Justia U.S. Supreme Court Opinion Summaries

Petitioner was convicted of first-degree murder based on the testimony of a single eyewitness. During state postconviction proceedings, petitioner obtained police files containing statements by the eyewitness contradicting his testimony. Petitioner argued that the prosecution's failure to disclose those statements violated Brady v. Maryland. The Court held that Brady required that petitioner's conviction be reversed where the eyewitness's testimony was the only evidence linking petitioner to the crime and the eyewitness's undisclosed statements contradicted his testimony. The eyewitness's statements were plainly material, and the State's failure to disclose those statements to the defense thus violated Brady. View "Smith v. Cain" on Justia Law

Defendant filed a federal habeas corpus petition in district court, alleging, inter alia, that the introduction of his nontestifying codefendants' statements violated the Confrontation Clause. At issue was whether "clearly established Federal law" under the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA), 28 U.S.C. 2254(d)(1), included decisions of the Court that were announced after the last adjudication of the merits in state court but before defendant's conviction became final. The Court held that under Section 2254(d)(1), "clearly established Federal law, as determined by the Supreme Court of the United States" included only the Court's decisions as of the time of the relevant state-court adjudication on the merits. Because the Pennsylvania Superior Court's decision - the last state-court adjudication on the merits of defendant's claim - predated Gray v. Maryland by nearly three months, the Third Circuit correctly held that Gray was not "clearly established Federal law" against which it could measure the state-court decision. It therefore correctly concluded that the state court's decision neither was "contrary to," nor "involved an unreasonable application of," any "clearly established Federal law." View "Greene v. Fisher" on Justia Law

Petitioner, a Mexican national, was convicted of murder and sentenced to death by a Texas court. Petitioner sought a stay of execution on the ground that his conviction was obtained in violation of the Vienna Convention on Consular Relations (Vienna Convention), and relied on Case Concerning Avena and Other Mexican Nationals (Avena). The Court held that petitioner's argument was foreclosed by Medellin v. Texas, in which the Court held that neither the Avena decision nor the President's Memorandum purporting to implement that decision constituted directly enforceable federal law. The Court declined to stay the execution so that Congress could consider whether to enact legislation implementing the Avena decision where the Due Process Clause did not prevent a State from carrying out a lawful judgment in light of unenacted legislation that might someday authorize a collateral attack on that judgment. The Court also declined the United State's request that the Court stay the execution until January 2012 in support of "future jurisdiction to review the judgment in a proceeding." Accordingly, the applications for stay of execution was denied and petition for a writ of habeas corpus was denied. View "Leal Garcia v. Texas" on Justia Law

In 2005, respondent was charged with delinquency under the Federal Juvenile Delinquency Act, 18 U.S.C. 5031 et seq., for sexually abusing a boy for approximately two years until respondent was 15 years old and his victim was 12 years old. Respondent was sentenced to two years of juvenile detention followed by juvenile supervision until his 21st birthday. In 2006, while respondent remained in juvenile detention, Congress enacted the Sex Offender Registration and Notification Act (SORNA), 42 U.S.C. 16902 et seq. In July 2007, the District Court determined that respondent had failed to comply with the requirements of his prerelease program. On appeal, respondent challenged his "special conditio[n]" of supervision and requested that the Court of Appeals "reverse th[e] portion of his sentence requiring Sex Offender Registration and remand with instructions that the district court ... strik[e] Sex Offender Registration as a condition of juvenile supervision." Over a year after respondent's 21st birthday, the Court of Appeals handed down its decision and held that the SORNA requirements violated the Ex Post Facto Clause of the Constitution, Art. I, section 9, cl. 3, when applied to juveniles adjudicated as delinquent before SORNA's enactment. The Court held that the Court of Appeals had no authority to enter that judgment because it had no live controversy before it where respondent had turned 21 and where the capable-of-repetition exception to mootness did not apply in this case. Accordingly, the judgment of the Ninth Circuit was vacated and the case remanded with instructions to dismiss the appeal. View "United States v. Juvenile Male" on Justia Law

The Arizona Citizens Clean Elections Act (matching funds provision), Ariz. Rev. Stat. Ann. 16-940 et seq., created a voluntary public financing system to fund the primary and general election campaigns of candidates for state office. Petitioners, candidates and independent expenditure groups, filed suit challenging the constitutionality of the matching funds provision. The Court held that the matching funds provision substantially burdened the speech of privately financed candidates and independent expenditure groups without serving a compelling state interest where the professed purpose of the state law was to cause a sufficient number of candidates to sign up for public financing, which subjected them to the various restrictions on speech that went along with that program. Therefore, the Court held that the matching funds scheme violated the First Amendment and reversed the judgment of the Ninth Circuit. View "Arizona Free Enterprise Club's Freedom Club PAC, et al. v. Bennett, et al; McComish, et al. v. Bennett, et al." on Justia Law

