Justia U.S. Supreme Court Opinion Summaries

The district court increased the length of Henderson’s sentence so he could participate in a prison drug rehabilitation program. Henderson’s counsel did not object to the sentence, but, on appeal, Henderson claimed plain error. While appeal was pending, the Supreme Court decided, in Tapia v. United States, that it is error for a court to impose or lengthen a prison sentence to enable an offender to complete a treatment pro¬gram or otherwise to promote rehabilitation. The Fifth Circuit determined that Rule 52(b) did not give it authority to correct the error, reasoning that an error is “plain” only if it was clear under law at the time of trial. The Supreme Court reversed. Regardless of whether a legal question was settled or unsettled at the time of trial, an error is “plain” under Rule 52(b) if it was plain at the time of appellate review. If “plain error” covers trial court decisions that were plainly correct when made and those that were plainly incorrect when made, it should cover cases where the law was unsettled. A “time of review” interpretation furthers the basic principle that “an appellate court must apply the law in effect at the time it renders its decision,” works little harm upon the competing principle that insists that counsel call a potential error to the trial court’s attention, and is consistent with Rule 52(b)’s purpose of creating a fairness-based exception to the general requirement that an objection be made at trial to preserve a claim of error. View "Henderson v. United States" on Justia Law

In an infringement suit, the district court declared Minton’s patent invalid under the “on sale” bar since he had leased his interactive securities trading system to a brokerage more than one year before the patent application, 35 U. S. C. 102(b). Seeking reconsideration, Minton argued for the first time that the lease was part of testing and fell within the “experimental use” exception to the bar. The Federal Circuit affirmed denial of the motion, concluding that the argument was waived. Minton sued for legal malpractice in Texas state court. His former attorneys argued that Minton’s claims would have failed even if the experimental-use argument had been timely raised. The trial court agreed. Minton then claimed that the court lacked jurisdiction under 28 U. S. C. 1338(a), which provides for exclusive federal jurisdiction over any case “arising under any Act of Congress relating to patents.” The Texas Court of Appeals rejected Minton’s argument and determined that Minton failed to establish experimental use. The state’s highest court reversed. The Supreme Court reversed, holding that Section 338(a) does not deprive state courts of subject matter jurisdiction over Minton’s malpractice claim. Federal law does not create that claim, so it can arise under federal patent law only if it necessarily raises a stated federal issue, actually disputed and substantial, which may be entertained without disturbing an approved balance of federal and state judicial responsibilities. Resolution of a federal patent question is “necessary” to Minton’s case and the issue is “actually disputed,” but it does not carry the necessary significance. No matter the resolution of the hypothetical “case within a case,” the result of the prior patent litigation will not change. Nor will allowing state courts to resolve these cases undermine development of a uniform body of patent law. View "Gunn v. Minton" on Justia Law

After the State of Michigan rested its case at Evans’ arson trial, the court granted a directed verdict of acquittal, concluding that the state had failed to prove that the burned building was not a dwelling, a fact the court mistakenly believed was an “element” of the statutory offense. The court of appeals reversed and remanded for retrial. In affirming, the state’s highest court held that a directed verdict based on an error of law that did not resolve a factual element of the charged offense was not an acquittal for double jeopardy purposes. The Supreme Court reversed; the Double Jeopardy Clause bars retrial. An acquittal encompasses any ruling that the prosecution’s proof is insufficient to establish criminal liability for an offense. Unlike procedural rulings, which lead to dismissals or mistrials on a basis unrelated to factual guilt or innocence, acquittals are substantive rulings that conclude proceedings absolutely, and raise significant double jeopardy concerns. The trial court clearly evaluated the state’s evidence and determined that it was legally insufficient to sustain a conviction. The acquittal was the product of an erroneous interpretation of governing legal principles, but that error affects only the accuracy of the determination to acquit, not its essential character. View "Evans v. Michigan" on Justia Law

Immigration officials initiated removal proceedings against Chaidez in 2009 upon learning that she had pleaded guilty to mail fraud in 2004. To avoid removal, she sought to overturn that conviction by filing a petition for a writ of coram nobis, contending that her former attorney’s failure to advise her of the guilty plea’s immigration consequences constituted ineffective assistance of counsel. While her petition was pending, the Supreme Court held, in Padilla v. Kentucky, that the Sixth Amendment requires defense attorneys to inform non-citizen clients of the deportation risks of guilty pleas. The district court vacated Chaidez’s conviction. The Seventh Circuit reversed, holding that Padilla had declared a new rule and should not apply in a challenge to a final conviction. The Supreme Court affirmed. Padilla does not apply retroactively to cases already final on direct review. A case does not announce a new rule if it merely applies a principle that governed a prior decision to a different set of facts. Padilla’s ruling answered an open question about the Sixth Amendment’s reach, in a way that altered the law of most jurisdictions, breaking new ground and imposing a new obligation. View "Chaidez v. United States" on Justia Law

