation. View "Class v. United States" on Justia Law

District of Columbia police officers responded to a complaint about loud music and illegal activities in a vacant house and found the house in disarray. They smelled marijuana and saw liquor. They found a makeshift strip club in the living room, and a naked woman and several men in a bedroom. The partygoers gave inconsistent stories. Two identified “Peaches” as the tenant and said that she had given permission for the party. When the officers spoke by phone to Peaches, she was agitated and evasive, eventually admitting that she did not have permission to use the house. The owner confirmed that he had not given anyone permission to be there. The officers arrested the partygoers for unlawful entry. Several partygoers sued for false arrest. The Supreme Court held that the officers had probable cause to arrest the partygoers. Considering the totality of the circumstances, the officers made an “entirely reasonable inference” that the partygoers knew they did not have permission to be in the house, The condition of the house and the conduct of the partygoers allowed the officers to make common-sense conclusions about human behavior and infer that the partygoers, who scattered and hid, knew the party was not authorized. The partygoers’ implausible answers gave the officers reason to infer that they were lying. The officers are entitled to qualified immunity under 42 U.S.C. 1983 even if they lacked actual probable cause because a reasonable officer could have interpreted the law as permitting the arrests. View "District of Columbia v. Wesby" on Justia Law

Tharpe moved to reopen his federal habeas corpus proceedings regarding his claim that the Georgia jury that convicted him of murder included a white juror, Gattie, who was biased against Tharpe because he is black. The district court denied the motion as procedurally defaulted in state court. The Eleventh Circuit denied a certificate of appealability application based on its conclusion, rooted in the state court’s fact-finding, that Tharpe had not established prejudice. The Supreme Court vacated and remanded. While the state court’s prejudice determination is binding on federal courts absent clear and convincing evidence to the contrary, Tharpe produced a sworn affidavit, signed by Gattie, indicating Gattie’s view that “there are two types of black people: 1. Black folks and 2. Niggers”; that Tharpe, “who wasn’t in the ‘good’ black folks category in my book, should get the electric chair for what he did”; that “[s]ome of the jurors voted for death because they felt Tharpe should be an example to other blacks who kill blacks, but that wasn’t my reason”; and that, “[a]fter studying the Bible, I have wondered if black people even have souls.” Gattie’s "remarkable" affidavit presents a strong factual basis for the argument that Tharpe’s race affected Gattie’s vote for a death verdict. "At the very least, jurists of reason could debate whether Tharpe has shown by clear and convincing evidence that the state court’s factual determination was wrong.” View "Tharpe v. Sellers" on Justia Law

The Acting Secretary of the Department of Homeland Security (DHS) announced steps to rescind the Deferred Action for Childhood Arrivals (DACA) program by March 2018, concluding that DACA violates the Administrative Procedure Act and the Due Process Clause. The Ninth Circuit ruled in favor of challengers. The government then moved to stay the district court order requiring completion of the administrative record until after resolution of motions to dismiss and for a preliminary injunction. The court stayed its order for one month. The government petitioned the Supreme Court, which vacated. The district court’s order required the government to turn over all “emails, letters, memoranda, notes, media items, opinions and other materials ... actually seen or considered, however briefly, by Acting Secretary ... in connection with the ... decision … all DACA-related materials considered by persons (anywhere in the government) who thereafter provided … written advice or input … all DACA-related materials considered by persons (anywhere in the government) who thereafter provided … verbal input … all comments and questions propounded ... to advisors or subordinates … and their responses, and … all materials directly or indirectly considered by former Secretary of DHS John Kelly leading to his February 2017 memorandum not to rescind DACA. The court should have first resolved the government’s threshold arguments that the decision was unreviewable as “committed to agency discretion,” 5 U.S.C. 701(a)(2), and that the Immigration and Nationality Act deprives the court of jurisdiction. The court may not compel the government to disclose any document that the government believes is privileged without first providing an opportunity to argue the issue. The Court did not consider the merits of the claims or defenses. View "In Re United States" on Justia Law