Justia U.S. Supreme Court Opinion Summaries

Douglas Horn, a commercial truck driver, purchased and consumed a CBD tincture called "Dixie X," marketed as THC-free by Medical Marijuana, Inc. After a random drug test by his employer detected THC in his system, Horn was fired for refusing to participate in a substance abuse program. Horn subsequently sued Medical Marijuana under the Racketeer Influenced and Corrupt Organizations Act (RICO), claiming that the company's false advertising led to his job loss.The District Court granted summary judgment in favor of Medical Marijuana, reasoning that Horn's job loss was a consequence of a personal injury (ingesting THC), and thus not recoverable under RICO, which only allows recovery for business or property injuries. The Second Circuit Court of Appeals reversed this decision, holding that Horn's job loss constituted an injury to his business under RICO, rejecting the "antecedent-personal-injury bar" that precludes recovery for business or property losses derived from personal injuries.The Supreme Court of the United States reviewed the case to determine whether civil RICO categorically bars recovery for business or property losses that derive from a personal injury. The Court held that under civil RICO, a plaintiff may seek treble damages for business or property loss even if the loss resulted from a personal injury. The Court emphasized that the statute's language allows recovery for business or property harms without excluding those that result from personal injuries. The judgment of the Second Circuit was affirmed, and the case was remanded for further proceedings consistent with this opinion. View "Medical Marijuana, Inc. v. Horn" on Justia Law

Salvatore Delligatti, an associate of the Genovese crime family, was convicted of using or carrying a firearm during a crime of violence under 18 U.S.C. §924(c). He had recruited gang members to kill a suspected police informant and provided them with a loaded revolver. Delligatti was charged with attempted murder under the violent-crimes-in-aid-of-racketeering (VICAR) statute, which required proof of attempted second-degree murder under New York law. He argued that a VICAR offense predicated on New York second-degree murder is not a crime of violence because homicide under New York law can be committed by omission.The District Court denied Delligatti’s motion to dismiss the §924(c) charge, holding that VICAR attempted murder is a crime of violence. A jury convicted Delligatti on all counts, and he was sentenced to 25 years in prison. The U.S. Court of Appeals for the Second Circuit affirmed the District Court’s decision, relying on the precedent set in United States v. Scott, which held that the knowing or intentional causation of bodily injury necessarily involves the use of physical force, even when the harm is caused by omission.The Supreme Court of the United States affirmed the Second Circuit’s decision. The Court held that the knowing or intentional causation of injury or death, whether by act or omission, necessarily involves the use of physical force against another person within the meaning of §924(c)(3)(A). The Court reasoned that it is impossible to deliberately cause physical harm without the use of physical force, extending the logic of United States v. Castleman to §924(c). The Court concluded that New York second-degree murder, including by omission, qualifies as a crime of violence under §924(c)’s elements clause. View "Delligatti v. United States" on Justia Law

Patrick Thompson took out three loans totaling $219,000 from a bank. After the bank failed, the FDIC took over the collection of the loans. Thompson disputed the $269,120.58 balance shown on his invoice, claiming he had only borrowed $110,000. He made similar statements in subsequent calls with FDIC contractors. Thompson was charged with violating 18 U.S.C. §1014, which prohibits making false statements to influence the FDIC’s actions on a loan. A jury found him guilty, and he moved for acquittal, arguing his statements were not false since he had indeed borrowed $110,000, even though he later borrowed more.The District Court denied Thompson’s motion, stating that the Seventh Circuit does not require literal falsity for a §1014 conviction and that misleading statements could suffice. The Seventh Circuit affirmed, citing its precedent that §1014 criminalizes misleading representations. The court found Thompson’s statements misleading because they implied he owed no more than $110,000, despite his total debt being $219,000.The Supreme Court of the United States reviewed the case and held that §1014 does not criminalize statements that are misleading but not false. The Court emphasized that the statute uses the word “false,” which means “not true,” and does not include “misleading.” The Court noted that many other statutes explicitly prohibit both false and misleading statements, indicating that Congress knew how to include misleading statements when it intended to do so. The Court vacated the Seventh Circuit’s judgment and remanded the case to determine whether a reasonable jury could find that Thompson’s statements were false. View "Thompson v. United States" on Justia Law

