Justia U.S. Supreme Court Opinion Summaries

Bond sought revenge for her husband’s affair by spreading toxic chemicals on Haynes’s car, mailbox, and door knob, in hopes that Haynes would develop a rash. Haynes suffered a minor chemical burn that she treated by rinsing with water. Federal prosecutors charged Bond with violating the Chemical Weapons Convention Implementation Act, which forbids any person knowingly to possess or use "any chemical weapon,” 18 U.S.C. 229(a)(1). A “chemical weapon” is “[a]toxic chemical and its precursors, except where intended for a purpose not prohibited under this chapter.” A “toxic chemical” is “any chemical which through its chemical action on life processes can cause death, temporary incapacitation or permanent harm to humans or animals … regardless of their origin or of their method of production, and regardless of whether they are produced in facilities, in munitions or elsewhere.” “[P]urposes not prohibited by this chapter” is defined as“[a]ny peaceful purpose related to an industrial, agricultural, research, medical, or pharmaceutical activity or other activity,” and other specific purposes. Bond pleaded guilty but reserved the right to appeal. On remand, the Third Circuit rejected her Tenth Amendment argument and an argument that section 229 does not reach her conduct. The Supreme Court reversed. Section 229 does not reach Bond’s simple assault. Seeing “no need to interpret the scope of the international Chemical Weapons Convention,” the Court stated that Bond was prosecuted under a federal statute, which, unlike the treaty, must be read consistent with the principles of federalism. There is no indication that Congress intended to reach purely local crimes; an ordinary speaker would not describe Bond’s feud-driven act of spreading irritating chemicals as involving a “chemical weapon.” The chemicals at issue here bear little resemblance to those whose prohibition was the object of an international Convention. Pennsylvania’s laws are sufficient to prosecute assaults like Bond’s, and the “global need to prevent chemical warfare does not require the Federal Government to reach into the kitchen cupboard.“ View "Bond v. United States" on Justia Law

After the Supreme Court held that the Eighth and Fourteenth Amendments forbid the execution of persons with intellectual disability, Hall asked a Florida state court to vacate his sentence, presenting evidence that included an IQ test score of 71. The court denied relief, determining that a Florida statute mandated that he show an IQ score of 70 or below before being permitted to present any additional intellectual disability evidence. The state’s highest court rejected Hall’s appeal, finding the 70-point threshold constitutional. The U.S. Supreme Court reversed. Florida’s rule disregards established medical practice that an individual score is best understood as a range. While nothing in its statute precludes Florida from considering an IQ test’s standard error of measurement, a statistical fact reflecting the test’s inherent imprecision, the interpretation of the Florida Supreme Court takes an IQ score as conclusive evidence of intellectual capacity. The interpretation fails to recognize that measurement’s inherent imprecision and bars consideration of other relevant evidence, e.g., deficits in adaptive functioning, including evidence of past performance, environment, and upbringing. Current thinking does not regard this strict cutoff as proper or humane. When a defendant’s IQ test score falls within the test’s acknowledged and inherent margin of error, the defendant must be able to present additional evidence of intellectual disability, including testimony regarding adaptive deficits. View "Hall v. Florida" on Justia Law

Martinez was indicted in 2006 on charges of aggravated battery and mob action against the state. After significant delays, caused by both sides, his trial was set to begin on May 17, 2010. His counsel was ready; the prosecution was not because it was unable to locate its complaining witnesses. The court delayed swearing the jurors, but ultimately told the state that it could at that point either have the jury sworn or move to dismiss its case. After several hours, the court swore in the jury and asked the state to present its first witness. It declined to present any evidence or participate in the trial. Martinez successfully moved for a directed not-guilty verdict. The court rejected a motion for a continuance, noting that the prosecution had named other witnesses and that the missing witnesses should have been relatively easy to locate. The Illinois Supreme Court allowed the state’s appeal, on the theory that jeopardy never attached because Martinez “was never at risk of conviction.” The Supreme Court reversed, citing the ”bright-line rule” that “jeopardy attaches when the jury is empaneled and sworn.” Martinez may not be retried. View "Martinez v. Illinois" on Justia Law

