Justia U.S. Supreme Court Opinion Summaries

Respondent, a prison inmate, sought to suppress his confession under Miranda v. Arizona after he was subjected to custodial interrogation when he was escorted from his prison cell by a corrections officer to a conference room where he was questioned by two sheriff's deputies about criminal activity he had allegedly engaged in before coming to prison. The Sixth Circuit subsequently held that precedent clearly established that a prisoner was in custody within the meaning of Miranda if the prisoner was taken aside and questioned about events that occurred outside the prison walls. The Court's decision, however, did not clearly establish such a rule, and therefore the Court of Appeals erred in holding that this rule provided a permissible basis for federal habeas relief under the relevant provision of the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA), 28 U.S.C. 2254(d)(1). The rule applied by the lower court did not represent a correct interpretation of the Court's Miranda law. Therefore, taking into account all of the circumstances of the questioning - including especially the undisputed fact that respondent was told he was free to end the questioning and to return to his cell - the Court held that respondent was not in custody within the meaning of Miranda. View "Howes v. Fields" on Justia Law

Petitioners, natives and citizens of Japan who have been lawful permanent residents of the United States since 1984, appealed a removal order after husband pleaded guilty to one count of willfully making and subscribing a false tax return in violation of 26 U.S.C. 7206(1) and wife pleaded guilty to one count of aiding and assisting in the preparation of a false tax return in violation of 26 U.S.C. 7206(2). At issue was whether aliens who commit certain federal tax crimes were subject to deportation as aliens who have been convicted of an aggravated felony. The Court held that violations of section 7206(1) and (2) were crimes "involv[ing] fraud or deceit" under 8 U.S.C. 1101(a)(43)(M)(i) and were therefore aggravated felonies as that term was defined in the Immigration and Nationality Act, 8 U.S.C. 1101 et seq., when the loss to the Government exceeded $10,000. Because petitioners were subject to deportation as aliens who have been convicted of aggravated felonies, the Court affirmed the judgment of the Court of Appeals. View "Kawashima v. Holder" on Justia Law

Respondent was convicted of drug trafficking and conspiracy charges. The District Court suppressed GPS data from a vehicle parked outside of respondent's residence, but held the remaining data admissible because respondent had no reasonable expectation of privacy when the vehicle was on a public street. The D.C. Circuit reversed, concluding that admission of the evidence obtained by warrantless use of the GPS device violated the Fourth Amendment. The Court held that the Government's installation of a GPS device on a target's vehicle, and its use of that device to monitor the vehicle's movements, constituted a search under the Fourth Amendment. Accordingly, the judgment of the Court of Appeals was affirmed. View "United States v. Jones" on Justia Law

This case concerned the Sex Offender Registration and Notification Act (Act), 18 U.S.C. 2250(a), which required convicted sex offenders to provide state governments with, and to update, information for state and federal sex offender registries. Petitioner, a pre-Act offender, registered in Missouri in 2005 but moved to Pennsylvania in September 2007 without updating the Missouri registration or registering in Pennsylvania. The question before the Court was the date on which the federal registration requirement took effect with respect to sex offenders convicted before the Act became law. The Court held that the Act did not require pre-Act offenders to register before the Attorney General validly specified that the Act's registration provisions applied to them. Accordingly, the Court reversed a Court of Appeals determination that, in effect, held the contrary. View "Reynolds v. United States" on Justia Law

Petitioner, a trade association representing meatpackers and processors, sued to enjoin enforcement of a California law against swine slaughterhouses, arguing that the Federal Meat Inspection Act (FMIA), 21 U.S.C. 601, et seq., preempted application of the law. The California law dictated what slaughterhouses must do with pigs that could not walk, known in the trade as nonambulatory pigs. The Court concluded that the FMIA regulated slaughterhouses' handling and treatment of nonambulatory pigs from the moment of their delivery through the end of the meat production process. California's law endeavored to regulate the same thing, at the same time, in the same place - except by imposing different requirements. The FMIA expressly preempted such a state law. Accordingly, the Court reversed the judgment of the Ninth Circuit and remanded for further proceedings. View "National Meat Assn. v. Harris" on Justia Law

