Justia U.S. Supreme Court Opinion Summaries

Officers arrested Gilbert for trespassing, took him to the St. Louis Metropolitan Police Department, and placed him in a holding cell. An officer saw Gilbert tie a piece of clothing around the cell bars and put it around his neck, in an apparent suicide attempt. Three officers entered Gilbert’s cell, eventually brought Gilbert to a kneeling position over a concrete bench, and handcuffed his arms behind his back. Gilbert kicked the officers and hit his head on the bench. They shackled his legs. Six officers moved Gilbert to a prone position, face down on the floor. Three officers held Gilbert down at the shoulders, biceps, and legs; at least one placed pressure on Gilbert’s back and torso. Gilbert tried to raise his chest, saying, “‘It hurts. Stop.’” After 15 minutes of struggling, Gilbert’s breathing became abnormal; he stopped moving. The officers rolled Gilbert onto his back and found no pulse; they performed chest compressions and rescue breathing. An ambulance transported Gilbert to the hospital, where he was pronounced dead. In an “excessive force” suit, the Eighth Circuit affirmed summary judgment in favor of the officers.The Supreme Court vacated. The excessive force inquiry requires careful attention to the facts and circumstances of each particular case, including the relationship between the need for the use of force and the amount of force used; the extent of the plaintiff’s injury; any effort by the officer to limit the amount of force; the severity of the underlying security problem; the threat reasonably perceived by the officer; and whether the plaintiff was actively resisting. Here, the court either failed to analyze or found insignificant, details such as that Gilbert was already handcuffed and shackled when placed in the prone position, that officers kept him in that position for 15 minutes, and that St. Louis instructs its officers that pressing down on the back of a prone subject can cause suffocation. The lower court’s opinion could be read to treat Gilbert’s “ongoing resistance” as controlling as a matter of law. Such a per se rule would contravene the careful, context-specific analysis required by precedent. View "Lombardo v. St. Louis" on Justia Law

Lange drove by a California highway patrol officer, playing loud music and honking his horn. The officer followed Lange and soon turned on his overhead lights to signal Lange to pull over. Rather than stopping, Lange drove a short distance to his driveway and entered his attached garage. Without obtaining a warrant, the officer followed Lange into the garage, questioned him, and, after observing signs of intoxication, put him through field sobriety tests. Charged with misdemeanor DUI, Lange moved to suppress the evidence obtained after the officer entered his garage. California courts rejected his Fourth Amendment arguments.The Supreme Court vacated. Under the Fourth Amendment, the pursuit of a fleeing misdemeanor suspect does not always justify a warrantless entry into a home. Precedent favors a case-by-case assessment of exigency when deciding whether a suspected misdemeanant’s flight justifies a warrantless home entry. Such exigencies may exist when an officer must act to prevent imminent injury, the destruction of evidence, or a suspect’s escape. Misdemeanors may be minor. When a minor offense (and no flight) is involved, police officers do not usually face the kind of emergency that can justify a warrantless home entry. Adding a suspect’s flight does not change the situation enough to justify a categorical rule. When the totality of circumstances (including the flight itself) show an emergency—a need to act before it is possible to get a warrant—the police may act without waiting. Common law afforded the home strong protection from government intrusion and did not include a categorical rule allowing warrantless home entry when a suspected misdemeanant flees. View "Lange v. California" on Justia Law

The 1986 mandatory-minimum penalties for possession with intent to distribute cocaine were based on drug quantity: a five-year mandatory minimum was triggered by either five grams of crack cocaine or 500 grams of powder cocaine; a 10-year mandatory minimum was triggered by either 50 grams of crack or five kilograms of powder. In 2008, Terry pleaded guilty to possession with intent to distribute an unspecified amount of crack. The district court determined that his offense involved about four grams of crack and sentenced Terry, as a career offender, to 188 months' imprisonment. The Fair Sentencing Act of 2010 subsequently increased the crack quantity thresholds from five grams to 28 for the five-year mandatory minimum and to 280 grams for the 10-year mandatory minimum. The change became retroactive in the 2018 First Step Act.The Eleventh Circuit and Supreme Court affirmed the denial of Terry’s motion for resentencing. An offender is eligible for a sentence reduction under the First Step Act only if convicted of a crack offense that triggered a mandatory minimum sentence. The Fair Sentencing Act modified the statutory penalties for offenses that triggered mandatory minimum penalties because a person charged with the same conduct today no longer would face the same statutory penalties that they would have faced before 2010; the Act did not modify the statutory penalties for Terry’s offense. Before 2010, a person charged with Terry’s offense—knowing or intentional possession with intent to distribute an unspecified amount of a schedule I or II drug—was subject to statutory penalties of imprisonment of 0-to-20 years. After 2010, a person charged with this conduct is subject to the same statutory penalties. View "Terry v. United States" on Justia Law