After a traffic stop, Rickard refused to produce identification or step out of the car, but led police officers on a high-speed chase. After a spin-out in a parking lot, Rickard continued to accelerate, even though his bumper was flush against a patrol car. An officer fired three shots into Rickard’s car. Rickard managed to drive away, almost hitting an officer. Officers fired 12 more shots as Rickard sped away, striking him and his passenger, both of whom died from a combination of gunshot wounds and injuries suffered when the car crashed. Rickard’s minor daughter filed a 42 U.S.C.1983 action, alleging excessive force. The district court denied the officers’ motion for summary judgment based on qualified immunity, holding that their conduct violated the Fourth Amendment and was contrary to clearly established law. The Sixth Circuit affirmed. After holding that the Sixth Circuit properly exercised jurisdiction, the Supreme Court reversed. The officers acted reasonably in using deadly force. Rickard’s outrageously reckless driving, lasting more than five minutes, exceeded 100 miles per hour, and included passing more than two dozen other motorists. The conduct posed a grave public safety risk. Under the circumstances when the shots were fired, all that a reasonable officer could have concluded from Rickard’s conduct was that he was intent on resuming his flight, which would pose a threat to others on the road. The officers did not fire more shots than necessary to end the public safety risk. During the 10-second span when all the shots were fired, Rickard never abandoned his attempt to flee and eventually managed to drive away. A passenger’s presence does not bear on whether officers violated Rickard’s Fourth Amendment rights. View "Plumhoff v. Rickard" on Justia Law

While campaigning for a second term, President George W. Bush planned to spend the night at a Jacksonville, Oregon, cottage. Local law enforcement permitted supporters and protesters to assemble on opposite sides of a street along the motorcade route. The President made a last-minute decision to have dinner at an Inn’s outdoor patio before going to the cottage. Protesters moved to the front of the Inn, within weapons range of the President. Supporters remained in their original location, where a building blocked sight of, and weapons access to, the patio. At the direction of the Secret Service, police moved protesters two blocks away. They did not require guests already inside the Inn to leave, avoid the patio, or go through security screening. After the President dined, his motorcade passed the supporters, but the protesters were beyond his sight and hearing. Protesters sued, alleging that the agents engaged in viewpoint discrimination, violating the First Amendment. The Ninth Circuit reversed the district court, holding that the protesters failed to state a claim under the Bell Atlantic and Iqbal decisions (rendered after they filed suit). On remand, protesters added allegations that the agents acted pursuant to unwritten Secret Service policy of working with the Bush White House to inhibit expression of disfavored views at presidential appearances. The district court denied a motion to dismiss. The Ninth Circuit affirmed, concluding that viewpoint discrimination could be inferred, absent a legitimate security rationale for different treatment of the groups. The Supreme Court reversed, holding that the agents are entitled to qualified immunity. At the time of the incident, the Court had addressed a constitutional challenge to Secret Service actions only once, recognizing the overwhelming importance of safeguarding the President. There was no precedent indicating that agents engaged in crowd control bear a First Amendment obligation to make sure that groups with conflicting views are at all times in equivalent positions. Maintenance of equal access would not make sense in the situation the agents confronted, where only the protesters, not the supporters, had a direct line of sight to the President. A map shows that, because of the protesters’ location, they posed a potential security risk, while the supporters did not. The agents could keep a close watch on the small number of people already inside the Inn, surveillance that would have been impossible for the hundreds of people outside the Inn. View "Wood v. Moss" on Justia Law

