Justia U.S. Supreme Court Opinion Summaries

A Nevada jury convicted Rippo of first-degree murder and other offenses and sentenced him to death. During his trial, Rippo received information that the judge was the target of a federal bribery probe, and he surmised that the Clark County District Attorney’s Office, which was prosecuting him, was playing a role in that investigation. Rippo unsuccessfully moved for the judge’s disqualification. After that judge’s indictment on federal charges a different judge denied Rippo’s motion for a new trial. The Nevada Supreme Court affirmed, reasoning that Rippo had not introduced evidence that state authorities were involved in the federal investigation. State courts denied post-conviction relief, reasoning that Rippo was not entitled to discovery or an evidentiary hearing because his allegations “d[id] not support the assertion that the trial judge was actually biased.” The Supreme Court vacated the Nevada Supreme Court’s judgment, stating that due process may sometimes demand recusal even when a judge “ ‘ha[s] no actual bias.’ Recusal is required when, objectively speaking, “the probability of actual bias on the part of the judge or decision-maker is too high to be constitutionally tolerable.” View "Rippo v. Baker" on Justia Law

After the 2010 census, the Virginia Legislature drew new lines for 12 state legislative districts, to ensure that each district would have a black voting-age population of at least 55%. Voters challenged the redistricting under the Equal Protection Clause. As to 11 districts, the district court concluded that the voters had not shown that race was the predominant factor motivating the legislature’s decision, reasoning that race predominates only where there is an “actual conflict between traditional redistricting criteria and race.” As to District 75, the court found that race did predominate, but the use of race was narrowly tailored to a compelling state interest--avoiding violation of the Voting Rights Act. The Supreme Court vacated in part, stating that the proper inquiry concerns the actual considerations that provided the essential basis for the lines drawn, not post hoc justifications. A legislature could construct a plethora of potential maps that look consistent with traditional, race-neutral principles, but if race is the overriding reason for choosing a map, race still may predominate. Challengers may establish racial predominance without evidence of an actual conflict. A holistic analysis is necessary to give the proper weight to districtwide evidence, such as stark splits in the racial composition of populations moved into and out of a district, or the use of a racial target. The judgment regarding District 75 is consistent with the basic narrow tailoring analysis; the state’s interest in complying with the Voting Rights Act was a compelling interest and the legislature had sufficient grounds to determine that the race-based calculus it employed was necessary to avoid violating the Act. View "Bethune-Hill v. Virginia State Board of Elections" on Justia Law

Buck was convicted of murder; under Texas law, the jury could impose a death sentence only if it found unanimously, beyond a reasonable doubt, that Buck was likely to commit future acts of violence. Buck’s attorney called a psychologist, Dr. Quijano, who had been appointed to evaluate Buck. While concluding that Buck was unlikely to be a future danger, Quijano stated, in his report and testimony, that Buck was statistically more likely to act violently because he is black. The jury returned a sentence of death. In his first post-conviction proceeding, Buck did not argue ineffective assistance of counsel. In the meantime, the Supreme Court vacated the judgment in a case in which Quijano had testified that Hispanic heritage weighed in favor of a finding of future dangerousness. The Texas Attorney General then identified six cases in which Quijano had testified and, in five cases, consented to resentencing. Buck’s second state habeas petition, alleging ineffective assistance, was dismissed for failure to raise the claim in his first petition. Buck sought federal habeas relief (28 U.S.C. 2254). His claim was held procedurally defaulted. The Supreme Court subsequently issued holdings (Martinez and Trevino) under which Buck’s claim could have been heard, had he demonstrated that state post-conviction counsel was constitutionally ineffective in failing to raise a claim that had some merit. The Fifth Circuit affirmed rejection of Buck’s motion to reopen, finding that Buck had not established extraordinary circumstances or ineffective assistance. The Supreme Court reversed. The question was not whether Buck had shown that his case is extraordinary; it was whether jurists of reason could debate that issue. No competent defense attorney would introduce evidence that his client is liable to be a future danger because of his race. There is a reasonable probability that Buck was sentenced to death in part because of his race, a concern that supports Rule 60(b)(6) relief. The Court rejected, as waived, the state’s argument that Martinez and Trevino did not apply. View "Buck v. Davis" on Justia Law