Petitioner was found guilty of murder and sentenced to death in Alabama state court. Petitioner sought postconviction relief in state court under Alabama Rule 32, alleging, among other things, that his trial attorneys failed to afford him the effective assistance guaranteed by the Sixth Amendment. At issue was whether the extraordinary facts of petitioner's case were "cause" to excuse petitioner's procedural default in state court, i.e., petitioner's failure to timely appeal the Alabama trial court's order denying him postconviction relief. The court held that petitioner had shown the requisite "cause" to excuse his procedural default where he was abandoned by counsel and left unrepresented at a critical time for his state postconviction petition, and he lacked a clue of any need to protect himself pro se. View "Maples v. Thomas" on Justia Law

The 2010 census showed an enormous increase in Texas' population which required the State to redraw its electoral districts for the United States Congress, the State Senate, and the State House of Representatives, in order to comply with the Constitution's one-person, one-vote rule. The State also had to create new districts for the four additional congressional seats it received. Plaintiffs subsequently brought suit in Texas, claiming that the State's newly enacted electoral plans violated the United States Constitution and section 2 of the Voting Rights Act, 42 U.S.C. 1973. The Court held that because it was unclear whether the District Court for the Western District of Texas followed the appropriate standards in drawing interim maps for the 2012 Texas elections, the orders implementing those maps were vacated, and the cases were remanded for further proceedings. View "Perry v. Perez" on Justia Law

Petitioners are orchestra conductors, musicians, publishers, and others who formerly enjoyed free access to literary and artistic works section 514 of the Uruguay Round Agreements Act (URAA), 17 U.S.C. 104A, 109(a), removed from the public domain. Petitioners maintained that Congress, in passing section 514, exceeded its authority under the Constitution's Copyright and Patent Clause and violated the First Amendment rights of anyone who previously had access to such works. The Tenth Circuit ruled that section 514 was narrowly tailored to fit the important government aim of protecting U.S. copyright holders' interests abroad. In accord with the judgment of the Tenth Circuit, the Court concluded that section 514 did not transgress constitutional limitations on Congress' authority. The Court held that neither the text of the Copyright and Patent Clause, historical practice, or the Court's precedent excluded application of copyright protection to works in the public domain. The Court also held that nothing in the historical record, subsequent congressional practice, or the Court's jurisprudence warranted exceptional First Amendment solicitude for copyrighted works that were once in the public domain. View "Golan v. Holder" on Justia Law

Petitioner filed a damages action in Federal District Court, alleging that respondent, seeking to collect a debt, violated the Telephone Consumer Protection Act of 1991 (TCPA), 47 U.S.C. 227, by repeatedly using an automatic telephone dialing system or prerecorded or artificial voice to call petitioner's cellular phone without his consent. At issue was whether Congress' provision for private actions to enforce the TCPA rendered state courts the exclusive arbiters of such actions. The Court found no convincing reason to read into the TCPA's permissive grant of jurisdiction to state courts any barrier to the U.S. district courts' exercise of the general federal-question jurisdiction they have possessed since 1875. Therefore, the Court held that federal and state courts have concurrent jurisdiction over private suits arising under the TCPA. View "Mims v. Arrow Financial Services, LLC" on Justia Law

This case concerned the BIA's policy for deciding when resident aliens could apply to the Attorney General for relief from deportation under a now-repealed provision of the immigration law. The Court held that the BIA's policy for applying section 212(c) of the Immigration and Nationality Act, 8 U.S.C. 1182(c), in deportation cases was arbitrary and capricious under the Administrative Procedure Act, 5 U.S.C. 706(2)(A). The Court concluded that the BIA's comparable-grounds rule was unmoored from the purposes and concerns of the immigration laws. It allowed an irrelevant comparison between statutory provisions to govern a matter of the utmost importance -whether lawful resident aliens with longstanding ties to this country could stay here. And contrary to the Government's protestations, it was not supported by text or practice or cost considerations. Therefore, the BIA's approach could not pass muster under ordinary principles of administrative law. View "Judulang v. Holder" on Justia Law