Justia U.S. Supreme Court Opinion Summaries

In this case, a Federal District Court enjoined a state court from considering a plaintiff's request to approve a class action. The District Court did so because it had earlier denied a motion to certify a class in a related case, brought by a different plaintiff against the same defendant alleging similar claims. The federal court thought its injunction appropriate to prevent relitigation of the issue it had decided. The Court held to the contrary and found that, in issuing the order to a state court, the federal court exceeded its authority under the "relitigation exception" of the Anti-Injunction Act ("Act"), 28 U.S.C. 2283, where the statutory provision permitted a federal court to enjoin a state proceeding only in rare cases, when necessary to "protect or effectuate [the federal court's] judgments." The Court held that the standard was not met in this case for two reasons. First, the issue presented in the state court was not identical to the one decided in the federal tribunal. Second, the plaintiff in the state court did not have the requisite connection to federal suit to be bound by the District Court's judgment. View "Smith v. Bayer Corp." on Justia Law

Petitioner was indicted for violating 18 U.S.C. 229, which forbid knowing possession or use, for nonpeaceful purposes, of a chemical that "can cause death, temporary incapacitation or permanent harm to humans," and which was part of a federal act implementing a chemical weapons treaty ratified by the United States. At issue was whether a person indicted for violating a federal statute had standing to challenge its validity on grounds that, by enacting it, Congress exceeded its powers under the Constitution, thus intruding upon the sovereignty and authority of the States. The Court held that petitioner had standing to challenge the federal statute where there was no basis in precedent or principle to deny petitioner's standing to raise her claims. The ultimate issue of the statute's validity turned in part on whether the law could be deemed "necessary and proper for carrying into Execution" the President's Article II, section 2 Treaty Power. Accordingly, the Court expressed no view on the merits of the argument and noted that it could be addressed by the Court of Appeals on remand. Therefore, the judgment of the Court of Appeals was reversed and the case remanded for further proceedings. View "Bond v. United States" on Justia Law

While conducting a routine vehicle stop, police arrested petitioner, a passenger of the vehicle, for giving a false name. After handcuffing him and securing the scene, the police searched the vehicle and found petitioner's revolver. Petitioner was subsequently indicted on charges of being a felon in possession of a firearm. In a suppression motion, petitioner acknowledged that the search of the vehicle complied with existing Eleventh Circuit precedent interpreting New York v. Belton, but he raised a Fourth Amendment challenge to preserve the issue on appeal. The District Court denied the motion and petitioner was convicted. While his appeal was pending, the Court announced, in Arizona v. Gant, a new rule governing automobile searches incident to arrests of recent occupants. At issue was whether to apply the exclusionary rule when the police conducted a search in compliance with binding precedent that was later overruled. Because the suppression would do nothing to deter police misconduct in these circumstances, and because it would come at a high cost to both the truth and the public safety, the Court held that the searches conducted in objectionable reliance on binding appellate precedent were not subject to the exclusionary rule. Accordingly, the Court affirmed the suppression of the revolver and petitioner's conviction. View "Davis v. United States" on Justia Law

J.D.B., a thirteen-year-old seventh-grade student, was taken from his classroom to a closed-door conference room where uniformed police and school administrators questioned him for at least 30 minutes regarding two home break-ins nearby. Before beginning, they did not give J.D.B. Miranda warnings, the opportunity to call his legal guardian, or tell him he was free to leave the room. After J.D.B. subsequently confessed to the break-ins and wrote a statement at the request of police, two juvenile petitions were filed against him. J.D.B.'s public defender moved to suppress his statements and the evidence derived therefrom, arguing that he had been interrogated in a custodial setting without being afforded Miranda warnings and that his statements were involuntary. At issue was whether the age of a child subjected to police questioning was relevant to the custody analysis of Miranda v. Arizona. The Court held that it was beyond dispute that children would often feel bound to submit to police questioning when an adult in the same circumstances would feel free to leave. Seeing no reason for police officers or courts to blind themselves to that commonsense reality, the Court held that a child's age group properly informed the Miranda custody analysis. Accordingly, the Court reversed and remanded to the state courts to address whether J.D.B. was in custody when he was interrogated, taking account of all of the relevant circumstances of the interrogation, including his age at the time. View "J. D. B. v. North Carolina" on Justia Law

