Justia U.S. Supreme Court Opinion Summaries

The 1995 Prison Litigation Reform Act provides that prisoners qualified to proceed in forma pauperis must pay an initial partial filing fee of “20 percent of the greater of ” the average monthly deposits in the prisoner’s account or the average monthly balance of the account over the preceding six months, 28 U.S.C. 1915(b)(1). They must pay the remainder in monthly installments of “20 percent of the preceding month’s income credited to the prisoner’s account.” The initial fee is assessed on a per-case basis and may not be exacted if the prisoner has no means to pay it; no monthly installments are required unless the prisoner has more than $10 in his account. Bruce, a federal inmate and a frequent litigant, argued that monthly payments do not become due until obligations previously incurred in other cases were satisfied. The D.C. Circuit disagreed, holding that Bruce’s monthly payments were due simultaneously with monthly payments for earlier cases. A unanimous Supreme Court affirmed. Section 1915(b)(2) calls for simultaneous, not sequential, recoupment of multiple monthly installment payments. The Court rejected Bruce’s reliance on the contrast between the singular “clerk” and the plural “fees” as those nouns appear in the statute, which requires payments to be forwarded “to the clerk of the court . . . until the filing fees are paid.” Section 1915’s text and context support the per-case approach. View "Bruce v. Samuels" on Justia Law

In 1997, Louisville police found the bodies of Malone and Warfield in their apartment. Malone had been stabbed. Warfield, then pregnant, had been strangled and scissors stuck out from her neck. Crime scene DNA matched Wheeler’s. During voir dire, Juror 638 gave equivocal answers about the death penalty, saying “I’m not sure that I have formed an opinion ... I believe there are arguments on both sides.” Asked about his ability to consider all available penalties, he noted he had “never been confronted with that situation in a, in a real-life sense of having to make that kind of determination.” “So it’s difficult … to judge how I would I guess act.” He agreed that he was “not absolutely certain whether [he] could realistically consider” the death penalty and described himself as “a bit more contemplative on the issue of taking a life and, uh, whether or not we have the right to take that life.” Later, however, he stated that he could consider all the penalty options. The court granted a prosecution motion to strike Juror 638 for cause based on his inconsistent replies. Wheeler was convicted and sentenced to death. The Kentucky Supreme Court affirmed, holding that the judge “appropriately struck for cause those jurors that could not impose the death penalty.” After exhausting state postconviction procedures, Wheeler unsuccessfully sought habeas corpus (28 U.S.C. 2254). The Sixth Circuit reversed, granting relief as to Wheeler’s sentence. The Supreme Court reversed. The Kentucky Supreme Court was not unreasonable in its application of clearly established federal law in concluding that Juror 638's exclusion did not violate the Sixth Amendment. View "White v. Wheeler" on Justia Law

Sergeant Baker, with a warrant, approached Leija’s car at a restaurant and stated that he was under arrest. Leija sped onto I-27. Leija led Baker and Texas Trooper Rodriguez on an 18-minute chase at 85-110 mph. Leija twice called dispatch, claiming to have a gun and threatening to shoot the officers. The dispatcher broadcast Leija’s threats and a report that Leija might be intoxicated. Officer Ducheneaux, who was trained in using tire spike strips, manned a spike strip beneath an overpass. Trooper Mullenix drove to that overpass, where he radioed a plan to shoot and disable the car. Rodriguez responded “10– 4.” Mullenix asked the dispatcher to inform his supervisor, Byrd, of his plan Before receiving a response, Mullenix took a shooting position. Byrd responded to “see if the spikes work first.” Whether Mullenix heard the response is disputed. Deputy Shipman informed Mullenix that another officer was beneath the overpass. Approximately three minutes after Mullenix took his position, he spotted Leija’s vehicle and fired six shots. Leija’s car engaged the spikes, hit the median, and rolled. Leija was killed by Mullenix’s shots. Apparently, no shots hit the radiator, hood, or engine block. Leija’s estate sued Mullenix under 42 U. S. C. 1983. Mullenix unsuccessfully sought summary judgment on the ground of qualified immunity. The Fifth Circuit affirmed, finding that immediacy of risk was a disputed fact. The Supreme Court reversed on the qualified immunity question, declining to address whether there was a Fourth Amendment violation. Mullenix confronted a reportedly intoxicated fugitive, set on avoiding capture through high-speed vehicular flight, who twice had threatened to shoot police officers, and who was moments away from encountering an officer; whatever the wisdom of Mullenix’s choice, Supreme Court precedents do not indicate that he “beyond debate” acted unreasonably. View "Mullenix v. Luna" on Justia Law

