Justia U.S. Supreme Court Opinion Summaries

Titlow and Rogers were charged with the murder of Rogers’s husband. After explaining to Titlow that the evidence could support a first-degree murder conviction, Titlow’s attorney negotiated a manslaughter plea in exchange for testimony against Rogers. Three days before trial, Titlow retained a new attorney, Toca, who demanded a lower sentence in exchange for the plea and testimony. The prosecutor rejected the proposal. Titlow withdrew the plea. Rogers was acquitted. Titlow was convicted of second-degree murder. On direct appeal, Titlow argued that Toca provided ineffective assistance by advising plea withdrawal without determining the strength of the evidence. The Michigan Court of Appeals concluded that Toca’s actions were reasonable, given his client’s claims of innocence. The federal district court denied habeas relief. The Sixth Circuit reversed, holding that the factual predicate for the state court’s decision, that the plea withdrawal was based on Titlow’s assertion of innocence, unreasonable, given Toca’s explanation at the withdrawal hearing that the plea offer was higher than the Michigan guidelines sentencing range. The Supreme Court reversed, applying the “doubly deferential” standard of review set forth in the Antiterrorism and Effective Death Penalty Act, 28 U.S.C. 2254(d)(2). The record supports a factual finding that Toca advised withdrawal of the guilty plea only after Titlow’s proclamation of innocence. Titlow passed a polygraph test, discussed the case with a jailer who advised against pleading guilty if Titlow was innocent, and hired Toca days before the trial at which Titlow was to self-incriminate. The facts strongly suggest that Titlow had second thoughts about confessing and proclaimed her innocence. The Sixth Circuit’s conclusion that Toca was ineffective because the record contained no evidence that he gave constitutionally adequate advice is contrary to the principle that counsel should be “strongly presumed to have rendered adequate assistance.” That Toca failed to retrieve the file from former counsel before withdrawing the plea cannot overcome that presumption. Titlow admitted in open court that former counsel had explained that the evidence would support a first-degree murder conviction. Toca justifiably relied on this to conclude that Titlow understood the strength of the prosecution’s case. View "Burt v. Titlow" on Justia Law

The Comptroller is sole trustee and chooses investments for the employee pension fund of the state of New York and its local governments. The Comptroller’s general counsel recommended against investing in a fund managed by FA; the general counsel then received anonymous e-mails demanding that he recommend the investment and threatening to disclose information about the general counsel’s alleged affair. Some of the e-mails were traced to the home computer of Sekhar, a managing partner of FA, who was convicted of attempted extortion under the Hobbs Act, 18 U.S.C. 1951(a). The Act defines “extortion” as “the obtaining of property from another, with his consent, induced by wrongful use of actual or threatened force, violence, or fear, or under color of official right.” The jury specified that the property at issue was the general counsel’s recommendation to approve the investment. The Second Circuit affirmed. The Supreme Court reversed. Attempting to compel a person to recommend that his employer approve an investment does not constitute “the obtaining of property from another” under the Hobbs Act. Congress generally intends to incorporate the well-settled meaning of the common-law terms it uses. Extortion historically required the obtaining of items of value, typically cash, from the victim. The Act’s text requires not only deprivation, but the acquisition of property; the property, therefore, must be transferable. No fluent English-speaker would say that “petitioner obtained and exercised the general counsel’s right to make a recommendation,” any more than he would say that a person “obtained and exercised another’s right to free speech.” View "Sekhar v. United States" on Justia Law

Based on the 1978 strangling death of a 74-year-old, Schad was convicted in 1985 of first-degree murder and sentenced to death. After extensive Arizona state and federal court proceedings, the Supreme Court denied petitions for certiorari and for rehearing. Schad immediately moved for a stay pending the Ninth Circuit’s decision in a separate en banc case The Ninth Circuit denied the motion, stating that an indefinite stay “would unduly interfere with Arizona’s execution process,” but also declined to issue its mandate as normally required by Federal Rule of Appellate Procedure 41(d)(2)(D). The court instead, sua sponte, construed Schad’s motion as a motion to reconsider a motion that it had denied six months earlier and remanded to the district court. Arizona then set an execution date. Based on its review of that previously rejected motion, the Ninth Circuit issued a stay a few days before Schad’s scheduled execution. The Supreme Court granted Arizona’s petition to vacate the stay and remanded with instructions to issue the mandate immediately, without any further proceedings. The Ninth Circuit did not demonstrate that exceptional circumstances justified withholding its mandate; its failure to issue its mandate constituted an abuse of discretion. View "Ryan v. Schad" on Justia Law

