Justia U.S. Supreme Court Opinion Summaries

Idaho enacted a law that prohibits abortions with a narrow exception to prevent the death of the woman. The federal government sued Idaho, arguing that the state could not enforce its abortion ban in certain situations governed by the federal Emergency Medical Treatment and Labor Act. Under EMTALA, a hospital that receives Medicare funding must provide necessary stabilizing treatment in its emergency room to a patient in an emergency medical condition. The federal government argued that this provision prevented Idaho from prohibiting abortions in hospitals when necessary to prevent serious harm to a woman's health, an exception not explicitly included in its abortion law.The district court granted a preliminary injunction against the enforcement of the Idaho abortion law in these circumstances. The Ninth Circuit Court of Appeals declined to stay the injunction. Idaho appealed to the U.S. Supreme Court.Initially, the Supreme Court stayed the injunction and granted Idaho's petition for certiorari before judgment. However, in a one-sentence per curiam opinion, it dismissed the writs of certiorari before judgment and vacated the stay that it had entered in January. This left the original district court preliminary injunction in place. View "Moyle v. United States" on Justia Law

The case involves two states and five individual social media users who sued several federal officials and agencies, alleging that the government pressured social media platforms to censor their speech in violation of the First Amendment. The plaintiffs' speech was related to COVID-19 and the 2020 election. The District Court issued a preliminary injunction, which was affirmed in part and reversed in part by the Fifth Circuit. The Fifth Circuit held that both the state and individual plaintiffs had standing to seek injunctive relief and that the government entities and officials, by coercing or significantly encouraging the platforms’ moderation decisions, transformed those decisions into state action.The Supreme Court of the United States reversed the Fifth Circuit's decision, holding that neither the individual nor the state plaintiffs have established Article III standing to seek an injunction against any defendant. The Court found that the plaintiffs' theories of standing depended on the platforms’ actions, yet the plaintiffs did not seek to enjoin the platforms from restricting any posts or accounts. Instead, they sought to enjoin the Government agencies and officials from pressuring or encouraging the platforms to suppress protected speech in the future. The Court concluded that the plaintiffs must show a substantial risk that, in the near future, at least one platform will restrict the speech of at least one plaintiff in response to the actions of at least one Government defendant. The Court found that the plaintiffs failed to meet this burden. View "Murthy v. Missouri" on Justia Law

The case involves James Snyder, the former mayor of Portage, Indiana, who was convicted of accepting an illegal gratuity in violation of 18 U.S.C. §666(a)(1)(B). In 2013, while Snyder was mayor, Portage awarded two contracts to a local truck company, Great Lakes Peterbilt, and purchased five trash trucks from the company for about $1.1 million. In 2014, Peterbilt paid Snyder $13,000. The FBI and federal prosecutors suspected that the payment was a gratuity for the City’s trash truck contracts, but Snyder claimed that the payment was for his consulting services as a contractor for Peterbilt. A federal jury convicted Snyder, and the District Court sentenced him to 1 year and 9 months in prison. On appeal, Snyder argued that §666 criminalizes only bribes, not gratuities. The Seventh Circuit affirmed Snyder’s conviction.The Supreme Court of the United States reversed the Seventh Circuit's decision. The Court held that 18 U.S.C. §666 proscribes bribes to state and local officials but does not make it a crime for those officials to accept gratuities for their past acts. The Court reasoned that the statutory text, history, structure, punishments, federalism principles, and fair notice considerations all support the conclusion that §666 is a bribery statute and not a gratuities statute. The Court concluded that a state or local official does not violate §666 if the official has taken the official act before any reward is agreed to, much less given. Although a gratuity offered and accepted after the official act may be unethical or illegal under other federal, state, or local laws, the gratuity does not violate §666. The case was remanded for further proceedings consistent with the Court's opinion. View "Snyder v. United States" on Justia Law

