Justia U.S. Supreme Court Opinion Summaries

Petitioner was found guilty of murder and sentenced to death in Alabama state court. Petitioner sought postconviction relief in state court under Alabama Rule 32, alleging, among other things, that his trial attorneys failed to afford him the effective assistance guaranteed by the Sixth Amendment. At issue was whether the extraordinary facts of petitioner's case were "cause" to excuse petitioner's procedural default in state court, i.e., petitioner's failure to timely appeal the Alabama trial court's order denying him postconviction relief. The court held that petitioner had shown the requisite "cause" to excuse his procedural default where he was abandoned by counsel and left unrepresented at a critical time for his state postconviction petition, and he lacked a clue of any need to protect himself pro se. View "Maples v. Thomas" on Justia Law

Respondent sought damages from employees at a privately run federal prison in California, claiming that they had deprived him of adequate medical care in violation of the Eighth Amendment's prohibition against cruel and unusual punishment. At issue was whether the Court could imply the existence of an Eighth Amendment-based damages action against employees of a privately operated federal prison. Because the Court believed that in the circumstances of this case, state tort law authorized adequate alternative damage actions - actions that provide both significant deterrence and compensation - no Bivens v. Six Unknown Fed. Narcotics Agents remedy could be implied here. View "Minneci v. Pollard" on Justia Law

Defendant was convicted of theft by unauthorized taking. On appeal, defendant argued that the trial court erred in requiring an initial showing that police arranged a suggestive identification procedure. Suggestive circumstances alone, defendant contended, sufficed to require court evaluation of the reliability of an eyewitness identification before allowing it to be presented to the jury. The New Hampshire Supreme Court rejected defendant's argument and affirmed his conviction. The Court held that the Due Process Clause did not require a preliminary judicial inquiry into the reliability of an eyewitness identification when the identification was not procured under unnecessarily suggestive circumstances arranged by law enforcement. Accordingly, the Court affirmed the judgment of the New Hampshire Supreme Court. View "Perry v. New Hampshire" on Justia Law

This case interpreted two provisions of the Antiterrorism and Effective Death Penalty Act of 1996, (AEDPA). The first, 28 U.S.C. 2253(c), provided that a habeas petitioner must obtain a certificate of appealability (COA) to appeal a federal district court's final order in a habeas proceeding (section 2253(c)(1)). The COA could issue only if the petitioner had made a "substantial showing of the denial of a constitutional right" (section 2253(c)(2)), and "shall indicate which specific issue" satisfied that showing (section 2253(c)(3)). The Court held that section 2253(c)(3) was not a jurisdictional requirement. Accordingly, a judge's failure to "indicate" the requisite constitutional issue in a COA did not deprive a court of appeals of subject-matter jurisdiction to adjudicate the habeas petitioner's appeal. The second provision, 28 U.S.C. 2244(d)(1)(A), established a 1-year limitations period for state prisoners to file federal habeas petitions, running from "the date on which the judgment became final by the conclusion of direct review or the expiration of the time for seeking such review." The Court held that, for a state prisoner who did not seek review in a State's highest court, the judgment became "final" on the date that the time for seeking such review expired. View "Gonzalez v. Thaler" on Justia Law

Petitioner was convicted of first-degree murder based on the testimony of a single eyewitness. During state postconviction proceedings, petitioner obtained police files containing statements by the eyewitness contradicting his testimony. Petitioner argued that the prosecution's failure to disclose those statements violated Brady v. Maryland. The Court held that Brady required that petitioner's conviction be reversed where the eyewitness's testimony was the only evidence linking petitioner to the crime and the eyewitness's undisclosed statements contradicted his testimony. The eyewitness's statements were plainly material, and the State's failure to disclose those statements to the defense thus violated Brady. View "Smith v. Cain" on Justia Law

Defendant filed a federal habeas corpus petition in district court, alleging, inter alia, that the introduction of his nontestifying codefendants' statements violated the Confrontation Clause. At issue was whether "clearly established Federal law" under the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA), 28 U.S.C. 2254(d)(1), included decisions of the Court that were announced after the last adjudication of the merits in state court but before defendant's conviction became final. The Court held that under Section 2254(d)(1), "clearly established Federal law, as determined by the Supreme Court of the United States" included only the Court's decisions as of the time of the relevant state-court adjudication on the merits. Because the Pennsylvania Superior Court's decision - the last state-court adjudication on the merits of defendant's claim - predated Gray v. Maryland by nearly three months, the Third Circuit correctly held that Gray was not "clearly established Federal law" against which it could measure the state-court decision. It therefore correctly concluded that the state court's decision neither was "contrary to," nor "involved an unreasonable application of," any "clearly established Federal law." View "Greene v. Fisher" on Justia Law

