Justia U.S. Supreme Court Opinion Summaries
Articles Posted in Constitutional Law
United States v. Jones
Respondent was convicted of drug trafficking and conspiracy charges. The District Court suppressed GPS data from a vehicle parked outside of respondent's residence, but held the remaining data admissible because respondent had no reasonable expectation of privacy when the vehicle was on a public street. The D.C. Circuit reversed, concluding that admission of the evidence obtained by warrantless use of the GPS device violated the Fourth Amendment. The Court held that the Government's installation of a GPS device on a target's vehicle, and its use of that device to monitor the vehicle's movements, constituted a search under the Fourth Amendment. Accordingly, the judgment of the Court of Appeals was affirmed. View "United States v. Jones" on Justia Law
Reynolds v. United States
This case concerned the Sex Offender Registration and Notification Act (Act), 18 U.S.C. 2250(a), which required convicted sex offenders to provide state governments with, and to update, information for state and federal sex offender registries. Petitioner, a pre-Act offender, registered in Missouri in 2005 but moved to Pennsylvania in September 2007 without updating the Missouri registration or registering in Pennsylvania. The question before the Court was the date on which the federal registration requirement took effect with respect to sex offenders convicted before the Act became law. The Court held that the Act did not require pre-Act offenders to register before the Attorney General validly specified that the Act's registration provisions applied to them. Accordingly, the Court reversed a Court of Appeals determination that, in effect, held the contrary. View "Reynolds v. United States" on Justia Law
National Meat Assn. v. Harris
Petitioner, a trade association representing meatpackers and processors, sued to enjoin enforcement of a California law against swine slaughterhouses, arguing that the Federal Meat Inspection Act (FMIA), 21 U.S.C. 601, et seq., preempted application of the law. The California law dictated what slaughterhouses must do with pigs that could not walk, known in the trade as nonambulatory pigs. The Court concluded that the FMIA regulated slaughterhouses' handling and treatment of nonambulatory pigs from the moment of their delivery through the end of the meat production process. California's law endeavored to regulate the same thing, at the same time, in the same place - except by imposing different requirements. The FMIA expressly preempted such a state law. Accordingly, the Court reversed the judgment of the Ninth Circuit and remanded for further proceedings. View "National Meat Assn. v. Harris" on Justia Law
Maples v. Thomas
Petitioner was found guilty of murder and sentenced to death in Alabama state court. Petitioner sought postconviction relief in state court under Alabama Rule 32, alleging, among other things, that his trial attorneys failed to afford him the effective assistance guaranteed by the Sixth Amendment. At issue was whether the extraordinary facts of petitioner's case were "cause" to excuse petitioner's procedural default in state court, i.e., petitioner's failure to timely appeal the Alabama trial court's order denying him postconviction relief. The court held that petitioner had shown the requisite "cause" to excuse his procedural default where he was abandoned by counsel and left unrepresented at a critical time for his state postconviction petition, and he lacked a clue of any need to protect himself pro se. View "Maples v. Thomas" on Justia Law
Perry v. Perez
The 2010 census showed an enormous increase in Texas' population which required the State to redraw its electoral districts for the United States Congress, the State Senate, and the State House of Representatives, in order to comply with the Constitution's one-person, one-vote rule. The State also had to create new districts for the four additional congressional seats it received. Plaintiffs subsequently brought suit in Texas, claiming that the State's newly enacted electoral plans violated the United States Constitution and section 2 of the Voting Rights Act, 42 U.S.C. 1973. The Court held that because it was unclear whether the District Court for the Western District of Texas followed the appropriate standards in drawing interim maps for the 2012 Texas elections, the orders implementing those maps were vacated, and the cases were remanded for further proceedings. View "Perry v. Perez" on Justia Law
Golan v. Holder
Petitioners are orchestra conductors, musicians, publishers, and others who formerly enjoyed free access to literary and artistic works section 514 of the Uruguay Round Agreements Act (URAA), 17 U.S.C. 104A, 109(a), removed from the public domain. Petitioners maintained that Congress, in passing section 514, exceeded its authority under the Constitution's Copyright and Patent Clause and violated the First Amendment rights of anyone who previously had access to such works. The Tenth Circuit ruled that section 514 was narrowly tailored to fit the important government aim of protecting U.S. copyright holders' interests abroad. In accord with the judgment of the Tenth Circuit, the Court concluded that section 514 did not transgress constitutional limitations on Congress' authority. The Court held that neither the text of the Copyright and Patent Clause, historical practice, or the Court's precedent excluded application of copyright protection to works in the public domain. The Court also held that nothing in the historical record, subsequent congressional practice, or the Court's jurisprudence warranted exceptional First Amendment solicitude for copyrighted works that were once in the public domain. View "Golan v. Holder" on Justia Law
