Justia U.S. Supreme Court Opinion Summaries

Petitioners pleaded guilty to drug conspiracy charges. The district court calculated their advisory Guidelines ranges, which fell below the mandatory minimums under 21 U.S.C. 841(b)(1), and concluded that the mandatory minimums superseded the Guidelines ranges. The court departed downward under 18 U.S.C. 3553(e) to reflect substantial assistance to the government in prosecuting other drug offenders. In determining the final sentences, the court considered the Guidelines “substantial assistance factors” but did not consider the original Guidelines ranges. The Sentencing Commission subsequently amended the Guidelines and reduced the base offense levels for certain drug offenses, including those for which petitioners were convicted. A unanimous Supreme Court affirmed the denial of petitioners’ motions for sentence reductions under section 3582(c)(2), which makes defendants eligible if they were sentenced “based on a sentencing range” that was later lowered. Petitioners’ sentences were not “based on” their lowered Guidelines ranges but were “based on” their mandatory minimums and on their substantial assistance to the government. For a sentence to be “based on” a lowered Guidelines range, the range must have at least played “a relevant part [in] the framework the [sentencing] judge used” in imposing the sentence. Just because courts routinely calculate Guidelines ranges does not mean that any sentence subsequently imposed must be regarded as “based on” a Guidelines range. In this case, the district court properly discarded their Guidelines ranges and permissibly considered only factors related to substantial assistance when departing downward. Identically situated defendants sentenced today may receive the same sentences petitioners received. View "Koons v. United States" on Justia Law

Hughes, indicted on drug and gun charges, negotiated a Type-C plea agreement, which stipulated that Hughes would receive a sentence of 180 months but did not refer to a particular Guidelines range. The district court sentenced him to 180 months, calculating Hughes’ Guidelines range as 188-235 months and finding that the sentence was in accordance with the Guidelines and other factors it was required to consider. Weeks later, the Sentencing Commission adopted and made retroactive an amendment that had the effect of reducing Hughes’ sentencing range to 151-188 months. The Eleventh Circuit affirmed the denial of Hughes’ motion for a reduced sentence under 18 U.S.C. 3582(c)(2). The Supreme Court reversed, resolving a split among the circuits. A sentence imposed pursuant to a Type-C agreement is “based on” a Guidelines range if that range was part of the framework the district court relied on to impose the sentence or accept the agreement. A district court imposes a sentence that is “based on” a Guidelines range for purposes of section 3582(c)(2) if the range was a basis for the court’s exercise of discretion. District courts are required to calculate and consider a defendant’s Guidelines range in every case. The Guidelines prohibit district courts from accepting Type-C agreements without first evaluating the recommended sentence in light of the defendant’s Guidelines range. View "Hughes v. United States" on Justia Law

Phillips, the owner of a Colorado bakery, told a same-sex couple that he would not create a cake for their wedding because of his religious opposition to same-sex marriages (which Colorado did not then recognize) but that he would sell them other baked goods. The couple filed a charge under the Colorado Anti-Discrimination Act, which prohibits discrimination based on sexual orientation in a “place of business engaged in any sales to the public.” An ALJ ruled in the couple’s favor. The Colorado Court of Appeals affirmed. The Supreme Court reversed. While Colorado law can protect gay persons in acquiring products and services on the same terms as are offered to other members of the public, the law must be applied in a manner that is neutral toward religion. “To Phillips, his claim that using his artistic skills to make an expressive statement, a wedding endorsement in his own voice and of his own creation, has a significant First Amendment speech component and implicates his deep and sincere religious beliefs.” Before Colorado recognized the validity of gay marriages and before the Supreme Court addressed that issue, Phillips was not unreasonable in thinking his decision lawful. State law afforded storekeepers some latitude to decline to create specific messages they considered offensive. Phillips was entitled to a neutral and respectful consideration of his claims but the Colorado Civil Rights Commission, acting inconsistently with its consideration of similar cases, showed impermissible hostility toward his sincere religious beliefs. A commissioner compared his religious beliefs to defenses of slavery and the Holocaust, without objection. The government cannot pass judgment upon or presuppose the illegitimacy of religious beliefs and practices. The state’s interest could have been weighed against Phillips’ sincere religious objections in a way consistent with the requisite religious neutrality. View "Masterpiece Cakeshop, Ltd. v. Colorado Civil Rights Commission" on Justia Law

