Justia U.S. Supreme Court Opinion Summaries

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

Sharif tried to discharge a debt to Wellness in his Chapter 7 bankruptcy. Wellness argued that a trust Sharif claimed to administer was actually Sharif’s alter ego, and that its assets were part of his bankruptcy estate. The Bankruptcy Court entered default judgment against Sharif. While appeal was pending, but before briefing concluded, the Supreme Court held (Stern v. Marshall) that Article III forbids bankruptcy courts to enter final judgment on claims that seek only to “augment” the bankruptcy estate and would otherwise “exis[t] without regard to any bankruptcy proceeding.” The district court denied Sharif permission to file a supplemental brief and affirmed. The Seventh Circuit determined that Sharif’s “Stern” objection could not be waived and reversed, holding that the Bankruptcy Court lacked constitutional authority to enter judgment on the alter ego claim. The Supreme Court reversed. Article III permits bankruptcy judges to adjudicate Stern claims with the parties’ knowing and voluntary consent. The right to adjudication before an Article III court is “personal” and “subject to waiver,” unless Article III’s structural interests as “an inseparable element of the constitutional system of checks and balances” are implicated; parties “cannot by consent cure the constitutional difficulty.” Allowing bankruptcy courts to decide Stern claims by consent does not usurp the constitutional prerogatives of Article III courts. Bankruptcy judges are appointed and may be removed by Article III judges, hear matters solely on a district court’s reference, and possess no free-floating authority to decide claims traditionally heard by Article III courts. Consent to adjudication by a bankruptcy court need not be express, but must be knowing and voluntary. The Seventh Circuit should decide on remand whether Sharif’s actions evinced the requisite knowing and voluntary consent and whether Sharif forfeited his Stern argument. View "Wellness Int’l Network, Ltd. v. Sharif" 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

After being charged with the felony offense of distributing marijuana, Henderson was required, as a condition of bail, to turn over firearms that he lawfully owned. Henderson pleaded guilty, and, as a felon, was prohibited under 18 U.S.C. 922(g) from possessing any firearms. Henderson asked the FBI, which had custody of his firearms, to transfer them to his friend. The agency refused. The district court reasoned that Henderson’s requested transfer would give him constructive possession of the firearms. The Eleventh Circuit affirmed. The unanimous Supreme Court vacated: A court-ordered transfer of a felon’s lawfully owned firearms from government custody to a third party is not barred by section 922(g) if the court is satisfied that the recipient will not give the felon control over the firearms, so that he could either use them or direct their use. The government’s view conflated possession, which section 922(g) prohibits, with an owner’s right to alienate his property, which it does not. The Court stated that a felon may select a firearms dealer or third party to sell his guns; a court, with proper assurances from the recipient, may also grant a felon’s request to transfer his guns to a person who expects to maintain custody of them. View "Henderson v. United States" on Justia Law

Maryland has a “state” income tax, Md. Tax-Gen. Code 10–105(a), and a “county” income tax, sections 10–103, 10–106. Residents who pay income tax to another jurisdiction for income earned in that other jurisdiction get a credit against the state tax but not the county tax. Nonresidents who earn income from Maryland sources must pay the state income tax; nonresidents not subject to the county tax must pay a “special nonresident tax.” Residents who earned pass-through income from a Subchapter S corporation that earned income in several states claimed an income tax credit on their Maryland tax return for taxes paid to other states. The Comptroller allowed a credit against state income tax but not against county income tax and assessed a tax deficiency. The Court of Appeals of Maryland held that the tax unconstitutionally discriminated against interstate commerce. The Supreme Court affirmed: Maryland’s personal income tax scheme violates the dormant Commerce Clause. The Court noted previous decisions invalidating state tax schemes that might lead to double taxation of out-of-state income and that discriminated in favor of intrastate over interstate economic activity. That conclusion is not affected by the fact that these cases involved a tax on gross receipts rather than net income, and a tax on corporations rather than individuals. Maryland’s income tax scheme fails the internal consistency test; if every state adopted its tax structure, interstate commerce would be taxed at a higher rate than intrastate commerce. The scheme is inherently discriminatory and operates as a tariff. The Court rejected an argument that, by offering residents who earn income in interstate commerce a credit against the state portion of the tax, Maryland receives less tax revenue from residents who earn interstate, rather than intrastate, commerce income; the total tax burden on interstate commerce is higher. View "Comptroller of Treasury of Md. v. Wynne" on Justia Law

Florida voters elect judges. The Florida Supreme Court adopted Canon 7C(1) of its Code of Judicial Conduct, stating that judicial candidates “shall not personally solicit campaign funds . . . but may establish committees of responsible persons” to raise money for election campaigns. Yulee mailed and posted online a letter soliciting financial contributions to her campaign for judicial office. The Florida Bar disciplined her for violating a Bar Rule requiring candidates to comply with Canon 7C(1). The Florida Supreme Court upheld the sanction against a First Amendment challenge. The U.S. Supreme Court affirmed. Florida’s interest in preserving public confidence in the integrity of its judiciary is compelling.. Unlike the legislature or the executive, the judiciary “has no influence over either the sword or the purse,” so its authority largely depends on the public’s willingness to respect its decisions. Canon 7C(1) raises no fatal underinclusivity concerns. The solicitation ban aims squarely at the conduct most likely to undermine public confidence in the integrity of the judiciary: it is not riddled with exceptions. Allowing a candidate to use a committee and to write thank you notes reflect Florida’s effort to respect the First Amendment interests of candidates and contributors. Canon 7C(1) is not overinclusive It allows judicial candidates to discuss any issue with any person at any time; to write letters, give speeches, and put up billboards; to contact potential supporters in person, on the phone, or online; and to promote their campaigns through the media. Though they cannot ask for money, they can direct their campaign committees to do so. Florida has reasonably determined that personal appeals for money by a judicial candidate inherently create an appearance of impropriety. Canon 7C(1) must be narrowly tailored, not “perfectly tailored” to address that concern. View "Williams-Yulee v. Florida Bar" on Justia Law

Struble, a K–9 officer, stopped Rodriguez for driving on a highway shoulder, a violation of Nebraska law. Struble attended to everything relating to the stop, including checking the driver’s licenses of Rodriguez and his passenger and issuing a warning. He then sought permission to walk his dog around the vehicle. Rodriguez refused. Struble detained him until another officer arrived, then retrieved his dog, who alerted to the presence of drugs. The ensuing search revealed methamphetamine. Seven or eight minutes elapsed from the time Struble issued the warning until the dog alerted. Rodriguez was indicted. He moved to suppress the evidence on the ground that Struble had prolonged the stop without reasonable suspicion. The district court denied the motion. Rodriguez entered a conditional guilty plea. The Eighth Circuit affirmed, characterizing the delay as a “de minimis intrusion” on personal liberty. The Supreme Court vacated. Absent reasonable suspicion, extension of a traffic stop in order to conduct a dog sniff constitutes an unreasonable seizure. A routine traffic stop is like a brief “Terry” stop; its tolerable duration is determined by the “mission.” Authority for the seizure ends when tasks tied to the traffic infraction are, or reasonably should be, completed. Lacking the same close connection to roadway safety as the ordinary inquiries, a dog sniff is not fairly characterized as part of the traffic mission. An officer who completes all traffic-related tasks expeditiously does not earn extra time to pursue unrelated criminal investigations; the question is not whether the dog sniff occurs before issuance of a ticket, but whether conducting the sniff adds time to the stop. The district court determination that detention for the dog sniff was not independently supported by individualized suspicion was not reviewed by the Eighth Circuit. View "Rodriguez v. United States" 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

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