In 1997, Justin Sneed murdered Barry Van Treese at an Oklahoma hotel managed by Richard Glossip. Sneed claimed Glossip orchestrated the murder to steal Van Treese's money. Glossip denied involvement but was convicted and sentenced to death based on Sneed's testimony. The Oklahoma Court of Criminal Appeals (OCCA) overturned the initial conviction due to ineffective defense counsel but upheld a second conviction despite inconsistencies in Sneed's testimony and new evidence suggesting prosecutorial misconduct.The OCCA initially reversed Glossip's conviction due to ineffective assistance of counsel but affirmed his second conviction, finding sufficient circumstantial evidence to support Sneed's testimony. Glossip's subsequent habeas petitions were unsuccessful. An independent investigation commissioned by Oklahoma legislators raised doubts about the conviction, revealing prosecutorial misconduct, including the destruction of evidence and false portrayal of Sneed. The State disclosed previously withheld documents, including evidence of Sneed's bipolar disorder and false testimony about his lithium prescription.The Supreme Court of the United States reviewed the case, focusing on whether the prosecution violated its constitutional obligation to correct false testimony under Napue v. Illinois. The Court found that the prosecution knowingly allowed Sneed to falsely testify about his lithium prescription and failed to correct it. This false testimony was material, as Sneed's credibility was crucial to Glossip's conviction. The Court held that the prosecution's failure to correct the false testimony violated Glossip's due process rights, warranting a new trial. The judgment of the OCCA was reversed, and the case was remanded for further proceedings consistent with this opinion. View "Glossip v. Oklahoma" on Justia Law

Brenda Andrew was convicted by an Oklahoma jury of murdering her husband, Rob Andrew, and was sentenced to death. During her trial, the prosecution introduced extensive evidence about her sex life and personal failings, which was later conceded to be irrelevant. Andrew argued in a federal habeas petition that this evidence was so prejudicial it violated the Due Process Clause.The Oklahoma Court of Criminal Appeals (OCCA) upheld her conviction, finding some of the evidence about her extramarital affairs relevant but acknowledging that much of the other evidence was irrelevant. Despite this, the OCCA deemed the errors harmless. Two judges dissented, arguing that the prejudicial evidence undermined the fairness of the trial.In federal court, the District Court denied relief, and the Tenth Circuit Court of Appeals affirmed, stating that Andrew failed to cite clearly established federal law. The Tenth Circuit majority acknowledged the precedent set by Payne v. Tennessee but dismissed it as a pronouncement rather than a holding. Judge Bacharach dissented, arguing that the prejudicial evidence deprived Andrew of a fair trial.The Supreme Court of the United States reviewed the case and held that the Tenth Circuit erred in its interpretation. The Court clarified that Payne established that the Due Process Clause can protect against the introduction of unduly prejudicial evidence that renders a trial fundamentally unfair. The Court vacated the Tenth Circuit's judgment and remanded the case for further proceedings to determine if the trial court's admission of irrelevant evidence was so prejudicial as to render Andrew's trial fundamentally unfair. View "Andrew v. White" on Justia Law

The case involves former President Donald Trump, who was indicted on four counts for conduct that occurred during his presidency following the November 2020 election. The indictment alleged that Trump conspired to overturn the election by spreading knowingly false claims of election fraud. Trump moved to dismiss the indictment based on Presidential immunity, arguing that a President has absolute immunity from criminal prosecution for actions performed within his official responsibilities. The District Court denied Trump’s motion to dismiss, holding that former Presidents do not possess federal criminal immunity for any acts. The D.C. Circuit affirmed this decision.The Supreme Court of the United States held that under the constitutional structure of separated powers, a former President is entitled to absolute immunity from criminal prosecution for actions within his conclusive and preclusive constitutional authority. He is also entitled to at least presumptive immunity from prosecution for all his official acts. However, there is no immunity for unofficial acts. The Court vacated the judgment of the D.C. Circuit and remanded the case for further proceedings consistent with its opinion. The Court emphasized that the President is not above the law, but under the system of separated powers, the President may not be prosecuted for exercising his core constitutional powers. View "Trump v. United States" on Justia Law

The case revolves around the interpretation of the Sarbanes-Oxley Act of 2002, specifically 18 U.S.C. §1512(c)(2), which imposes criminal liability on anyone who corruptly obstructs, influences, or impedes any official proceeding, or attempts to do so. The petitioner, Joseph Fischer, was charged with violating this provision for his actions during the Capitol breach on January 6, 2021. Fischer moved to dismiss the charge, arguing that the provision only criminalizes attempts to impair the availability or integrity of evidence. The District Court granted his motion, but a divided panel of the D.C. Circuit reversed and remanded for further proceedings.The Supreme Court of the United States held that to prove a violation of §1512(c)(2), the Government must establish that the defendant impaired the availability or integrity for use in an official proceeding of records, documents, objects, or other things used in an official proceeding, or attempted to do so. The Court reasoned that the "otherwise" provision of §1512(c)(2) is limited by the list of specific criminal violations that precede it in (c)(1). The Court also considered the broader context of §1512 in the criminal code and found that an unbounded interpretation of subsection (c)(2) would render superfluous the careful delineation of different types of obstructive conduct in §1512 itself. The Court vacated the judgment of the D.C. Circuit and remanded the case for further proceedings consistent with its opinion. View "Fischer v. United States" on Justia Law