After Oklahoma adopted lethal injection as its method of execution, it used a three-drug protocol of sodium thiopental (a barbiturate) to induce a state of unconsciousness; a paralytic agent to inhibit all muscular-skeletal movements; and potassium chloride to induce cardiac arrest. In 2008 the Supreme Court held that that protocol did not violate the Eighth Amendment’s prohibition against cruel and unusual punishments. Anti-death-penalty advocates pressured pharmaceutical companies to prevent sodium thiopental and another barbiturate (pentobarbital) from being used in executions. Oklahoma substituted a 500-milligram dose of midazolam, a sedative. Oklahoma death-row inmates filed suit under 42 U.S.C. 1983, arguing that a 500-milligram dose of midazolam will not render them unable to feel pain associated with administration of the second and third drugs. The Tenth Circuit and Supreme Court affirmed rejection of their request for a preliminary injunction. The prisoners failed to establish that any risk of harm was substantial when compared to a known and available alternative method of execution. The Eighth Amendment requires a prisoner to plead and prove a known and available alternative. The state’s expert presented persuasive testimony that a 500-milligram dose of midazolam would make it virtually certain that an inmate will not feel pain associated with the second and third drugs; the prisoners’ experts acknowledged that they had no contrary scientific proof. It is not dispositive that midazolam is not recommended or approved for use as the sole anesthetic during painful surgery. The Court upheld a conclusion that the safeguards adopted by Oklahoma to ensure proper administration of midazolam minimize any risk that the drug will not operate as intended. View "Glossip v. Gross" on Justia Law

After Johnson pleaded guilty to being a felon in possession of a firearm, 18 U.S.C. 922(g), the prosecution sought an enhanced sentence under the Armed Career Criminal Act, which imposes an increased prison term upon a defendant with three prior convictions for a “violent felony,” a term defined by section 924(e)(2)(B)’s residual clause to include any felony that “involves conduct that presents a serious potential risk of physical injury to another.” The government argued that Johnson’s prior conviction for unlawful possession of a short-barreled shotgun met this definition. The district court agreed and imposed a 15-year sentence under ACCA. The Eighth Circuit affirmed. The Supreme Court reversed and remanded, rejecting prior holdings in which the Court had spoken to the clause. Imposing an increased sentence under ACCA’s residual clause violates due process because that clause is unconstitutionally vague. Courts use the “categorical approach” when deciding whether an offense is a violent felony, looking “only to the fact that the defendant has been convicted of crimes falling within certain categories, and not to the facts underlying the prior convictions.” Deciding whether the residual clause covers a crime requires a court to picture “the ordinary case,” and to judge whether that abstraction presents a serious potential risk of physical injury. The clause creates uncertainty about how to estimate the risk posed by a crime and about how much risk it takes for a crime to qualify as a violent felony. Holding the clause void for vagueness does not put other laws that use terms such as “substantial risk” in doubt, because those laws generally require gauging the riskiness of an individual’s conduct on a particular occasion, not the riskiness of an idealized ordinary case. View "Johnson v. United States" on Justia Law