Appling owed about $60,000 to his law firm (Lamar), which threatened to withdraw representation and place a lien on its work product. Appling told Lamar that he could cover owed and future legal expenses with an expected tax refund, so Lamar continued representation. Appling used the refund, which was much less than he had stated, for business expenses, but told Lamar he was still waiting for the refund. Lamar completed pending litigation. Appling never paid. Lamar obtained a judgment. Appling filed for Chapter 7 bankruptcy. Lamar initiated an adversary proceeding, arguing that Appling’s debt was nondischargeable under 11 U.S.C. 523(a)(2). Section 523(a)(2)(A) bars discharge of debts arising from “false pretenses, a false representation, or actual fraud, other than a statement respecting the debtor’s . . . financial condition.” Subparagraph (B) bars discharge of debts arising from a materially false “statement . . . respecting the debtor’s . . . financial condition” if that statement is “in writing.” The Eleventh Circuit found that Appling made a statement “respecting” his “financial condition,” which was not in writing. The Supreme Court affirmed. A statement about a single asset can be a “statement respecting the debtor’s financial condition” under section 523(a)(2). A statement is “respecting” a debtor’s financial condition if it has a direct relation to or impact on the debtor’s overall financial status. A single asset has a direct relation to and impact on aggregate financial condition, so a statement about that asset bears on a debtor’s overall financial condition and can help indicate whether a debtor is solvent or insolvent. View "Lamar, Archer & Cofrin, LLP v. Appling" on Justia Law

Lagos was convicted of using a company he controlled to defraud a lender of millions of dollars. After Lagos’ company went bankrupt, the lender conducted a private investigation and participated as a party in the company’s bankruptcy proceedings, spending nearly $5 million in legal, accounting, and consulting fees. When Lagos pleaded guilty to federal wire fraud charges, the court ordered him to pay the lender restitution for those fees. The Fifth Circuit affirmed, citing the Mandatory Victims Restitution Act of 1996, which requires defendants convicted of certain federal offenses, including wire fraud, to “reimburse the victim for lost income and necessary child care, transportation, and other expenses incurred during participation in the investigation or prosecution of the offense or attendance at proceedings related to the offense,” 18 U.S.C. 3663A(b)(4). The Supreme Court, acting unanimously, reversed. The words “investigation” and “proceedings” are limited to government investigations and criminal proceedings and do not include private investigations and civil or bankruptcy proceedings. A broader reading would require courts to resolve difficult, fact-intensive disputes about whether particular expenses “incurred during” participation in a private investigation were actually “necessary,” and about whether proceedings such as a licensing proceeding or a Consumer Products Safety Commission hearing were sufficiently “related to the offense.” The Court acknowledged that its interpretation means that some victims will not receive restitution for all of their losses, but reasoned that is consistent with the Act’s enumeration of limited categories. View "Lagos v. United States" on Justia Law

While investigating traffic incidents involving an orange and black motorcycle with an extended frame, Officer Rhodes learned that the motorcycle likely was stolen and in Collins’ possession. On Collins’ Facebook profile, Rhodes discovered photographs of an orange and black motorcycle parked in the driveway of a house. From the street, Rhodes could see what appeared to be the motorcycle under a tarp, in the location shown in the photograph. Without a search warrant, Rhodes walked up the driveway, removed the tarp, confirmed that the motorcycle was stolen by running the license plate and vehicle identification numbers, replaced the tarp, and returned to his car to wait. When Collins returned, Rhodes arrested him. The Virginia Supreme Court affirmed the denial of a motion to suppress, citing the Fourth Amendment’s automobile exception. The Supreme Court reversed. The automobile exception does not permit the warrantless entry of a home or its curtilage to search a vehicle therein. Curtilage, the area immediately surrounding and associated with the home, is part of the home for Fourth Amendment purposes. When an officer physically intrudes on the curtilage to gather evidence, a Fourth Amendment search has occurred and is presumptively unreasonable absent a warrant. The part of the driveway where the motorcycle was parked is curtilage. The scope of the automobile exception extends no further than the automobile itself; its proposed expansion would undervalue the core Fourth Amendment protection afforded to the home and its curtilage and untether the exception from its justifications. View "Collins v. Virginia" on Justia Law

