Justia U.S. Supreme Court Opinion Summaries

Windsor and Spyer, two women, married in Canada in 2007. Their home state, New York, recognized the marriage. Spyer died in 2009 and left her estate to Windsor, who sought to claim the federal estate tax exemption for surviving spouses. Her claim was barred by section 3 of the Defense of Marriage Act (DOMA), 28 U.S.C. 1738C, which defined “marriage” and “spouse” to exclude same-sex partners for purposes of federal law. Windsor paid $363,053 in taxes and sought a refund, which the IRS denied. Windsor sued, challenging DOMA. The Department of Justice declined to defend section 3’s constitutionality. The district court ordered a refund, finding section 3 unconstitutional. The Second Circuit affirmed. The Supreme Court affirmed, 5-4, first holding that the government retained a stake, sufficient to support Article III jurisdiction, because the unpaid refund is “a real and immediate economic injury.” There was sufficient argument for section 3’s constitutionality to satisfy prudential concerns. DOMA is unconstitutional as a deprivation of the equal liberty of persons under the Fifth Amendment. Regulation of marriage has traditionally been within the authority of the states. DOMA, applicable to more than 1,000 federal statues and all federal regulations, was directed to a class of persons that the laws of New York and 11 other states have sought to protect. DOMA is inconsistent with the principle that marriage laws may vary from state to state, but are consistent within each state. A state’s decision to give a class of persons the right to marry confers a dignity and status of immense import. New York’s decision was a proper exercise of its sovereign authority. By seeking to injure the class New York seeks to protect, DOMA violated basic due process and equal protection principles applicable to the federal government. Constitutional guarantees of equality “must at the very least mean that a bare congressional desire to harm a politically unpopular group cannot” justify disparate treatment of the group. DOMA’s history and text indicate a purpose and practical effect to impose a disadvantage, a separate status, and a stigma upon those entering into same-sex marriages made lawful by the states. The law deprived some couples married under the laws of their states, but not others, of rights and responsibilities, creating two contradictory marriage regimes within the same state; it diminished the stability and predictability of basic personal relations. View "United States v. Windsor" on Justia Law

The Voting Rights Act of 1965, 42 U.S.C. 1973(a), was enacted to address racial discrimination in voting. Section 2 bans any “standard, practice, or procedure” that “results in a denial or abridgement of the right of any citizen ... to vote on account of race or color,” applies nationwide, and is permanent. Other sections apply to some parts of the country. Section 4 defines “covered jurisdictions” as states or political subdivisions that maintained tests or devices as prerequisites to voting and had low voter registration or turnout in the 1960s and early 1970s. Section 5 provides that no change in voting procedures can take effect in covered jurisdictions until approved by federal authorities (preclearance). The coverage formula and preclearance requirement were to expire after five years, but the Act was reauthorized. In 2006, the Act was reauthorized for an additional 25 years, but coverage still turned on whether a jurisdiction had a voting test and low registration or turnout almost 50 years ago. Shelby County, in the covered jurisdiction of Alabama, sought a declaratory judgment that sections 4(b) and 5 are facially unconstitutional. The district court upheld the Act. The D. C. Circuit affirmed. A 5-4 Supreme Court reversed, finding Section 4 unconstitutional. Its formula may not be used to require preclearance. States have broad autonomy in structuring their governments and pursuing legislative objectives; the Tenth Amendment reserves to states “the power to regulate elections.” There is a “fundamental principle of equal sovereignty” among the states. The Voting Rights Act departs from those principles by requiring states to request federal permission to implement laws that they would otherwise have the right to enact and execute. The Act applies to only nine states (and additional counties). In 1966, the departures were justified by racial discrimination that had “infected the electoral process in parts of our country for nearly a century” so that the coverage formula was rational in practice and theory. Nearly 50 years later, “things have changed dramatically.” Voter turnout and registration rates in covered jurisdictions approach parity; blatantly discriminatory evasions of federal decrees are rare. Minority candidates hold office at unprecedented levels. Congress, if it is to continue to divide the states, must identify jurisdictions to be singled out on a basis that makes sense under current conditions. Data compiled by Congress before reauthorizing the Act did not show anything like the pervasive, rampant discrimination found in covered jurisdictions in 1965. Congress reenacted the formula based on 40-year-old facts with no logical relation to the present day. View "Shelby County v. Holder" on Justia Law

