Justia U.S. Supreme Court Opinion Summaries

Donald, Liggins, Moore, Saine, and Zaya decided to rob a drug dealer (Makki). Donald, Moore, and Liggins drove to Makki’s home. Moore and Donald entered. Liggins waited in the car. McGinnis, a drug runner, was present, and dropped to the floor. He heard a scuffle and gunshots. After Moore and Donald left, he found Makki, dying. Moore and Donald returned to the car. Donald stated that he had stolen $320 and that Moore had accidentally shot him. Donald later went to a hospital for the wound. Weeks later, the state charged Donald with first-degree felony murder and two counts of armed robbery. Liggins and Zaya pleaded guilty. Donald was tried with Moore and Saine. His defense was that he was present, but did not participate. The court admitted a chart chronicling phone calls from the day of the crime among Moore, Saine, and Zaya. Donald’s attorney did not object, saying: “it does not affect me.’” When the trial resumed after a recess, Donald’s counsel was not in the courtroom. Ten minutes later, the lawyer returned. The judge informed him that “we only were discussing the telephone chart.” The attorney replied, “I had no dog in the race and no interest in that.” Donald was convicted. Michigan courts rejected his claim that his attorney’s absence during the phone call testimony denied him effective assistance of counsel. The federal district court granted habeas relief. The Sixth Circuit affirmed, based on the Supreme Court’s “Cronic” holding that courts may presume unconstitutional prejudice if a defendant “is denied counsel at a critical stage of his trial.” The Supreme Court, per curiam, reversed. The state court’s decision could not be “contrary to” any Supreme Court holding; no holding addresses counsel’s absence during testimony that is irrelevant within the defendant’s own theory of the case. A fair-minded jurist could conclude that a presumption of prejudice is not warranted by counsel’s short absence during testimony about other defendants, irrelevant to the defendant’s theory. View "Woods v. Donald" on Justia Law

While inspecting a commercial fishing vessel in the Gulf of Mexico, a federal agent found that the catch contained undersized red grouper, in violation of conservation regulations, and instructed the captain, Yates, to keep the undersized fish segregated from the rest of the catch until the ship returned to port. After the officer departed, Yates told the crew to throw the undersized fish overboard. Yates was convicted of destroying, concealing, and covering up undersized fish to impede a federal investigation under 18 U. S. C. 519, which applies when a person “knowingly alters, destroys, mutilates, conceals, covers up, falsifies, or makes a false entry in any record, document, or tangible object with the intent to impede, obstruct, or influence” a federal investigation. Yates argued that section 1519 originated in the Sarbanes-Oxley Act, to protect investors, and that its reference to “tangible object” includes objects used to store information, such as computer hard drives. The Eleventh Circuit affirmed. The Supreme Court reversed, holding that “tangible object” refers to one used to record or preserve information. Section 1519’s position within Title 18, Chapter 73 and its title, “Destruction, alteration, or falsification of records in Federal investigations and bankruptcy,” signal that it was not intended to serve as a cross-the-board ban on the destruction of physical evidence. The words immediately surrounding “tangible object,” “falsifies, or makes a false entry in any record [or] document,” also indicate the contextual meaning of that term. Even if traditional tools of statutory construction leave any doubt about the meaning of the term, it would be appropriate to invoke the rule of lenity. View "Yates v. United States" on Justia Law

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