Justia U.S. Supreme Court Opinion Summaries

North Carolina law made it a felony for a registered sex offender “to access a commercial social networking Web site where the sex offender knows that the site permits minor children to become members or to create or maintain personal Web pages.” N.C. Gen. Stat. 14–202.5(a), (e). The state has prosecuted over 1,000 people under that law. Petitioner was indicted after posting a statement on his personal Facebook profile about a positive traffic court experience. State courts upheld the law. The Supreme Court reversed. The statute impermissibly restricts lawful speech in violation of the First Amendment. Today, one of the most important places to exchange views is cyberspace, particularly social media. Even if the statute is content-neutral and subject to intermediate scrutiny, the provision is not “narrowly tailored to serve a significant governmental interest.” While social media will be exploited by criminals and sexual abuse of a child is a most serious crime, the assertion of a valid governmental interest “cannot, in every context, be insulated from all constitutional protections.” The statute “enacts a prohibition unprecedented in the scope of First Amendment speech it burdens…. With one broad stroke, North Carolina bars access to what for many are the principal sources for knowing current events, checking ads for employment, speaking and listening in the modern public square, and otherwise exploring the vast realms of human thought and knowledge.” The state did not establish that this sweeping law is necessary to keep convicted sex offenders away from vulnerable victims. View "Packingham v. North Carolina" on Justia Law

In 1999, LeBlanc, then age 16, raped a 62- year-old woman. In 2003, a state trial court sentenced him to life in prison. Virginia had abolished traditional “parole” for felony offenders and enacted its “geriatric release” program, which allows older inmates to receive conditional release under some circumstances. In 2010, the Supreme Court held, in Graham v. Florida, that the Eighth Amendment prohibits juvenile offenders convicted of nonhomicide offenses from being sentenced to life without parole and that states must give defendants “some meaningful opportunity to obtain release based on demonstrated maturity and rehabilitation.” LeBlanc sought to vacate his sentence in light of Graham. The state court denied the motion, citing the Supreme Court of Virginia’s decision in Angel v. Commonwealth, that Virginia’s geriatric release program satisfies Graham’s requirement of parole for juvenile offenders: “The regulations for conditional release under this statute provide that if the prisoner meets the qualifications for consideration contained in the statute, the factors used in the normal parole consideration process apply to conditional release decisions under this statute.” LeBlanc filed a federal habeas petition, 28 U.S.C. 2254. The Supreme Court reversed the Fourth Circuit’s grant of relief. The Virginia trial court’s ruling, resting on the Virginia Supreme Court’s ruling in Angel, was not objectively unreasonable in light of existing Supreme Court authority. View "Virginia v. LeBlanc" on Justia Law

The Immigration and Nationality Act, 8 U.S.C. 1401(a)(7), provides a path to citizenship for a child born abroad if the child’s U.S.-citizen parent has 10 years’ physical presence in the U.S. before the child’s birth, “at least five of which were after attaining” age 14. Section 1409(c) provides that an unwed U.S.-citizen mother's citizenship can be transmitted to a child born abroad if she has lived continuously in the U.S. for one year before the child’s birth. Morales-Santana’s father, José, moved to the Dominican Republic 20 days before his 19th birthday, so he did not satisfy 1401(a)(7)’s requirement for physical presence after age 14. A Dominican woman gave birth to Morales-Santana in 1962. José accepted parental responsibility. Morales-Santana has lived in the U.S. since he was 13. In 2000, the government sought to remove Morales-Santana based on criminal convictions, ranking him as alien. The Supreme Court affirmed the Second Circuit, ruling in Morales-Santana’s favor. The statute’s gender line is incompatible with the Fifth Amendment’s equal protection requirement. Morales-Santana has third-party standing to vindicate his deceased father’s rights. The Court applied “heightened scrutiny” and found no important governmental interest for the law’s “overbroad generalizations.” Given the choice between extending favorable treatment to the excluded class or withdrawing favorable treatment from the favored class, the Court noted that extension of favorable treatment to fathers would displace Congress’ general rule, the longer physical-presence requirements. Pending Congressional action, the five-year requirement should apply, prospectively, to children born to unwed U.S-citizen mothers. View "Sessions v. Morales-Santana" on Justia Law

