Justia U.S. Supreme Court Opinion Summaries

Lefemine and members of CCL demonstrate, carrying pictures of aborted fetuses, to protest abortions. In 2005, Lefemine and about 20 other CCL members demonstrated at a busy intersection in Greenwood County, South Carolina. Citing complaints about the signs, a police officer informed Lefemine that if the signs were not discarded, he would be ticketed for breach of the peace. Lefemine objected, but disbanded the protest. A year later, Lefemine’s attorney sent a letter to the sheriff, informing him that the group intended to return to the same site with the disputed signs. The department responded that the police had not violated Lefemine’s rights and warned that “should we observe any protester or demonstrator committing the same act, we will again order the person(s) to stop or face criminal sanctions.” Fearing sanctions, the group did not protest in the county for two years. Lefemine filed suit under 42 U.S.C. 1983. The district court permanently enjoined content-based restrictions on Lefemine’s display of graphic signs under similar circumstances, but refused Lefemine’s requests for nominal damages, based on qualified immunity, and attorney fees. The Fourth Circuit affirmed the denial of attorney’s fees. The Supreme Court vacated, holding that the injunction, which altered the legal relationship between the parties, made Lefemine a “prevailing party” under the Civil Rights Attorney’s Fees Awards Act, 42 U. S.C. 1988. View "Lefemine v. Wideman" on Justia Law

Arkansas Game and Fish Commission owns and manages the Donaldson Black River Wildlife Management Area, 23,000 acres with multiple hardwood species and used for recreation and hunting. In 1948, the U.S. Army Corps of Engineers constructed Clearwater Dam upstream from the Area and adopted the Water Control Manual, setting seasonally varying rates for release of water from the Dam. From 1993-2000, the Corps, at the request of farmers, authorized deviations from the Manual that extended flooding into peak timber growing season. The Commission objected that deviations adversely impacted the Area, and opposed a proposal to make deviations part of the permanent water-release plan. After testing, the Corps abandoned the proposed Manual revision and ceased temporary deviations. The Commission sued, alleging that the deviations caused sustained flooding during growing season and that the cumulative impact of the flooding caused destruction of Area timber and substantial change in the terrain, necessitating costly reclamation. The Claims Court judgment ($5,778,757) in favor of the Commission was reversed by the Federal Circuit, which held that government-induced flooding can support a taking claim only if “permanent or inevitably recurring.” The Supreme Court reversed and remanded. Government-induced flooding of limited duration may be compensable. There is no blanket temporary-flooding exception to Takings Clause jurisprudence and no reason to treat flooding differently than other government intrusions. While the public interests are important, they are not categorically different from interests at stake in other takings cases. When regulation or temporary physical invasion by government interferes with private property, time is a factor in determining the existence of a compensable taking, as are the degree to which the invasion is intended or the foreseeable result of authorized government action, the character of the land, the owner’s “reasonable investment-backed expectations,” and the severity of the interference. View "AR Game & Fish Comm'n v. United States" on Justia Law

Plaintiffs claimed that West Virginia's 2011 congressional redistricting plan violated the "one person, one vote" principle that the Court held to be embodied in Article I, section 2, of the United States Constitution. A three-judge District Court for the Southern District of West Virginia agreed, declaring the plan "null and void" and enjoining West Virginia's Secretary of State from implementing it. The state defendants appealed directly to the Court. Because the District Court misapplied the standard for evaluating such challenges set out in Karcher v. Daggett, and failed to afford appropriate deference to West Virginia's reasonable exercise of its political judgment, the Court reversed. View "Tennant v. Jefferson County" on Justia Law