The Upper Skagit Indian Tribe purchased land and commissioned a boundary survey, which convinced the Tribe that about an acre of its land lay on the other side of a boundary fence between its land and land owned by the Lundgrens. The Lundgrens filed a quiet title action in Washington state court, arguing adverse possession and mutual acquiescence. The Washington Supreme Court rejected the Tribe’s sovereign immunity claim, reasoning that tribal sovereign immunity does not apply to in rem suits. The U.S. Supreme Court vacated and remanded. The precedent on which the state court relied (Yakima) addressed not the scope of tribal sovereign immunity, but a question of statutory interpretation of the Indian General Allotment Act of 1887. The Act authorized the President to allot parcels of reservation land to individual tribal members and directed the government to issue fee patents to the allottees. In 1934, Congress reversed course but did not withdraw the lands already conveyed so that Indian reservations sometimes contain both trust land held by the government and fee-patented land held by private parties. The Supreme Court held that the state collection of property taxes on fee-patented land within reservations was allowed under the Act; Yakima resolved nothing about the law of sovereign immunity. View "Upper Skagit Tribe v. Lundgren" on Justia Law

Despite employment contracts providing for individualized arbitration to resolve employment disputes, employees sought to litigate Fair Labor Standards Act claims through collective actions. The Federal Arbitration Act generally requires courts to enforce arbitration agreements, but the employees argued that its “saving clause” removes that obligation if an arbitration agreement violates some other federal law and that the agreements violated the National Labor Relations Act (NLRA). The National Labor Relations Board ruled that the NLRA effectively nullifies the Arbitration Act in such cases. The Supreme Court disagreed. The Arbitration Act requires courts to enforce the arbitration terms the parties select, 9 U.S.C. 2-4. The saving clause allows courts to refuse to enforce arbitration agreements only on grounds that exist for the revocation of any contract, such as fraud, duress, or unconscionability. The NLRA, which guarantees employees “the right to self-organization, to form, join, or assist labor organizations, to bargain collectively . . . , and to engage in other concerted activities for the purpose of collective bargaining or other mutual aid or protection,” 29 U.S.C. 157, does not mention class or collective actions nor indicate a clear and manifest wish to displace the Arbitration Act. The catchall term “other concerted activities” should be understood to protect the things employees do in exercising their right to free association in the workplace. The Board’s interpretation of the Arbitration Act, which it does not administer, is not entitled to Chevron deference. View "Epic Systems Corp. v. Lewis" on Justia Law

A judge normally may issue a wiretap order permitting the interception of communications only “within the territorial jurisdiction of the court in which the judge is sitting,” 18 U.S.C. 2518(3). A District of Kansas judge authorized nine wiretap orders during the investigation of a suspected drug distribution ring. The government primarily intercepted communications from a Kansas listening post but each order contained a sentence purporting to authorize interception outside of Kansas and the government intercepted additional communications from a listening post in Missouri. Defendants moved to suppress the evidence. The government agreed not to introduce any evidence arising from its Missouri listening post. The court denied the motion. The Tenth Circuit and Supreme Court affirmed. Because the orders were not lacking any information that the statute required them to include and would have been sufficient absent the challenged language authorizing interception outside the court’s territorial jurisdiction, the orders were not "facially insufficient" under 2518(10)(a)(ii). While that subparagraph covers at least an order’s failure to include information required by 2518(4)(a)–(e), not every defect that may appear in an order results in an insufficiency. The sentence authorizing interception outside Kansas is surplus; absent the challenged language, every wiretap that produced evidence introduced at trial was properly authorized. The orders set forth the authorizing judge’s territorial jurisdiction and the statute presumptively limits every order’s scope to the issuing court’s territorial jurisdiction. View "Dahda v. United States" on Justia Law

The Southern District of California adopted a districtwide policy permitting the use of full restraints—handcuffs connected to a waist chain, with legs shackled—on most in-custody defendants produced in court for non-jury proceedings by the U.S. Marshals Service. Before the Ninth Circuit could issue a decision on a challenge to the policy, the underlying criminal cases ended. That court—viewing the case as a “functional class action” seeking “class-like relief,” held that the case was not moot and the policy was unconstitutional. A unanimous Supreme Court vacated, finding the case moot. The federal judiciary may adjudicate only “actual and concrete disputes, the resolutions of which have direct consequences on the parties involved.”. Such a dispute “must be extant at all stages of review, not merely at the time the complaint is filed.” Precedent does not support a freestanding exception to mootness outside the Rule 23 class action context. The Federal Rules of Criminal Procedure establish for criminal cases no vehicle comparable to the civil class action, and the Supreme Court has never permitted criminal defendants to band together to seek prospective relief in their individual cases on behalf of a class. The “exception to the mootness doctrine for a controversy that is capable of repetition, yet evading review” does not apply, based only the possibility that some of the parties again will be prosecuted for violating valid criminal laws. View "United States v. Sanchez-Gomez" on Justia Law