The North Carolina General Assembly redrew state legislative districts in 2011 to account for population changes revealed by the 2010 census. Plaintiffs alleged that 28 majority-black districts in the new plan were unconstitutional racial gerrymanders. The district court ruled for the plaintiffs in August 2016, declined to require changes before the November 2016 election, but ordered the General Assembly to redraw the map. Three weeks after the November 2016 election, the court set a March 2017 deadline for drawing new districts, ordering that “[t]he term of any legislator elected in 2016” from a district later redrawn would be replaced by new ones, to be chosen in court-ordered special elections in fall, 2017, to serve a one-year term. The court suspended provisions of the North Carolina Constitution requiring prospective legislators to reside within a district for one year before they may be elected to represent it. The Supreme Court granted a stay pending appeal and subsequently vacated the remedial order. Relief in redistricting cases is “‘fashioned in the light of well-known principles of equity.’” The district court “addressed the balance of equities in only the most cursory fashion.” In determining whether or when a special election may be a proper remedy for a racial gerrymander, obvious considerations include the severity and nature of the particular constitutional violation, the extent of the likely disruption to the ordinary processes of governance if early elections are imposed, and the need to act with proper judicial restraint when intruding on state sovereignty. View "North Carolina v. Covington" on Justia Law

Based on alleged work-related injuries, Nelson, a North Dakota resident, and Tyrrell, the administrator of a South Dakota estate, brought Federal Employers’ Liability Act, 45 U.S.C. 51, suits against BNSF Railroad. Neither injury occurred in Montana. Neither incorporated nor headquartered there, BNSF maintains less than five percent of its workforce and about six percent of its total track mileage in Montana. The Montana Supreme Court held that Montana courts could exercise general personal jurisdiction over BNSF because the railroad “d[id] business” in the state within the meaning of 45 U.S.C. 56. The U.S. Supreme Court reversed. Section 56 does not address personal jurisdiction over railroads but is only a venue prescription. The Montana courts’ exercise of personal jurisdiction did not comport with the Due Process Clause. Only the propriety of general personal jurisdiction was at issue because neither plaintiff alleged injury from work in or related to Montana. A state court may exercise general jurisdiction over out-of-state corporations when their “affiliations with the State are so ‘continuous and systematic’ as to render them essentially at home in the forum State.” The “paradigm” forums in which a corporate defendant is “at home” are its place of incorporation and its principal place of business. In an “exceptional case,” a corporate defendant’s operations in another forum “may be so substantial and of such a nature as to render the corporation at home in that State,” but that constraint does not vary with the type of claim asserted or business enterprise sued. View "BNSF Railroad Co. v. Tyrrell" on Justia Law

The Los Angeles County Sheriff’s Department had information that a potentially armed and dangerous parolee-at-large had been seen at a certain residence. While others searched the main house, deputies searched the property. Unbeknownst to the deputies, Mendez and Garcia were napping inside a shack where they lived. Without a search warrant and without announcing their presence, the deputies opened the shack's door. Mendez rose from the bed, holding a BB gun that he used to kill pests. The deputies shot the men multiple times. In a suit under 42 U.S.C. 1983, the court awarded nominal damages on warrantless entry and knock-and-announce claims. The court found the use of force reasonable, but cited a Ninth Circuit rule, which makes an otherwise reasonable use of force unreasonable if the officer “intentionally or recklessly provokes a violent confrontation” and “the provocation is an independent Fourth Amendment violation. The Ninth Circuit held that the officers were entitled to qualified immunity on the knock-and-announce claim; that the warrantless entry violated clearly established law; and that the provocation rule applied. The Supreme Court vacated. There is a settled, exclusive framework for analyzing whether the force used in making a seizure complies with the Fourth Amendment: “whether the totality of the circumstances justifie[s] a particular sort of search or seizure.” The provocation rule instructs courts to look back to see if a different Fourth Amendment violation was somehow tied to the eventual use of force, mistakenly and unnecessarily conflating distinct Fourth Amendment claims that should be analyzed separately. If plaintiffs cannot recover on their excessive force claim, that will not foreclose recovery for injuries proximately caused by the warrantless entry. View "County of Los Angeles v. Mendez" on Justia Law

