Justia U.S. Supreme Court Opinion Summaries

A Mississippi jury convicted Jones of murder for killing his grandfather when Jones was 15 years old. Under Mississippi law, murder carried a mandatory sentence of life without parole. That sentence was affirmed on appeal. The Supreme Court subsequently held, in Miller v. Alabama, that the Eighth Amendment permits a life-without-parole sentence for a defendant who committed homicide when he was under 18 only if the sentence is not mandatory and the sentencer has the discretion to impose a lesser punishment. The Mississippi Supreme Court ordered that Jones be resentenced. The judge at resentencing acknowledged that he had discretion under Miller to impose a sentence less than life without parole but determined that life without parole remained the appropriate sentence. The Supreme Court had recently held (Montgomery v. Louisiana) that Miller applied retroactively on collateral review. The Mississippi Court of Appeals rejected Jones’s argument that, under Miller and Montgomery, a sentencer must make a separate factual finding that a murderer under 18 is permanently incorrigible before sentencing the offender to life without parole.The Supreme Court affirmed. In the case of a defendant who committed homicide when he was under 18, Miller and Montgomery do not require the sentencer to make a separate factual finding of permanent incorrigibility before sentencing the defendant to life without parole; a discretionary sentencing system is both constitutionally necessary and constitutionally sufficient. The cases require consideration of an offender’s youth but not any particular factual finding nor an on-the-record sentencing explanation with an “implicit finding” of permanent incorrigibility before sentencing a murderer under 18 to life without parole. Jones's resentencing complied with Miller and Montgomery because the sentencer had discretion to impose a sentence less than life without parole in light of Jones’s youth. View "Jones v. Mississippi" on Justia Law

In March 1985, Hines, carrying a concealed hunting knife, checked into a motel. The manager had put Jenkins in charge of the motel, providing her with a bag of money. Another visitor, Jones, later found Jenkins’ body in a guest's room, with several knife wounds. Her money, keys, and vehicle were missing. A group of travelers later picked Hines up from beside Jenkins' broken-down car. Hines had dried blood on his shirt and “ke[pt] contradicting himself.” Hines admitted to his sister that he had stabbed somebody at the motel; he had a lot of money and the keys to Jenkins’ car. Hines changed his story when he surrendered to the police but offered to confess if guaranteed the death penalty. A search of Hines' motel room revealed stab marks. Jones testified he knew the motel's owners and had stopped by, taken a key from the office, and entered Hines’ room to use the bathroom. Hines’ counsel stressed to the jury this odd sequence of events. The jury heard discrepancies between his account and the first responders' timeline. When Hines unsuccessfully sought post-conviction review, Jones admitted that he was at the motel with a woman other than his wife and had helped himself to a room key. His story was confirmed by his companion who watched through the room’s window. Hines’ attorney was aware of Jones’ affair but had decided to spare him some embarrassment.The Supreme Court reversed the Sixth Circuit's 2020 grant of habeas relief. A federal court “shall not” grant habeas relief unless the state decision took an “unreasonable” view of the facts or law. Substantial evidence linked Hines to the crime. The theory that a more aggressive attorney could have changed the result by casting doubt on Jones’ credibility or portraying him as a viable suspect ignores that Jones’ testimony about discovering the body did not indicate that Hines was the culprit. Ample other evidence did that. If Jones’ credibility mattered, the jury had good reasons to be skeptical. Had the Sixth Circuit properly considered the entire record, it would have had little trouble deferring to the Tennessee court’s conclusion that Hines suffered no prejudice. View "Mays v. Hines" on Justia Law

