Justia U.S. Supreme Court Opinion Summaries

Kemp and seven codefendants were convicted of drug and gun crimes. The Eleventh Circuit consolidated their appeals and, in November 2013, affirmed their convictions and sentences. In April 2015, Kemp moved to vacate his sentence, 28 U.S.C. 2255. The district court dismissed Kemp’s motion as untimely because it was not filed within one year of “the date on which [his] judgment of conviction [became] final.” Kemp did not appeal. In 2018, Kemp sought to reopen his section 2255 proceedings, arguing that the one-year limitations period on his 2255 motion did not begin to run until his codefendants’ rehearing petitions were denied in May 2014. The Eleventh Circuit agreed that his section 2255 motion was timely but concluded that because Kemp alleged judicial mistake, his FRCP 60(b) motion fell under Rule 60(b)(1), with a one-year limitations period and was untimely.The Supreme Court affirmed. The term “mistake” in Rule 60(b)(1) includes a judge’s errors of law. Because Kemp’s motion alleged such a legal error, it was cognizable under Rule 60(b)(1) and untimely under Rule 60(c)’s one-year limitations period. The Court rejected Kemp’s arguments for limiting Rule 60(b)(1) to non-judicial, non-legal errors and applying Rule 60(b)(6), which allows a party to seek relief “within a reasonable time” for “any other reason that justifies relief,” but is available only when the other grounds for relief specified in Rules 60(b)(1)–(5) are inapplicable. View "Kemp v. United States" on Justia Law

The Bureau of Indian Affairs filed a CFR court complaint against Denezpi, a member of the Navajo Nation, charging Denezpi with crimes alleged to have occurred within the Ute Mountain Ute Reservation: assault and battery, terroristic threats, and false imprisonment. CFR courts administer justice for Indian tribes where tribal courts have not been established. Denezpi pleaded guilty to assault and battery and was sentenced to time served. Months later, a federal grand jury indicted Denezpi for aggravated sexual abuse in Indian country, under the federal Major Crimes Act. Denezpi unsuccessfully argued that the Double Jeopardy Clause barred the consecutive prosecution and was sentenced to 360 months’ imprisonment.The Tenth Circuit and Supreme Court affirmed. The Double Jeopardy Clause does not bar successive prosecutions of distinct offenses arising from a single act, even if a single sovereign prosecutes them. Denezpi’s single act transgressed two laws: the Ute Mountain Ute Code’s assault and battery ordinance and the U.S. Code’s proscription of aggravated sexual abuse in Indian country. The two laws—defined by separate sovereigns—proscribe separate offenses, so Denezpi’s second prosecution did not place him in jeopardy again “for the same offence.” The Court did not address whether CFR prosecutors exercise tribal or federal authority because the Double Jeopardy Clause does not prohibit successive prosecutions by the same sovereign but only prohibits successive prosecutions “for the same offence.” The Double Jeopardy Clause does not ask who puts a person in jeopardy; it focuses on what the person is put in jeopardy for. View "Denezpi v. United States" on Justia Law

The Arizona Supreme Court affirmed each prisoner's conviction and death sentence on direct review; each was denied state postconviction relief. Rejecting their petitions for federal habeas relief under 28 U.S.C. 2254, the district court found their ineffective-assistance-of-trial-counsel claims procedurally defaulted as not properly presented in state court. Each unsuccessfully argued that ineffective assistance of postconviction counsel constituted "cause" to excuse the procedural default. The Ninth Circuit reversed and remanded.The Supreme Court reversed. Under section 2254(e)(2), a federal habeas court may not conduct an evidentiary hearing or otherwise consider evidence beyond the state-court record based on the ineffective assistance of state postconviction counsel. The Antiterrorism and Effective Death Penalty Act, section 2254(b)(1)(A), requires state prisoners to “exhaus[t] the remedies available in the courts of the State” before seeking federal habeas relief. The doctrine of procedural default, a “corollary” to the exhaustion requirement, generally prevents federal courts from hearing any federal claim that was not presented to the state courts “consistent with [the State’s] own procedural rules.” Together, exhaustion and procedural default protect against “the significant harm to the States that results from the failure of federal courts to respect” state procedural rules,Federal courts may excuse procedural default only if a prisoner “can demonstrate cause for the default and actual prejudice.” Attorney error cannot provide cause to excuse a default in proceedings for which the Constitution does not guarantee the assistance of counsel except where the state requires prisoners to raise such claims for the first time during state collateral proceedings. Under section 2254(e)(2), when a prisoner is “at fault” for the undeveloped record in state court, a federal court may hold “an evidentiary hearing on the claim” in only two limited scenarios not relevant here and also must show that further fact-finding would demonstrate, by clear and convincing evidence, that he is innocent. State postconviction counsel’s ineffective assistance in developing the state-court record is attributed to the prisoner because there is no constitutional right to counsel in state postconviction proceedings. When a federal habeas court convenes an evidentiary hearing for any purpose or otherwise reviews any evidence for any purpose, it may not consider that evidence on the merits of a negligent prisoner’s defaulted claim unless the exceptions in section 2254(e)(2) are satisfied. View "Shinn v. Martinez Ramirez" on Justia Law