Kebodeaux was convicted by special court-martial of a federal sex offense. After serving his sentence and receiving a bad-conduct discharge from the Air Force, he moved to Texas where he registered with state authorities as a sex offender. Congress later enacted the Sex Offender Registration and Notification Act (SORNA), which requires federal sex offenders to register in the states where they live, study, and work, 42 U.S.C. 16913(a). SORNA applies to offenders who, when SORNA became law, had completed their sentences. When Kebodeaux moved within Texas and failed to update his registration, the federal government prosecuted him and the district court convicted him under SORNA. The Fifth Circuit reversed. The Supreme Court reversed, holding that SORNA’s registration requirements, as applied to Kebodeaux, fall within the scope of congressional authority under the Necessary and Proper Clause. Congress did not apply SORNA to an individual who was, before its enactment, “unconditionally released,” but to an individual already subject to federal registration requirements. SORNA somewhat modified registration requirements to which Kebodeaux was already subject, to make more uniform "a patchwork of federal and 50 individual state registration requirements." At the time of his offense and conviction, Kebodeaux was subject to the Wetterling Act, which imposed similar registration requirements and was promulgated under the Military Regulation Clause (Art. I, s. 8, cl. 14), and the Necessary and Proper Clause. The same power that authorized Congress to promulgate the Uniform Code of Military Justice and punish Kebodeaux’s crime also authorized Congress to make the civil registration requirement at issue a consequence of conviction. Imposing a civil registration requirement that would apply upon the release of an offender like Kebodeaux is “eminently reasonable,” as is assignment of a special role to the federal government in ensuring compliance with federal sex offender registration requirements. View "United States v. Kebodeaux" on Justia Law

Riley was stopped for a traffic violation, which led to his arrest on weapons charges. An officer searching Riley incident to the arrest seized a cell phone from Riley’s pants pocket, accessed information on the phone, and noticed repeated use of a term associated with a street gang. At the police station two hours later, a detective specializing in gangs further examined the phone’s digital contents. Based in part on photographs found, the state charged Riley in connection with a shooting and sought an enhanced sentence based on gang membership. The trial court denied a motion to suppress. His conviction was affirmed. Wurie was arrested after police observed him participate in an apparent drug sale. At the station, the officers seized a cell phone from Wurie’s person and noticed that the phone was receiving calls from a source identified as “my house” on its screen. The officers opened the phone, accessed its call log, and traced that number to what they suspected was Wurie’s apartment. They secured a warrant and found drugs, a firearm and ammunition, and cash in the ensuing search. Wurie was charged with drug and firearm offenses. The district court denied a motion to suppress. Wurie was convicted. The First Circuit reversed and vacated the convictions. The Supreme Court reversed as to Riley and affirmed as to Wurie. The police generally may not, without a warrant, search digital information on a cell phone seized from an individual who has been arrested. The exception for searches incident to arrest does not apply; such searches must be limited to the area within the arrestee’s immediate control, where it is justified by the interests in officer safety and in preventing evidence destruction. A search of digital information on a cell phone implicates substantially greater individual privacy interests than a brief physical search; data stored on a cell phone cannot itself be used as a weapon to harm an arresting officer or to effectuate an escape. To the extent that a search of cell phone data might warn officers of an impending danger,, such a concern is better addressed under case-specific exceptions to the warrant requirement, such as exigent circumstances. There is little indication that either remote wiping or encryption is prevalent or that the opportunity to perform a search incident to arrest would be an effective solution. View "Riley v. California" on Justia Law

The bank fraud statute, 18 U.S.C. 1344(2), makes it a crime to “knowingly execut[e] a scheme ... to obtain” property owned by, or under the custody of, a bank “by means of false or fraudulent pretenses.” Loughrin was charged with bank fraud after he was caught forging stolen checks, using them to buy goods at a Target store, and then returning the goods for cash. The district court declined to give Loughrin’s proposed jury instruction that section 1344(2) required proof of “intent to defraud a financial institution.” A jury convicted Loughrin. The Tenth Circuit and Supreme Court affirmed. Section 1344(2) does not require proof that a defendant intended to defraud a financial institution, but requires only that a defendant intended to obtain bank property and that this was accomplished “by means of” a false statement. Imposing Loughrin’s proposed requirement would prevent the law from applying to cases falling within the statute’s clear terms, such as frauds directed against a third-party custodian of bank-owned property. The Court rejected Loughrin’s argument that without an element of intent to defraud a bank, section 1344(2) would apply to every minor fraud in which the victim happens to pay by check, stating that the statutory language limits application to cases in which the misrepresentation has some real connection to a federally insured bank, and thus to the pertinent federal interest. View "Loughrin v. United States" on Justia Law

