Justia U.S. Supreme Court Opinion Summaries

Frost helped associates commit armed robberies in Washington, generally as the driver. Frost admitted involvement, but claimed he acted under duress. Frost’s lawyer planned to argue both that the state failed to meet its burden of proof and that Frost acted under duress. The judge insisted that the defense choose between the arguments, explaining that state law prohibited simultaneously contesting the elements of the crime and presenting the affirmative defense of duress. Frost’s lawyer limited his summation to duress. The jury convicted Frost of robbery, attempted robbery, burglary, and assault. The Washington Supreme Court affirmed, rejecting the trial court’s view that state law prohibited Frost from both contesting liability and arguing duress and stating that this improper restriction qualified as a trial error (reviewable for harmlessness) rather than a structural error (requiring automatic reversal). Because the jury heard taped confessions and Frost’s confession on the witness stand, the court held that any error was harmless beyond a reasonable doubt. The district court dismissed his habeas petition; the Ninth Circuit, en banc, reversed. A unanimous Supreme Court reversed. Under the Antiterrorism and Effective Death Penalty Act, the petition could be granted only if the state court decision “was contrary to, or involved an unreasonable application of, clearly established Federal law, as determined by the Supreme Court of the United States,” or “was based on an unreasonable determination of the facts in light of the evidence presented in the State court proceeding,.” 28 U. S. C. 2254(d). No Supreme Court case clearly requires placing improper restriction of closing argument in these narrow categories. The trial court did not prohibit the defense from arguing that the prosecution failed to prove the elements of the crime. Reasonable minds could disagree whether requiring the defense to choose between alternative theories. View "Glebe v. Frost" on Justia Law

In 1999, Christeson was convicted of three counts of capital murder and sentenced to death. The Missouri Supreme Court affirmed Christeson’s conviction and sentence and denial of his post-conviction motion for relief. Under the one-year limitations period imposed by the Antiterrorism and Effective Death Penalty Act, 28 U. S. C. 244(d)(1), Christeson’s federal habeas petition was due on April 10, 2005. Nine months before that deadline, the court appointed attorneys Horwitz and Butts to represent Christeson, 18 U. S. C. 599(a)(2). The attorneys subsequently acknowledged that they failed to meet with Christeson until six weeks after his petition was due. There is no evidence that they communicated with him at all. They finally filed the petition 117 days late. The district court dismissed; the Eighth Circuit denied a certificate of appealability. Christeson, who has severe cognitive disabilities, relied entirely on his attorneys, and may not have known of the dismissal. About seven years later, the attorneys contacted attorneys Merrigan and Perkovich to discuss Christeson’s case. Christeson’s only hope for merits review was to move under FRCP60(b) to reopen final judgment on the ground that AEDPA’s statute of limitations should have been equitably tolled. Horwitz and Butts would not file that motion, premised on their own malfeasance. In 2014, Merrigan and Perkovich unsuccessfully moved to substitute counsel. The Eighth Circuit dismissed, reasoning that they were not authorized to file on Christeson’s behalf. The Missouri Supreme Court set an October 29, 2014 execution date. The district court denied a second motion as untimely, stating that Horwitz and Butts had not “abandoned” Christeson, and reasoning that allowing the motion would permit “‘abusive’” delays in capital cases. The Eighth Circuit affirmed. The Supreme Court stayed execution and reversed, stating that the denials contravened its 2012 decision, Martel v. Clair, concerning the “interests of justice” standard, and noting the obvious conflict of interest with respect to the original attorneys. View "Christeson v. Roper" on Justia Law

The inmate, a devout Muslim wanted to grow a ½-inch beard in accordance with his religious beliefs. The Arkansas Department of Correction prohibits prisoners from growing beards, with an exception that inmates with diagnosed skin conditions may grow ¼-inch beards. Prison officials denied him an exemption. Department witnesses testified that beards compromise safety because they can hide contraband and because an inmate could quickly shave to disguise his identity. The district court dismissed, emphasizing that prison officials are entitled to deference on security matters and that the prison permitted exercise of his religion in other ways. The Eighth Circuit affirmed. The Supreme Court reversed. The policy violates the Religious Land Use and Institutionalized Persons Act. 42 U.S.C. 2000cc-1(a). The prisoner’s sincerity is not in dispute and the policy forces him to choose between “engag[ing] in conduct that seriously violates [his] religious belie[f]” and risking discipline. Although he testified that his religion would “credit” him for attempting to follow his beliefs, even if the attempt were unsuccessful, RLUIPA applies to religious exercise regardless of whether it is “compelled.” RLUIPA’s guarantees are not limited to beliefs which are shared by all of the members of a religious sect. The Department failed to show that enforcing its prohibition against the prisoner furthers its stated compelling interests. The Court noted the difficulty of hiding contraband in such a short beard; the lack of a corresponding policy regulating the length of hair on the head; and that the Department did not establish that its security concerns cannot be satisfied by searching a ½-inch beard. Even if the policy furthered a compelling interest in prisoner identification, it violates RLUIPA as applied. Requiring inmates to be photographed both with and without beards would be a less restrictive means. Many institutions allow facial hair and the Department failed to explain the substantial underinclusiveness of its policy with regard to “analogous nonreligious conduct.” View "Holt v. Hobbs" on Justia Law