Kayer murdered Haas in 1994. Kayer was convicted of premeditated first-degree murder, refused to fully cooperate with a mitigation specialist, and refused to agree to a continuance. The court ruled him competent to make that choice. At sentencing, Kayer again refused an offer of more time and stated he would not cooperate.Arizona law authorized a death sentence only if a judge found at least one aggravating circumstance and found no mitigating circumstance sufficient to call for leniency. The judge found two aggravating factors beyond a reasonable doubt: Kayer's 1981 conviction for first-degree burglary and that Kayer murdered Haas for “pecuniary gain.” The court found one nonstatutory mitigator: his importance in his son’s life. Judge Kiger sentenced Kayer to death; the Arizona Supreme Court affirmed.Kayer sought postconviction relief, arguing ineffective assistance of counsel because his attorneys failed to investigate mitigating circumstances at the outset of their representation. The judge considered evidence of Kayer’s addictions to alcohol and gambling; his heart attack weeks before the murder; mental illness, including a diagnosis of bipolar disorder; and of his childhood difficulties. The court found that trial counsel’s performance was not deficient because Kayer had refused to cooperate and, alternatively, that there was no prejudice because it had considered the assertions of mental illness, physical illness, jail conditions, childhood development, and addictions. The Arizona Supreme Court denied review.Kayer filed an unsuccessful federal habeas petition, 28 U.S.C. 2254. The Ninth Circuit reversed.The Supreme Court vacated. A state prisoner may not obtain federal habeas relief with respect to an ineffective assistance claim that was adjudicated on the merits in state court unless the decision was contrary to, or involved an unreasonable application of, clearly established federal law, as determined by the Supreme Court. The Arizona decision is not so obviously wrong that its error lies “beyond any possibility for fair-minded disagreement.” The Ninth Circuit “essentially evaluated the merits de novo, only tacking on a perfunctory statement" that the state court’s decision was unreasonable and that “there is a reasonable probability Kayer’s sentence would have been less than death.” The most probable reason for Judge Kiger’s determination is that the new mitigation evidence offered in the post-conviction proceeding did not create a substantial likelihood of a different sentence. A fair-minded jurist could see Kayer’s past conviction as having substantial weight. Fair-minded jurists also could take a different view of Kayer’s mitigating evidence. View "Shinn v. Kayer" on Justia Law

Under the Uniform Code of Military Justice (UCMJ), a military offense, “punishable by death, may be tried and punished at any time without limitation,” 10 U.S.C. 843(a). Other military offenses are subject to a five-year statute of limitations. Three military service members, each convicted of rape at a time when the UCMJ provided that rape could be “punished by death” argued that the five-year limitations period barred their prosecutions because the Supreme Court held in 1977 (Coker v. Georgia) that the Eighth Amendment forbids a death sentence for the rape of an adult woman.Reversing the Court of Appeals for the Armed Forces, the Supreme Court held that the prosecutions were timely. The UCMJ is a uniform code. The most natural place to determine whether rape was “punishable by death” within the meaning of section 843(a) is section 920’s directive that rape could be “punished by death,” regardless of the UCMJ’s separate prohibition on “cruel or unusual punishment.” If “punishable by death” requires consideration of all applicable law, the deadline for filing rape charges would be unclear. That deadline would depend on an unresolved constitutional question about Coker’s application to military prosecutions, on "evolving standards of decency” under the Eighth Amendment, and on whether UCMJ section 855 independently prohibits a death sentence for rape. The ends served by statutes of limitations differ from those served by the Eighth Amendment or UCMJ 855. Factors legislators may find important in setting a limitations period—such as the difficulty of gathering evidence and mounting a prosecution—play no part in an Eighth Amendment analysis. View "United States v. Briggs" on Justia Law

Taylor, a Texas inmate, alleges that in September 2013, correctional officers confined him in a cell covered, nearly floor to ceiling, in “ ‘massive amounts’ of feces.” Taylor did not eat or drink for nearly four days. Officers then moved Taylor to another, frigidly cold cell, which was equipped with only a clogged floor drain to dispose of bodily wastes. Taylor held his bladder for over 24 hours, but eventually, involuntarily relieved himself, causing the drain to overflow and raw sewage to spill across the floor. The cell lacked a bunk and Taylor was confined without clothing; he was left to sleep naked in sewage.The Fifth Circuit held that such conditions of confinement violate the Eighth Amendment’s prohibition on cruel and unusual punishment but, concluding that “[t]he law wasn’t clearly established” that “prisoners couldn’t be housed in cells teeming with human waste” “for only six days,” the court held that the prison officials did not have “ ‘fair warning’ that their specific acts were unconstitutional.”The Supreme Court vacated. The officers were not entitled to qualified immunity; no reasonable correctional officer could have concluded that, under these extreme circumstances, it was constitutionally permissible to house Taylor in such deplorably unsanitary conditions for an extended period of time. There was no evidence that the conditions of Taylor’s confinement were compelled by necessity or exigency nor that those conditions could not have been mitigated, either in degree or duration. While an officer-by-officer analysis will be necessary on remand, the record suggests that at least some officers involved in Taylor’s ordeal were deliberately indifferent to the conditions of his cells. View "Taylor v. Riojas" on Justia Law

