Justia U.S. Supreme Court Opinion Summaries

Delilah Diaz was stopped at a U.S.-Mexico border port of entry, where border patrol officers discovered over 54 pounds of methamphetamine hidden in the car she was driving. Diaz was charged with importing methamphetamine, a charge that required the government to prove that Diaz knowingly transported the drugs. Diaz claimed she was unaware of the drugs in the car. To counter this claim, the government planned to call an expert witness, Homeland Security Investigations Special Agent Andrew Flood, to testify that drug traffickers generally do not entrust large quantities of drugs to people who are unaware they are transporting them. Diaz objected to this testimony under Federal Rule of Evidence 704(b), which prohibits an expert witness from stating an opinion about whether the defendant did or did not have a mental state or condition that constitutes an element of the crime charged or of a defense. The court ruled that Agent Flood could testify that most couriers know they are transporting drugs. Diaz was found guilty and appealed, challenging Agent Flood’s testimony under Rule 704(b).The Court of Appeals held that because Agent Flood did not explicitly opine that Diaz knowingly transported methamphetamine, his testimony did not violate Rule 704(b). Diaz appealed this decision to the Supreme Court of the United States.The Supreme Court affirmed the decision of the Court of Appeals. The Court held that expert testimony that "most people" in a group have a particular mental state is not an opinion about "the defendant" and thus does not violate Rule 704(b). The Court reasoned that Agent Flood did not express an opinion about whether Diaz herself knowingly transported methamphetamine. Instead, he testified about the knowledge of most drug couriers, which does not necessarily describe Diaz’s mental state. The Court concluded that because Agent Flood did not express an opinion about whether Diaz herself knowingly transported methamphetamine, his testimony did not violate Rule 704(b). View "Diaz v. United States" on Justia Law

The case revolves around the legality of bump stocks, accessories that allow semi-automatic rifles to fire at a rate similar to machine guns. The Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) had long held that semi-automatic rifles equipped with bump stocks were not machine guns under the statute. However, following a mass shooting in Las Vegas, Nevada, where the shooter used bump stocks, the ATF reversed its position and issued a rule classifying bump stocks as machine guns.The case was first heard in the District Court, where Michael Cargill, who had surrendered two bump stocks to the ATF under protest, challenged the rule. Cargill argued that the ATF lacked statutory authority to classify bump stocks as machine guns because they did not meet the definition of a machine gun under §5845(b). The District Court ruled in favor of the ATF, concluding that a bump stock fits the statutory definition of a machine gun.The case was then taken to the Court of Appeals, which initially affirmed the District Court's decision but later reversed it after rehearing en banc. The majority of the Court of Appeals agreed that §5845(b) was ambiguous as to whether a semi-automatic rifle equipped with a bump stock fits the statutory definition of a machine gun. They concluded that the rule of lenity required resolving that ambiguity in Cargill's favor.The Supreme Court of the United States affirmed the decision of the Court of Appeals. The Court held that a semi-automatic rifle equipped with a bump stock is not a machine gun because it cannot fire more than one shot by a single function of the trigger. Furthermore, even if it could, it would not do so automatically. Therefore, the ATF exceeded its statutory authority by issuing a rule that classifies bump stocks as machine guns. View "Garland v. Cargill" on Justia Law

The case involves Danny Lee Jones, who was convicted of three murders committed with the intent to steal a gun collection. Jones brutally killed a man, his 7-year-old daughter, and his grandmother. After being found guilty, the trial court proceeded to sentencing. Under Arizona law, the court was required to impose a death sentence if it found one or more aggravating circumstances and no mitigating circumstances sufficiently substantial to call for leniency. The court found three aggravating circumstances and sentenced Jones to death. The Arizona Supreme Court affirmed the decision.Jones sought postconviction review, arguing that his attorney was ineffective. He claimed that his attorney should have retained an independent neuropsychologist, rather than relying on a court-appointed psychiatrist. The state court denied this claim. Jones then filed a habeas petition in Federal District Court, reasserting his ineffective-assistance-of-counsel claims. The District Court held an evidentiary hearing but concluded that Jones could not show prejudice because the additional information he presented barely altered the sentencing profile presented to the sentencing judge. The Ninth Circuit reversed, but the Supreme Court vacated that judgment and remanded for the Ninth Circuit to determine whether it had been proper to consider the new evidence presented at the federal evidentiary hearing.On reconsideration, the Ninth Circuit again granted habeas relief. The panel held that it was permissible to consider the new evidence and concluded that there was a reasonable probability that Jones would not have received a death sentence if that evidence had been presented at sentencing. The Supreme Court granted certiorari to review the Ninth Circuit’s interpretation and application of Strickland.The Supreme Court reversed the Ninth Circuit's decision, stating that it had departed from the well-established rules in at least three ways. The Supreme Court found that the Ninth Circuit failed to adequately take into account the weighty aggravating circumstances in this case, applied a strange Circuit rule that prohibits a court in a Strickland case from assessing the relative strength of expert witness testimony, and held that the District Court erred by attaching diminished persuasive value to Jones’s mental health conditions because it saw no link between those conditions and Jones’s conduct when he committed the three murders. The Supreme Court concluded that there was no reasonable probability that the evidence on which Jones relies would have altered the outcome at sentencing. View "Thornell v. Jones" on Justia Law