Respondents, representing the video game and software industries, filed a preenforcement challenge to California Assembly Bill 1179 (Act), Cal. Civ. Code Ann. 1746-1746.5, which restricted the sale or rental of violent video games to minors. At issue was whether the Act comported with the First Amendment. The Court held that, because the Act imposed a restriction on the content of protected speech, it was invalid unless California could demonstrate that it passed strict scrutiny. The Court held that California had a legitimate interest in addressing a serious social problem and helping concerned parents control their children. The Court held, however, that as a means of protecting children from portrayals of violence, the legislation was seriously underinclusive, not only because it excluded portrayals other than video games, but also because it permitted a parental or avuncular veto. The Court also held that, as a means of assisting concerned parents, it was seriously overinclusive because it abridged the First Amendment rights of young people whose parents think violent video games were a harmless pastime. The Court further held that the overbreadth in achieving one goal was not cured by the overbreadth in achieving the other and therefore, the legislation could not survive strict scrutiny. Accordingly, the court affirmed the judgment of the Ninth Circuit enjoining the Act's enforcement. View "Brown, et al. v. Entertainment Merchants Assn. et al." on Justia Law

The Sentencing Reform Act of 1984 ("Act"), 18 U.S.C. 3551 et seq., called for the creation of Sentencing Guidelines to inform judicial discretion in order to reduce unwarranted disparities in federal sentencing. The Act allowed retroactive amendments to the Guidelines for cases where the Guidelines became a cause of inequality. When a retroactive Guideline amendment was adopted, section 3682(c)(2) permitted defendants sentenced based on a sentencing range that had been modified to move for a reduced sentence. In this case, petitioner was indicted for various crimes, including possessing with intent to distribute cocaine base, and entered into a Federal Rule of Criminal Procedure 11(c)(1)(C) agreement to plead guilty to all charges where the Government, in return, agreed to a 106 month sentence. At issue was whether defendants who enter into plea agreements that recommended a particular sentence as a condition of the guilty plea could be eligible for relief under section 3682(c)(2). The Court held that the text and purpose of the statute, Rule 11(c)(1)(C), and the governing Guidelines policy statements compelled the conclusion that the district court had authority to entertain section 3582(c)(2) motions when sentences were imposed in light of the Guidelines, even if the defendant entered into an Rule 11(c)(1)(C) agreement. The Court also held that petitioner's sentencing hearing transcript revealed that the District Court expressed its independent judgment that the sentence was appropriate in light of the applicable Guidelines range. Therefore, the District Court's decisions was "based on" that range within section 3682(c)(2)'s meaning. Accordingly, the judgment of the Court of Appeals was reversed and the case remanded for further proceedings. View "Freeman v. United States" on Justia Law

Petitioner was arrested on charges of driving while intoxicated ("DWI") and the principal evidence against him was a forensic laboratory report certifying that his blood alcohol concentration was well above the threshold for aggravated DWI. At trial, the prosecution did not call as a witness the analyst who signed the certification and, instead, called another analyst who was familiar with the laboratory's testing procedures but had neither participated in nor observed the test on petitioner's blood sample. At issue was whether the Confrontation Clause permitted the prosecution to introduce a forensic laboratory report containing a testimonial certification, made for the purpose of proving a particular fact, through the in-court testimony of a scientist who did not sign the certification or perform or observe the test reported in the certification. The Court held that surrogate testimony of that order did not meet the constitutional requirement where the accused's right was to be confronted with the analyst who made the certification, unless that analyst was unavailable at trial and the accused had an opportunity, pretrial, to cross-examine that particular scientist. Accordingly, the judgment of the New Mexico Supreme Court was reversed and the case remanded for further proceedings. View "Bullcoming v. New Mexico" on Justia Law

Vermont's Prescription Confidentiality Law, Vt. Stat. Ann., Tit. 18, 4631(d), restricted the sale, disclosure, and use of pharmacy records that revealed the prescribing practices of individual doctors. Respondents, Vermont data miners and an association of brand-name drug manufacturers, sought declaratory and injunctive relief against state officials, contending that section 4631(d) violated their rights under the Free Speech Clause of the First Amendment. At issue was whether section 4631(d) must be tested by heightened judicial scrutiny and, if so, whether Vermont could justify the law. The Court held that the Vermont Statute, which imposed content-based and speaker-based burdens on protected expression, was subject to heightened judicial scrutiny. The Court also held that Vermont's justifications for section 4631(d) did not withstand such heightened scrutiny and therefore, affirmed the Second Circuit's judgment that section 4631(d) unconstitutionally burdened the speech of pharmaceutical marketers and data miners without adequate justification. View "Sorrell, et al. v. IMS Health Inc., et al." on Justia Law

This case stemmed from petitioner's civil contempt proceedings where South Carolina's Family Court enforced child support orders against him. At issue was whether the Fourteenth Amendment's Due Process Clause required the State to provide counsel at the civil contempt hearing to an indigent person potentially faced with incarceration. The Court held that even though petitioner had completed his 12 month prison sentence, and there were not alleged to be collateral consequences of the contempt determination that might keep the dispute alive, this case was not moot because it was capable of repetition while evading review. The Court held that the Fourteenth Amendment's Due Process Clause did not automatically require the State to provide counsel at civil contempt proceedings to an indigent noncustodial parent who was subject to a child support order, even if that individual faced incarceration. In particular, that Clause did not require that counsel be provided where the opposing parent or other custodian was not represented by counsel and the State provided alternative procedural safeguards equivalent to adequate notice of the importance of the ability to pay, a fair opportunity to present, and to dispute, relevant information, and express court findings as to the supporting parent's ability to comply with the support order. Under the circumstances, petitioner's incarceration violated due process because he received neither counsel nor the benefit of alternative procedures like those the Court described. Accordingly, the Court vacated the judgment and remanded for further proceedings. View "Turner v. Rogers, et al." on Justia Law