Justia U.S. Supreme Court Opinion Summaries

Cruz, convicted of capital murder and sentenced to death, argued that under the Supreme Court’s “Simmons” decision, he should have been allowed to inform the jury that a life sentence in Arizona would be without parole. The Arizona Supreme Court held that Arizona’s capital sentencing scheme did not trigger Simmons. The Supreme Court subsequently held ("Lynch" (2016)), that it was fundamental error to conclude that Simmons “did not apply” in Arizona.Cruz sought to raise the Simmons issue under Arizona Rule of Criminal Procedure 32.1(g), which permits a successive post-conviction petition if “there has been a significant change in the law that, if applicable ... would probably overturn the defendant’s judgment or sentence.” The Arizona Supreme Court denied relief, reasoning that a significant change in the application of a law is not a significant change in the law itself, focusing on whether Lynch was a significant change in federal law.The U.S. Supreme Court vacated. A state procedural ruling that is “firmly established and regularly followed” ordinarily forecloses review of a federal claim but the Arizona ruling rests on such a novel and unforeseeable interpretation of a state-court procedural rule that it is not adequate to foreclose review of the federal claim. Although Lynch did not change the Supreme Court’s interpretation of Simmons, it did change the operation of Simmons by Arizona courts in a way that matters for Rule 32.1(g). The analytic focus of Arizona courts applying Rule 32.1(g) has always been on the impact on Arizona law. View "Cruz v. Arizona" on Justia Law

Castro-Huerta was convicted of child neglect in Oklahoma state court. The Supreme Court subsequently held that the Creek Nation’s eastern Oklahoma reservation was never properly disestablished and remained “Indian country.” Castro-Huerta then argued that the federal government had exclusive jurisdiction to prosecute him (a non-Indian) for a crime committed against his stepdaughter (Cherokee Indian) in Tulsa (Indian country). The Oklahoma Court of Criminal Appeals vacated his conviction.The Supreme Court reversed. The federal government and the state have concurrent jurisdiction to prosecute crimes committed by non-Indians against Indians in Indian country. States have jurisdiction to prosecute crimes committed in Indian country unless preempted either under ordinary preemption principles, or when the exercise of state jurisdiction would unlawfully infringe on tribal self-government. Neither preempts state jurisdiction in this case.The General Crimes Act, 18 U.S.C. 1152, does not preempt state authority but simply “extend[s]” the federal laws applicable to federal enclaves to Indian country. The Act does not say that Indian country is equivalent to a federal enclave, that federal jurisdiction is exclusive in Indian country, or that state jurisdiction is preempted in Indian country. Public Law 280 affirmatively grants certain states broad jurisdiction to prosecute state-law offenses by or against Indians in Indian country, 18 U.S.C. 1162; 25 U.S.C. 1321, and does not otherwise preempt state jurisdiction.Employing a balancing test, the Court considered tribal, federal, and state interests to conclude that this exercise of state jurisdiction would not infringe on tribal self-government nor preclude an earlier or later federal prosecution. Oklahoma has a strong sovereign interest in ensuring public safety and criminal justice within its territory. Indian country is part of a state, not separate from it. View "Oklahoma v. Castro-Huerta" on Justia Law