Committees of the U. S. House of Representatives issued subpoenas seeking information about the finances of President Trump, his children, and affiliated businesses. The subpoenas were issued to financial institutions and the President’s personal accounting firm. The President in his personal capacity, his children, and affiliated businesses argued that the subpoenas lacked a legitimate legislative purpose and violated the separation of powers. The President did not argue that any of the requested records were protected by executive privilege.The Supreme Court vacated decisions by the D.C. Circuit and the Second Circuit and remanded. The courts below did not take adequate account of the significant separation of powers concerns implicated by congressional subpoenas for the President’s information. A congressional subpoena is valid only if it is “related to, and in furtherance of, a legitimate task of the Congress” and serves a “valid legislative purpose.” Congress may not issue a subpoena for the purpose of “law enforcement,” because that power is assigned to the Executive and the Judiciary.While executive privilege protections should not be transplanted to cases involving nonprivileged, private information, a limitless subpoena power could transform the established practice of the political branches and allow Congress to aggrandize itself at the President’s expense. The subpoenas at issue represent not a run-of-the-mill legislative effort but rather a clash between rival branches of government over records of intense political interest. Separation of powers concerns are no less palpable because the subpoenas were issued to third parties.A balanced approach is necessary to address those concerns. Courts should carefully assess whether the asserted legislative purpose warrants the significant step of involving the President and his papers. Congress may not rely on the President’s information if other sources could reasonably provide Congress the information it needs in light of its particular legislative objective. Courts should insist on a subpoena no broader than reasonably necessary to support Congress’s legislative objective and should be attentive to the nature of the evidence that a subpoena advances a valid legislative purpose. Courts should assess the burdens imposed on the President and incentives to use subpoenas for institutional advantage. Other considerations may also be pertinent. View "Trump v. Mazars USA, LLP" on Justia Law

The New York County District Attorney’s Office served a subpoena duces tecum on the personal accounting firm of President Trump, seeking financial records relating to the President and his businesses. The President, acting in his personal capacity, sought to enjoin enforcement of the subpoena.The Second Circuit and the Supreme Court affirmed the denial of injunctive relief. Article II and the Supremacy Clause do not categorically preclude or require a heightened standard for the issuance of a state criminal subpoena to a sitting President. The Court examined precedent concerning federal subpoenas, from Aaron Burr’s motion for a subpoena directed at President Jefferson, through Monroe, Clinton, and Nixon, and concluded that, with respect to the state subpoena, the President’s “generalized assertion of privilege must yield to the demonstrated, specific need for evidence in a pending criminal trial.”The Court rejected an argument that a state grand jury subpoena for a sitting President’s personal records must meet a heightened standard of need because of the possibility of diversion, stigma, and harassment. The President conceded that the criminal investigations are permitted under Article II and the Supremacy Clause; the receipt of a subpoena does not categorically magnify the harm to the President’s reputation and grand jury secrecy rules aim to prevent the stigma the President anticipates.Although a President cannot be treated as an “ordinary individual” when executive communications are sought, with regard to private papers, a President stands in “nearly the same situation with any other individual.” Absent a need to protect the Executive, the public interest in fair and effective law enforcement cuts in favor of comprehensive access to evidence. A President may avail himself of the same protections available to every other citizen, including the right to challenge the subpoena on grounds permitted by state law, such as bad faith and undue burden or breadth. A President can raise subpoena-specific constitutional challenges in either a state or a federal forum and can challenge the subpoena as an attempt to influence the performance of his official duties, in violation of the Supremacy Clause. View "Trump v. Vance" on Justia Law