Kebodeaux was convicted by special court-martial of a federal sex offense. After serving his sentence and receiving a bad-conduct discharge from the Air Force, he moved to Texas where he registered with state authorities as a sex offender. Congress later enacted the Sex Offender Registration and Notification Act (SORNA), which requires federal sex offenders to register in the states where they live, study, and work, 42 U.S.C. 16913(a). SORNA applies to offenders who, when SORNA became law, had completed their sentences. When Kebodeaux moved within Texas and failed to update his registration, the federal government prosecuted him and the district court convicted him under SORNA. The Fifth Circuit reversed. The Supreme Court reversed, holding that SORNA’s registration requirements, as applied to Kebodeaux, fall within the scope of congressional authority under the Necessary and Proper Clause. Congress did not apply SORNA to an individual who was, before its enactment, “unconditionally released,” but to an individual already subject to federal registration requirements. SORNA somewhat modified registration requirements to which Kebodeaux was already subject, to make more uniform "a patchwork of federal and 50 individual state registration requirements." At the time of his offense and conviction, Kebodeaux was subject to the Wetterling Act, which imposed similar registration requirements and was promulgated under the Military Regulation Clause (Art. I, s. 8, cl. 14), and the Necessary and Proper Clause. The same power that authorized Congress to promulgate the Uniform Code of Military Justice and punish Kebodeaux’s crime also authorized Congress to make the civil registration requirement at issue a consequence of conviction. Imposing a civil registration requirement that would apply upon the release of an offender like Kebodeaux is “eminently reasonable,” as is assignment of a special role to the federal government in ensuring compliance with federal sex offender registration requirements. View "United States v. Kebodeaux" on Justia Law

Based on the 1978 strangling death of a 74-year-old, Schad was convicted in 1985 of first-degree murder and sentenced to death. After extensive Arizona state and federal court proceedings, the Supreme Court denied petitions for certiorari and for rehearing. Schad immediately moved for a stay pending the Ninth Circuit’s decision in a separate en banc case The Ninth Circuit denied the motion, stating that an indefinite stay “would unduly interfere with Arizona’s execution process,” but also declined to issue its mandate as normally required by Federal Rule of Appellate Procedure 41(d)(2)(D). The court instead, sua sponte, construed Schad’s motion as a motion to reconsider a motion that it had denied six months earlier and remanded to the district court. Arizona then set an execution date. Based on its review of that previously rejected motion, the Ninth Circuit issued a stay a few days before Schad’s scheduled execution. The Supreme Court granted Arizona’s petition to vacate the stay and remanded with instructions to issue the mandate immediately, without any further proceedings. The Ninth Circuit did not demonstrate that exceptional circumstances justified withholding its mandate; its failure to issue its mandate constituted an abuse of discretion. View "Ryan v. Schad" on Justia Law

Since the Court’s 2003 decision, Grutter v. Bollinger, the University of Texas at Austin has considered race as a factor in undergraduate admissions. A Caucasian, rejected for admission, sued, alleging that consideration of race in admissions violated the Equal Protection Clause. The district court granted summary judgment to the University. The Fifth Circuit affirmed. The Supreme Court vacated and remanded, reasoning that the Fifth Circuit did not hold the University to the demanding burden of strict scrutiny articulated in Supreme Court precedent. A university must clearly demonstrate that its purpose or interest is constitutionally permissible and substantial, and that its use of the classification is necessary to the accomplishment of its purpose, and “that the reasons for any [racial] classification [are] clearly identified and unquestionably legitimate.” A court may give some deference to a university’s judgment that diversity is essential to its educational mission, if diversity is not defined as mere racial balancing and there is a reasoned, principled explanation for the academic decision. The University must prove that the means it chose to attain diversity are narrowly tailored to its goal and that admissions processes “ensure that each applicant is evaluated as an individual and not in a way that makes an applicant’s race or ethnicity the defining feature of his or her application.” A reviewing court must ultimately be satisfied that no workable race-neutral alternative would produce the educational benefits of diversity. The Fifth Circuit simply presumed that the school acted in good faith and gave the plaintiff the burden of rebutting that presumption. Strict scrutiny does not permit a court to accept a school’s assertion that its admissions process uses race in a permissible way without closely examining how the process works in practice. On remand, the Fifth Circuit must assess whether the University has offered sufficient evidence to prove that its admissions program is narrowly tailored to obtain the educational benefits of diversity. View "Fisher v. Univ. of TX at Austin" on Justia Law

The U.S. Leadership Against HIV/AIDS, Tuberculosis, and Malaria Act of 2003, 22 U.S.C. 7601, authorizes appropriations to fund nongovernmental efforts to combat HIV/AIDS worldwide, with conditions that: no funds “may be used to promote or advocate the legalization or practice of prostitution” and no funds may be used by an organization “that does not have a policy explicitly opposing prostitution” (the Policy Requirement). To enforce the Policy Requirement, the Department of Health and Human Services and the U.S. Agency for International Development require funding recipients to agree that they oppose prostitution. Funding recipients, wishing to remain neutral on prostitution, sought a declaratory judgment that the Policy Requirement violates their First Amendment rights. The district court issued a preliminary injunction, barring the government from cutting off funding during the litigation. The Second Circuit and Supreme Court affirmed. The First Amendment “prohibits the government from telling people what they must say.” The Spending Clause grants Congress broad discretion to fund private programs for the general welfare and to limit the use of funds to ensure they are used in the manner intended. There is a distinction between conditions that define the limits of the spending program and specify the activities Congress wants to subsidize and conditions that seek to leverage funding to regulate speech outside the contours of the federal program itself. The Act’s other condition, prohibiting use of funds “to promote or advocate the legalization or practice of prostitution or sex trafficking,” ensures that federal funds will not be used for prohibited purposes. The Policy Requirement goes further and, by its very nature, affects protected conduct outside the scope of the federally funded program. The Requirement goes beyond preventing recipients from using private funds in a way that could undermine the federal program and requires them to pledge allegiance to government policy. View "Agency for Int'l Dev. v. Alliance for Open Soc'y Int'l, Inc." on Justia Law