Petitioner was convicted of, inter alia, smuggling unauthorized aliens into the United States. The District Court imposed a 51 month prison sentence, reasoning that petitioner should serve that long in order to qualify for and complete the Bureau of Prisons' Residential Drug Abuse Program ("RDAP"). At issue was whether the Sentencing Reform Act ("SRA"), 18 U.S.C. 3582(a), precluded federal courts from imposing or lengthening a prison term in order to promote a criminal defendant's rehabilitation. The Court held that the text, context, and history of section 3582(a) precluded sentencing courts from imposing or lengthening a prison term to promote an offender's rehabilitation. The Court also held that Amicus' attempts to recast what the SRA said about rehabilitation were unavailing. The court further held that the record indicated that the District Court may have increased the length of petitioner's sentence to ensure her completion of RDAP, something a court could not do. Accordingly, the Court reversed and remanded for further proceedings and held that the Ninth Circuit was left to consider on remand the effect of petitioner's failure to object to the sentence when imposed. View "Tapia v. United States" on Justia Law

Petitioner administered and enforced Nevada's Ethics in Government Law, Nev. Rev. Stat. 281A.420, and investigated respondent, an elected official who voted to approve a hotel/casino project proposed by a company that used respondent's long-time friend and campaign manager as a paid consultant. Petitioner concluded that respondent had a disqualifying conflict of interest under section 281A.420(8)(e)'s catch-all provision and censured him for failing to abstain from voting on the project. At issue was whether legislators have a personal, First Amendment right to vote on any given matter. The Court held that the Nevada Ethics in Government Law was not unconstitutionally overbroad where the law prohibited a legislator who had a conflict both from voting on a proposal and from advocating its passage or failure; where a universal and long-established tradition of prohibiting certain conduct created a strong presumption that the prohibition was constitutional; and where restrictions on legislators' voting were not restrictions on legislators' protected speech because the legislator's vote was the commitment of his apportioned share of the legislature's power to the passage or defeat of a particular proposal and the legislative power thus committed was not personal to the legislator but belonged to the people. The Court also concluded that additional arguments raised in respondent's brief were not decided or raised in his brief in opposition and were thus considered waived. Accordingly, the Court reversed the judgment of the Nevada Supreme Court and remanded the case for further proceedings. View "Nevada Commission on Ethics v. Carrigan" on Justia Law

Respondent, First Derivative Traders, representing a class of stockholders in petitioner Janus Capital Group, Inc. ("JCG"), filed a private action under the Securities and Exchange Commission ("SEC") Rule 10b-5, alleging that JCG and its wholly owned subsidiary, petitioner Janus Capital Management LLC ("JCM"), made false statements in mutual funds prospectuses filed by Janus Investment Fund, for which JCM was the investment adviser and administrator, and that those statements affected the price of JCG's stock. Although JCG created Janus Investment Fund, it was a separate legal entity owned entirely by mutual fund investors. At issue was whether JCM, a mutual fund investment adviser, could be held liable in a private action under Rule 10b-5 for false statements included in its client mutual funds' prospectuses. The Court held that, because the false statements included in the prospectuses were made by Janus Investment Fund, not by JCM, JCM and JCG could not be held liable in a private action under Rule 10b-5. The Court found that, although JCM could have been significantly involved in preparing the prospectuses, it did not itself "make" the statements at issue for Rule 10b-5 purposes where its assistance in crafting what was said was subject to Janus Investment Fund's ultimate control. Accordingly, respondent had not stated a claim against JCM under Rule 10b-5 and the judgment of the Fourth Circuit was reversed. View "Janus Capital Group, Inc. v. First Derivative Traders" on Justia Law