The Stolen Valor Act makes it a crime to falsely claim receipt of military decorations or medals and provides an enhanced penalty if the Congressional Medal of Honor is involved, 18 U. S. C. 704 (b),(c). After pleading guilty to falsely claiming that he had received the Medal of Honor, Alvarez challenged the Act as unconstitutional. The Ninth Circuit held that the Act is invalid under the First Amendment. The Supreme Court affirmed. Characterizing the law as a content-based restriction on protected speech, the Court applied the “most exacting scrutiny.” Falsity alone does not take speech outside the First Amendment. While the government’s interest in protecting the integrity of the Medal of Honor is beyond question, the First Amendment requires a direct causal link between the restriction imposed and the injury to be prevented; that link was not established. The government had no evidence that the public’s general perception of military awards is diluted by false claims or that counter-speech, such as the ridicule Alvarez received online and in the press, would not suffice to achieve its interest. The law does not represent the “least restrictive means among available, effective alternatives.” The government could likely protect the integrity of the military awards system by creating a database of Medal winners accessible and searchable. Dissenting Justices Alito, Scalia, and Thomas viewed the Act as significantly limited and necessary to the important governmental objective. View "United States v. Alvarez" on Justia Law

In a 5-4 ruling, the Supreme Court has upheld the 2010 Patient Protection and Affordable Care Act. While only four Justices found its requirement that certain individuals pay a financial penalty for not obtaining health insurance (26 U.S.C. 5000A) constitutional under the Commerce Clause, Chief Justice Roberts found it constitutional by reasonably characterizing it as a tax. Chief Justice Roberts wrote: “it is not our role to forbid it, or to pass upon its wisdom or fairness." The penalty is to be paid to the IRS, along with the individual’s income taxes. In a limited ruling, the Court held that the Act’s “Medicaid expansion” is unconstitutional in threatening states with loss of existing Medicaid funding if they decline to comply, but that the penalty provision is severable (which means that failure of that provision does not cause the entire Act to fail). The Act requires that state programs provide Medicaid coverage by 2014 to adults with incomes up to 133 percent of the federal pov­erty level, (many states now cover adults with children only if their income is considerably lower, and do not cover childless adults at all) and increases federal funding to cover states’ costs, 42 U.S.C. 1396d(y)(1). The decision leaves intact less controversial provisions, protecting individuals with preexisting conditions, allowing children to be covered by parents’ insurance until age 26, and prohibiting higher costs for insuring women. View "Nat'l Fed'n of Indep. Bus. v. Sebelius" on Justia Law

Montana state law provides that a "corporation may not make ... an expenditure in connection with a candidate or a political committee that supports or opposes a candidate or a political party." Mont. Code 13–35–227(1). The Montana Supreme Court rejected a claim that the statute violated the First Amendment. The Supreme Court reversed the Montana decision, based on its 2010 decision, Citizens United v. Federal Election Commission, in which the Court struck down a similar federal law, holding that "political speech does not lose First Amendment protection simply because its source is a corporation." Dissenting Justices Breyer, Ginsburg, Sotomayor, and Kagan stated that "Montana’s experience, like considerable experience elsewhere since the Court’s decision in Citizens United, casts grave doubt on the Court’s supposition that independent expenditures do not corrupt or appear to do so." View "Am. Tradition P'ship, Inc. v. Bullock" on Justia Law

In each of two underlying cases, a 14-year-old was convicted of murder and sentenced to a mandatory term of life imprisonment without possibility of parole. The highest courts of Alabama and Arkansas upheld the sentences. The Supreme Court reversed. The Eighth Amendment forbids a sentencing scheme that mandates life in prison without possibility of parole for juvenile homicide offenders. Children are constitutionally different from adults for sentencing purposes. Their lack of maturity and underdeveloped sense of responsibility lead to recklessness, impulsiveness, and heedless risk-taking. They are more vulnerable to negative influences and lack ability to extricate themselves from horrific, crime-producing settings. A child’s actions are less likely to be evidence of irretrievable depravity. The mandatory penalty schemes at issue prevent the sentencing court from considering youth and from assessing whether the harshest term of imprisonment proportionately punishes a juvenile offender. Life-without-parole sentences share characteristics with death sentences, demanding individualized sentencing. The Court rejected the states’ argument that courts and prosecutors sufficiently consider a juvenile defendant’s age, background and the circumstances of his crime, when deciding whether to try him as an adult. The argument ignores that many states use mandatory transfer systems or lodge the decision in the hands of the prosecutors, rather than courts. View "Miller v. Alabama" on Justia Law