Jennings sought federal habeas relief based on ineffective assistance of counsel during the punishment phase of his state capital murder trial. The district court granted relief on his “Wiggins theories,” that counsel failed to present evidence of a deprived background and failed to investigate evidence of mental impairment, but not on his “Spisak theory,” that counsel expressed resignation to a death sentence during his closing argument. The court ordered Texas to release Jennings unless, within 120 days, it granted a new sentencing hearing or commuted his death sentence. The Fifth Circuit reversed with respect to the Wiggins theories and determined that it lacked jurisdiction over the Spisak claim, noting that Jennings neither filed a timely notice of appeal nor obtained the certificate of appealability. The Supreme Court reversed. Jennings’ Spisak theory was a defense of his judgment on alternative grounds, so he was not required to take a cross-appeal or obtain a certificate of appealability to argue it. Jennings, as an appellee who did not cross-appeal, could “urge” his Spisak theory unless doing so would enlarge his rights or lessen the state’s rights under the district court’s judgment. Jennings’ rights under the judgment were release, retrial, or commutation and his Spisak claim, if accepted, would give him no more. Nor would it encumber the state’s rights to retain Jennings in custody pending retrial or to commute his sentence. Jennings, whether prevailing on a single theory or all three, sought the same, indivisible relief: a new sentencing hearing. View "Jennings v. Stephens" on Justia Law

Whitfield, fleeing a botched bank robbery, entered 79-year-old Parnell’s home and guided her from a hallway to a room a few feet away, where she suffered a fatal heart attack. He was convicted of, among other things, violating 18 U. S. C.2113(e), which establishes enhanced penalties for anyone who “forces any person to accompany him without the consent of such person” in the course of committing or fleeing from a bank robbery. The Fourth Circuit held that the movement Whitfield required Parnell to make satisfied the forced-accompaniment requirement. The unanimous Supreme Court affirmed. A bank robber “forces [a] person to accompany him,” for purposes of section 2113(e), when he forces that person to go somewhere with him, even if the movement occurs entirely within a single building or over a short distance. The word “accompany” does not connote movement over a substantial distance. The severity of the penalties for a forced-accompaniment conviction, a mandatory minimum of 10 years and a maximum of life imprisonment, does not militate against this interpretation; the danger of a forced accompaniment does not vary depending on the distance traversed. View "Whitfield v. United States" on Justia Law

Following a suspicious vehicle, Sergeant Darisse noticed that only one of the brake lights was working and pulled the driver over. While issuing a warning ticket for the broken light, Darisse became suspicious of the actions of the occupants and their answers to his questions. Heien, the car’s owner, gave Darisse consent to search the vehicle. Darisse found cocaine. Heien was arrested and charged with attempted trafficking. The trial court denied Heien’s motion to suppress, concluding that the faulty light gave Darisse reasonable suspicion for the stop. The North Carolina Court of Appeals reversed, holding that N. C. Gen. Stat. 20–129(g), requires only a single lamp, which Heien’s vehicle had, so that the justification for the stop was objectively unreasonable. Reversing, the state Supreme Court held that Darisse’s mistake was reasonable. The U.S. Supreme Court affirmed. The Fourth Amendment requires government officials to act reasonably, not perfectly. Reasonable suspicion arises from an understanding of both the facts and the law. Whether an officer is reasonably mistaken about the one or the other, the result is the same. Because the Fourth Amendment tolerates only objectively reasonable mistakes, an officer gains no advantage by “Ignorance of the law.” The vehicle code’s wording made it objectively reasonable to think that a faulty brake light constituted a violation. View "Heien v. North Carolina" on Justia Law

Pennsylvania State Police received a report that Zita had stolen a car and loaded handguns and might have fled to the Carman home and sent Officers Carroll and Roberts to that home. The officers parked at the far rear of the corner-lot property, and walked toward the house. They saw a sliding glass door that opened onto a ground-level deck. Carroll thought the door “looked like a customary entryway,” so he and Roberts decided to knock on it. As they stepped onto the deck, a man exited the house and “aggressively approached” them. The officers identified themselves, explained they were looking for Zita, and asked the man for his name. The man refused to answer, but turned away and appeared to reach for his waist. Carroll grabbed his arm to make sure he was not reaching for a weapon. He twisted away and fell into the yard. A woman came outside, identified herself as Karen Carman, identified the man as her husband, and stated that Zita was not there. Karen consented to a search. The officers searched the house, did not find Zita, then left. The Carmans sued under 42 U. S. C. 1983. Carroll argued that his entry was lawful under the “knock and talk” exception to the warrant requirement, which he contended, allows officers to knock on someone’s door, so long as they stay “on those portions of [the] property that the general public is allowed to go on.” The Carmans responded that a normal visitor would have gone to their front door. The jury returned a verdict for Carroll. The Third Circuit reversed. The Supreme Court reversed, holding that Carroll was entitled to qualified immunity. The Court declined to address whether an officer may conduct a “knock and talk” at any entrance that is open to visitors or only the front door, but stated that Carroll may reasonably have concluded that he was allowed to knock on any door that was open to visitors. View "Carroll v. Carman" on Justia Law

