Justia U.S. Supreme Court Opinion Summaries

Petitioner requested that the Secretary of the Interior take into trust on its behalf a tract of land known as the Bradley Property, which petitioner intended to use "for gaming purposes." The Secretary took title to the property and respondent subsequently filed suit under the Administrative Procedures Act (APA), 5 U.S.C. 500 et seq., asserting that the Indian Reorganization Act (IRA), 25 U.S.C. 465, did not authorize the Secretary to acquire the property because petitioner was not a federally recognized tribe when the IRA was enacted in 1934. At issue was whether the United States had sovereign immunity from the suit by virtue of the Quiet Title Act (QTA), 86 Stat. 1176, and whether respondent had prudential standing to challenge the Secretary's acquisition. The Court held that the United States had waived its sovereign immunity from respondent's action under the QTA. The Court also held that respondent had prudential standing to challenge the Secretary's acquisition where respondent's interests came within section 465's regulatory ambit. View "Match-E-Be-Nash-She-Wish Band of Pottawatomi Indians v. Patchak" on Justia Law

Under the Civil Service Reform Act of 1978 (CSRA), 5 U.S.C. 1101 et seq., certain federal employees could obtain administrative and judicial review of specified adverse employment actions. At issue was whether the CSRA provided the exclusive avenue to judicial review when a qualifying employee challenged an adverse employment action by arguing that a federal statute was unconstitutional. The Court held that it did. The CSRA precluded district court jurisdiction over petitioners' claims because it was fairly discernible that Congress intended the statute's review scheme to provide the exclusive avenue to judicial review for covered employees who challenged covered adverse employment actions, even when those employees argued that a federal statute was unconstitutional. View "Elgin v. Dept. of Treasury" on Justia Law

This case arose when respondent brought an action against petitioners, two Secret Service agents, and others, under 42 U.S.C. 1983 and Bivens v. Six Unknown Fed. Narcotics Agents, claiming that he was arrested and searched without probable cause, in violation of the Fourth Amendment, and that the arrest violated the First Amendment because it was made in retaliation for respondent's criticism of Vice President Cheney. At issue was whether two federal law enforcement agents were immune from suit for allegedly arresting a suspect in retaliation for his political speech, when the agents had probable cause to arrest the suspect for committing a federal crime. The Court held that petitioners were entitled to qualified immunity because, at the time of respondent's arrest, it was not clearly established that an arrest supported by probable cause could give rise to a First Amendment violation. View "Reichle v. Howards" on Justia Law

An Indiana statute, the "Barrett Law," Ind. Code 36-9-15(b)(3), authorized Indiana's cities to impose upon benefited owners the cost of sewer improvement projects. The Law also permitted those lot owners to pay either immediately in the form of a lump sum or over time in installments. In 2005, the city of Indianapolis adopted a new assessment and payment method, the "STEP" plan, and it forgave any Barrett Law installments that lot owners had not yet paid. A group of lot owners who had already paid their entire Barrett Law assessment in a lump sum believed that the City should have provided them with equivalent refunds. At issue was whether the City's refusal to do so unconstitutionally discriminated against them in violation of the Equal Protection Clause, Amdt. 14, section 1. The Court held that the City had a rational basis for distinguishing between those lot owners who had already paid their share of project costs and those who had not. Therefore, the Court concluded that there was no equal protection violation. View "Armour v. Indianapolis" on Justia Law

This case arose when defendant was charged with capital murder for the death of a one-year-old. Before the jury concluded deliberations, it reported that it was unanimous against guilt on charges of capital murder and first-degree murder, was deadlocked on manslaughter, and had not voted on negligent homicide. The trial court told the jury to continue to deliberate. The jury did so but still could not reach a verdict, and the trial court declared a mistrial. All agreed that defendant could be retried on charges of manslaughter and negligent homicide. At issue was whether defendant could also be retried on charges of capital and first-degree murder. The Court concluded that the jury in this case did not convict defendant of any offense, but it did not acquit him of any either. When the jury was unable to return a verdict, the trial court properly declared a mistrial and discharged the jury. As a consequence, the Double Jeopardy Clause did not stand in the way of a second trial on the same offenses. Accordingly, the Court affirmed the judgment of the Supreme Court of Arkansas. View "Blueford v. Arkansas" on Justia Law