The Supreme Court of the United States was tasked with interpreting the Armed Career Criminal Act (ACCA) in relation to state drug convictions that occurred before recent amendments to the federal drug schedules. The ACCA imposes a 15-year mandatory minimum sentence on defendants convicted for illegal firearm possession who have a criminal history demonstrating a propensity for violence. A defendant with three previous convictions for a "serious drug offense" qualifies for ACCA's enhanced sentencing.Petitioners Justin Rashaad Brown and Eugene Jackson were separately convicted of the federal crime of possession of a firearm by a convicted felon. In both cases, an ACCA enhancement was recommended based on prior state felony drug convictions. Both defendants argued that their prior convictions did not qualify as "serious drug offenses" due to changes in the federal definition of the drugs involved in their convictions. The District Courts disagreed and sentenced the petitioners to enhanced sentences, and the respective appellate courts affirmed.The Supreme Court held that a state drug conviction counts as an ACCA predicate if it involved a drug on the federal schedules at the time of that conviction. The Court reasoned that the ACCA is a recidivist statute that gauges what a defendant’s “history of criminal activity” says about his or her “culpability and dangerousness.” The Court also noted that the Government’s interpretation best fulfills ACCA’s statutory objectives. The Court affirmed the judgments of the Courts of Appeals. View "Brown v. United States" on Justia Law

The case revolves around Louis McIntosh, who was indicted on multiple counts of Hobbs Act robbery and firearm offenses. The indictment demanded that McIntosh forfeit all property derived from proceeds traceable to the commission of the offenses. The Government later provided McIntosh with a pretrial bill of particulars that included as property subject to forfeiture $75,000 in cash and a BMW that McIntosh purchased just five days after one of the robberies. After a jury convicted McIntosh, the District Court imposed a forfeiture of $75,000 and the BMW at the sentencing hearing. However, the Government failed to submit an order of forfeiture for the court’s signature within a week from the hearing as ordered by the District Court.On appeal, the Government moved for a limited remand to supplement the record with a written order of forfeiture. The Second Circuit granted the unopposed motion. Back in District Court, McIntosh argued that the failure to comply with Federal Rule of Criminal Procedure 32.2(b)(2)(B) meant that the District Court could not proceed with forfeiture at all. The District Court overruled McIntosh’s objections, finding that the Rule is a time-related directive, and that the failure to enter a preliminary order of forfeiture before sentencing did not prevent the court from ordering forfeiture because the missed deadline did not prejudice McIntosh. The Second Circuit affirmed in relevant part.The Supreme Court of the United States held that a district court’s failure to comply with Rule 32.2(b)(2)(B)’s requirement to enter a preliminary order before sentencing does not bar a judge from ordering forfeiture at sentencing subject to harmless-error principles on appellate review. The Court agreed with the Second Circuit and the Government that Rule 32.2(b)(2)(B) establishes a time-related directive. The Court affirmed the judgment of the Court of Appeals for the Second Circuit. View "McIntosh v. United States" on Justia Law

The Supreme Court of the United States decided in the case of Mark Pulsifer, who was convicted for distributing methamphetamine and sought to minimize his sentence using the "safety valve" provision of federal sentencing law. This provision allows a sentencing court to disregard the statutory minimum if a defendant meets five criteria, one of which is related to the defendant's criminal history. The government argued that Pulsifer did not meet this requirement due to his previous three-point offenses, disqualifying him under the safety valve provision. Pulsifer, however, contended that he should be considered eligible as he did not have a two-point violent offense, arguing that only the combination of all three elements of the provision could prevent him from receiving safety-valve relief.The court held that a defendant is eligible for safety-valve relief only if he or she satisfies each of the provision’s three conditions. More specifically, a defendant is eligible only if they do not have more than four criminal-history points, do not have a prior three-point offense, and do not have a prior two-point violent offense. This interpretation aligns with the text and context of the law and the Sentencing Guidelines. The court rejected Pulsifer’s attempts to invoke the rule of lenity, as the court found no ambiguity in the statute and, therefore, no room for lenity to play a role. The court affirmed the judgment of the Court of Appeals for the Eighth Circuit. View "Pulsifer v. United States" on Justia Law

In 2012, Damian McElrath, a young man diagnosed with multiple serious mental health disorders, killed his mother. Georgia charged McElrath with three crimes: malice murder, felony murder, and aggravated assault. At trial, McElrath asserted an insanity defense. The jury found him not guilty by reason of insanity on the malice-murder charge but guilty but mentally ill on the felony-murder and aggravated-assault charges. The state courts, however, decided that these verdicts were "repugnant" because they required contradictory conclusions about McElrath's mental state at the time of the crime. They therefore nullified both the "not guilty" and "guilty" verdicts and authorized McElrath’s retrial.The Supreme Court of the United States held that the Double Jeopardy Clause of the Fifth Amendment prevents the State from retrying McElrath for the crime that had resulted in the “not guilty by reason of insanity” finding. The court clarified that a jury’s determination that a defendant is not guilty by reason of insanity is a conclusion that “criminal culpability had not been established,” just as much as any other form of acquittal. Despite the seemingly inconsistent findings, the court emphasized that, once rendered, a jury’s verdict of acquittal is inviolate, and the Double Jeopardy Clause prohibits second-guessing the reason for a jury’s acquittal. The Supreme Court reversed the judgment of the Supreme Court of Georgia and remanded the case for further proceedings not inconsistent with its opinion. View "McElrath v. Georgia" on Justia Law