The case involves a dispute over the allocation of water from the Rio Grande River among the states of Texas, New Mexico, and Colorado. The Rio Grande Compact, an interstate agreement, governs the equitable distribution of the river's waters among these states. In 2013, Texas sued New Mexico and Colorado, alleging that excessive groundwater pumping in New Mexico was depleting the river's water supply intended for Texas, in violation of the Compact. The United States sought to intervene, asserting its own interests in the Compact's enforcement due to its operation of the Rio Grande Project, an irrigation system in southern New Mexico.In previous proceedings, the Supreme Court allowed the United States to intervene, recognizing its distinct federal interests in the Compact. The Court noted that the Compact was intertwined with the United States' operation of the Rio Grande Project and that the federal government had an interest in ensuring New Mexico complied with its obligations under the Compact.Texas and New Mexico proposed a consent decree to resolve the case, which would establish a methodology for determining each state's allocation of the river's waters. However, the United States opposed the proposed consent decree, arguing that it would dispose of its claims that New Mexico's groundwater pumping was violating the Compact.The Supreme Court of the United States agreed with the United States, holding that parties who choose to resolve litigation through settlement may not dispose of the claims of a third party without that party's agreement. The Court found that the United States still had the same claims it did in 2018, backed by the same unique federal interests. The Court concluded that the proposed consent decree would settle all parties' Compact claims and, in the process, cut off the United States' requested relief as to New Mexican groundwater pumping. As such, the Court denied the motion to enter the consent decree. View "Texas v. New Mexico" on Justia Law

In December 2019, Zackey Rahimi, the respondent, had a violent altercation with his girlfriend, C. M., who is also the mother of his child. Rahimi grabbed C. M., dragged her back to his car, and shoved her in, causing her to hit her head. When a bystander witnessed the incident, Rahimi retrieved a gun from his car. C. M. managed to escape, and Rahimi fired his gun, though it is unclear whether he was aiming at C. M. or the witness. Following this incident, C. M. sought a restraining order against Rahimi, which was granted by a state court in Texas. The order included a finding that Rahimi had committed “family violence” and posed “a credible threat” to the “physical safety” of C. M. or their child. The order also suspended Rahimi’s gun license for two years. Despite the order, Rahimi violated it by approaching C. M.’s home and contacting her through social media. He was later charged with aggravated assault with a deadly weapon for threatening another woman with a gun.Rahimi was indicted for possessing a firearm while subject to a domestic violence restraining order, in violation of 18 U. S. C. §922(g)(8). Rahimi moved to dismiss the indictment, arguing that Section 922(g)(8) violated his Second Amendment right to keep and bear arms. The District Court denied his motion, and Rahimi pleaded guilty. On appeal, he again raised his Second Amendment challenge, which was denied. Rahimi petitioned for rehearing en banc.The Supreme Court of the United States held that when a restraining order contains a finding that an individual poses a credible threat to the physical safety of an intimate partner, that individual may—consistent with the Second Amendment—be banned from possessing firearms while the order is in effect. The Court found that since the founding, the nation's firearm laws have included provisions preventing individuals who threaten physical harm to others from misusing firearms. As applied to the facts of this case, Section 922(g)(8) fits comfortably within this tradition. The Court reversed the judgment of the Court of Appeals for the Fifth Circuit and remanded the case for further proceedings consistent with its opinion. View "United States v. Rahimi" on Justia Law

