Justia U.S. Supreme Court Opinion Summaries

The Port of Los Angeles is run by a Board of Harbor Commissioners under a municipal ordinance (the tariff) and leases terminal facilities to operators that load and unload ships. Federally-licensed short-haul drayage trucks move cargo in and out of the Port. In response to concerns over proposed port expansion, the Board implemented a Clean Truck Program that involved a standard “concession agreement,” governing the relationship between the Port and drayage companies. It required a placard on each truck including a phone number and submission a plan listing off-street parking locations. Other requirements relate to financial capacity, truck maintenance, and drivers. The Board amended the tariff to make it a misdemeanor for a terminal operator to grant access to an unregistered drayage truck. An association of drayage companies sued, claiming that the requirements are expressly preempted by the Federal Aviation Administration Authorization Act of 1994 (FAAAA), 49 U.S.C. 4501(c)(1), and that even if the requirements are valid, the Port may not enforce them by withdrawing a right to operate at the Port. The district court ruled in favor of the Port. The Ninth Circuit affirmed, finding only the driver-employment provision preempted. A unanimous Supreme Court reversed in part. The FAAAA expressly preempts the placard and parking requirements, which relate to a motor carrier’s price, route, or service with respect to transporting property and “hav[e] the force and effect of law.” The Port exercised classic regulatory authority in forcing terminal operators and, therefore, trucking companies, to alter their conduct by implementing a criminal prohibition punishable by imprisonment. The Port’s proprietary intentions do not control. The Court declined to determine, in a “pre-enforcement posture” whether precedent limits the way the Port can en¬force the financial-capacity and truck-maintenance requirements. View "Am. Trucking Ass'ns., Inc. v. City of Los Angeles" on Justia Law

Peugh was convicted of bank fraud for conduct that occurred in 1999-2000. Under the 1998 Sentencing Guidelines, his sentencing range was 30 to 37 months, but the 2009 Guidelines yielded a range of 70 to 87 months. The district court rejected an ex post facto claim and sentenced Peugh to 70 months in prison. The Seventh Circuit affirmed. The Supreme Court reversed, holding that sentencing a defendant to a longer term, under Guidelines promulgated after the commission of the criminal acts, violates the Ex Post Facto Clause. The Court rejected the government’s argument that the Sentencing Guidelines lack sufficient legal effect to have the status of “law” within the meaning of the Ex Post Facto Clause. The existence of discretion does not displace the constitutional protections. View "Peugh v. United States" on Justia Law

The Agricultural Marketing Agreement Act of 1937 (AMAA), enacted to stabilize prices for agricultural commodities, regulate “handlers,” defined as “processors, associations of producers, and others engaged in the handling” of covered agricultural commodities, 7 U.S.C. 608c(1). The California Raisin Marketing Order, promulgated under the AMAA, established a Raisin Administrative Committee, which recommends annual reserve pools of raisins not to be sold on the open domestic market and requires handlers to pay assessments to help cover administrative costs. The petitioners, raisin producers, refused to surrender requisite portions of raisins to the reserve. The USDA began administrative proceedings. An ALJ found that petitioners were handlers and had violated the AMAA and the Order, and rejected a takings defense. The district court entered summary judgment for the USDA. The Ninth Circuit affirmed. A unanimous Supreme Court reversed, holding that the Ninth Circuit had jurisdiction to decide the takings claim. Petitioners argued that they were producers, not subject to the AMAA or the Order, but the USDA and the district court concluded that they were handlers. Fines and penalties were levied on them in that capacity. Their takings claim, therefore, was necessarily raised in that capacity. The Ninth Circuit confused a statutory argument that they were producers with a constitutional argument that, if they were handlers, their fine violated the Fifth Amendment. The claim was ripe. The petitioners were subject to a final agency order; because the AMAA provides a comprehensive remedial scheme that withdraws Tucker Act jurisdiction over a handler’s takings claim, there is no alternative remedy. View "Horne v. Department of Agriculture" on Justia Law

