Justia U.S. Supreme Court Opinion Summaries

Petitioner filed a 42 U.S.C. 1983 action in the district court against government entities that ran the jails and other defendants, alleging Fourth and Fourteenth Amendment violations, and arguing that persons arrested for minor offenses could not be subjected to invasive searches unless prison officials have reason to suspect concealment of weapons, drugs, or other contraband. The district court granted him summary judgment, ruling that "strip-searching" nonindictable offenders without reasonable suspicion violated the Fourth Amendment. The Third Circuit Reversed. The Court affirmed and concluded that the search procedure at the county jails struck a reasonable balance between inmate privacy and the needs of the institutions, and thus the Fourth and Fourteenth Amendments did not require adoption of the framework and rules petitioner proposed. View "Florence v. Board of Chosen Freeholders of County of Burlington" on Justia Law

Claiming that the FAA, DOT, and SSA violated the Privacy Act of 1974, 5 U.S.C. 552a(g)(4)(A), by sharing his records with one another, respondent filed suit alleging that the unlawful disclosure to the DOT of his confidential medical information, including his HIV status, had caused him "humiliation, embarrassment, mental anguish, fear of social ostracism, and other severe emotional distress." The District Court granted summary judgment against respondent, concluding that respondent could not recover damages because he alleged only mental and emotional harm, not economic loss. Reversing the District Court, the Ninth Circuit concluded that "actual damages" in the Act was not ambiguous and included damages for mental and emotional distress. Applying traditional rules of construction, the Court held that the Act did not unequivocally authorize an award of damages for mental or emotional distress. Accordingly, the Act did not waive the Government's sovereign immunity from liability for such harms. Therefore, the Court reversed the judgment of the Ninth Circuit and remanded for further proceedings. View "FAA v. Cooper" on Justia Law

When petitioner was indicted in a Texas court on drug charges, the State also moved to revoke the probation term that he was then serving for another drug offense. At about the same time, petitioner pleaded guilty to federal drug charges. At issue was whether a district court, in sentencing a defendant for a federal offense, had authority to order that the federal sentence be consecutive to an anticipated state sentence that had not yet been imposed. The Sentencing Reform Act of 1984, 18 U.S.C. 3584(a), addressed the concurrent-vs.-consecutive decision, but not the situation here, since the District Court did not impose "multiple terms of imprisonment... at the same time," and petitioner was not "already subject to" the state sentence at issue. This did not mean that the District Court lacked authority to act as it did and that the Bureau of Prisons was to make the concurrent-vs.-consecutive decision after the federal sentence had been imposed. It was more natural to read section 3584(a) as leaving room for the exercise of judicial discretion in situations not covered than it was to read section 3621(b) as giving the Bureau what amounted to sentencing authority. Because it was within the District Court's discretion to order that petitioner's sentence run consecutively to his anticipated state sentence in the probation revocation proceeding; and because the state court's subsequent decision to make that sentence concurrent with its other sentence did not establish that the District Court abused its discretion by imposing an unreasonable sentence; the Court affirmed the judgment of the Fifth Circuit. View "Setser v. United States" on Justia Law

Petitioner, a native of Greece and a lawful permanent resident (LPR) of the United States, plead guilty to a felony in 1994. Petitioner later traveled to Greece in 2003 to visit his parents and on his return to the United States, he was treated as an inadmissible alien and placed in removal proceedings. Under the law governing at the time of petitioner's plea, an alien in his situation could travel abroad for brief periods without jeopardizing his resident alien status, 8 U.S.C. 1101(a)(13). This case presented a question of retroactivity not addressed by Congress: As to an LPR convicted of a crime before the effective date of the Illegal Immigration Reform and Immigrant Responsibility Act (IIRIRA), 8 U.S.C. 1101(a)(13)(C)(v) and 1182(a)(2), which regime governed, the one in force at the time of the conviction, or IIRIRA? Guided by the deeply rooted presumption against retroactive legislation, the Court held that section 1101(a)(13)(C)(v) did not apply to petitioner's conviction. The impact of petitioner's brief travel abroad on his permanent resident status was therefore determined not by IIRIRA, but by the legal regime in force at the time of his conviction. Accordingly, the Court reversed the judgment of the Second Circuit and remanded for further proceedings. View "Vartelas v. Holder" on Justia Law