In the 1970s the FCC began enforcing 18 U.S.C. 1464, which bans broadcast of "any obscene, indecent, or profane language." This case concerns two isolated utterances of obscene words during live broadcasts aired by Fox and an ABC television show during which the nude buttocks of an adult female character were shown for approximately seven seconds and the side of her breast for a moment. Under 2001 Guidelines, a key consideration was whether the material dwelled on or repeated at length the offending description or depiction. After these incidents, the FCC issued its Golden Globes Order, declaring that fleeting expletives could be actionable. It concluded that the broadcasts violated this standard. On remand, the Second Circuit found the policy unconstitutionally vague and invalid. The Supreme Court held that, because the FCC failed to give Fox or ABC fair notice prior to the broadcasts, its standards were vague as applied to the broadcasts. Although the FCC declined to impose a forfeiture on Fox and said that it would not consider the broadcasts in renewing licenses or in other contexts, it has statutory power to take prior offenses into account when setting a penalty, 47 U.S.C. 503(b)(2)(E), and due process protection against vague regulations "does not leave [regulated parties] ... at the mercy of noblesse oblige." The challenged orders could also have an adverse impact on Fox’s reputation with audiences and advertisers. The Court declined to address the constitutionality of the current indecency policy. View "Fed. Commc'n Comm'n v. Fox Television Stations, Inc." on Justia Law

The company was convicted of violating the Resource Conservation and Recovery Act for knowingly storing liquid mercury without a permit "on or about September 19, 2002 to October 19, 2004." Violations are punishable by a fine of not more than $50,000 per day, 42 U.S.C. 6928(d). The probation office calculated a maximum fine of $38.1 million, based on 762 days. The company argued that any fine greater than $50,000 would be unconstitutional under Apprendi v. New Jersey, which held that the Sixth Amendment requires that any fact (other than prior conviction) that increases maximum punishment be proved to a jury beyond a reasonable doubt. The district court held that Apprendi applies to criminal fines, but concluded that the jury found a 762-day violation and imposed a fine of $6 million and a community service obligation of $12 million. The First Circuit affirmed on the ground that Apprendi does not apply to criminal fines. The Supreme Court reversed. Apprendi applies to criminal fines. The "core concern, to reserve to the jury determination of facts that warrant punishment for a specific statutory offense, applies whether the sentence is a criminal fine or imprisonment or death. Dissenters argued that facts relevant to a fine’s amount typically quantify the harm and do not define a separate set of acts for punishment. The majority rejected the assumption that, in determining maximum punishment, there is a constitutionally significant difference between a fact that is an "element" and one that is a "sentencing factor." View "Southern Union Co. v. United States" on Justia Law

In petitioner's bench trial for rape, the prosecution called an expert who testified that a DNA profile produced by an outside lab matched a profile produced by the state police lab using a sample of petitioner's blood. At issue was whether Crawford v. Washington precluded the expert witness from testifying in a manner that had long been allowed under the law of evidence. Specifically, did Crawford bar an expert from expressing an opinion based on facts about a case that have been made known to the expert but about which the expert was not competent to testify. Also at issue was whether Crawford substantially impeded the ability of prosecutors to introduce DNA evidence and thus could effectively relegate the prosecution in some cases to reliance on older, less reliable forms of proof. The Court concluded that this form of expert testimony did not violate the Confrontation Clause because the provision had no application to out-of-court statements that were not offered to prove the truth of the matter asserted. Therefore, the Court concluded that the expert's testimony did not violate the Sixth Amendment. As a second, independent basis for the Court's decision, even if the report produced by the outside lab had been admitted into evidence, there would have been no Confrontation Clause violation. View "Williams v. Illinois" on Justia Law