The Major Crimes Act (MCA) provides that, within “the Indian country,” “[a]ny Indian who commits” certain enumerated offenses “shall be subject to the same law and penalties as all other persons committing any of [those] offenses, within the exclusive jurisdiction of the United States,” 18 U.S.C. 1153(a). “Indian country” includes “all land within the limits of any Indian reservation under the jurisdiction of the United States Government.” McGirt was convicted by an Oklahoma state court of sexual offenses. He unsuccessfully argued in state postconviction proceedings that the state lacked jurisdiction to prosecute him because he is an enrolled member of the Seminole Nation and his crimes took place on the Creek Reservation.The Supreme Court held that McGirt was entitled to a federal trial. For MCA purposes, land reserved for the Creek Nation since the 19th century remains “Indian country.” An 1856 Treaty promised that “no portion” of Creek lands “would ever be embraced or included within, or annexed to, any Territory or State,” 11 Stat. 700, and that the Creeks would have the “unrestricted right of self-government,” with “full jurisdiction” over enrolled Tribe members. Once a federal reservation is established, only Congress can diminish or disestablish it. Congress did not end the Creek Reservation during the “allotment era,” when Congress sought to pressure many tribes to abandon their communal lifestyles and parcel their lands into smaller lots owned by individual tribal members. Other limitations on the promised right to self-governance, including abolishing the Creeks’ tribal courts and requiring Presidential approval for certain tribal ordinances fell short of eliminating all tribal interest in the contested lands. Many of Oklahoma’s arguments rest “on state prosecutorial practices that defy the MCA, rather than on the law’s plain terms.” Acknowledging the potential consequences of its ruling, such as unsettling convictions and frustrating the state’s ability to prosecute future crimes, the Court stated that Oklahoma and its tribes have proven that they can work successfully together and Congress remains free to supplement its statutory directions about the lands. View "McGirt v. Oklahoma" on Justia Law

Andrus was six years old, his mother sold drugs out of their apartment. She turned to prostitution and regularly left her five children to binge on drugs. She often was high and had drug-addicted, sometimes violent, boyfriends. When Andrus was 16, he served as a lookout while others committed a robbery. During 18 months in juvenile detention, he was exposed to gangs, drugs, and extended solitary confinement, resulting in suicidal urges. In 2008, Andrus, then 20, attempted a carjacking while under the influence of PCP-laced marijuana. Andrus fired multiple shots, killing two people. At his capital murder trial, Andrus’ defense counsel declined to present an opening statement or evidence. In his closing argument, counsel conceded Andrus’ guilt. The jury found Andrus guilty of capital murder.During the punishment phase, the prosecution presented evidence of Andrus' aggressive behavior in juvenile detention; that Andrus had gang tattoos; that Andrus had hit, kicked, and thrown excrement at prison officials while awaiting trial; and that Andrus was involved in an aggravated robbery. Counsel raised no material objections. In mitigation, counsel focused on Andrus’ basic biographical information, without revealing the circumstances of Andrus’ childhood; the only expert witness focused on the general effects of drug use on adolescent brains. A prison counselor testified that Andrus “started having remorse.” Andrus testified about his childhood. The jury sentenced Andrus to death.In Andrus’ state habeas proceeding, Andrus’ life history came to light. Andrus’ counsel offered no reason for failing to investigate Andrus’ history. The trial court recommended a new sentencing proceeding. The Texas Court of Criminal Appeals disagreed. The U.S. Supreme Court vacated. Andrus demonstrated counsel’s deficient performance under Strickland, but the Court of Criminal Appeals may have failed properly to engage with the question of whether Andrus established that counsel’s deficient performance prejudiced him. View "Andrus v. Texas" on Justia Law

The Prison Litigation Reform Act of 1995 (PLRA) established the three-strikes rule, which generally prevents a prisoner from bringing suit in forma pauperis (IFP) if he has had three or more prior suits dismissed on the grounds that they were frivolous, malicious, or failed to state a claim upon which relief may be granted. 28 U.S.C. 1915(g). Colorado inmate Lomax sued prison officials to challenge his expulsion from the facility’s sex-offender treatment program and moved for IFP status. He had already brought three unsuccessful legal actions during his time in prison. The district court and Tenth Circuit rejected Lomax’s argument that two of the dismissals should not count as strikes because they were without prejudice.The Supreme Court affirmed. Section 1915(g)’s three-strikes provision refers to any dismissal for failure to state a claim, whether with prejudice or without. A Section 1915(g) strike-call hinges exclusively on the basis for the dismissal, regardless of the decision’s prejudicial effect. Courts can and sometimes do dismiss frivolous actions without prejudice. View "Lomax v. Ortiz-Marquez" on Justia Law