From 2014-2016, Counterman sent hundreds of Facebook messages to C.W., a local musician. Each time C.W. tried to block him, Counterman created a new Facebook account and resumed contacting C.W. Several of his messages envisaged violent harm. C.W. stopped walking alone, declined social engagements, canceled performances, and eventually contacted the authorities. Counterman was charged under a Colorado statute making it unlawful to repeatedly make any form of communication with another person in a manner that would cause a reasonable person to suffer serious emotional distress, that does cause that person to suffer serious emotional distress. Colorado courts rejected Counterman’s First Amendment argument.The Supreme Court vacated. In true-threat cases, the prosecution must prove that the defendant had some subjective understanding of his statements’ threatening nature.The First Amendment permits restrictions upon the content of speech in a few areas, including true threats--serious expressions conveying that a speaker means to commit an act of unlawful violence. The existence of a threat depends on what the statement conveys to the person receiving it but the First Amendment may demand a subjective mental-state requirement shielding some true threats because bans on speech have the potential to deter speech outside their boundaries. In this context, a recklessness standard, a showing that a person consciously disregarded a substantial and unjustifiable risk that his conduct will cause harm to another, is the appropriate mental state. Requiring purpose or knowledge would make it harder for states to counter true threats, with diminished returns for protected expression. View "Counterman v. Colorado" on Justia Law

Samia, Hunter, and Stillwell were tried jointly for the murder-for-hire of Lee, a real estate broker. The prosecution argued that Hunter had hired Samia and Stillwell to pose as buyers and visit properties with Lee. The court admitted Stillwell’s confession that he was in the van in which Lee was killed, but he claimed that Samia had shot Lee. Since Stillwell would not be testifying and the full confession implicated Samia, the prosecution introduced the testimony of a DEA agent, who described Stillwell’s confession in a way that eliminated Samia’s name while avoiding obvious indications of redaction. Before that testimony and again before deliberations, the court instructed the jury that the testimony about Stillwell’s confession was admissible only as to Stillwell and should not be considered as to Samia or Hunter. All three were convicted. The Second Circuit held that the admission of Stillwell’s confession did not violate Samia’s Confrontation Clause rights.The Supreme Court affirmed. The Confrontation Clause was not violated by the admission of a non-testifying codefendant’s confession that did not directly inculpate the defendant and was subject to a proper limiting instruction. The Sixth Amendment’s Confrontation Clause forbids the introduction of out-of-court “testimonial” statements unless the witness is unavailable and the defendant has had the chance to cross-examine the witness previously but applies only to witnesses “against the accused.” Ordinarily, a witness at a joint trial is not considered a witness ‘against’ a defendant if the jury is instructed to consider that testimony only against a codefendant. This rule is consistent with the Clause’s text, historical practice, and the law’s reliance on limiting instructions in other contexts. To mandate severance whenever the prosecution wishes to introduce the confession of a non-testifying codefendant in a joint trial would be “too high” a price to pay. View "Samia v. United States" on Justia Law

Hansen promised hundreds of noncitizens a path to U.S. citizenship through “adult adoption,” earning nearly $2 million from his fraudulent scheme. The government charged Hansen under 8 U.S.C. 1324(a)(1)(A)(iv), which forbids “encourag[ing] or induc[ing] an alien to come to, enter, or reside in the United States, knowing or in reckless disregard of the fact that such [activity] is or will be in violation of law.” The Ninth Circuit found Clause (iv) unconstitutionally overbroad, in violation of the First Amendment.The Supreme Court reversed. Because 1324(a)(1)(A)(iv) forbids only the purposeful solicitation and facilitation of specific acts known to violate federal law, the clause is not unconstitutionally overbroad. A statute is facially invalid under the overbreadth doctrine if it “prohibits a substantial amount of protected speech” relative to its “plainly legitimate sweep.” Here, Congress used “encourage” and “induce” as terms of art referring to criminal solicitation and facilitation (capturing only a narrow band of speech) not as those terms are used in ordinary conversation. Criminal solicitation is the intentional encouragement of an unlawful act, and facilitation—i.e., aiding and abetting—is the provision of assistance to a wrongdoer with the intent to further an offense’s commission. Neither requires lending physical aid; both require an intent to bring about a particular unlawful act. The context of these words and statutory history indicate that Congress intended to refer to their well-established legal meanings. Section 1324(a)(1)(A)(iv) reaches no further than the purposeful solicitation and facilitation of specific acts known to violate federal law and does not “prohibi[t] a substantial amount of protected speech” relative to its “plainly legitimate sweep.” View "United States v. Hansen" on Justia Law