In its 2019 “Rehaif” decision, the Supreme Court clarified that for 18 U.S.C. 922(g) firearms-possession offenses, the prosecution must prove both that the defendant knew he possessed a firearm and that he knew he was a felon when he possessed the firearm. Before Rehaif, the petitioners were convicted under section 922(g)(1). The Eleventh Circuit rejected Greer's request for a new trial based on the court’s failure to instruct the jury that Greer had to know he was a felon to be found guilty. The Fourth Circuit agreed that Gary's guilty plea must be vacated because the court failed to advise him that, if he went to trial, a jury would have to find that he knew he was a felon.The Supreme Court affirmed Greer's conviction and reversed as to Gary. A Rehaif error is not a basis for plain-error relief unless the defendant makes a sufficient argument that he would have presented evidence at trial that he did not know he was a felon. A defendant who has “an opportunity to object” to an alleged error and fails to do so forfeits the claim of error. If a defendant later raises the forfeited claim, Federal Rule of Criminal Procedure 52(b)’s plain-error standard applies. Rehaif errors occurred during the underlying proceedings and the errors were plain but Greer must show that, if the court had correctly instructed the jury, there is a “reasonable probability” that he would have been acquitted; Gary must show that, if the court had correctly advised him, there is a “reasonable probability” that he would not have pled guilty. They have not carried that burden. Both had multiple prior felony convictions. The Court rejected arguments that Rehaif errors are “structural” and require automatic vacatur. View "Greer v. United States" on Justia Law

Borden pleaded guilty as a felon-in-possession. The prosecution sought an enhanced sentence under the Armed Career Criminal Act (ACCA), which mandates a 15-year minimum sentence for persons found guilty of illegally possessing a firearm who have three or more prior convictions for a “violent felony.” An offense qualifies as a violent felony under ACCA’s elements clause if it necessarily involves “the use, attempted use, or threatened use of physical force against the person of another,” 18 U.S.C. 924(e)(2)(B)(i). One of Borden’s three predicate convictions was for reckless aggravated assault in violation of Tennessee law. Borden argued that this offense was not a violent felony under ACCA’s elements clause because a mental state of recklessness suffices for conviction and only purposeful or knowing conduct satisfies the requirement of the use of force “against the person of another.” The Sixth Circuit affirmed his enhanced sentence.The Supreme Court reversed and remanded, with four Justices concluding that a criminal offense with a mens rea of recklessness does not qualify as a “violent felony” under ACCA’s elements clause. The Justices found that the narrow “category of violent, active crimes” is best understood to involve a purposeful or knowing mental state—a deliberate choice of wreaking harm on another, rather than mere indifference to risk. Classifying reckless crimes as “violent felonies” would also conflict with ACCA’s purpose of addressing the special danger created when a particular type of offender, a violent criminal, possesses a gun. The “against” clause is not window dressing: It is the “critical” text for deciding the level of mens rea needed. View "Borden v. United States" on Justia Law

Former Georgia police sergeant Van Buren used his credentials on a patrol-car computer to access a law enforcement database to retrieve license plate information in exchange for money. His conduct violated a department policy against obtaining database information for non-law-enforcement purposes. The Eleventh Circuit upheld Van Buren's conviction for a felony violation of the Computer Fraud and Abuse Act of 1986 (CFAA), which covers anyone who “intentionally accesses a computer without authorization or exceeds authorized access,” 18 U.S.C. 1030(a)(2), defined to mean “to access a computer with authorization and to use such access to obtain or alter information in the computer that the accesser is not entitled so to obtain or alter.”The Supreme Court reversed. An individual “exceeds authorized access” when he accesses a computer with authorization but then obtains information located in particular areas of the computer (files, folders, databases) that are off-limits to him. Van Buren “access[ed] a computer with authorization” and “obtain[ed] . . . information in the computer.” The phrase “is not entitled so to obtain” refers to information one is not allowed to obtain by using a computer that he is authorized to access.“Without authorization” protects computers themselves from outside hackers; the “exceeds authorized access” clause protects certain information within computers from "inside hackers." One either can or cannot access a computer system, and one either can or cannot access certain areas within the system. The Act’s precursor to the “exceeds authorized access” language covered any person who, “having accessed a computer with authorization, uses the opportunity such access provides for purposes to which such authorization does not extend.” Congress removed any reference to “purpose” in the CFAA. On the government’s reading, an employee who sends a personal e-mail or reads the news using a work computer may have violated the CFAA. View "Van Buren v. United States" on Justia Law