Petitioner, a Mexican national, was convicted of murder and sentenced to death by a Texas court. Petitioner sought a stay of execution on the ground that his conviction was obtained in violation of the Vienna Convention on Consular Relations (Vienna Convention), and relied on Case Concerning Avena and Other Mexican Nationals (Avena). The Court held that petitioner's argument was foreclosed by Medellin v. Texas, in which the Court held that neither the Avena decision nor the President's Memorandum purporting to implement that decision constituted directly enforceable federal law. The Court declined to stay the execution so that Congress could consider whether to enact legislation implementing the Avena decision where the Due Process Clause did not prevent a State from carrying out a lawful judgment in light of unenacted legislation that might someday authorize a collateral attack on that judgment. The Court also declined the United State's request that the Court stay the execution until January 2012 in support of "future jurisdiction to review the judgment in a proceeding." Accordingly, the applications for stay of execution was denied and petition for a writ of habeas corpus was denied. View "Leal Garcia v. Texas" on Justia Law

In 2005, respondent was charged with delinquency under the Federal Juvenile Delinquency Act, 18 U.S.C. 5031 et seq., for sexually abusing a boy for approximately two years until respondent was 15 years old and his victim was 12 years old. Respondent was sentenced to two years of juvenile detention followed by juvenile supervision until his 21st birthday. In 2006, while respondent remained in juvenile detention, Congress enacted the Sex Offender Registration and Notification Act (SORNA), 42 U.S.C. 16902 et seq. In July 2007, the District Court determined that respondent had failed to comply with the requirements of his prerelease program. On appeal, respondent challenged his "special conditio[n]" of supervision and requested that the Court of Appeals "reverse th[e] portion of his sentence requiring Sex Offender Registration and remand with instructions that the district court ... strik[e] Sex Offender Registration as a condition of juvenile supervision." Over a year after respondent's 21st birthday, the Court of Appeals handed down its decision and held that the SORNA requirements violated the Ex Post Facto Clause of the Constitution, Art. I, section 9, cl. 3, when applied to juveniles adjudicated as delinquent before SORNA's enactment. The Court held that the Court of Appeals had no authority to enter that judgment because it had no live controversy before it where respondent had turned 21 and where the capable-of-repetition exception to mootness did not apply in this case. Accordingly, the judgment of the Ninth Circuit was vacated and the case remanded with instructions to dismiss the appeal. View "United States v. Juvenile Male" on Justia Law

The Sentencing Reform Act of 1984 ("Act"), 18 U.S.C. 3551 et seq., called for the creation of Sentencing Guidelines to inform judicial discretion in order to reduce unwarranted disparities in federal sentencing. The Act allowed retroactive amendments to the Guidelines for cases where the Guidelines became a cause of inequality. When a retroactive Guideline amendment was adopted, section 3682(c)(2) permitted defendants sentenced based on a sentencing range that had been modified to move for a reduced sentence. In this case, petitioner was indicted for various crimes, including possessing with intent to distribute cocaine base, and entered into a Federal Rule of Criminal Procedure 11(c)(1)(C) agreement to plead guilty to all charges where the Government, in return, agreed to a 106 month sentence. At issue was whether defendants who enter into plea agreements that recommended a particular sentence as a condition of the guilty plea could be eligible for relief under section 3682(c)(2). The Court held that the text and purpose of the statute, Rule 11(c)(1)(C), and the governing Guidelines policy statements compelled the conclusion that the district court had authority to entertain section 3582(c)(2) motions when sentences were imposed in light of the Guidelines, even if the defendant entered into an Rule 11(c)(1)(C) agreement. The Court also held that petitioner's sentencing hearing transcript revealed that the District Court expressed its independent judgment that the sentence was appropriate in light of the applicable Guidelines range. Therefore, the District Court's decisions was "based on" that range within section 3682(c)(2)'s meaning. Accordingly, the judgment of the Court of Appeals was reversed and the case remanded for further proceedings. View "Freeman v. United States" on Justia Law

Petitioner was arrested on charges of driving while intoxicated ("DWI") and the principal evidence against him was a forensic laboratory report certifying that his blood alcohol concentration was well above the threshold for aggravated DWI. At trial, the prosecution did not call as a witness the analyst who signed the certification and, instead, called another analyst who was familiar with the laboratory's testing procedures but had neither participated in nor observed the test on petitioner's blood sample. At issue was whether the Confrontation Clause permitted the prosecution to introduce a forensic laboratory report containing a testimonial certification, made for the purpose of proving a particular fact, through the in-court testimony of a scientist who did not sign the certification or perform or observe the test reported in the certification. The Court held that surrogate testimony of that order did not meet the constitutional requirement where the accused's right was to be confronted with the analyst who made the certification, unless that analyst was unavailable at trial and the accused had an opportunity, pretrial, to cross-examine that particular scientist. Accordingly, the judgment of the New Mexico Supreme Court was reversed and the case remanded for further proceedings. View "Bullcoming v. New Mexico" on Justia Law