Under Georgia’s Hospital Authorities Law, Ga. Code 31-7-75, political subdivisions may create special-purpose hospital authorities to exercise public and essential governmental functions, including acquiring public health facilities. The Albany-Dougherty County Authority owns Memorial, one of two hospitals in the county, and formed private nonprofit corporations (PPHS AND PPMH)to manage it. After the Authority decided to purchase the county’s other hospital and lease it to a PPHS subsidiary, the Federal Trade Commission issued an administrative complaint alleging that the transaction would violate the Federal Trade Commission Act and the Clayton Act. The FTC and Georgia sought an injunction. The district court dismissed, citing the state-action doctrine. The Eleventh Circuit affirmed, holding that the Authority, as a local governmental entity, was entitled to immunity because the challenged anti-competitive conduct was a foreseeable result of the Law. The Supreme Court reversed. Georgia has not clearly articulated and affirmatively expressed a policy allowing hospital authorities to make acquisitions that substantially lessen competition, so state-action immunity does not apply. State-action immunity is disfavored and applies only when it is clear that the challenged conduct is undertaken pursuant to the state’s own regulatory scheme. There is no evidence Georgia affirmatively contemplated that hospital authorities would displace competition by consolidating hospital ownership. The Authority’s powers, including acquisition and leasing powers, simply mirror general powers routinely conferred by states on private corporations; a reasonable legislature’s ability to anticipate the possibility of anti-competitive use of those powers falls short of clearly articulating an affirmative state policy to displace competition. View "Fed. Trade Comm'n v. Phoebe Putney Health Sys., Inc." on Justia Law

Officer Wheetley pulled Harris over for a routine traffic stop. Wheetley sought consent to search Harris’s truck, based on Harris’s nervousness and seeing an open beer can. When Harris refused, Wheetley executed a sniff test with his trained narcotics dog, Aldo, who alerted at the driver’s-side door, leading Wheetley to conclude that he had probable cause to search. The search turned up nothing Aldo was trained to detect, but did reveal ingredients for manufacturing methamphetamine. Harris was charged with illegal possession of those ingredients. In a subsequent stop while Harris was out on bail, Aldo again alerted on Harris’s truck but nothing of interest was found. The trial court denied a motion to suppress. The Florida Supreme Court reversed, holding that if an officer failed to keep records of field performance, including how many times a dog falsely alerted, he could never have probable cause to think the dog a reliable indicator of drugs. The Supreme Court reversed. Training and testing records supported Aldo’s reliability in detecting drugs and Harris failed to undermine that evidence, so Wheetley had probable cause to search. Whether an officer has probable cause depends on the totality of the circumstances, not rigid rules, bright-line tests, and mechanistic inquiries. Requiring the state to introduce comprehensive documentation of a dog’s prior hits and misses in the field is the antithesis of a totality-of-the-circumstances approach. Field records may sometimes be relevant, but the court should evaluate all the evidence, and should not prescribe an inflexible set of requirements. View "Florida v. Harris" on Justia Law

The Hague Convention on the Civil Aspects of International Child Abduction requires contracting states to order a child returned to her country of habitual residence upon finding that the child has been wrongfully removed to or retained in the contracting state. The International Child Abduction Remedies Act, 42 U. S. C. 11601, implements the Convention. Chafin, a U.S. citizen, married a United Kingdom citizen (mother), in Germany, where they had a daughter, E. C. When Chafin was deployed with the military to Afghanistan, mother took E. C. to Scotland. When Chafin was transferred to Alabama, mother traveled there with E. C. Chafin filed for divorce and custody. Mother filed a petition under the Convention and ICARA. The district court concluded that E. C.’s country of habitual residence was Scotland. In Scotland, mother was granted interim custody and a preliminary injunction prohibiting Chafin from removing E. C. The Eleventh Circuit dismissed Chafin’s appeal as moot. The Supreme Court vacated and remanded. Return of a child to a foreign country does not render appeal of a return order moot. The Chafins continue to contest where their daughter will be raised. Chafin’s claim for re-return cannot be dismissed as so implausible that it is insufficient to preserve jurisdiction; his prospects of success are not pertinent to mootness. Even if Scotland were to ignore a re-return order, U. S. courts would continue to have personal jurisdiction over mother and could command her to take action under threat of sanctions. Enforcement of the order may be uncertain, but that does not typically render cases moot. If cases were to become moot upon return of a child, courts would be more likely to routinely grant stays, to prevent loss of any right to appeal, conflicting with the Convention’s mandate of prompt return. View "Chafin v. Chafin" on Justia Law

