Justia U.S. Supreme Court Opinion Summaries

The National Railroad Passenger Corporation (Amtrak) has priority to use track systems owned by the freight railroads for passenger rail travel, at agreed rates or rates set by the Surface Transportation Board. In 2008, Congress gave Amtrak and the Federal Railroad Administration (FRA) joint authority to issue “metrics and standards” addressing performance and scheduling of passenger railroad services, 122 Stat. 4907, including Amtrak’s on-time performance and delays caused by host railroads. The Association of American Railroads sued. The District of Columbia Circuit accepted a separation of powers claim, reasoning that Amtrak is a private corporation and cannot constitutionally be granted regulatory power. The Supreme Court vacated. For purposes of determining the validity of the standards, Amtrak is a governmental entity. The D.C. Circuit relied on the statutory command that Amtrak “is not a department, agency, or instrumentality of the United States,” 49 U.S.C. 24301(a)(3), and “shall be operated and managed as a for profit corporation,” but independent inquiry reveals that the political branches control most of Amtrak’s stock and its Board of Directors, most of whom are appointed by the President. The political branches exercise substantial, statutorily mandated supervision over Amtrak’s priorities and operations: Amtrak is required to pursue broad public objectives; certain day-to-day operations are mandated by Congress; and Amtrak has been dependent on federal financial support during every year of its existence. Amtrak is not an autonomous private enterprise and, in jointly issuing the metrics and standards with the FRA, Amtrak acted as a governmental entity for separation of powers purposes. Treating Amtrak as governmental for these purposes is not an unbridled grant of authority to an unaccountable actor. On remand, the court may address any remaining issues respecting the lawfulness of the metrics and standards. View "Dep't of Transp. v. Ass'n of Am. Railroads" on Justia Law

Colorado requires residents who purchase goods from a retailer that does not collect sales or use taxes to file a return and remit taxes directly to its Department of Revenue. Noncollecting retailers must notify any Colorado customer of the requirement and report tax-related information to those customers and the Department. An association of retailers sued, alleging that Colorado’s law violates the United States and Colorado Constitutions. The district court enjoined enforcement of the notice and reporting requirements. The Tenth Circuit reversed, holding that the Tax Injunction Act (TIA), which provides that federal district courts “shall not enjoin, suspend or restrain the assessment, levy or collection of any tax under State law where a plain, speedy and efficient remedy may be had in the courts of such State,” 28 U.S.C. 1341, deprived the court of jurisdiction. The Supreme Court reversed. The requested relief would not “enjoin, suspend or restrain the assessment, levy or collection” of taxes. The terms “assessment,” “levy,” and “collection” do not encompass enforcement of notice and reporting requirements. The terms, read in light of the federal Tax Code, refer to discrete phases of the taxation process that do not include informational notices or private reports of information relevant to tax liability. Assessment and collection are triggered after the state receives the returns and makes the deficiency determinations that the notice and reporting facilitate. The context in which the TIA uses the word “restrain” favors a narrow meaning. The Court took no position on whether the suit such as this might be barred under the “comity doctrine.” View "Direct Marketing Ass'n v. Brohl" on Justia Law