Paul Erlinger pleaded guilty to being a felon in possession of a firearm, a violation of 18 U.S.C. §922(g). At sentencing, the judge found Erlinger eligible for an enhanced sentence under the Armed Career Criminal Act (ACCA), which increases the penalty for a §922(g) conviction from a maximum of 10 years to a mandatory minimum of 15 years when the defendant has three or more qualifying convictions for offenses committed on different occasions. The Seventh Circuit later ruled that two of the offenses used for Erlinger’s sentence enhancement no longer qualified as ACCA predicate offenses. The District Court vacated Erlinger’s sentence and scheduled resentencing. At the resentencing hearing, prosecutors pursued an ACCA sentence enhancement based on a new set of 26-year-old convictions for burglaries committed by Erlinger over several days. Erlinger argued that the burglaries were part of a single criminal episode and did not occur on separate occasions, as required by ACCA. He also argued that the Fifth and Sixth Amendments required that a jury make that assessment. The District Court rejected Erlinger’s request for a jury and issued a 15-year enhanced sentence. On appeal, the government confessed error, admitting that the Constitution requires a jury to decide unanimously and beyond a reasonable doubt whether Erlinger’s prior offenses were committed on different occasions.The Supreme Court of the United States held that the Fifth and Sixth Amendments require a unanimous jury to make the determination beyond a reasonable doubt that a defendant’s past offenses were committed on separate occasions for ACCA purposes. The Court noted that the Sixth Amendment promises that in all criminal prosecutions, the accused has the right to a speedy and public trial, by an impartial jury. The Fifth Amendment further promises that the government may not deprive individuals of their liberty without due process of law. The Court has repeatedly cautioned that trial and sentencing practices must remain within the guardrails provided by these two Amendments. The Court vacated the judgment of the Court of Appeals for the Seventh Circuit and remanded the case for further proceedings consistent with its opinion. View "Erlinger v. United States" on Justia Law

The case involves Sandra Muñoz, an American citizen, and her husband Luis Asencio-Cordero, a citizen of El Salvador. The couple sought to obtain an immigrant visa for Asencio-Cordero to live in the United States. After several interviews, a consular officer denied Asencio-Cordero's application, citing a provision that renders inadmissible a noncitizen whom the officer believes seeks to engage in unlawful activity. Asencio-Cordero and Muñoz sued the Department of State, claiming that it had abridged Muñoz’s constitutional liberty interest in her husband’s visa application by failing to give a sufficient reason why Asencio-Cordero is inadmissible under the “unlawful activity” bar.The District Court granted summary judgment to the State Department, but the Ninth Circuit vacated the judgment, holding that Muñoz had a constitutionally protected liberty interest in her husband’s visa application and that the State Department was required to give Muñoz a reason for denying her husband’s visa. The court further held that by declining to give Muñoz more information earlier in the process, the State Department had forfeited its entitlement to insulate its decision from judicial review under the doctrine of consular nonreviewability.The Supreme Court of the United States reversed the Ninth Circuit's decision, holding that a citizen does not have a fundamental liberty interest in her noncitizen spouse being admitted to the country. The Court noted that while Congress has extended special treatment to marriage in immigration matters, it has never made spousal immigration a matter of right. The Court also noted that the assertion of a procedural due process right in someone else's legal proceeding would have unsettling collateral consequences. The case was remanded for further proceedings consistent with the Court's opinion. View "Department of State v. Munoz" on Justia Law

The case involves the Sixth Amendment's Confrontation Clause, which guarantees a criminal defendant the right to confront the witnesses against him. The defendant, Jason Smith, was charged with various drug offenses after law enforcement officers found him with a large quantity of what appeared to be drugs and drug-related items. The seized items were sent to a crime lab for scientific analysis. Analyst Elizabeth Rast ran forensic tests on the items and concluded that they contained usable quantities of methamphetamine, marijuana, and cannabis. Rast prepared a set of typed notes and a signed report about the testing. However, Rast stopped working at the lab prior to trial, so the State substituted another analyst, Greggory Longoni, to provide an independent opinion on the drug testing performed by Rast. At trial, Longoni conveyed to the jury what Rast’s records revealed about her testing, before offering his “independent opinion” of each item’s identity. Smith was convicted. On appeal, he argued that the State’s use of a substitute expert to convey the substance of Rast’s materials violated his Confrontation Clause rights. The Arizona Court of Appeals rejected Smith’s challenge.The Supreme Court of the United States held that when an expert conveys an absent analyst’s statements in support of the expert’s opinion, and the statements provide that support only if true, then the statements come into evidence for their truth. The Court vacated the judgment of the Arizona Court of Appeals and remanded the case for further proceedings. The Court clarified that the Confrontation Clause still allows forensic experts to play a useful role in criminal trials. However, a state may not introduce the testimonial out-of-court statements of a forensic analyst at trial, unless she is unavailable and the defendant has had a prior chance to cross-examine her. The Court concluded that the State used Longoni to relay what Rast wrote down about how she identified the seized substances, and thus Longoni effectively became Rast’s mouthpiece. If the out-of-court statements were also testimonial, their admission violated the Confrontation Clause. View "Smith v. Arizona" on Justia Law