The case involves James Snyder, the former mayor of Portage, Indiana, who was convicted of accepting an illegal gratuity in violation of 18 U.S.C. §666(a)(1)(B). In 2013, while Snyder was mayor, Portage awarded two contracts to a local truck company, Great Lakes Peterbilt, and purchased five trash trucks from the company for about $1.1 million. In 2014, Peterbilt paid Snyder $13,000. The FBI and federal prosecutors suspected that the payment was a gratuity for the City’s trash truck contracts, but Snyder claimed that the payment was for his consulting services as a contractor for Peterbilt. A federal jury convicted Snyder, and the District Court sentenced him to 1 year and 9 months in prison. On appeal, Snyder argued that §666 criminalizes only bribes, not gratuities. The Seventh Circuit affirmed Snyder’s conviction.The Supreme Court of the United States reversed the Seventh Circuit's decision. The Court held that 18 U.S.C. §666 proscribes bribes to state and local officials but does not make it a crime for those officials to accept gratuities for their past acts. The Court reasoned that the statutory text, history, structure, punishments, federalism principles, and fair notice considerations all support the conclusion that §666 is a bribery statute and not a gratuities statute. The Court concluded that a state or local official does not violate §666 if the official has taken the official act before any reward is agreed to, much less given. Although a gratuity offered and accepted after the official act may be unethical or illegal under other federal, state, or local laws, the gratuity does not violate §666. The case was remanded for further proceedings consistent with the Court's opinion. View "Snyder v. United States" on Justia Law

In December 2019, Zackey Rahimi, the respondent, had a violent altercation with his girlfriend, C. M., who is also the mother of his child. Rahimi grabbed C. M., dragged her back to his car, and shoved her in, causing her to hit her head. When a bystander witnessed the incident, Rahimi retrieved a gun from his car. C. M. managed to escape, and Rahimi fired his gun, though it is unclear whether he was aiming at C. M. or the witness. Following this incident, C. M. sought a restraining order against Rahimi, which was granted by a state court in Texas. The order included a finding that Rahimi had committed “family violence” and posed “a credible threat” to the “physical safety” of C. M. or their child. The order also suspended Rahimi’s gun license for two years. Despite the order, Rahimi violated it by approaching C. M.’s home and contacting her through social media. He was later charged with aggravated assault with a deadly weapon for threatening another woman with a gun.Rahimi was indicted for possessing a firearm while subject to a domestic violence restraining order, in violation of 18 U. S. C. §922(g)(8). Rahimi moved to dismiss the indictment, arguing that Section 922(g)(8) violated his Second Amendment right to keep and bear arms. The District Court denied his motion, and Rahimi pleaded guilty. On appeal, he again raised his Second Amendment challenge, which was denied. Rahimi petitioned for rehearing en banc.The Supreme Court of the United States held that when a restraining order contains a finding that an individual poses a credible threat to the physical safety of an intimate partner, that individual may—consistent with the Second Amendment—be banned from possessing firearms while the order is in effect. The Court found that since the founding, the nation's firearm laws have included provisions preventing individuals who threaten physical harm to others from misusing firearms. As applied to the facts of this case, Section 922(g)(8) fits comfortably within this tradition. The Court reversed the judgment of the Court of Appeals for the Fifth Circuit and remanded the case for further proceedings consistent with its opinion. View "United States v. Rahimi" on Justia Law

Paul Erlinger pleaded guilty to being a felon in possession of a firearm, a violation of 18 U.S.C. §922(g). At sentencing, the judge found Erlinger eligible for an enhanced sentence under the Armed Career Criminal Act (ACCA), which increases the penalty for a §922(g) conviction from a maximum of 10 years to a mandatory minimum of 15 years when the defendant has three or more qualifying convictions for offenses committed on different occasions. The Seventh Circuit later ruled that two of the offenses used for Erlinger’s sentence enhancement no longer qualified as ACCA predicate offenses. The District Court vacated Erlinger’s sentence and scheduled resentencing. At the resentencing hearing, prosecutors pursued an ACCA sentence enhancement based on a new set of 26-year-old convictions for burglaries committed by Erlinger over several days. Erlinger argued that the burglaries were part of a single criminal episode and did not occur on separate occasions, as required by ACCA. He also argued that the Fifth and Sixth Amendments required that a jury make that assessment. The District Court rejected Erlinger’s request for a jury and issued a 15-year enhanced sentence. On appeal, the government confessed error, admitting that the Constitution requires a jury to decide unanimously and beyond a reasonable doubt whether Erlinger’s prior offenses were committed on different occasions.The Supreme Court of the United States held that the Fifth and Sixth Amendments require a unanimous jury to make the determination beyond a reasonable doubt that a defendant’s past offenses were committed on separate occasions for ACCA purposes. The Court noted that the Sixth Amendment promises that in all criminal prosecutions, the accused has the right to a speedy and public trial, by an impartial jury. The Fifth Amendment further promises that the government may not deprive individuals of their liberty without due process of law. The Court has repeatedly cautioned that trial and sentencing practices must remain within the guardrails provided by these two Amendments. The Court vacated the judgment of the Court of Appeals for the Seventh Circuit and remanded the case for further proceedings consistent with its opinion. View "Erlinger v. United States" on Justia Law