In 1998, defendant allegedly forced his way into the apartment of his former girlfriend, Heathmon,raped and hit her, stole a ring, and dragged her outside by the neck and hair. A witness confronted him and defendant fled. Police observed injuries to Heathmon’s neck and scalp, consistent with her account. Defendant was arrested. Although he did not testify at trial, his statements to police were admitted into evidence. He claimed that the sex was consensual and denied dragging Heathmon, but admitted that she might have felt threatened and that he hit her. Before trial, Heathmon sent the judge a letter recanting her accusations and stating that she would not testify. She went into hiding, but police took her into custody as a material witness. Heatthmon disavowed the letter and agreed to testify. She stated that defendant’s associates had forced her to write the letter and had threatened to hurt her if she testified. At trial, the defense sought to introduce testimony and police reports showing that Heathmon had called the police on prior occasions claiming that defendant had raped or assaulted her. Police were unable to corroborate many of those allegations. Although the court gave the defense wide latitude to cross¬examine Heathmon, it refused to admit the police reports or to allow the defense to call involved officers as witnesses. Defendant was sentenced to life imprisonment. After exhausting state remedies, defendant filed a federal habeas petition, 28 U.S.C. 2254(d). The district court denied relief, but a divided Ninth Circuit reversed, finding violation of defendant’s constitutional right to present a defense, and that the Nevada Supreme Court’s decision to the contrary was an unreasonable application of Supreme Court precedent. The Supreme Court reversed, holding that the Nevada Supreme Court’s decision was reasonable. The Constitution grants broad latitude in establishing rules excluding evidence from criminal trials. The Nevada statute generally precludes admission of extrinsic evidence of specific instances of the conduct of a witness, for the purpose of attacking or supporting the witness’ credibility, other than conviction of crime, Nev. Rev. Stat. 50.085(3). The state has “good reason[s]” for limiting use of extrinsic evidence, and its statute is akin to the widely accepted rule of evidence. The statute has an exception for previous fabricated sexual assault accusations, but the defendant must file written notice, and the trial court must hold a hearing. Defendant did not file the requisite notice. No decision of the Supreme Court clearly establishes that the notice requirement is unconstitutional. Some of the evidence that defendant sought to introduce concerned prior incidents that did not involve alleged sexual assault; the state court reasoned that the proffered evidence had little impeachment value because it showed simply that the victim’s reports could not be corroborated. The admission of extrinsic evidence of specific instances of a witness’ conduct to impeach the witness may confuse the jury, unfairly embarrass the victim, surprise the prosecution, and unduly prolong a trial. The Supreme Court has never held that the Confrontation Clause entitles a criminal defendant to introduce extrinsic evidence for impeachment. View "Nevada v. Jackson" on Justia Law

After his arrest on first- and second-degree assault charges, King was processed through a Wicomico County, Maryland, facility, where personnel used a cheek swab to take a DNA sample pursuant to the Maryland DNA Collection Act (Act), which authorizes officers to collect DNA samples from persons charged with violent crimes. A sample may not be added to a database before an individual is arraigned, and it must be destroyed if he is not convicted. Only identity information may be added to the database. King’s swab was matched to an unsolved 2003 rape. He unsuccessfully moved to suppress the DNA match. The Maryland Court of Appeals set aside his conviction, finding portions of the Act authorizing DNA collection from felony arrestees unconstitutional. The Supreme Court reversed. Taking and analyzing a cheek swab of the arrestee’s DNA is, like fingerprinting and photographing, a legitimate police booking procedure that is reasonable under the Fourth Amendment when officers make an arrest supported by probable cause to hold and bring the suspect to the station to be detained in custody, for a serious offense. DNA testing involves minimal intrusion that may significantly improve both the criminal justice system and police investigative practices; it is quick and painless and requires no intrusion beneath the skin. When probable cause exists to remove an individual from the normal channels of society and hold him in legal custody, DNA identification plays a critical role in serving interests in properly identifying who has been arrested, ensuring that the custody of an arrestee does not create inordinate risks for staff, for the existing detainee population, and for a new detainee, and in ensuring that persons accused of crimes are available for trials. Identifying an arrestee as the perpetrator of some heinous crime may have the salutary effect of freeing a person wrongfully imprisoned. The Court noted that the test does not reveal an arrestee’s genetic traits and is unlikely to reveal any private medical information. View "Maryland v. King" on Justia Law