Crow Police Officer Saylor approached a truck parked on U.S. Highway 212, a public right-of-way within the Crow Reservation in Montana. Saylor observed that the driver, Cooley, appeared to be non-native and had watery, bloodshot eyes. Saylor saw two semi-automatic rifles, a glass pipe, and a plastic bag that contained methamphetamine. Additional officers, including an officer with the Bureau of Indian Affairs, arrived. Saylor was directed to seize all contraband in plain view, leading Saylor to discover more methamphetamine. Cooley, charged with drug and gun offenses, successfully moved to suppress the drug evidence. The Ninth Circuit affirmed.The Supreme Court vacated. Tribal police officers have authority to detain temporarily and to search non-Indian persons traveling on public rights-of-way running through a reservation for potential violations of state or federal law; they are not required to first determine whether a suspect is non-Indian and, if so, to temporarily detain a non-Indian only for “apparent” legal violations. Generally, the inherent sovereign powers of an Indian tribe do not extend to the activities of nonmembers of the tribe, but a tribe retains inherent authority over the conduct of non-Indians on the reservation when that conduct threatens or has some direct effect on the health or welfare of the tribe. When the jurisdiction to try and punish an offender rests outside the tribe, tribal officers may exercise their power to detain the offender and transport him to the proper authorities; the authority to search that individual before transport is ancillary to that authority. View "United States v. Cooley" on Justia Law

During an argument with his wife, Caniglia placed a handgun on a table and asked his wife to “shoot [him] and get it over with.” His wife left and spent the night at a hotel. The next morning, unable to reach her husband by phone, she called the police to request a welfare check. Officers encountered Caniglia on the porch of his home and called an ambulance, believing that Caniglia posed a risk to himself or others. Caniglia agreed to go to the hospital for a psychiatric evaluation if the officers would not confiscate his firearms. After Caniglia left, the officers located and seized his weapons. Caniglia sued, claiming that the officers had violated his Fourth Amendment rights. The First Circuit affirmed summary judgment in favor of the officers, extrapolating from the Supreme Court’s “Cady” decision a theory that the officers’ removal of Caniglia and his firearms from his home was justified by a “community caretaking exception” to the warrant requirement.A unanimous Supreme Court vacated. Cady held that a warrantless search of an impounded vehicle for an unsecured firearm did not violate the Fourth Amendment in light of the officers’ “community caretaking functions.” Searches of vehicles and homes are constitutionally different; the core of the Fourth Amendment’s guarantee is the right of a person to retreat into his home and “free from unreasonable governmental intrusion.” View "Caniglia v. Strom" on Justia Law

In 2007, a Louisiana jury found Edwards guilty of armed robbery, rape, and kidnapping. Louisiana law then permitted non-unanimous jury verdicts if at least 10 of the 12 jurors found the defendant guilty; 11 of 12 Edwards jurors returned a guilty verdict as to some crimes, and 10 of 12 jurors returned a guilty verdict as to others. After Edwards’s conviction became final, Edwards filed a federal habeas corpus petition. The district court rejected his argument that the non-unanimous jury verdict violated his constitutional rights as foreclosed by “Apodaca.” The Fifth Circuit denied a certificate of appealability.While Edwards’s petition for a writ of certiorari was pending, the Supreme Court repudiated Apodoca and held (“Ramos”) that a state jury must be unanimous to convict a criminal defendant of a serious offense.The Supreme Court affirmed with respect to Edwards. The Ramos jury-unanimity rule does not apply retroactively on federal collateral review. New rules of criminal procedure apply to cases on direct review, even if the defendant’s trial has already concluded but, historically, did not apply retroactively on federal collateral review unless a new rule constituted a “watershed” rule of criminal procedure. The Supreme Court has never found that any new procedural rule actually satisfies the “watershed” exception and acknowledged that the exception is “moribund.” Continuing to articulate a theoretical exception that never actually applies "offers false hope to defendants, distorts the law, misleads judges, and wastes" resources. View "Edwards v. Vannoy" on Justia Law

An Alaska jury convicted Wright of 13 counts of sexual abuse of a minor. Wright finished serving his sentence and moved to Tennessee. Once there, he failed to register as a sex offender as required by the Sex Offender Registration and Notification Act, 34 U.S.C. 20913. Wright pleaded guilty to failure to register and received a sentence of time served plus supervised release. During those federal proceedings, Wright filed a petition for a writ of habeas corpus in Alaska under 28 U.S.C. 2241 and 2254, arguing that the Alaska Supreme Court had unreasonably applied clearly established federal law when it denied his Sixth Amendment claims and affirmed his 2009 state conviction and sentence. The district court denied the motion, reasoning that Wright was not in custody pursuant to the judgment of a state court. The Ninth Circuit reversed, reasoning that Wright’s state conviction was “ ‘a necessary predicate’ ” to his federal conviction. The Supreme Court vacated. Section 2254(a) permits a federal court to entertain an application for a writ of habeas corpus on behalf of a person “in custody pursuant to the judgment of a State court.” A habeas petitioner does not remain “in custody” under a conviction “after the sentence imposed for it has fully expired, merely because of the possibility that the prior conviction will be used to enhance the sentences imposed for any subsequent crimes.” That Wright’s state conviction served as a predicate for his federal conviction did not render him “in custody pursuant to the judgment of a State court.” If Wright’s second conviction had been for a state crime, he independently could have satisfied section 2254(a)’s “in custody” requirement, though his ability to attack the first conviction would have been limited. View "Alaska v. Wright" on Justia Law