Concepcion pleaded guilty to distributing crack cocaine, 21 U.S.C. 841(a)(1), and was sentenced, in 2009, to 228 months in prison. The career offender provision and other enhancements increased Concepcion’s Sentencing Guidelines range from 57-71 months to 262-327 months.The 2010 Fair Sentencing Act corrected a disparity between crack and powder cocaine sentencing; it did not apply retroactively. A 2011 Sentencing Guidelines amendment lowered the sentencing range for crack-cocaine offenses, retroactively for some defendants. The 2018 First Step Act authorized district courts to “impose a reduced sentence” on defendants serving sentences for certain crack-cocaine offenses “as if" the Fair Sentencing Act "were in effect" when the offense was committed.Because Concepcion was sentenced as a career offender, he was not eligible for relief under the 2011 amendment. Concepcion sought a sentence reduction under the First Step Act, arguing that he would no longer be considered a career offender because one of his prior convictions had been vacated and his remaining convictions would not constitute crimes of violence. Concepcion pointed to post-sentencing evidence of rehabilitation. The First Circuit affirmed the denial of his motion.The Supreme Court reversed. The First Step Act allows courts to consider intervening changes of law or fact in exercising their discretion to reduce a sentence. District courts’ discretion is bounded only when Congress or the Constitution expressly limits the type of information the court may consider. A court may not consider a First Step Act motion only if the movant’s sentence was already reduced under the Fair Sentencing Act or if the court considered and rejected a First Step Act motion. The “as if ” clause does not impose any limit on the information a court can consider in exercising its discretion. In resentencing proceedings, courts may consider nonretroactive Guidelines changes, rehabilitation, and unrelated Guidelines changes. View "Concepcion v. United States" on Justia Law

Two medical doctors, licensed to prescribe controlled substances, were convicted for violating 21 U.S.C. 841, which makes it a crime, “[e]xcept as authorized[,] . . . for any person knowingly or intentionally . . . to manufacture, distribute, or dispense . . . a controlled substance.” Registered doctors may dispense controlled substances via prescription only if the prescription is “issued for a legitimate medical purpose by an individual practitioner acting in the usual course of his professional practice.” 21 CFR 1306.04(a).The Supreme Court vacated their convictions. Section 841’s “knowingly or intentionally” mental state applies to the statute’s “except as authorized” clause. Once a defendant meets the burden of producing evidence that his conduct was “authorized,” the government must prove beyond a reasonable doubt that the defendant knowingly or intentionally acted in an unauthorized manner. Section 885 does not provide a basis for inferring that Congress intended to do away with, or weaken ordinary and longstanding scienter requirements but supports applying normal scienter principles to the “except as authorized” clause. The Court of Appeals in both cases evaluated the jury instructions relating to "mens rea" under an incorrect understanding of section 841’s scienter requirements. View "Ruan v. United States" on Justia Law

Los Angeles County Deputy Vega questioned Tekoh at the medical center where Tekoh worked regarding the reported sexual assault of a patient. Vega did not inform Tekoh of his Miranda rights. Tekoh eventually provided a written statement and was prosecuted for unlawful sexual penetration. His written statement was admitted against him at trial. After the jury returned a verdict of not guilty, Tekoh sued Vega under 42 U.S.C. 1983. The Ninth Circuit held that the use of an un-Mirandized statement against a defendant in a criminal proceeding violated the Fifth Amendment and could support a section 1983 claim.The Supreme Court reversed. A violation of the Miranda rules does not provide a basis for a section 1983 claim. In Miranda, the Court concluded that additional procedural protections were necessary to prevent the violation of the Fifth Amendment right against self-incrimination. Miranda did not hold that a violation of the rules it established necessarily constitute a Fifth Amendment violation. The Miranda rules have been described as “constitutionally based” with “constitutional underpinnings,” but a Miranda violation is not the same as a violation of the Fifth Amendment right.Miranda warnings are “prophylactic,” and can require balancing competing interests. A judicially crafted prophylactic rule should apply only where its benefits outweigh its costs. While the benefits of permitting the assertion of Miranda claims under section 1983 would be slight, the costs would be substantial. View "Vega v. Tekoh" on Justia Law