At 2:00 a.m., December 31, 2008, Officer Edwards was patrolling Bellaire, Texas. He saw a black Nissan SUV park in front of a house; Tolan and Cooper emerged. Edwards attempted to enter the license plate number into his squad car computer, but entered an incorrect character that matched a stolen vehicle of the same color and make, which triggered an automatic alert to other police units. Edwards exited his cruiser, drew his gun and ordered the men to the ground. Accused of having stolen the car, Cooper responded, “That’s not true” and Tolan stated, “That’s my car.” Tolan laid down on the porch of the home where he lived with his parents, who came outside. Tolan’s father told Cooper to lie down, then identified Tolan and Cooper (his nephew). Tolan’s mother stated that the vehicle belonged to the family. Sergeant Cotton arrived and drew his pistol. Tolan’s mother reiterated that they owned the car. Cotton ordered her to stand against the garage. She responded, “[A]re you kidding me? We’ve lived her[e] 15 years.” Tolan, his mother, and Cooper later testified that Cotton grabbed her arm and slammed her against the garage with such force that she fell to the ground. There was photographic evidence of bruises on her arms and back. Cotton testified that he was escorting her to the garage, when she flipped her arm up and told him to get his hands off her. Tolan testified that, seeing his mother being pushed, he rose to his knees. Edwards and Cotton testified that Tolan rose to his feet. All agree that Tolan exclaimed, “[G]et your fucking hands off my mom.” Cotton drew his pistol and fired at Tolan, hitting Tolan’s chest, collapsing his right lung and piercing his liver. He survived, but suffered an injury that disrupted his budding baseball career and causes him pain on a daily basis. Dismissing a suit under 42 U.S.C. 1983, the district court found that Cotton’s use of force was not unreasonable. The Fifth Circuit affirmed. The Supreme Court vacated. In holding that Cotton’s actions did not violate clearly-established law, the Fifth Circuit failed to view the evidence in the light most favorable to Tolan as required on summary judgment; it failed to credit evidence that contradicted key factual conclusions, concerning whether the porch was dimly-lit, whether Tolan’s mother refused to remain calm, whether Tolan was verbally threatening, and whether Tolan was moving to intervene. View "Tolan v. Cotton" on Justia Law

Since 1999, Greece, New York has opened monthly town board meetings with a roll call, recitation of the Pledge of Allegiance, and a prayer by a local clergy member. While the prayer program is open to all creeds, nearly all local congregations are Christian. Citizens alleged violation of the First Amendment’s Establishment Clause by preferring Christians over other prayer givers and by sponsoring sectarian prayers and sought to limit the town to “inclusive and ecumenical” prayers that referred only to a “generic God.” The district court entered summary judgment upholding the prayer practice. The Second Circuit reversed, holding that some aspects of the prayer program, viewed in their totality by a reasonable observer, conveyed the message that the town endorsed Christianity.  A divided Supreme Court reversed, upholding the town’s practice. Legislative prayer, while religious in nature, has long been understood as compatible with the Establishment Clause. Most states have also had a practice of legislative prayer and there is historical precedent for opening local legislative meetings with prayer. Any test of such a practice must acknowledge that it was accepted by the Framers and has withstood the scrutiny of time and political change. The inquiry is whether the town of Greece's practice fits within that tradition. To hold that invocations must be nonsectarian would force legislatures sponsoring prayers and courts deciding these cases to act as censors of religious speech, thus involving government in religious matters to a greater degree than under the town’s current practice of neither editing nor approving prayers in advance nor criticizing their content after the fact. It is doubtful that consensus could be reached as to what qualifies as a generic or nonsectarian prayer. The First Amendment is not a “majority rule” and government may not seek to define permissible categories of religious speech. The relevant constraint derives from the prayer’s place at the opening of legislative sessions, where it is meant to lend gravity  and reflect values long part of the Nation’s heritage. Absent a pattern of prayers that over time denigrate, proselytize, or betray an impermissible government purpose, a challenge based only on the content of a particular prayer will not likely establish a constitutional violation. If the town maintains a policy of nondiscrimination, the Constitution does not require it to search beyond its borders for non-Christian prayer givers to achieve religious balance.  View "Town of Greece v. Galloway" on Justia Law