Alleyne was convicted using or carrying a firearm in relation to a crime of violence, 18 U.S.C. 924(c)(1)(A), which carries a five-year mandatory minimum sentence. The sentences increases to a seven-year minimum if the firearm is brandished, 924(c)(1)(A)(ii), and to a 10-year minimum if it is discharged, 924(c)(1)(A)(iii). The jury form indicated that Alleyne had “[u]sed or carried a firearm during and in relation to a crime of violence,” but not that the firearm was “[b]randished.” Alleyne objected to a sentencing report recommendation of a seven-year term, arguing that the jury did not find brandishing beyond a reasonable doubt and that raising his mandatory minimum sentence based on a judge’s finding of brandishing would violate his Sixth Amendment right to a jury trial. The district court overruled the objection. The Fourth Circuit affirmed. The Supreme Court vacated and remanded, overruling Harris v. United States, 536 U.S. 545 and applying Apprendi v. New Jersey, 530 U.S. 466. Mandatory minimum sentences increase the penalty for a crime and any fact that increases the mandatory minimum is an "element" that must be submitted to the jury. Defining facts that increase a mandatory minimum as part of the substantive offense enables a defendant to predict the applicable penalty from the face of the indictment and preserves the jury’s role as intermediary between the state and criminal defendants. Because the fact of brandishing aggravates the prescribed range of allowable sentences, it constitutes an element of a separate, aggravated offense that must be found by the jury, regardless of what sentence the defendant might have received had a different range been applicable. The Court noted that its ruling does not mean that any fact that influences judicial discretion must be found by a jury. View "Alleyne v. United States" on Justia Law

The National Voter Registration Act of 1993 (NVRA) requires states to accept and use a uniform federal form to register voters for federal elections, 42 U.S.C. 1973gg–4(a)(1). The form developed by the Election Assistance Commission, requires only that an applicant aver, under penalty of perjury, that he is a citizen. Arizona law required rejection of any application for registration, including the federal form, if not accompanied by documentary evidence of citizenship. The district court granted summary judgment, upholding Arizona’s requirement. The Ninth Circuit reversed in part, holding that the requirement is preempted by the NVRA. The Supreme Court affirmed. The Elections Clause imposes on states the duty to prescribe the time, place, and manner of electing Representatives and Senators, but confers on Congress the power to alter those regulations or supplant them altogether. The Clause confers authority to provide a complete code for congressional elections, including regulations relating to “registration.” The NVRA term “accept” implies that the form is to be accepted as sufficient and Congress, when it acts under the Clause, is always on notice that its legislation will displace some element of a state’s preexisting legal regime. While the NVRA forbids states to demand additional information beyond that required by the federal form, it does not preclude states from denying registration based on information in their possession establishing the applicant’s ineligibility. The NVRA can be read to avoid a conflict, however. The NVRA permits a state to request state-specific instructions on the federal form and a state may challenge rejection of that request. That alternative means of enforcing its constitutional power to determine voting qualifications remains open to Arizona. View "Arizona v. Inter Tribal Council of Ariz., Inc." 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

Davila, under indictment on tax fraud charges, wrote to the district court, expressing dissatisfaction with his court-appointed attorney, whom, he claimed, simply advised him to plead guilty. Davila requested new counsel. A magistrate held an in camera hearing with Davila and his attorney, but no representative of the prosecution, and told Davila that he would not get another court-appointed attorney and that his best course, given the strength of the prosecution’s case, was to plead guilty. More than three months later, Davila pleaded guilty to a conspiracy charge in exchange for dismissal of 33 other charges. He stated under oath that he was not forced or pressured to enter the plea and did not mention the hearing. Before sentencing, Davila moved to vacate his plea and dismiss the indictment, asserting that he had entered the plea to force the prosecution to acknowledge errors in the indictment. The district judge denied the motion, finding the plea knowing and voluntary. Davila did not mention the in camera hearing. The Eleventh Circuit held that the magistrate’s violation of Federal Rule of Criminal Procedure 11(c)(1), prohibiting court participation in plea discussions, required automatic vacatur. The Supreme Court vacated, noting that both Rule 11 and Rule 52(a), governing trial court error in general, allow for harmless error. Vacatur of the plea is not in order if the record shows no prejudice to Davila’s decision to plead guilty. Rule 11(c)(1) was adopted as a prophylactic measure, not one impelled by the Due Process Clause or any other constitutional requirement, so its violation does not belong in the highly exceptional category of structural errors (denial of counsel of choice or denial of a public trial) that trigger automatic reversal because they undermine the fairness of the entire criminal proceeding. The Court noted that three months elapsed between the in camera meeting and Davila’s appearance before the district judge who examined and accepted his guilty plea after an "exemplary" Rule 11 colloquy. View "United States v. Davila" on Justia Law