Davenport, convicted of first-degree murder following a jury trial where he sat shackled at a table with a “privacy screen,” argued that his conviction should be set aside because the Due Process Clause generally forbids such shackling absent “a special need.” On remand, the trial court conducted a hearing; jurors testified that the shackles had not affected their verdict. The federal district court found habeas relief unwarranted under the Antiterrorism and Effective Death Penalty Act (AEDPA), 28 U.S.C. 2254(d). The Sixth Circuit reversed without analyzing the case under AEDPA.The Supreme Court reversed. When a state court has ruled on the merits of a prisoner’s claim, a federal court cannot grant habeas relief without applying both the Supreme Court's "Brecht" test and AEDPA. Brecht held that the harmless-error rule for direct appeals was inappropriate for federal habeas review of final state-court judgments. A state prisoner must show that a state court's error had a “substantial and injurious effect or influence” on the trial’s outcome, AEDPA instructs that if a state court has adjudicated the petitioner’s claim on the merits, a federal court “shall not” grant habeas relief “unless” the state court’s decision was “contrary to” or an “unreasonable application of” clearly established federal law, as determined by the Supreme Court, or based on an “unreasonable determination of the facts” presented in the state-court proceeding.The Court rejected Davenport’s argument that the AEDPA inquiry represents a logical subset of the Brecht test, so the Sixth Circuit necessarily found that he satisfied AEDPA. AEDPA asks whether every fair-minded jurist would agree that an error was prejudicial, Brecht asks only whether a federal habeas court itself harbors grave doubt about the verdict. The legal materials a court may consult when answering each test also differ. Even assuming that Davenport’s claim can survive Brecht, he cannot satisfy AEDPA. Nothing in Supreme Court precedent is inconsistent with the Michigan Court of Appeals’ reliance on post-trial testimony from actual jurors. View "Brown v. Davenport" on Justia Law

Thompson was living with his fiancée and their newborn baby in a Brooklyn apartment. Thompson’s sister-in-law, apparently suffering from mental illness, called 911 to report that Thompson was sexually abusing the baby. When Emergency Medical Technicians arrived, Thompson denied that anyone had called 911. The EMTs returned with police officers, Thompson told them that they could not enter without a warrant. The police nonetheless entered. Thompson was arrested and charged with obstructing governmental administration and resisting arrest. EMTs took the baby to the hospital where medical professionals examined her and found no signs of abuse. Thompson was detained for two days. The charges against Thompson were dismissed without any explanation. The Second Circuit affirmed the dismissal of Thompson’s 42 U.S.C. 1983 claim.The Supreme Court reversed, resolving a split among the Circuits. To demonstrate favorable termination of criminal prosecution for purposes of a section 1983 Fourth Amendment malicious prosecution claim, a plaintiff need not show that the criminal prosecution ended with some affirmative indication of innocence but need only show that his prosecution ended without a conviction. The American tort-law consensus as of 1871 did not require a plaintiff in a malicious prosecution suit to show that his prosecution ended with an affirmative indication of innocence; similarly construing Thompson’s claim is consistent with “the values and purposes” of the Fourth Amendment. Questions concerning whether a defendant was wrongly charged, or whether an individual may seek redress for wrongful prosecution, cannot reasonably depend on whether the prosecutor or court explained why charges were dismissed. Requiring a plaintiff to show that his prosecution ended with an affirmative indication of innocence is not necessary to protect officers from unwarranted civil suits. View "Thompson v. Clark" on Justia Law