In 1987, petitioner was convicted of murder and other crimes by a Colorado court and sentenced to life imprisonment. Petitioner filed a federal habeas petition in 2008. After receiving the petition, the district court asked the State if it planned to argue that the petition was untimely. In response, the State twice informed the district court that it would "not challenge, but [was] not conceding," the timeliness of the petition. Thereafter, the district court ordered the parties to brief both the merits and the timeliness of the petition. At issue was the authority of a federal court to raise, on its own motion, a statute of limitations defense to a habeas corpus petition. The Court held that courts of appeal, like district courts, have the authority - though not the obligation - to raise a forfeited timeliness defense on their own initiative in exceptional cases. The Tenth Circuit abused its discretion when it dismissed the petition as untimely. In the district court, the State was well aware of the statute of limitations defense available to it, and of the arguments that could be made in support of that defense. Yet, the State twice informed the district court that it would "challenge" the timeliness of the petition. In doing so, the State deliberately waived the statute of limitations defense. In light of that waiver, the Tenth Circuit should have followed the district court's lead and decided the merits of the petition. Accordingly, the Court reversed and remanded. View "Wood v. Milyard" on Justia Law

Respondent, a firefighter employed by the City of Rialto, brought an action under 42 U.S.C. 1983 against the City, the Fire Department, the private attorney hired by the City, and other individuals. The district court granted summary judgment to the individual defendants based on qualified immunity. The Ninth Circuit concluded that the attorney the City hired was not entitled to seek qualified immunity because he was a private attorney, not a City employee. At issue before the Court was whether an individual hired by the government to do its work was prohibited from seeking qualified immunity, solely because he worked for the government on something other than a permanent full-time basis. The Court held that a private individual temporarily retained by the government to carry out its work was entitled to seek qualified immunity from suit under section 1983. Therefore, the Court reversed the judgment of the Ninth Circuit. View "Filarsky v. Delia" on Justia Law

Respondent, the chief investigator for a district attorney's office, testified at grand jury proceedings that resulted in petitioner's indictment. After the indictments were dismissed, petitioner brought an action under 42 U.S.C. 1983, alleging that respondent had conspired to present and did present false testimony to the grand jury. The district court denied respondent's motion to dismiss on immunity grounds, but the Eleventh Circuit reversed, holding that respondent had absolute immunity from a section 1983 claim based on his grand jury testimony. The Court affirmed and held that a witness in a grand jury proceeding was entitled to the same absolute immunity from suit under section 1983 as a witness who testified at trial. View "Rehberg v. Paulk" on Justia Law

Petitioner filed a 42 U.S.C. 1983 action in the district court against government entities that ran the jails and other defendants, alleging Fourth and Fourteenth Amendment violations, and arguing that persons arrested for minor offenses could not be subjected to invasive searches unless prison officials have reason to suspect concealment of weapons, drugs, or other contraband. The district court granted him summary judgment, ruling that "strip-searching" nonindictable offenders without reasonable suspicion violated the Fourth Amendment. The Third Circuit Reversed. The Court affirmed and concluded that the search procedure at the county jails struck a reasonable balance between inmate privacy and the needs of the institutions, and thus the Fourth and Fourteenth Amendments did not require adoption of the framework and rules petitioner proposed. View "Florence v. Board of Chosen Freeholders of County of Burlington" on Justia Law

When petitioner was indicted in a Texas court on drug charges, the State also moved to revoke the probation term that he was then serving for another drug offense. At about the same time, petitioner pleaded guilty to federal drug charges. At issue was whether a district court, in sentencing a defendant for a federal offense, had authority to order that the federal sentence be consecutive to an anticipated state sentence that had not yet been imposed. The Sentencing Reform Act of 1984, 18 U.S.C. 3584(a), addressed the concurrent-vs.-consecutive decision, but not the situation here, since the District Court did not impose "multiple terms of imprisonment... at the same time," and petitioner was not "already subject to" the state sentence at issue. This did not mean that the District Court lacked authority to act as it did and that the Bureau of Prisons was to make the concurrent-vs.-consecutive decision after the federal sentence had been imposed. It was more natural to read section 3584(a) as leaving room for the exercise of judicial discretion in situations not covered than it was to read section 3621(b) as giving the Bureau what amounted to sentencing authority. Because it was within the District Court's discretion to order that petitioner's sentence run consecutively to his anticipated state sentence in the probation revocation proceeding; and because the state court's subsequent decision to make that sentence concurrent with its other sentence did not establish that the District Court abused its discretion by imposing an unreasonable sentence; the Court affirmed the judgment of the Fifth Circuit. View "Setser v. United States" on Justia Law