The Individuals with Disabilities Education Act (IDEA) provides federal funds to states for furnishing a “free appropriate public education” (FAPE) to children with disabilities, 20 U.S.C. 1412(a)(1)(A), and establishes administrative procedures for resolving disputes concerning the provision of a FAPE. The Americans with Disabilities Act (ADA) and the Rehabilitation Act also protect the rights of disabled children; under the Handicapped Children’s Protection Act of 1986, a plaintiff bringing suit under those or similar laws “seeking relief that is also available under [the IDEA]” must first exhaust IDEA administrative procedures. E. is a child with cerebral palsy; a trained service dog (Wonder) assists her with daily activities. Her school refused to allow Wonder to join E. in kindergarten, stating that the human aide provided as part of E.’s individualized education program rendered the dog superfluous. The Department of Education’s Office for Civil Rights found that the determination violated the ADA and Rehabilitation Act. School officials invited E. to return to school with Wonder. Her parents enrolled E. in a different school, then filed suit. The Sixth Circuit affirmed dismissal for failure to exhaust IDEA administrative procedures. The Supreme Court vacated. Exhaustion of IDEA administrative procedures is unnecessary where the gravamen of the lawsuit is something other than denial of a FAPE. The IDEA focuses on ensuring a FAPE for children with disabilities; its administrative procedures test whether a school has met that obligation. Determining the gravamen of a complaint can come from asking whether the plaintiff could have brought essentially the same claim if the alleged conduct had occurred at a public facility other than a school and whether an adult at the school could have pressed essentially the same grievance. The parents’ complaint alleged only disability-based discrimination, without any reference to the adequacy of the special education services. View "Fry v. Napoleon Community Schools" on Justia Law

Promega sublicensed a patent, which claims a toolkit for genetic testing, to Life Technologies for the manufacture and sale of kits for use in licensed law enforcement fields worldwide. One of the kit’s five components, an enzyme, was manufactured by Life Technologies in the U.S. and shipped to the United Kingdom, where the other components were made, for combination there. When Life Technologies began selling kits outside the licensed fields of use, Promega sued, citing section 271(f)(1) of the Patent Act, which prohibits the supply from the U.S. of “all or a substantial portion of the components of a patented invention” for combination abroad. The district court held that the section did not encompass the supply of a single component of a multicomponent invention. The Federal Circuit reversed, reasoning that a single important component could constitute a “substantial portion” of the components of an invention. The Supreme Court reversed. The supply of a single component of a multicomponent invention for manufacture abroad does not give rise to liability under section 271(f)(1), which refers to a quantitative measurement. The Court rejected Promega’s proffered “case-specific approach,” which would require a factfinder to decipher whether the components at issue are a “substantial portion” under either a qualitative or a quantitative test. When a product is made abroad and all components but a single commodity article are supplied from abroad, the activity is outside the statute’s scope. View "Life Technologies Corp. v. Promega Corp." on Justia Law

The Federal National Mortgage Association (Fannie Mae) is a federally-chartered corporation that participates in the secondary mortgage market, with authority “to sue and to be sued, and to complain and to defend, in any court of competent jurisdiction, State or Federal,” 12 U.S.C. 1723a(a). Plaintiffs filed suit in state court alleging deficiencies in the refinancing, foreclosure, and sale of their home. Fannie Mae removed the case to federal court, relying on its sue-and-be-sued clause as the basis for federal jurisdiction. The district court denied a motion to remand the case to state court and later entered judgment against plaintiffs. The Ninth Circuit affirmed. A unanimous Supreme Court reversed. The clause does not grant federal courts jurisdiction over all cases involving Fannie Mae. Distinguishing cases in which a sue-and-be-sued clause was held to confer jurisdiction, the Court noted that Fannie Mae’s clause adds the qualification “any court of competent jurisdiction.” A court of competent jurisdiction is a court with an existing source of subject-matter jurisdiction; the clause does not grant federal court subject-matter jurisdiction, but confers only a general right to sue. View "Lightfoot v. Cendant Mortgage Corp" on Justia Law

Two women called 911 to report Daniel as a “‘drunk driver’” on a highway near Santa Fe, then followed Daniel with their bright lights on. Daniel, feeling threatened, pulled over at an off-ramp to confront them. After a nonviolent encounter, Daniel drove to a secluded house where he lived with his brother, Samuel. Officer Truesdale interviewed the women at the off-ramp and obtained Daniel’s license plate number. The dispatcher identified the brothers’ address. Truesdale was joined by Officers White and Mariscal. The three agreed there was insufficient probable cause for arrest, but decided to speak with Daniel. White remained behind in case Daniel returned. Truesdale and Mariscal drove separately, less than a half mile, to the address, without flashing lights. They approached the house in a covert manner, found Daniel’s pickup truck, and spotted two men moving inside the residence. They radioed White, who left the off-ramp to join them. At approximately 11 p.m., the brothers became aware of their presence and yelled, “‘Who are you?’” and “‘What do you want?’” Mariscal and Truesdale laughed and responded: “‘Hey, (expletive), we got you surrounded. Come out or we’re coming in.’” Truesdale shouted: “‘Open the door, State Police, open the door.’” Mariscal yelled: “‘Open the door, open the door.’” The brothers heard, “We’re coming in” and did not hear the officers identify themselves. They armed themselves and yelled, “We have guns.” Truesdale positioned himself behind the house and shouted “‘Open the door, come outside.’” White, walking toward the house, heard “We have guns,” drew his gun and took cover behind a stone wall. Mariscal took cover behind a truck. Daniel fired two shotgun blasts from the back door while screaming loudly. Seconds later, Samuel opened a window and pointed a handgun in White’s direction. Mariscal fired at Samuel but missed. “‘Four to five seconds’” later, White shot and killed Samuel. In a suit under 42 U.S.C. 1983, the district court denied the officers summary judgment on the defense of qualified immunity. The Tenth Circuit affirmed. The Supreme Court vacated. Officer White did not violate clearly established law. The Court declined to consider whether a reasonable jury could infer that White witnessed the other officers’ deficient performance and should have realized that corrective action was necessary before using deadly force because neither lower court addressed that argument. The Court expressed no opinion on whether Truesdale and Mariscal are entitled to qualified immunity. View "White v. Pauly" on Justia Law