Trevino was convicted of capital murder in Texas state court and sentenced to death. Neither new counsel appointed for direct appeal nor new counsel appointed for state collateral review raised the claim that trial counsel provided ineffective assistance during the penalty phase by failing to adequately investigate and present mitigating circumstances. When that claim was finally raised in Trevino’s federal habeas petition, the district court stayed proceedings so Trevino could raise it in state court. The state court found the claim procedurally defaulted. The federal court concluded that this failure was an independent and adequate state ground barring federal courts from considering the claim. The Fifth Circuit affirmed. The Supreme Court subsequently held, in Martinez v. Ryan, that “a procedural default will not bar a federal habeas court from hearing a substantial claim of ineffective assistance at trial if, in the [State’s] initial-review collateral proceeding, there was no counsel or counsel in that proceeding was ineffective.” Martinez concerned a prisoner from Arizona, where state law required the prisoner to raise the claim during his first state collateral review proceeding. Texas law does not require a defendant to raise his ineffective-assistance claim on collateral review and the Fifth Circuit subsequently held that Martinez was inapplicable to Texas cases. The Supreme Court vacated and remanded. Where, as here, state procedures make it highly unlikely in a typical case that a defendant will have a meaningful opportunity to raise an ineffective-¬assistance-of-trial-counsel claim on direct appeal, the Martinez exception applies. Texas procedures make it nearly impossible for an ineffective-assistance claim to be presented on direct review; a writ of habeas corpus is normally needed to gather the facts necessary for evaluating such claims. Were Martinez not to apply, the Texas procedural system would create significant unfairness. The Court noted Texas courts’ own “well-supported determination that collateral review normally is the preferred procedural route for raising an ineffective-assistance-of-trial-counsel claim.” Failure to consider a lawyer’s “ineffectiveness” during an initial-review collateral proceeding as a potential “cause” for excusing a procedural default will deprive the defendant of any opportunity for review of an ineffective-assistance-of-trial-counsel claim. View "Trevino v. Thaler" on Justia Law

Henderson was stabbed to death after leaving a party with Perkins and Jones. Perkins was charged with murder. Jones testified that Perkins alone committed the murder while Jones watched. Perkins testified that Jones and Henderson left him during the evening, and that he later saw Jones with blood on his clothing. Perkins was convicted and sentenced to life in prison without the possibility of parole. The Antiterrorism and Effective Death Penalty Act of 1996 gives a state prisoner one year to file a federal habeas corpus petition, 28 U. S. C. 244(d)(1)(A). If the petition alleges newly-discovered evidence, the filing deadline is one year from “the date on which the factual predicate of the claim ... could have been discovered through ... due diligence.” More than 11 years after his conviction became final in 1997, Perkins filed his federal habeas petition, alleging ineffective assistance of trial counsel. To overcome AEDPA’s time limitations, he asserted newly discovered evidence of actual innocence in the form of three affidavits, the most recent dated July 16, 2002, each pointing to Jones as the murderer. The district court found that, even if the affidavits could be characterized as evidence newly discovered, Perkins had failed to show diligence entitling him to equitable tolling of AEDPA’s limitations period, and, alternatively, that Perkins had not shown that, taking account of all the evidence, no reasonable juror would have convicted him. The Sixth Circuit reversed, holding that Perkins’ actual-innocence claim allowed him to present his ineffective-assistance claim as if it had been filed on time. The Supreme Court vacated and remanded. A federal habeas court, faced with an actual-innocence gateway claim, should count unjustifiable delay on a habeas petitioner’s part, not as an absolute barrier to relief, but as a factor in determining whether actual innocence has been reliably shown. A petitioner invoking the miscarriage of justice exception must show that it is more likely than not that no reasonable juror would have convicted him in light of the new evidence.” Unexplained delay in presenting new evidence bears on the determination whether the petitioner has made the requisite showing. The district court’s appraisal of Perkins’ petition as insufficient to meet the demanding Schlup standard for actual innocence should be dispositive, absent cause to upset that evaluation. View "McQuiggin v. Perkins" on Justia Law