The Jicarilla Apache Nation's ("Tribe") reservation contained natural resources that were developed pursuant to statutes administered by the Interior Department and proceeds from these resources were held by the United States in trust for the Tribe. The Tribe filed a breach-of-trust action in the Court of Federal Claims ("CFC") seeking monetary damages for the Government's alleged mismanagement of the Tribe's trust funds in violation of 25 U.S.C. 161-162a and other laws. During discovery, the Tribe moved to compel production of certain documents and the Government agreed to the release of some documents but asserted that others were protected by, inter alia, the attorney-client privilege. At issue was whether the fiduciary exception to the attorney-client privilege applied to the general trust relationship between the United States and Indian tribes. The Court held that the fiduciary exception did not apply where the trust obligations of the United States to the Indian tribes were established and governed by statute rather than the common law and, in fulfilling its statutory duties, the Government acted not as a private trustee but pursuant to its sovereign interest in the execution of federal law. The reasons for the fiduciary exception, that the trustee had no independent interest in trust administration, and that the trustee was subject to a general common-law duty of disclosure, did not apply in this context. Accordingly, the Court reversed and remanded for further proceedings. View "United States v. Jicarilla Apache Nation" on Justia Law

Petitioner was convicted for distribution of 50 grams or more of cocaine base under section 841(a)(1) and (b)(1)(A)(iii) of the Anti-Drug Abuse Act of 1986 ("ADAA"), 21 U.S.C. 841(a)(1) and (b)(1)(A)(iii), and sentenced to the 120 months prison term mandated by the statute. At issue was whether the term "cocaine base" as used in the statute referred generally to cocaine in its chemically basic form or exclusively to what was colloquially known as "crack cocaine." The court held that "cocaine base," as used in section 841(b)(1), meant not just "crack cocaine," but cocaine in its chemically basic form where, at the time the statute was enacted, "cocaine" was commonly used to refer to powder cocaine, and the scientific and medical literature often used "cocaine" to refer to all cocaine-related substances, including ones that were not chemically basic; where Congress had good reason to include the term "cocaine" in clause (ii), and the slight inconsistency created by its use of "cocaine base" in clause (iii) was insufficient reason to adopt petitioner's interpretation of the statute; and where petitioner's additional arguments were unpersuasive. Accordingly, the court affirmed the judgment of the First Circuit adhering to its precedent holding that "cocaine base" referred to all forms of cocaine. View "DePierre v. United States" on Justia Law

When petitioner pleaded guilty to being a felon in possession of a firearm, he had prior convictions for at least three felonies, including the state-law crime of "using a vehicle" to "knowingly or intentionally" "flee from a law enforcement officer" after being ordered to stop pursuant to Ind. Code 35-44-3-3(b)(1)(A). The Federal District Court decided that the prior convictions subjected petitioner to the 15-year mandatory minimum prison term that the Armed Career Criminal Act ("ACCT"), 18 U.S.C. 924(e), provided for an armed defendant who had three prior "violent felony" convictions. Rejecting petitioner's argument that his vehicle flight felony was not "violent" under the ACCA, the Seventh Circuit affirmed. The Court held that felony vehicle flight, as proscribed by Indiana law, was a violent felony for purposes of the ACCA where felony vehicle flight presented a serious potential risk of physical injury to another; where, because felony vehicle flight was not a strict-liability, negligence, or recklessness crime and was, as a categorical matter, similar in risk to the crimes listed in the residual clause, it was a violent felony; where Indiana treated subsection 35-44-3-3(b)(1)(A) and 35-44-3-3(b)(1)(B) as felonies of the same magnitude carrying similar prison terms; and where Congress had power to enact the residual clause to impose enhanced punishment for unlawful firearm possession when the relevant prior offenses involved a potential risk of physical injury similar to that presented by several enumerated offenses. Accordingly, the court affirmed the judgment of the Seventh Circuit. View "Sykes v. United States" on Justia Law