Clark sent his girlfriend to engage in prostitution while he cared for her 3-year-old son L.P. and 18-month-old daughter A.T. When L.P.’s preschool teachers noticed marks on his body, he identified Clark as his abuser. At Clark’s trial, the state introduced L.P.’s statements to his teachers as evidence of Clark’s guilt, but L.P. did not testify. The trial court denied Clark’s motion to exclude the statements under the Sixth Amendment’s Confrontation Clause. The Supreme Court of Ohio affirmed reversal of his conviction on Confrontation Clause grounds. The Supreme Court reversed. The Confrontation Clause generally prohibits the introduction of “testimonial” statements by a nontestifying witness, unless the witness is “unavailable to testify, and the defendant had had a prior opportunity for cross-examination.” A statement qualifies as testimonial if the “primary purpose” of the conversation was to “creat[e] an out-of-court substitute for trial testimony. Considering all relevant circumstances, L.P.’s statements were not testimonial; they were not made with the primary purpose of creating evidence for Clark’s prosecution. They occurred in the context of an ongoing emergency involving suspected child abuse. L.P.’s teachers asked questions aimed at identifying and ending a threat. L.P. never hinted that he intended his statements to be used by the police or prosecutors; the conversation was informal and spontaneous. Statements by very young children rarely, if ever, implicate the Confrontation Clause. Mandatory reporting obligations do not convert a conversation between a concerned teacher and her student into a law enforcement mission aimed at gathering evidence for prosecution. Whether a statement is testimonial is not determined by examining whether a jury would view the statement as the equivalent of in-court testimony, but by whether a statement was given with the “primary purpose of creating an out-of-court substitute for trial testimony.” View "Ohio v. Clark" on Justia Law

During jury selection in Ayala’s murder trial, Ayala, who is Hispanic, objected that seven of the prosecution’s peremptory challenges were impermissibly race-based under Batson v. Kentucky. The judge permitted the prosecution to disclose its reasons for the strikes outside the presence of the defense and concluded that there were valid, race-neutral reasons for the strikes. Ayala was convicted and sentenced to death. The California Supreme Court concluded that it was harmless error, under state law, to exclude Ayala from the hearings, and that, if a federal error occurred, it too was harmless beyond a reasonable doubt. A divided Ninth Circuit panel granted Ayala habeas relief, 28 U.S.C. 2254(d). The Supreme Court reversed. Any federal constitutional error that may have occurred by excluding Ayala’s attorney from part of the Batson hearing was harmless. The California Supreme Court’s decision was an “adjudication on the merits” of Ayala’s claim; a federal court cannot grant Ayala relief unless the state court’s rejection of his claim was contrary to or involved an unreasonable application of clearly established federal law as determined by the Supreme Court, or was based on an unreasonable determination of the facts. Any federal constitutional error was harmless with respect to all seven prospective jurors. Each of the reasons for using a challenge was amply supported by the record and there is no basis for finding that the absence of defense counsel affected the trial judge’s evaluation of the strikes. The trial judge heard counsel’s arguments and concluded that the record supplied a legitimate basis for the prosecution’s concern. That defense counsel did not have the opportunity to repeat that argument does not create grave doubt about whether the trial court would have decided the issue differently. View "Davis v. Ayala" on Justia Law

Brumfield was convicted of murder in a Louisiana court and sentenced to death before the Supreme Court held, in Atkins v. Virginia, that the Eighth Amendment prohibits execution of the intellectually disabled. The Louisiana Supreme Court subsequent determined that an evidentiary hearing is required when a defendant provides objective factors sufficient to raise a “a reasonable ground’” to believe that he has an intellectual disability, defined as “(1) subaverage intelligence, as measured by objective standardized IQ tests; (2) significant impairment in several areas of adaptive skills; and (3) manifestations of this neuro-psychological disorder in the developmental stage.” Brumfield amended his pending state post-conviction petition to raise an Atkins claim. Seeking an evidentiary hearing, he pointed to evidence introduced at sentencing that he had an IQ of 75, had a fourth-grade reading level, had been prescribed numerous medications and treated at psychiatric hospitals as a child, had been identified as having a learning disability, and had been placed in special education classes. The trial court dismissed without holding a hearing or granting funds to conduct additional investigation. Brumfield sought federal habeas relief. The district court granted relief under 28 U.S.C. 2254(d)(1), (2). The Fifth Circuit reversed. The Supreme Court vacated and remanded. The factual determinations underlying the state trial court’s decision—that Brumfield’s IQ score was inconsistent with a diagnosis of intellectual disability and that he presented no evidence of adaptive impairment—were unreasonable under section 2254(d)(2). The fact that the record contains some contrary evidence cannot be said to foreclose all reasonable doubt as to his intellectual disability. The trial court should have taken into account that the evidence was introduced before Brumfield’s intellectual disability was at issue. View "Brumfield v. Cain" on Justia Law