This case involves a dispute between Jascha Chiaverini, a jewelry store owner, and police officers from Napoleon, Ohio. The officers charged Chiaverini with three crimes: receiving stolen property, dealing in precious metals without a license, both misdemeanors, and money laundering, a felony. After obtaining a warrant, the police arrested Chiaverini and detained him for three days. However, county prosecutors later dropped the case. Chiaverini, believing that his arrest and detention were unjustified, sued the officers, alleging a Fourth Amendment malicious-prosecution claim under 42 U.S.C. §1983. To win this claim, he had to show that the officers brought criminal charges against him without probable cause, leading to an unreasonable seizure of his person.The District Court granted summary judgment to the officers, and the Court of Appeals for the Sixth Circuit affirmed. The Court of Appeals held that Chiaverini’s prosecution was supported by probable cause. In its decision, the court did not address whether the officers had probable cause to bring the money-laundering charge. The court believed that there was clearly probable cause to charge Chiaverini with the two misdemeanors. As long as one charge was supported by probable cause, it thought, a malicious-prosecution claim based on any other charge must fail.The Supreme Court of the United States held that the presence of probable cause for one charge in a criminal proceeding does not categorically defeat a Fourth Amendment malicious-prosecution claim relating to another, baseless charge. The parties, and the United States as amicus curiae, all agreed with this conclusion, which follows from both the Fourth Amendment and traditional common-law practice. The Supreme Court vacated the judgment of the Court of Appeals and remanded the case for further proceedings consistent with its opinion. View "Chiaverini v. City of Napoleon" on Justia Law

Delilah Diaz was stopped at a U.S.-Mexico border port of entry, where border patrol officers discovered over 54 pounds of methamphetamine hidden in the car she was driving. Diaz was charged with importing methamphetamine, a charge that required the government to prove that Diaz knowingly transported the drugs. Diaz claimed she was unaware of the drugs in the car. To counter this claim, the government planned to call an expert witness, Homeland Security Investigations Special Agent Andrew Flood, to testify that drug traffickers generally do not entrust large quantities of drugs to people who are unaware they are transporting them. Diaz objected to this testimony under Federal Rule of Evidence 704(b), which prohibits an expert witness from stating an opinion about whether the defendant did or did not have a mental state or condition that constitutes an element of the crime charged or of a defense. The court ruled that Agent Flood could testify that most couriers know they are transporting drugs. Diaz was found guilty and appealed, challenging Agent Flood’s testimony under Rule 704(b).The Court of Appeals held that because Agent Flood did not explicitly opine that Diaz knowingly transported methamphetamine, his testimony did not violate Rule 704(b). Diaz appealed this decision to the Supreme Court of the United States.The Supreme Court affirmed the decision of the Court of Appeals. The Court held that expert testimony that "most people" in a group have a particular mental state is not an opinion about "the defendant" and thus does not violate Rule 704(b). The Court reasoned that Agent Flood did not express an opinion about whether Diaz herself knowingly transported methamphetamine. Instead, he testified about the knowledge of most drug couriers, which does not necessarily describe Diaz’s mental state. The Court concluded that because Agent Flood did not express an opinion about whether Diaz herself knowingly transported methamphetamine, his testimony did not violate Rule 704(b). View "Diaz v. United States" on Justia Law