Ramirez was sentenced to death for a 2004 murder. Texas informed Ramirez of his September 2021 execution date. Ramirez requested that his pastor be present in the execution chamber. Texas amended its protocol to allow a prisoner’s spiritual advisor to enter the execution chamber. Ramirez then asked that his pastor be permitted to “lay hands” on him and “pray over” him during his execution. Texas denied Ramirez’s request without reference to its execution protocol despite a history of allowing prison chaplains to engage in such activities. The district court and Fifth Circuit declined to grant injunctive relief under the Religious Land Use and Institutionalized Persons Act (RLUIPA), 42 U.S.C. 2000cc–1(a). The Supreme Court stayed Ramirez’s execution, then reversed. Ramirez is likely to succeed on his RLUIPA claims because Texas’s restrictions on religious touch and audible prayer in the execution chamber burden religious exercise and are not the least restrictive means of furthering the state’s compelling interests. Ramirez's requests are “sincerely based on a religious belief.” The laying on of hands and prayer are traditional forms of religious exercise; Ramirez’s pastor confirmed that they are a significant part of their faith tradition.The Court rejected arguments about security and possible trauma to the victim’s family; that absolute silence is necessary to monitor the inmate; and that if spiritual advisors were allowed to pray aloud, the opportunity “could be exploited to make a statement to the witnesses or officials.” Prison officials have less restrictive ways to handle any concerns. Ramirez is likely to suffer irreparable harm absent injunctive relief. The balance of equities and public interest tilt in Ramirez’s favor because it is possible to accommodate Ramirez’s sincere religious beliefs without delaying or impeding his execution. There was no evidence that Ramirez engaged in litigation misconduct that should preclude equitable relief. View "Ramirez v. Collier" on Justia Law

Wooden was convicted as a felon in possession of a firearm, 18 U.S.C. 922(g). The Armed Career Criminal Act (ACCA) mandates a 15-year minimum penalty for section 922(g) offenders with at least three prior convictions for specified felonies “committed on occasions different from one another.” Wooden had 10 burglary convictions arising from a single episode in 1997, during which Wooden unlawfully entered a one-building storage facility and stole items from 10 different storage units. The application of ACCA’s penalty enhancement to Wooden’s 922(g) sentence resulted in a sentence of almost 16 years. The Sixth Circuit affirmed.The Supreme Court reversed. Wooden’s 10 burglary offenses did not occur on different “occasions” and count as only one prior conviction under ACCA. An ordinary person using language in its normal way would describe Wooden’s entries into the storage units as happening on a single occasion. An occasion may encompass multiple, temporally distinct activities. The government’s contrary view could make someone a career offender in the space of a minute. Whether criminal activities occurred on one occasion or different occasions may depend on several circumstances, including timing, location, and the character and relationship of the offenses. Congress’s amendment of ACCA to add the single occasion requirement was based on its belief that a person who robbed a restaurant and did nothing else, is not a career offender. Wooden’s burglary of a single storage facility does not suggest the “special danger” posed by an “armed career criminal.” View "Wooden v. United States" on Justia Law

In 2013, brothers Dzhokhar and Tamerlan planted and detonated homemade bombs near the Boston Marathon’s finish line, killing three and wounding hundreds. The brothers fled, murdering a campus police officer, carjacking a student, and fighting a street battle with police during which Dzhokhar inadvertently killed Tamerlan.Dzhokhar was indicted for 30 crimes, including 17 capital offenses. In a 100-question screening form that included several questions regarding whether media coverage had biased prospective jurors, the district court declined to include a question that asked each prospective juror to list the facts he had learned about the case from the media and other sources. Dzhokhar was convicted on all counts. At sentencing, Dzhokhar argued that Tamerlan had masterminded the bombing and pressured Dzhokhar to participate. The court denied Dzhokhar's request to introduce allegations that, years earlier, Tamerlan had participated in a triple homicide in Waltham. The jury imposed the death penalty. The First Circuit vacated Dzhokhar’s capital sentences.The Supreme Court reversed. The district court did not abuse its broad discretion; the jury question at issue wrongly emphasized what a juror knew before coming to court, rather than potential bias. The court used the 100-question juror form to cull prospective jurors, then subjected those remaining to three weeks of individualized voir dire that probed for bias. The court instructed the jurors that their decisions must be based only on the evidence presented at trial.At the sentencing phase of a capital trial, “information may be presented as to any matter relevant to the sentence, including any mitigating or aggravating factor,” 18 U.S.C. 3593(c). A district court may exclude information “if its probative value is outweighed by the danger of creating unfair prejudice, confusing the issues, or misleading the jury.” The excluded evidence would not have allowed the jury to assess Tamerlan’s alleged role in the Waltham murders and had the potential to confuse the jury. Section 3593(c) does not violate the Eighth Amendment but establishes a regime that affords a capital defendant every reasonable opportunity to present relevant mitigation evidence. The inclusion of the Waltham-murders evidence risked producing a confusing mini-trial in which the only witnesses were dead. View "United States v. Tsarnaev" on Justia Law