While police were preparing to execute a search warrant for a basement apartment, detectives in an unmarked car outside the apartment saw two men, later identified as Bailey and Middleton, leave the gated area above the apartment, get in a car, and drive away. The detectives followed for about a mile, then stopped the car. They found keys during a pat-down search of Bailey, who said that he resided in the apartment. He later denied it when informed of the search. The men were handcuffed and driven to the apartment, where the search team had found a gun and illicit drugs. One of Bailey’s keys unlocked the apartment’s door. The district court denied Bailey’s motion to suppress the key and statement, holding that Bailey’s detention was justified under Michigan v. Summers, as a detention incident to execution of a search warrant, and, in the alternative, that the detention was supported by reasonable suspicion under Terry v. Ohio. Bailey was convicted. The Second Circuit affirmed, without ruling on the Terry claim. The Supreme Court reversed and remanded for determination of whether Terry applies. The rule in Summers, permitting detention even if there is no particular suspicion that an individual is involved in criminal activity or poses a specific danger to officers, is limited to the immediate vicinity of the premises to be searched. None of the law enforcement interests identified in Summers applies with similar force to the detention of recent occupants beyond the immediate vicinity of the premises to be searched. View "Bailey v. United States" on Justia Law

Reimbursement providers for inpatient services rendered to Medicare beneficiaries is adjusted upward for hospitals that serve disproportionate numbers of patients who are eligible for Supplemental Security Income. The Centers for Medicare & Medicaid Services annually submit the SSI fraction for eligible hospitals to a “fiscal intermediary,” a Health and Human Services contractor, which computes the reimbursement amount and sends the hospitals notice. A provider may appeal to the Provider Reimbursement Review Board within 180 days, 42 U. S. C. 1395oo(a)(3). The PRRB may extend the period, for good cause, up to three years, 42 CFR 405.1841(b). A hospital timely appealed its SSI fraction calculations for 1993 through 1996. The PRRB found that errors in CMS’s methodology resulted in a systematic under-calculation. When the decision was made public, hospitals challenged their adjustments for 1987 through 1994. The PRRB held that it lacked jurisdiction, reasoning that it had no equitable powers save those granted by legislation or regulation. The district court dismissed the claims. The D. C. Circuit reversed. The Supreme Court reversed. While the 180-day limitation is not “jurisdictional” and does not preclude regulatory extension, the regulation is a permissible interpretation of 1395oo(a)(3). Applying deferential review, the Court noted the Secretary’s practical experience in superintending the huge program and the PRRB. Rejecting an argument for equitable tolling, the Court noted that for nearly 40 years the Secretary has prohibited extensions, except as provided by regulation, and Congress not amended the 180-day provision or the rule-making authority. The statutory scheme, which applies to sophisticated institutional providers, is not designed to be “unusually protective” of claimants. Giving intermediaries more time to discover over-payments than providers have to discover underpayments may be justified by the “administrative realities” of the system: a few dozen intermediaries issue tens of thousands of NPRs, while each provider can concentrate on its own NPR. View "Sebelius v. Auburn Reg'l Med. Ctr." on Justia Law

Lozman’s floating home was a plywood structure with empty bilge space underneath to keep it afloat. He had it towed several times before deciding on a marina owned by the city of Riviera Beach. After various disputes and unsuccessful efforts to evict him from the marina, the city brought an admiralty lawsuit in rem against the home, seeking a lien for dockage fees and damages for trespass. The district court found the floating home to be a “vessel” under the Rules of Construction Act, which defines a “vessel” as including “every description of watercraft or other artificial contrivance used, or capable of being used, as a means of transportation on water,” 1 U. S. C. 3; concluded that admiralty jurisdiction was proper; and awarded fees and damages. The Eleventh Circuit affirmed, noting that the home was “capable” of movement over water despite subjective intent to remain moored indefinitely. The Supreme Court reversed, holding that the case was not moot, although the home has been destroyed. Lozman’s floating home is not a “vessel.” The definition of “transportation” must be applied in a practical way; a structure does not fall within its scope unless a reasonable observer, looking to the home’s physical characteristics and activities, would consider it designed to a practical degree for carrying people or things over water. But for the fact that it floats, nothing about Lozman’s home suggests that it was designed to any practical degree to transport persons or things over water. It had no steering mechanism, had an unraked hull and rectangular bottom 10 inches below water, and had no capacity to generate or store electricity. It lacked self-propulsion, unlike an ordinary houseboat. The Court considered only objective evidence to craft a “workable and consistent” definition that “should offer guidance in a significant number of borderline cases.” View "Lozman v. City of Riviera Beach" on Justia Law