In 2005, Smith’s wife was killed at home by a blow to the head from a log roller. The home appeared to have been ransacked. Jewelry was missing. Smith was charged with first-degree murder. The prosecution presented evidence that he was unfaithful for many years, that his wife was threatening a divorce, and that he told an employee that “the ‘only way’ … out of their marriage was ‘to die’.” Smith’s DNA was found on the murder weapon, duct tape found near the body, and a matchstick that may have been used to burn the body. The missing jewelry was discovered in the trunk of Smith’s car, wrapped in duct tape from the same roll as pieces found near the body. Smith claimed that he could not have delivered the fatal blow due to surgery weeks before the murder. The prosecution successfully requested an aiding-and-abetting instruction and argued that even if he had not delivered the fatal blow, he could be convicted. The jury did not specify which theory it adopted. The California Court of Appeal affirmed, rejecting an assertion that Smith had inadequate notice of the aiding-and-abetting theory. The California Supreme Court denied his petition for review. The Ninth Circuit affirmed the district court’s grant of habeas relief, stating that the information charging first degree murder was initially sufficient, because under California law, aiding and abetting is the same substantive offense as perpetrating the crime, but that Smith’s Sixth Amendment and due process right to notice were violated because the prosecution (until it sought an aiding-and-abetting instruction) had tried the case on the theory that Smith himself had delivered the fatal blow. The Supreme Court reversed. When a state prisoner seeks federal habeas relief on the ground that a state court, in adjudicating a claim on the merits, misapplied federal law, a federal court may grant relief only if the state court’s decision was “contrary to, or involved an unreasonable application of, clearly established Federal law, as determined by the Supreme Court of the United States,” 28 U. S. C. 2254(d)(1). The Ninth Circuit relied only on its own precedent in this case. View "Lopez v. Smith" on Justia Law

The Armed Career Criminal Act (ACCA) increases the sentences of federal defendants who have three prior convictions “for a violent felony,” including “burglary, arson, or extortion,” 18 U.S.C. 924(e). Under the “categorical approach” courts compare the statutory elements of a prior conviction with the elements of the “generic” crime, the offense as commonly understood. If the statutory elements are the same as, or narrower than, those of the generic offense, a prior conviction qualifies as an ACCA predicate. A “modified categorical approach” is employed when a prior conviction is for violating a “divisible statute” that sets out one or more elements in the alternative, such as burglary involving entry into a building or an automobile. That approach permits the court to consult certain documents, such as indictments and jury instructions, to determine which alternative element was the basis of the prior conviction. Descamps, convicted of being a felon in possession of a firearm, had three prior convictions, including one under a California statute, which provides that a “person who enters” certain locations “with intent to commit grand or petit larceny or any felony is guilty of burglary.” The district court concluded that the conviction could serve as an ACCA predicate. The Ninth Circuit affirmed. The Supreme Court reversed. Instead of reviewing extra-statutory documents only to determine which alternative element was the basis for the conviction, the Ninth Circuit examined those materials to discover what the defendant actually did. Generic unlawful entry is not an element, or an alternative element of, the California law, so a conviction under that statute is never for generic burglary and ACCA enhancement was improper. The modified categorical approach does not apply to statutes that contain a single, indivisible set of elements. An elements-centric categorical approach is consistent with ACCA’s text and history, avoids Sixth Amendment concerns arising from sentencing courts’ making factual findings that properly belong to juries, and averts “the practical difficulties and potential unfairness of a factual approach.”View "Descamps v. United States" on Justia Law

Without being placed in custody or receiving Miranda warnings, the defendant voluntarily answered questions about a murder. He fell silent when asked whether ballistics testing would match his shotgun to casings found at the murder scene. At trial in Texas state court, over defendant’s objection, the prosecution used his failure to answer as evidence of guilt. Defendant was convicted and state courts of appeals affirmed. The Supreme Court affirmed, reasoning that the defendant did not expressly invoke the Fifth Amendment privilege in response to the question. A witness who desires the protection of the privilege must claim it at the time he relies on it. A defendant need not take the stand and assert the privilege at trial, but there is no comparable unqualified right not to speak during a police interview. Failure to invoke the privilege must be excused if governmental coercion makes its forfeiture involuntary, but this defendant agreed to accompany officers to the station and was free to leave at any time. Neither silence nor official suspicion is sufficient by itself to relieve a witness of the obligation to expressly invoke the privilege and they do not do so together. The Court rejected arguments that reliance on the Fifth Amendment privilege is the most likely explanation for silence in a case like this, stating that such silence is “insolubly ambiguous,” and that it would be unfair to require a suspect unschooled in the particulars of legal doctrine to do anything more than remain silent in order to invoke his “right to remain silent.” View "Salinas v. Texas" on Justia Law