A prisoner who challenges a state’s proposed method of execution under the Eighth Amendment must identify a readily available alternative method that would significantly reduce the risk of severe pain. Nance brought suit under 42 U.S.C. 1983 to enjoin Georgia from executing him by lethal injection, the only method of execution that Georgia now authorizes. Nance proposes death by firing squad—a method currently approved by four other states. The Eleventh Circuit held that Nance could advance his method-of-execution claim only by a habeas petition. The Supreme Court reversed. Section 1983 remains an appropriate vehicle for a prisoner’s method-of-execution claim where the prisoner proposes an alternative method not authorized by the state’s death-penalty statute. Both section 1983 and the federal habeas statute enable a prisoner to complain of “unconstitutional treatment at the hands of state officials.” When a prisoner seeks relief that would “necessarily imply the invalidity of his conviction or sentence,” he must proceed in habeas. Here, Georgia would have to change its statute to carry out Nance’s execution by firing squad, so an order granting relief would not “necessarily prevent” the state from implementing the execution. The state has a pathway forward even if the proposed alternative is unauthorized by present state law. Section 1983 can compel changes to state laws when necessary to vindicate federal constitutional rights. It would be strange to read state-by-state discrepancies into how section 1983 and the habeas statute apply to federal constitutional claims. View "Nance v. Ward" on Justia Law

Twyford was convicted of aggravated murder and was sentenced to death. Ohio courts affirmed his conviction and sentence, then denied post-conviction relief, rejecting Twyford’s claim that his trial counsel was ineffective for failing to present evidence of a head injury Twyford had sustained. The district court dismissed most of Twyford’s federal habeas claims but allowed others to proceed and ordered the state to transport him to a medical facility for neurological testing that might lead to evidence to support his claim. The court cited the All Writs Act, which authorizes federal courts to “issue all writs necessary or appropriate in aid of their respective jurisdictions.” 28 U.S.C. 1651(a). The Sixth Circuit affirmed.The Supreme Court reversed. A transportation order that allows a prisoner to search for new evidence is not “necessary or appropriate in aid of” a federal court’s adjudication of a habeas corpus action when the prisoner has not shown that the desired evidence would be admissible in connection with a claim for relief. The Antiterrorism and Effective Death Penalty Act (AEDPA) restricts the ability of a federal habeas court to develop and consider new evidence: Before a federal court may decide whether to grant an evidentiary hearing or “otherwise consider new evidence” under 28 U.S.C. 2254(e)(2), it must first determine that such evidence could be legally considered in the prisoner’s case. The All Writs Act cannot be used to circumvent statutory requirements or binding procedural rules. Twyford never explained how the results of neurological testing could be admissible in his habeas proceedings, given that AEDPA review is limited to “the record that was before the state court.” View "Shoop v. Twyford" on Justia Law

Following an unsuccessful robbery during which his accomplice shot a man, Taylor was charged under the Hobbs Act, 18 U.S.C. 1951(a), and with committing a “crime of violence” under section 924(c). The Hobbs Act makes it a crime to commit, attempt to commit, or conspire to commit a robbery with an interstate component. Section 924(c) authorizes enhanced punishments for using a firearm in connection with a “crime of violence” as defined in 18 U.S.C. 924(c)(3)(A) (elements clause) or 924(c)(3)(B) (residual clause). Taylor's sentence was based on his admission that he had committed both conspiracy to commit and attempted Hobbs Act robbery. In habeas proceedings, Taylor argued neither offense qualified as a “crime of violence” following the Supreme Court's holding that 924(c)(3)(B)’s residual clause was unconstitutionally vague. The Fourth Circuit vacated Taylor’s 924(c) conviction.The Supreme Court affirmed. Attempted Hobbs Act robbery does not qualify as a “crime of violence” under 924(c)(3)(A). Under the “categorical approach” for determining whether a federal felony may serve as a predicate under the elements clause, the question is whether that felony “has as an element the use, attempted use, or threatened use of physical force.” The relevant inquiry is not how any particular defendant may commit the crime but whether that felony always requires the government to prove, beyond a reasonable doubt, as an element of its case, the use, attempted use, or threatened use of force. To secure a conviction for attempted Hobbs Act robbery, the government must prove that the defendant intended to complete the offense and that the defendant completed a “substantial step” toward that end; it need not prove that the defendant used, attempted to use, or even threatened to use force against another person or his property. View "United States v. Taylor" on Justia Law

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