Minneci v. Pollard
Respondent sought damages from employees at a privately run federal prison in California, claiming that they had deprived him of adequate medical care in violation of the Eighth Amendment's prohibition against cruel and unusual punishment. At issue was whether the Court could imply the existence of an Eighth Amendment-based damages action against employees of a privately operated federal prison. Because the Court believed that in the circumstances of this case, state tort law authorized adequate alternative damage actions - actions that provide both significant deterrence and compensation - no Bivens v. Six Unknown Fed. Narcotics Agents remedy could be implied here. View "Minneci v. Pollard" on Justia Law
Perry v. New Hampshire
Defendant was convicted of theft by unauthorized taking. On appeal, defendant argued that the trial court erred in requiring an initial showing that police arranged a suggestive identification procedure. Suggestive circumstances alone, defendant contended, sufficed to require court evaluation of the reliability of an eyewitness identification before allowing it to be presented to the jury. The New Hampshire Supreme Court rejected defendant's argument and affirmed his conviction. The Court held that the Due Process Clause did not require a preliminary judicial inquiry into the reliability of an eyewitness identification when the identification was not procured under unnecessarily suggestive circumstances arranged by law enforcement. Accordingly, the Court affirmed the judgment of the New Hampshire Supreme Court. View "Perry v. New Hampshire" on Justia Law
Hosanna-Tabor Evangelical Lutheran Church and School v. EEOC
Hosanna-Tabor, a member congregation of the Lutheran Church-Missouri Synod, operated a small school in Michigan offering a "Christian-centered education" to students in kindergarten through eighth grade. The Synod classified its school teachers into two categories: "called" and "lay." "Called" teachers, among other things, were regarded as having been called to their vocation by God. To be eligible to be called from a congregation, a teacher must satisfy certain academic requirements. "Lay" or "contract" teachers, by contrast, were not required to be trained by the Synod or even to be Lutheran. "Called" teacher, Cheryl Perich filed a charge with the EEOC, claiming that her employment had been terminated in violation of the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq. The EEOC brought suit against Hosanna-Tabor, alleging that Perich had been fired in retaliation for threatening to file an ADA lawsuit. Perich intervened. Invoking what was known as the "ministerial exception," Hosanna-Tabor argued that the suit was barred by the First Amendment because the claims concerned the employment relationship between a religious institution and one of its ministers. The Court held that the Establishment and Free Exercise Clauses of the First Amendment barred suits brought on behalf of ministers against their churches, claiming termination in violation of employment discrimination laws. Because Perich was a minister within the meaning of the ministerial exception, the First Amendment required dismissal of this employment discrimination suit against her religious employer. View "Hosanna-Tabor Evangelical Lutheran Church and School v. EEOC" on Justia Law
Gonzalez v. Thaler
This case interpreted two provisions of the Antiterrorism and Effective Death Penalty Act of 1996, (AEDPA). The first, 28 U.S.C. 2253(c), provided that a habeas petitioner must obtain a certificate of appealability (COA) to appeal a federal district court's final order in a habeas proceeding (section 2253(c)(1)). The COA could issue only if the petitioner had made a "substantial showing of the denial of a constitutional right" (section 2253(c)(2)), and "shall indicate which specific issue" satisfied that showing (section 2253(c)(3)). The Court held that section 2253(c)(3) was not a jurisdictional requirement. Accordingly, a judge's failure to "indicate" the requisite constitutional issue in a COA did not deprive a court of appeals of subject-matter jurisdiction to adjudicate the habeas petitioner's appeal. The second provision, 28 U.S.C. 2244(d)(1)(A), established a 1-year limitations period for state prisoners to file federal habeas petitions, running from "the date on which the judgment became final by the conclusion of direct review or the expiration of the time for seeking such review." The Court held that, for a state prisoner who did not seek review in a State's highest court, the judgment became "final" on the date that the time for seeking such review expired. View "Gonzalez v. Thaler" on Justia Law