McFadden was charged with violation of the Controlled Substance Analogue Enforcement Act, which identifies substances substantially similar to those listed on the federal controlled substances schedules, 21 U.S.C. 802(32)(A), and instructs courts to treat those analogues as schedule I controlled substances if they are intended for human consumption, Arguing that he did not know the “bath salts” he was distributing were regulated as analogues, McFadden unsuccessfully sought an instruction that would have prevented the jury from finding him guilty unless it found that he knew the substance had chemical structures and effects on the central nervous system substantially similar to those of controlled substances. The Fourth Circuit affirmed his conviction, holding that the Analogue Act’s intent element required only proof that McFadden intended the substance to be consumed by humans. The Supreme Court vacated and remanded. Section 841(a)(1) requires the prosecution to establish that the defendant knew he was dealing with a substance regulated under the Controlled Substances Act (CSA) or Analogue Act. The CSA’s mental-state requirement applies when the controlled substance is, in fact, an analogue; the prosecution must prove that a defendant knew that the substance was “a controlled substance,” even in prosecutions dealing with analogues. The key fact that brings a substance within the scope of the Act is that the substance is “controlled.” That can be established by evidence that a defendant knew that the substance is controlled under the CSA or Analogue Act, regardless of whether he knew the substance’s identity, or by evidence that the defendant knew the specific analogue he was distributing, even if he did not know its legal status as an analogue. A defendant with knowledge of the features defining a controlled substance analogue under section 802(32)(A), knows all of the facts that make his conduct illegal. View "McFadden v. United States" on Justia Law

Mellouli, a lawful permanent resident, pleaded guilty to a misdemeanor offense under Kansas law, the possession of drug paraphernalia “to . . . store [or] conceal . . . a controlled substance,” consisting of a sock in which he had placed four unidentified orange tablets. An Immigration Judge ordered him deported under 8 U.S.C. 1227(a)(2)(B)(i), which authorizes the deportation of an alien “convicted of a violation of . . . any law or regulation of a State, the United States, or a foreign country relating to a controlled substance (defined in section 802 of Title 21).” Section 802 limits “controlled substance” to a “drug or other substance” included in federal schedules. Kansas defines “controlled substance” according to its own schedules, without reference to Section 802, and included substances not on the federal lists. The Board of Immigration Appeals affirmed. The Eighth Circuit denied a petition for review. The Supreme Court reversed. Mellouli’s Kansas conviction for concealing unnamed pills in his sock did not trigger removal. Under the categorical approach, a state conviction triggers removal only if, by definition, the underlying crime falls within a category of removable offenses defined by federal law. The BIA’s reasoning, that there is no need to show that the type of controlled substance involved in a paraphernalia conviction is one defined in section 802, leads to the anomalous result of treating less grave paraphernalia possession misdemeanors more harshly than drug possession and distribution offenses. The Court rejected the government’s argument that aliens who commit any drug crime in states whose drug schedules substantially overlap the federal schedules are deportable, because the state statutes are laws “relating to” federally controlled substances. To trigger removal under 1227(a)(2)(B)(i), the government must connect an element of the alien’s conviction to a drug defined in section 802. View "Mellouli v. Lynch" on Justia Law