Abramski offered to purchase a gun for his uncle. Form 4473 asked whether he was the “actual transferee/buyer” of the gun and warned that a straw purchaser (buying a gun on behalf of another) was not the actual buyer. Abramski falsely answered that he was the actual buyer. Abramski was convicted for knowingly making false statements “with respect to any fact material to the lawfulness of the sale” of a gun, 18 U.S.C. 922(a)(6), and for making a false statement “with respect to the information required ... to be kept” in the gun dealer’s records, section 924(a)(1)(A). The Fourth Circuit affirmed. The Supreme Court affirmed, holding that the misrepresentation was material and rejecting Abramski’s argument that federal gun laws are unconcerned with straw arrangements. While the law regulates licensed dealer’s transactions with “persons” or “transferees” without specifying whether that language refers to the straw buyer or the actual purchaser, read in light of the statute’s context, structure, and purpose, the language clearly refers to the true buyer rather than the straw. The law establishes an elaborate system of in-person identification and background checks to ensure that guns are kept out of the hands of felons and other prohibited purchasers and imposes record-keeping requirements to assist authorities in investigating serious crimes through the tracing of guns tor buyers. The provisions would mean little if they could be avoided simply by enlisting the aid of an intermediary to execute the paperwork. The statute’s language is thus best read in context to refer to the actual rather than nominal buyer. While Abramski’s uncle could, possibly, have legally bought a gun for himself, Abramski’s false statement prevented the dealer from insisting that the true buyer appear in person, provide identifying information, show a photo ID, and submit to a background check. The dealer could not have lawfully sold the gun had it known that Abramski was not the true buyer, so the misstatement was material to the lawfulness of the sale. View "Abramski v. United States" on Justia Law

Bond sought revenge for her husband’s affair by spreading toxic chemicals on Haynes’s car, mailbox, and door knob, in hopes that Haynes would develop a rash. Haynes suffered a minor chemical burn that she treated by rinsing with water. Federal prosecutors charged Bond with violating the Chemical Weapons Convention Implementation Act, which forbids any person knowingly to possess or use "any chemical weapon,” 18 U.S.C. 229(a)(1). A “chemical weapon” is “[a]toxic chemical and its precursors, except where intended for a purpose not prohibited under this chapter.” A “toxic chemical” is “any chemical which through its chemical action on life processes can cause death, temporary incapacitation or permanent harm to humans or animals … regardless of their origin or of their method of production, and regardless of whether they are produced in facilities, in munitions or elsewhere.” “[P]urposes not prohibited by this chapter” is defined as“[a]ny peaceful purpose related to an industrial, agricultural, research, medical, or pharmaceutical activity or other activity,” and other specific purposes. Bond pleaded guilty but reserved the right to appeal. On remand, the Third Circuit rejected her Tenth Amendment argument and an argument that section 229 does not reach her conduct. The Supreme Court reversed. Section 229 does not reach Bond’s simple assault. Seeing “no need to interpret the scope of the international Chemical Weapons Convention,” the Court stated that Bond was prosecuted under a federal statute, which, unlike the treaty, must be read consistent with the principles of federalism. There is no indication that Congress intended to reach purely local crimes; an ordinary speaker would not describe Bond’s feud-driven act of spreading irritating chemicals as involving a “chemical weapon.” The chemicals at issue here bear little resemblance to those whose prohibition was the object of an international Convention. Pennsylvania’s laws are sufficient to prosecute assaults like Bond’s, and the “global need to prevent chemical warfare does not require the Federal Government to reach into the kitchen cupboard.“ View "Bond v. United States" on Justia Law

After the Supreme Court held that the Eighth and Fourteenth Amendments forbid the execution of persons with intellectual disability, Hall asked a Florida state court to vacate his sentence, presenting evidence that included an IQ test score of 71. The court denied relief, determining that a Florida statute mandated that he show an IQ score of 70 or below before being permitted to present any additional intellectual disability evidence. The state’s highest court rejected Hall’s appeal, finding the 70-point threshold constitutional. The U.S. Supreme Court reversed. Florida’s rule disregards established medical practice that an individual score is best understood as a range. While nothing in its statute precludes Florida from considering an IQ test’s standard error of measurement, a statistical fact reflecting the test’s inherent imprecision, the interpretation of the Florida Supreme Court takes an IQ score as conclusive evidence of intellectual capacity. The interpretation fails to recognize that measurement’s inherent imprecision and bars consideration of other relevant evidence, e.g., deficits in adaptive functioning, including evidence of past performance, environment, and upbringing. Current thinking does not regard this strict cutoff as proper or humane. When a defendant’s IQ test score falls within the test’s acknowledged and inherent margin of error, the defendant must be able to present additional evidence of intellectual disability, including testimony regarding adaptive deficits. View "Hall v. Florida" on Justia Law

Martinez was indicted in 2006 on charges of aggravated battery and mob action against the state. After significant delays, caused by both sides, his trial was set to begin on May 17, 2010. His counsel was ready; the prosecution was not because it was unable to locate its complaining witnesses. The court delayed swearing the jurors, but ultimately told the state that it could at that point either have the jury sworn or move to dismiss its case. After several hours, the court swore in the jury and asked the state to present its first witness. It declined to present any evidence or participate in the trial. Martinez successfully moved for a directed not-guilty verdict. The court rejected a motion for a continuance, noting that the prosecution had named other witnesses and that the missing witnesses should have been relatively easy to locate. The Illinois Supreme Court allowed the state’s appeal, on the theory that jeopardy never attached because Martinez “was never at risk of conviction.” The Supreme Court reversed, citing the ”bright-line rule” that “jeopardy attaches when the jury is empaneled and sworn.” Martinez may not be retried. View "Martinez v. Illinois" on Justia Law