In 1993, Lancaster, a former police officer with a long history of severe mental-health problems, killed his girlfriend. At his jury trial in Michigan state court, Lancaster asserted a defense of diminished capacity. Under then-prevailing Michigan Court of Appeals precedent, the diminished-capacity defense permitted a legally sane defendant to present evidence of mental illness to negate the specific intent required to commit a particular crime. The jury convicted him of first-degree murder. Lancaster later obtained federal habeas relief. By the time of Lancaster’s retrial, the Michigan Supreme Court had rejected the diminished-capacity defense in its 2001 decision, Carpenter. The judge at his second trial applied Carpenter and disallowed renewal of his diminished-capacity defense. Lancaster was again convicted. The Michigan Court of Appeals rejected Lancaster’s argument that retroactive application of Carpenter violated due process. Lancaster reasserted his due process claim in a federal habeas petition. The district court denied the petition, but the Sixth Circuit reversed. A unanimous Supreme Court reversed, holding that Lancaster is not entitled to federal habeas relief. The Michigan Court of Appeals’ rejection of Lancaster’s due process claim does not represent an unreasonable application of Supreme Court precedent, 28 U. S. C.2254(d)(1). In Carpenter, the Michigan Supreme Court rejected a diminished-capacity defense, reasonably finding the defense to have no origin in an on-point statute. The Supreme Court has never found a due process violation where a state supreme court, squarely addressing a particular issue for the first time, rejected a consistent line of lower court decisions based on the supreme court’s reasonable interpretation of a controlling statute. Fair-minded jurists could conclude that a state supreme court decision of that order is not “unexpected and indefensible by reference to [existing] law.” View "Metrish v. Lancaster" on Justia Law

Virginia’s Freedom of Information Act grants Virginia citizens access to all public records, but grants no such right to non-Virginians. Citizens of other states, including the owner of a business that obtains real estate tax records on behalf of clients, filed requests under the Act. After each was denied, they filed a 42 U. S. C. 1983 suit, alleging violations of the Privileges and Immunities Clause and the dormant Commerce Clause. The district court granted Virginia summary judgment. The Fourth Circuit and the Supreme Court affirmed. The Constitution does not guarantee the existence of FOIA laws. The Privileges and Immunities Clause protects only privileges and immunities that are “fundamental.” The Clause protects the right of citizens to “ply their trade, practice their occupation, or pursue a common calling,” only with respect to laws enacted for the protectionist purpose of burdening out-of-state citizens. Virginia’s FOIA exists to allow Virginia citizens to obtain an accounting from their public officials; noncitizens have no comparable need. The distinction between citizens and noncitizens recognizes that citizens pay fixed costs underlying record-keeping. The law does not prevent noncitizens from obtaining documents necessary to the transfer of property or deprive noncitizens of “reasonable and adequate” access to Commonwealth courts. It gives noncitizens access to non-privileged litigation documents, to judicial records, and to records pertaining directly to them. Virginia’s FOIA does not violate the dormant Commerce Clause. It neither prohibits access to an interstate market nor imposes burdensome regulation on that market; if there is a “market” for Virginia’s public documents, it is a market for a product that the Commonwealth has created and of which the Commonwealth is the sole manufacturer. View "McBurney v. Young" on Justia Law

McNeely, stopped for speeding and crossing the centerline, declined to take a breath test to measure his blood alcohol concentration (BAC). He was arrested and taken to a hospital. The officer never attempted to secure a search warrant. McNeely refused to consent, but the officer directed a lab technician to take a sample. McNeely’s BAC tested above the legal limit, and he was charged with driving while intoxicated. The trial court suppressed the test result, concluding that the exigency exception to the warrant requirement did not apply because, apart from the fact that McNeely’s blood alcohol was dissipating, no circumstances suggested that the officer faced an emergency. The Missouri Supreme Court and U.S. Supreme Court affirmed. The Court looked to the “totality of circumstances,” declining to announce a per se rule. When officers in drunk-driving investigations can reasonably obtain a warrant before having a blood sample drawn without significantly undermining the efficacy of the search, the Fourth Amendment mandates that they do so. Circumstances may make obtaining a warrant impractical such that dissipation will support an exigency, but that is a reason to decide each case on its facts. Blood testing is different in critical respects from other destruction-of-evidence cases; BAC evidence naturally dissipates in a gradual and relatively predictable manner. Because an officer must typically obtain a trained medical professional’s assistance before having a blood test conducted, some delay between the time of the arrest and time of the test is inevitable regardless of whether a warrant is obtained. View "Missouri v. McNeely" on Justia Law