Before Hurricane Katrina, State Farm issued federal government-backed flood insurance policies and its own homeowner policies. Relators, former claims adjusters for a State Farm contractor (Renfroe) filed a complaint under seal in April 2006, claiming that State Farm instructed adjusters to misclassify wind damage as flood damage to shift its insurance liability to the government. The district court extended the seal several times at the government’s request, lifting it in part in January 2007 for disclosure to another district court hearing a suit by Renfroe against the relators. In August, the court lifted the seal. The government declined to intervene. State Farm moved to dismiss on grounds that the relators’ attorney had disclosed the complaint’s existence to news outlets, which issued stories about the fraud allegations, but did not mention the False Claims Act (FCA, 31 U.S.C. 3729) complaint and the relators had met with a Congressman who later spoke against the purported fraud. Under the FCA: “The complaint shall be filed in camera, shall remain under seal for at least 60 days, and shall not be served on the defendant until the court so orders.” The court decided against dismissal, balancing actual harm to the government, severity of the violations, and evidence of bad faith. The Fifth Circuit and a unanimous Supreme Court affirmed. A seal violation does not mandate dismissal. The FCA has several provisions expressly requiring the dismissal, indicating that Congress did not intend to require dismissal for a violation of the seal requirement. This result is consistent with the purpose of section 3730(b)(2), which was enacted to “encourage more private enforcement suits,” and to protect the government’s interests when a relator filing a civil complaint could alert defendants to a pending federal criminal investigation. View "State Farm Fire & Casualty Co. v. United States ex rel. Rigsby" on Justia Law

Shaw used identifying numbers of Hsu's bank account in a scheme to transfer funds from that account to accounts at other institutions from which Shaw was able to obtain Hsu’s funds. Shaw was convicted under 18 U.S.C. 1344(1), which makes it a crime to “knowingly execut[e] a scheme . . . to defraud a financial institution.” The Ninth Circuit affirmed. A unanimous Supreme Court vacated and remanded for consideration of whether the district court improperly instructed the jury that a scheme to defraud a bank must be one to deceive the bank or deprive it of something of value, instead of one to deceive and deprive. The Court rejected Shaw’s other arguments. Subsection (1) of the statute covers schemes to deprive a bank of money in a customer’s account. The bank had property rights in Hsu’s deposits as a source of loans from which to earn profits or as a bailee. The statute requires neither a showing that the bank suffered ultimate financial loss nor a showing that the defendant intended to cause such loss. Shaw knew that the bank possessed Hsu’s account, Shaw made false statements to the bank, Shaw believed that those false statements would lead the bank to release from that account funds that ultimately, wrongfully ended up with Shaw. Shaw knew that he was entering into a scheme to defraud the bank even if he was not familiar with bank-related property law. Subsection (2), which criminalizes the use of “false or fraudulent pretenses” to obtain “property . . . under the custody or control of” a bank, does not exclude Shaw’s conduct from subsection (1). View "Shaw v. United States" on Justia Law

The Patent Act prohibits the manufacture or sale an “article of manufacture” to which a patented design or a colorable imitation thereof has been applied and makes an infringer liable “to the extent of his total profit,” 35 U.S.C. 289. A jury found that Samsung smartphones infringed Apple's design patents, which covered a rectangular front face with rounded edges and a grid of colorful icons on a black screen. Apple was awarded $399 million—Samsung’s entire profit from the sale of its infringing smartphones. The Federal Circuit affirmed the award. A unanimous Supreme Court reversed and remanded. In the case of a multicomponent product, the relevant “article of manufacture” for a section 289 damages award need not be the end product sold to the consumer but may be only a component of that product. The Court noted Patent Act section 171(a), which makes certain “design[s] for an article of manufacture” eligible for design patent protection and permits a design patent that extends to only a component of a multicomponent product. The term “article of manufacture” is broad enough to embrace both a product sold to a consumer and a component of that product, whether sold separately or not. The Court declined to resolve whether the relevant article of manufacture for each design patent at issue is the smartphone or a particular smartphone component. View "Samsung Electronics Co. v. Apple Inc." on Justia Law