North Carolina redrew Congressional Districts 1 and 12 after the 2010 census. Previously, neither district had a majority black voting-age population (BVAP), but both consistently elected candidates preferred by most African-American voters. The state needed to add 100,000 people to District 1 to comply with the one-person-one-vote principle; it took most of them from heavily black areas of Durham—increasing the district’s BVAP from 48.6% to 52.7%. District 12’s BVAP increased from 43.8% to 50.7%. State courts upheld the redistricting. The district court found it unconstitutional. The Supreme Court affirmed. Although the state court’s decision is relevant, the district court properly concluded that race furnished the predominant rationale for District 1’s redesign and that compliance with the Voting Rights Act could not justify that consideration of race, which subordinated other criteria. The redistricting cannot withstand strict scrutiny under the “Gingles” factors. For nearly 20 years, African-Americans made up less than a majority of District 1’s voters, but their preferred candidates scored victories. District 1 was a “crossover” district, in which members of the majority help a “large enough” minority to elect its candidate. History gave the state no reason to think that the Act required it to ramp up District 1’s BVAP. The evidence, even without an alternative map, adequately supported the conclusion that race, not politics, accounted for District 12’s reconfiguration. “By slimming the district and adding a couple of knobs to its snakelike body, North Carolina added 35,000 African-Americans and subtracted 50,000 whites, turning District 12 into a majority-minority district,” indicating a determination to concentrate black voters. View "Cooper v. Harris" on Justia Law

Nelson, convicted of felonies and misdemeanors arising from the alleged abuse of her children, was sentenced to prison and ordered to pay $8,192.50 in court costs, fees, and restitution. Nelson’s conviction was reversed; on retrial, she was acquitted. Madden was also convicted by a Colorado jury. The court imposed a prison sentence and ordered him to pay $4,413.00 in costs, fees, and restitution. Madden’s convictions were reversed and vacated; the state did not appeal or retry the case. The Colorado Department of Corrections withheld $702.10 from Nelson’s inmate account between her conviction and acquittal. Madden paid the state $1,977.75 after his conviction. Once their convictions were invalidated, they sought refunds. The Colorado Supreme Court reasoned that Colorado’s Exoneration Act provided the exclusive authority for refunds and that neither petitioner had filed a claim under that Act; the court also upheld the constitutionality of the Act, which permits Colorado to retain conviction-related assessments until the prevailing defendant institutes a discrete civil proceeding and proves her innocence by clear and convincing evidence. The Supreme Court reversed. The Act’s scheme violates the guarantee of due process. Petitioners have an obvious interest in regaining the money. The state may not retain these funds simply because their convictions were in place when the funds were taken; once the convictions were erased, the presumption of innocence was restored. Colorado may not presume a person, adjudged guilty of no crime, guilty enough for monetary exactions. Colorado’s scheme creates an unacceptable risk of the erroneous deprivation of defendants’ property, conditioning refunds on proof of innocence by clear and convincing evidence, while defendants in petitioners’ position are presumed innocent. When the amount sought is not large, the cost of pursuing a claim under the Act would be prohibitive. Colorado has no equitable interest in withholding petitioners’ money. View "Nelson v. Colorado" on Justia Law

Businesses challenged New York General Business Law section 518, which provides that “[n]o seller in any sales transaction may impose a surcharge on a holder who elects to use a credit card in lieu of payment by cash, check, or similar means,” as violating the First Amendment by regulating how they communicate their prices, and as unconstitutionally vague. The Second Circuit vacated a judgment in favor of the businesses, reasoning that in the context of singlesticker pricing—where merchants post one price and would like to charge more to customers who pay by credit card—the law required that the sticker price be the same as the price charged to credit card users. In that context, the law regulated a relationship between two prices: conduct, not speech. The Supreme Court vacated, limiting its review to single-sticker pricing. Section 518 regulates speech. It is not a typical price regulation, which simply regulates the amount a store can collect. The law tells merchants nothing about the amount they may collect from a cash or credit card payer, but regulates how sellers may communicate their prices. Section 518 is not vague as applied to the businesses; it bans the single-sticker pricing they wish to employ, and “a plaintiff whose speech is clearly proscribed cannot raise a successful vagueness claim.” View "Expressions Hair Design v. Schneiderman" on Justia Law

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