In 2007, respondent filed numerous actions under section 16(b) of the Securities Exchange Act of 1934, 15 U.S.C. 78p(b), claiming that, in underwriting various initial public offerings in the late 1990's and 2000, petitioners and others inflated the stocks' aftermarket prices, allowing them to profit from the aftermarket sales. She also claimed that petitioners had failed to comply with section 16(a)'s requirement that insiders disclose any changes to their ownership in interests. That failure, according to respondent, tolled section 16(b)'s 2-year time period. The district court dismissed and the Ninth Circuit reversed, citing its decision in Whittaker v. Whittaker Corp. The Court held that, even assuming that the 2-year period could be extended, the Ninth Circuit erred in determining that it was tolled until a section 16(a) statement was filed. The text of section 16(b) simply did not support the Whittaker rule. The rule was also not supported by the background rule of equitable tolling for fraudulent concealment. Accordingly, the Court vacated the judgment of the Ninth Circuit and remanded for further proceedings. View "Credit Suisse Securities (USA) LLC v. Simmonds" on Justia Law

Petitioner was born in Jerusalem and his mother requested that his place of birth be listed as "Israel" on a consular report of birth abroad and on his passport pursuant to section 214(d) of the Foreign Relations Authorization Act, Fiscal Year 2003, 116 Stat. 1350. U.S. officials refused the request and petitioner's parents filed suit on his behalf against the Secretary of State. The district court dismissed, holding that the case presented a nonjusticiable political question and the D.C. Circuit affirmed, reasoning that the Constitution gave the Executive the exclusive power to recognize foreign sovereigns and that the exercise of that power could not be reviewed by the courts. The Court held that the courts were fully capable of determining whether this statute could be given effect, or instead must be struck down in light of authority conferred on the Executive by the Constitution. The only real question for the courts was whether the statute was constitutional. Having determined that the case was justiciable, the Court left it to the lower courts to consider the merits in the first instance. Accordingly, the Court vacated the judgment of the D.C. Circuit and remanded for further proceedings. View "Zivotofsky v. Clinton" on Justia Law

In this case, a criminal defendant sought a remedy when inadequate assistance of counsel caused nonacceptance of a plea offer and further proceedings led to a less favorable outcome. After the plea offer had been rejected, there was a full and fair trial before the jury. After a guilty verdict, defendant received a sentence harsher than that offered in the rejected plea bargain. The instant case came to the Court with the concession that counsel's advice with respect to the plea offer fell below the standard of adequate assistance of counsel guaranteed by the Sixth Amendment, applicable to the States through the Fourteenth Amendment. The Court held that, where counsel's ineffective advice led to an offer's rejection, and where the prejudice alleged was having to stand trial, a defendant must show that but for the ineffective advice, there was a reasonable probability that the plea offer would have been presented to the court, that the court would have accepted its terms, and that the conviction or sentence, or both, under the offer's terms would have been less severe than under the actual judgment and sentence imposed. Therefore, the Court vacated the judgment of the Sixth Circuit and remanded for further proceedings. View "Lafler v. Cooper" on Justia Law

This case arose in the context of claimed ineffective assistance that led to the lapse of a prosecution offer of a plea bargain, a proposal that offered terms more lenient than the terms of the guilty plea entered later. At issue was the constitutional right to effective assistance with respect to those offers. Further at issue was what a defendant must demonstrate in order to show that prejudice resulted from counsel's deficient performance. The Court held that the Sixth Amendment right to effective assistance of counsel extended to the consideration of plea offers that lapsed or were rejected. That right applied to "all 'critical' stages of the criminal proceedings." The Court vacated the judgment of the Missouri Court of Appeals and remanded for further proceedings. View "Missouri v. Frye" on Justia Law

Petitioners brought a civil action under the Administrative Procedures Act (APA), 5 U.S.C. 500 et seq., to challenge the issuance by the EPA of an administrative compliance order under section 309 of the Clean Water Act (Act), 33 U.S.C. 1319. The order asserted that petitioners' property was subject to the Act, and that they have violated its provisions by placing fill material on the property; and on this basis it directed them immediately to restore the property pursuant to an EPA work plan. The Court concluded that the compliance order was final agency action for which there was no adequate remedy other than APA review, and that the Act did not preclude that review. Therefore, the Court reversed the judgment of the Ninth Circuit and remanded the case for further proceedings. View "Sackett v. EPA" on Justia Law

Arizona prisoners could raise claims of ineffective assistance of trial counsel only in state collateral proceedings, not on direct review. In petitioner's first state collateral proceeding, his counsel did not raise such a claim. On federal habeas review with new counsel, petitioner argued that he received ineffective assistance both at trial and in his first state collateral proceeding. He also claimed that he had a constitutional right to an effective attorney in the collateral proceeding because it was the first place to raise his claim of ineffective assistance at trial. The Court held that where, under state law, ineffective-assistance-of-trial-counsel claims must be raised in an initial-review collateral proceeding, a procedural default would not bar a federal habeas court from hearing those clams if, in the initial-review collateral proceeding, there was no counsel or counsel in the proceeding was ineffective. Therefore, the Court reversed the judgment of the Ninth Circuit. View "Martinez v. Ryan" on Justia Law