Frost helped associates commit armed robberies in Washington, generally as the driver. Frost admitted involvement, but claimed he acted under duress. Frost’s lawyer planned to argue both that the state failed to meet its burden of proof and that Frost acted under duress. The judge insisted that the defense choose between the arguments, explaining that state law prohibited simultaneously contesting the elements of the crime and presenting the affirmative defense of duress. Frost’s lawyer limited his summation to duress. The jury convicted Frost of robbery, attempted robbery, burglary, and assault. The Washington Supreme Court affirmed, rejecting the trial court’s view that state law prohibited Frost from both contesting liability and arguing duress and stating that this improper restriction qualified as a trial error (reviewable for harmlessness) rather than a structural error (requiring automatic reversal). Because the jury heard taped confessions and Frost’s confession on the witness stand, the court held that any error was harmless beyond a reasonable doubt. The district court dismissed his habeas petition; the Ninth Circuit, en banc, reversed. A unanimous Supreme Court reversed. Under the Antiterrorism and Effective Death Penalty Act, the petition could be granted only if the state court decision “was contrary to, or involved an unreasonable application of, clearly established Federal law, as determined by the Supreme Court of the United States,” or “was based on an unreasonable determination of the facts in light of the evidence presented in the State court proceeding,.” 28 U. S. C. 2254(d). No Supreme Court case clearly requires placing improper restriction of closing argument in these narrow categories. The trial court did not prohibit the defense from arguing that the prosecution failed to prove the elements of the crime. Reasonable minds could disagree whether requiring the defense to choose between alternative theories. View "Glebe v. Frost" on Justia Law

The inmate, a devout Muslim wanted to grow a ½-inch beard in accordance with his religious beliefs. The Arkansas Department of Correction prohibits prisoners from growing beards, with an exception that inmates with diagnosed skin conditions may grow ¼-inch beards. Prison officials denied him an exemption. Department witnesses testified that beards compromise safety because they can hide contraband and because an inmate could quickly shave to disguise his identity. The district court dismissed, emphasizing that prison officials are entitled to deference on security matters and that the prison permitted exercise of his religion in other ways. The Eighth Circuit affirmed. The Supreme Court reversed. The policy violates the Religious Land Use and Institutionalized Persons Act. 42 U.S.C. 2000cc-1(a). The prisoner’s sincerity is not in dispute and the policy forces him to choose between “engag[ing] in conduct that seriously violates [his] religious belie[f]” and risking discipline. Although he testified that his religion would “credit” him for attempting to follow his beliefs, even if the attempt were unsuccessful, RLUIPA applies to religious exercise regardless of whether it is “compelled.” RLUIPA’s guarantees are not limited to beliefs which are shared by all of the members of a religious sect. The Department failed to show that enforcing its prohibition against the prisoner furthers its stated compelling interests. The Court noted the difficulty of hiding contraband in such a short beard; the lack of a corresponding policy regulating the length of hair on the head; and that the Department did not establish that its security concerns cannot be satisfied by searching a ½-inch beard. Even if the policy furthered a compelling interest in prisoner identification, it violates RLUIPA as applied. Requiring inmates to be photographed both with and without beards would be a less restrictive means. Many institutions allow facial hair and the Department failed to explain the substantial underinclusiveness of its policy with regard to “analogous nonreligious conduct.” View "Holt v. Hobbs" on Justia Law

Jennings sought federal habeas relief based on ineffective assistance of counsel during the punishment phase of his state capital murder trial. The district court granted relief on his “Wiggins theories,” that counsel failed to present evidence of a deprived background and failed to investigate evidence of mental impairment, but not on his “Spisak theory,” that counsel expressed resignation to a death sentence during his closing argument. The court ordered Texas to release Jennings unless, within 120 days, it granted a new sentencing hearing or commuted his death sentence. The Fifth Circuit reversed with respect to the Wiggins theories and determined that it lacked jurisdiction over the Spisak claim, noting that Jennings neither filed a timely notice of appeal nor obtained the certificate of appealability. The Supreme Court reversed. Jennings’ Spisak theory was a defense of his judgment on alternative grounds, so he was not required to take a cross-appeal or obtain a certificate of appealability to argue it. Jennings, as an appellee who did not cross-appeal, could “urge” his Spisak theory unless doing so would enlarge his rights or lessen the state’s rights under the district court’s judgment. Jennings’ rights under the judgment were release, retrial, or commutation and his Spisak claim, if accepted, would give him no more. Nor would it encumber the state’s rights to retain Jennings in custody pending retrial or to commute his sentence. Jennings, whether prevailing on a single theory or all three, sought the same, indivisible relief: a new sentencing hearing. View "Jennings v. Stephens" on Justia Law

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

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