Defendant pleaded guilty to capital murder, capital kidnaping, and first-degree rape, the statutory aggravating circumstance for the murder. At the penalty phase, the trial court denied defense counsel’s request to instruct the jury not to draw any adverse inference from defendant’s decision not to testify. He was sentenced to death. The Kentucky Supreme Court affirmed, finding that the Fifth Amendment’s requirement of a no-adverse-inference instruction to protect a non-testifying defendant at the guilt phase is not required at the penalty phase. The district court granted federal habeas relief. The Sixth Circuit affirmed. The Supreme Court reversed, holding that the Kentucky Supreme Court’s rejection of the Fifth Amendment claim was not objectively unreasonable. The high standard of 28 U.S.C. 2254(d) permits federal habeas relief only if adjudication on the merits in state court “resulted in a decision that was contrary to, or involved an [objectively] unreasonable application of, clearly established Federal law, as determined by” the Supreme Court. After examining its own precedent, the Court stated that the Kentucky Supreme Court’s conclusion was not an unreasonable application of the holdings in those cases, which cannot be read to require the type of blanket no-adverse-inference instruction requested and denied here. The defendant’s own admissions of guilt had established every relevant fact on which Kentucky bore the burden of proof. Section 2254(d)(1) does not require state courts to extend Supreme Court precedent or license federal courts to treat the failure to do so as error. The appropriate time to consider, as a matter of first impression, whether the cited cases require a penalty-phase no-adverse-inference instruction would be on direct review, not in a section 2254(d) habeas case. View "White v. Woodall" on Justia Law

After the Supreme Court decided that the University of Michigan’s undergraduate admissions plan’s use of race-based preferences violated the Equal Protection Clause, but that its law school admission plan’s limited use did not, Michigan voters adopted a new section of the state constitution (Proposal 2), prohibiting use of race-based preferences in the admissions process for state universities. The district court upheld Proposal 2, but the Sixth Circuit reversed, concluding that it violated Supreme Court precedent. The Supreme Court reversed. Justice Kennedy, with Chief Justice Roberts and Justice Alito, reasoned that the principle that consideration of race in admissions is permissible when certain conditions are met was not challenged; the issue was whether, and how, state voters may choose to prohibit consideration of such racial preferences. The decision by Michigan voters reflects an ongoing national dialogue; there was no infliction of a specific injury of the type at issue in cases cited by the Sixth Circuit. Individual liberty has constitutional protection, but the Constitution also embraces the right of citizens to act through a lawful electoral process, as Michigan voters did. Justices Scalia and Thomas stated that the question here, as in every case in which neutral state action is said to deny equal protection on account of race, is whether the challenged action reflects a racially discriminatory purpose. Stating that it did not, the Justices stated that the proposition that a facially neutral law may deny equal protection solely because it has a disparate racial impact “has been squarely and soundly rejected.” Justice Breyer agreed that the amendment is consistent with the Equal Protection Clause, but reasoned that the amendment only applies to, and forbids, race-conscious admissions programs that consider race solely in order to obtain the educational benefits of a diverse student body; the Constitution permits, but does not require, the use of that kind of race-conscious program. The ballot box, not the courts, is the instrument for resolving debates about such programs. This case does not involve a diminution of the minority’s ability to participate in the political process. View "Schuette v. Coal. Defend Affirmative Action, Integration & Immigration Rights" on Justia Law

A California Highway Patrol officer stopped a pickup truck that matched the description of a vehicle that a 911 caller had recently reported as having run her off the road. As officers approached the truck, they smelled marijuana. They searched the truck’s bed, found 30 pounds of marijuana, and arrested defendants, who moved to suppress the evidence, arguing that the traffic stop violated the Fourth Amendment. The motion was denied. They pleaded guilty to transporting marijuana. The California Court of Appeal and the U.S. Supreme Court affirmed. The Fourth Amendment permits brief investigative stops when an officer has “a particularized and objective basis for suspecting the particular person stopped of ... criminal activity.” Reasonable suspicion considers “the totality of the circumstances,” and depends “upon both the content of information possessed by police and its degree of reliability.” The totality of the circumstances indicated that the officer had reasonable suspicion that the truck’s driver was intoxicated. The 911 call bore adequate indicia of reliability for the officer to credit the caller’s account. The caller claimed an eyewitness basis of knowledge. The apparently short time between the reported incident and the 911 call suggests that the caller had little time to fabricate the report. A reasonable officer could conclude that a false tipster would think twice before using the 911 system. The tip created reasonable suspicion of drunk driving. Reasonable suspicion “need not rule out the possibility of innocent conduct.” The officer’s failure to observe additional suspicious conduct during the short period that he followed the truck did not dispel the reason able suspicion of drunk driving. View "Navarette v. California" on Justia Law