Justia U.S. Supreme Court Opinion Summaries

Petitioner was born in Jerusalem and his mother requested that his place of birth be listed as "Israel" on a consular report of birth abroad and on his passport pursuant to section 214(d) of the Foreign Relations Authorization Act, Fiscal Year 2003, 116 Stat. 1350. U.S. officials refused the request and petitioner's parents filed suit on his behalf against the Secretary of State. The district court dismissed, holding that the case presented a nonjusticiable political question and the D.C. Circuit affirmed, reasoning that the Constitution gave the Executive the exclusive power to recognize foreign sovereigns and that the exercise of that power could not be reviewed by the courts. The Court held that the courts were fully capable of determining whether this statute could be given effect, or instead must be struck down in light of authority conferred on the Executive by the Constitution. The only real question for the courts was whether the statute was constitutional. Having determined that the case was justiciable, the Court left it to the lower courts to consider the merits in the first instance. Accordingly, the Court vacated the judgment of the D.C. Circuit and remanded for further proceedings. View "Zivotofsky v. Clinton" on Justia Law

In this case, a criminal defendant sought a remedy when inadequate assistance of counsel caused nonacceptance of a plea offer and further proceedings led to a less favorable outcome. After the plea offer had been rejected, there was a full and fair trial before the jury. After a guilty verdict, defendant received a sentence harsher than that offered in the rejected plea bargain. The instant case came to the Court with the concession that counsel's advice with respect to the plea offer fell below the standard of adequate assistance of counsel guaranteed by the Sixth Amendment, applicable to the States through the Fourteenth Amendment. The Court held that, where counsel's ineffective advice led to an offer's rejection, and where the prejudice alleged was having to stand trial, a defendant must show that but for the ineffective advice, there was a reasonable probability that the plea offer would have been presented to the court, that the court would have accepted its terms, and that the conviction or sentence, or both, under the offer's terms would have been less severe than under the actual judgment and sentence imposed. Therefore, the Court vacated the judgment of the Sixth Circuit and remanded for further proceedings. View "Lafler v. Cooper" on Justia Law

This case arose in the context of claimed ineffective assistance that led to the lapse of a prosecution offer of a plea bargain, a proposal that offered terms more lenient than the terms of the guilty plea entered later. At issue was the constitutional right to effective assistance with respect to those offers. Further at issue was what a defendant must demonstrate in order to show that prejudice resulted from counsel's deficient performance. The Court held that the Sixth Amendment right to effective assistance of counsel extended to the consideration of plea offers that lapsed or were rejected. That right applied to "all 'critical' stages of the criminal proceedings." The Court vacated the judgment of the Missouri Court of Appeals and remanded for further proceedings. View "Missouri v. Frye" on Justia Law

Arizona prisoners could raise claims of ineffective assistance of trial counsel only in state collateral proceedings, not on direct review. In petitioner's first state collateral proceeding, his counsel did not raise such a claim. On federal habeas review with new counsel, petitioner argued that he received ineffective assistance both at trial and in his first state collateral proceeding. He also claimed that he had a constitutional right to an effective attorney in the collateral proceeding because it was the first place to raise his claim of ineffective assistance at trial. The Court held that where, under state law, ineffective-assistance-of-trial-counsel claims must be raised in an initial-review collateral proceeding, a procedural default would not bar a federal habeas court from hearing those clams if, in the initial-review collateral proceeding, there was no counsel or counsel in the proceeding was ineffective. Therefore, the Court reversed the judgment of the Ninth Circuit. View "Martinez v. Ryan" on Justia Law

Respondent was convicted of capital murder and subsequently commenced federal habeas proceedings by filing a request for appointment of counsel under 18 U.S.C. 3599. Section 3599(e) contemplated that appointed counsel could be "replaced . . . upon motion of the defendant," but did not specify the standard that district courts should use in evaluating those motions. The Court held that courts should employ the same "interests of justice" standard that they apply in non-capital cases under a related statute, 18 U.S.C. 3006A. The Court also held that the district court here did not abuse its discretion in denying respondent's motion to change counsel. View "Martel v. Clair" on Justia Law

George Corson and his wife sued respondents, claiming injury from Corson's exposure to asbestos in locomotives and locomotive parts distributed by respondents. The Corsons alleged state-law claims of defective design and failure to warn of the dangers posed by asbestos. After Corson died, his wife was substituted as a party. Respondents removed the case to the Federal District Court, which granted respondents summary judgment, ruling that the state-law claims were pre-empted by the Locomotive Inspection Act (LIA), 49 U.S.C. 20701, et seq. The Third Circuit affirmed. The Court held that petitioners' state-law design-defect and failure-to-warn claims fell within the field of locomotive equipment regulation pre-empted by the LIA, as that field was defined in Napier v. Atlantic Coast Line. R. Co. Accordingly, the judgment of the Court of Appeals was affirmed. View "Kurns, et al. v. Railroad Friction Products Corp., et al." on Justia Law