A stray 9-millimeter bullet killed a child after a Bronx street fight. Eyewitnesses described the shooter as wearing a blue shirt or sweater. Police officers determined Gilliam was involved and that Morris was at the scene. A search of Morris’ apartment revealed a 9-millimeter cartridge and .357-caliber bullets. Gilliam initially identified Morris as the shooter but subsequently said that Hemphill was the shooter. Morris was charged with murder and possession of a 9-millimeter handgun. The prosecution agreed to dismiss the murder charges if Morris pleaded guilty to possession of a .357 revolver. Years later, Hemphill was indicted for the murder; his DNA matched a blue sweater found in Morris’ apartment shortly after the murder. Hemphill elicited testimony that police had recovered 9-millimeter ammunition from Morris’ apartment, pointing to Morris as the culprit. Morris was not available to testify. The court allowed the prosecution to introduce parts of Morris’ plea allocation transcript to rebut Hemphill’s theory, reasoning that although Morris’ out-of-court statements had not been subjected to cross-examination, Hemphill’s arguments had “opened the door” and admission of the statements was reasonably necessary to correct a misleading impression. Hemphill was convicted. The Supreme Court reversed. Admission of the plea allocution transcript violated Hemphill’s Sixth Amendment right to confront the witnesses against him. While the Sixth Amendment permits reasonable procedural rules concerning the exercise of a defendant’s confrontation right, the “door-opening principle” is a substantive principle that dictates what material is relevant and admissible. It was not for the trial judge to determine whether Hemphill’s theory that Morris was the shooter was unreliable, incredible, or otherwise misleading in light of the state’s proffered, unconfronted plea evidence, nor whether this evidence was reasonably necessary to correct that misleading impression. View "Hemphill v. New York" on Justia Law

In 1996, Reeves and some friends went “looking for some robberies ” but their car broke down. Johnson offered to tow their vehicle. After they arrived, Reeves shot Johnson and directed the others to get his money. Reeves bragged that the murder would earn him a gang tattoo; at a party, Reeves mocked pumping a shotgun and the way that Johnson died. Alabama charged Reeves with murder. His appointed attorneys explored possible intellectual disability. They obtained Reeves’ educational, medical, and correctional records and funding to hire a neuropsychologist (Dr.Goff). Reeves was within the “borderline” range of intelligence but had been denied special education services. A psychologist evaluated Reeves and opined that he was not intellectually disabled. Reeves’ attorneys apparently elected to pursue other mitigation strategies. The jury recommended a death sentence.Reeves unsuccessfully sought state post-conviction relief, alleging that he was intellectually disabled or that counsel should have hired Dr. Goff to develop mitigation. Dr. Goff testified that Reeves was intellectually disabled. The state’s expert administered his own evaluation and concluded that Reeves was not intellectually disabled, noting that Reeves had a leadership role in a drug-dealing group. Although his lawyers were available, Reeves did not call them to testify. The Court of Criminal Appeals affirmed. The federal district court denied habeas relief. The Eleventh Circuit reversed in part, finding that Reeves's lawyers were constitutionally deficient for not developing evidence of intellectual disability and that this failure might have changed the outcome of the trial. The Supreme Court reversed. The Alabama court did not violate clearly established federal law in rejecting Reeves’ claim. Counsel’s strategic decisions are entitled to a “strong presumption” of reasonableness. The analysis is “doubly deferential” when a state court has decided that counsel performed adequately. Despite Reeves’ allegations about his lawyers, he offered no evidence from them. Counsel’s efforts to collect Reeves’ records and obtain funding hardly indicates neglect and disinterest. The Alabama court conducted a case-specific analysis and reasonably concluded that the incomplete evidentiary record doomed Reeves’ belated efforts to second-guess his attorneys. The Eleventh Circuit recharacterized its analysis as a “categorical rule” that any prisoner will always lose if he fails to question trial counsel regarding his reasoning. View "Dunn v. Reeves" on Justia Law