The Court granted certiorari in these cases to decide whether Medicaid providers and recipients could maintain a cause of action under the Supremacy Clause to enforce a federal Medicaid law. Since the Court granted certiorari, however, the relevant circumstances have changed. The federal agency in charge of administering Medicaid, CMS, approved the state statutes as consistent with the federal law. In light of the changed circumstances, the Court believed that the question before it was whether, once the agency approved the state statutes, groups of Medicaid providers and beneficiaries could still maintain a Supremacy Clause action asserting that the state statutes were inconsistent with the federal Medicaid law. Given the present posture of the cases, the Court did not address whether the Ninth Circuit properly recognized a Supremacy Clause action to enforce the federal law before the agency took final action. To decide whether these cases could proceed under the Supremacy Clause now that the agency has acted, it would be necessary on remand to consider at least the matters addressed by the Court. Accordingly, the Court vacated the judgment and remanded for further proceedings. View "Douglas v. Independent Living Center of Southern Cal., Inc." on Justia Law

Respondents filed an action under 42 U.S.C. 1983 against petitioners, police officers, alleging that the officers had subjected them to an unreasonable search in violation of the Fourth Amendment. The district court granted summary judgment to respondents and the Ninth Circuit affirmed the denial of qualified immunity. The Court held, however, that the officers were entitled to qualified immunity. The Court concluded that the case did not fall within the narrow exception to allowing suit where it would not be entirely unreasonable for an officer to believe that there was probable cause to search for all firearms and firearm-related materials. Regarding the warrant's authorization to search for gang-related materials, a reasonable officer could view Jerry Ray Bowen's attack as motivated not by the souring of his romantic relationship with Shelly Kelly but by a desire to prevent her from disclosing details of his gang activity to the police. The fact that the officers sought and obtained approval of the warrant application from a superior and a deputy district attorney before submitting it to the magistrate provided further support for the conclusion than an officer could reasonably have believed that the scope of the warrant was supported by probable cause. In holding that the warrant in this case was so obviously defective that no reasonable officer could have believed it to be valid, the court below erred in relying on Groh v. Ramirez. Accordingly, the judgment was reversed. View "Messerschmidt, et al. v. Millender, et al." on Justia Law

This case concerned three rivers which flow through Montana and then beyond its borders. At issue was whether discrete, identifiable segments of these rivers in Montana were nonnavigable, as federal law defined that concept for purposes of determining whether the State acquired title to the riverbeds underlying those segments, when the State entered the Union in 1989. Montana contended that the rivers must be found navigable at the disputed locations. The Court held that the Montana Supreme Court's ruling that Montana owned and could charge for use of the riverbeds at issue was based on an infirm legal understanding of the Court's rules of navigability for title under the equal-footing doctrine. The Montana Supreme Court erred in its treatment of the question of river segments and portage and erred as a matter of law in relying on evidence of present-day primarily recreational use of the Madison River. Because this analysis was sufficient to require reversal, the Court declined to decide whether the State Supreme Court also erred as to the burden of proof regarding navigability. Montana's suggestion that denying the State title to the disputed riverbeds would undermine the public trust doctrine underscored its misapprehension of the equal-footing and public trust doctrines. Finally, the reliance by petitioner and its predecessors in title on the State's long failure to assert title to the riverbeds was some evidence supporting the conclusion that the river segments over those beds were nonnavigable for purposes of the equal-footing doctrine. Accordingly, the judgment was reversed. View "PPL Montana, LLC v. Montana" on Justia Law

Respondent, a prison inmate, sought to suppress his confession under Miranda v. Arizona after he was subjected to custodial interrogation when he was escorted from his prison cell by a corrections officer to a conference room where he was questioned by two sheriff's deputies about criminal activity he had allegedly engaged in before coming to prison. The Sixth Circuit subsequently held that precedent clearly established that a prisoner was in custody within the meaning of Miranda if the prisoner was taken aside and questioned about events that occurred outside the prison walls. The Court's decision, however, did not clearly establish such a rule, and therefore the Court of Appeals erred in holding that this rule provided a permissible basis for federal habeas relief under the relevant provision of the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA), 28 U.S.C. 2254(d)(1). The rule applied by the lower court did not represent a correct interpretation of the Court's Miranda law. Therefore, taking into account all of the circumstances of the questioning - including especially the undisputed fact that respondent was told he was free to end the questioning and to return to his cell - the Court held that respondent was not in custody within the meaning of Miranda. View "Howes v. Fields" on Justia Law