Justia U.S. Supreme Court Opinion Summaries

In Patent Act infringement cases, courts may increase the damages up to three times the amount assessed, 35 U.S.C. 284. Under the Federal Circuit’s “Seagate” test for section 284 damages, a patent-holder had to demonstrate by clear and convincing evidence that the infringer acted despite an objectively high likelihood that its actions constituted infringement of a valid patent and that the risk of infringement “was either known or so obvious that it should have been known to the accused infringer.” The Federal Circuit reviewed objective recklessness de novo; subjective knowledge for substantial evidence; and the award of enhanced damages for abuse of discretion. The Supreme Court unanimously held that the Seagate test is inconsistent with section 284, which includes no precise rule for awarding damages. By requiring an objective recklessness finding, the test excluded from discretionary punishment many of the most culpable offenders, including the “wanton and malicious pirate” who intentionally infringes a patent, with no thoughts about its validity or defenses. A patent infringer’s subjective willfulness, whether intentional or knowing, may warrant enhanced damages, regardless of whether infringement was objectively reckless. Under Seagate, the ability of the infringer to muster a reasonable defense at trial was dispositive, even if he was not previously aware of the defense. Culpability is generally measured against the actor’s knowledge at the time of the challenged conduct. Seagate’s clear and convincing evidence requirement is also inconsistent with section 284, which imposes no specific evidentiary burden, much less such a high one. The Court also rejected the Federal Circuit’s tripartite appellate review framework. Section 284 commits the enhanced damages determination to the district court’s discretion; that decision should be reviewed for abuse of discretion. View "Halo Elecs., Inc. v. Pulse Elecs., Inc." on Justia Law

Defendants each sold a gun to an undercover police officer. Each was indicted for violation of the Puerto Rico Arms Act of 2000. While those charges were pending, federal grand juries indicted them, based on the same transactions, for violations of analogous U.S. gun-trafficking statutes. Both pleaded guilty to the federal charges and successfully moved to dismiss the Commonwealth charges on double jeopardy grounds. The Supreme Court of Puerto Rico and U.S. Supreme Court upheld the dismissals. The Double Jeopardy Clause bars Puerto Rico and the United States from successively prosecuting a person for the same conduct under equivalent criminal laws. While the Double Jeopardy Clause does not bar successive prosecutions brought by separate sovereigns, “sovereignty” in this context does not bear its ordinary meaning. The issue is the “ultimate source” of the power authorizing the prosecutions. The states are separate sovereigns from the federal government and from one another, but U. S. territories, including an earlier incarnation of Puerto Rico, are not sovereigns distinct from the United States. Federal and territorial prosecutors do not derive their powers from independent sources of authority. Although constitutional developments made Puerto Rico “sovereign” in one commonly understood sense of that term, the dual-sovereignty test focuses not on the fact of self-rule, but on where it originated. Congress conferred the authority to create the Puerto Rico Constitution, which confers the authority to bring criminal charges. That makes Congress the original source of power for Puerto Rico’s prosecutors, as it is for the federal government’s. The island’s Constitution does not break the chain. View "Puerto Rico v. Valle" on Justia Law

Following a Montana automobile accident, Dietz sued Bouldin. Bouldin admitted liability and stipulated to damages of $10,136 for Dietz’ medical expenses. Dietz wanted more. During deliberations, the jury sent a note asking whether Dietz’ medical expenses had been paid and by whom. The judge, with the parties’ consent, responded that the information was not relevant. The jury returned a verdict in Dietz’ favor, awarding $0 in damages. The judge discharged the jury; they left the courtroom. Moments later, the judge realized that the verdict was not “legally possible in view of stipulated damages.” He ordered the clerk to bring back the jurors, who were all in the building. One may have briefly left. Over Dietz's objection, in the interest of judicial economy and efficiency, the judge recalled the jury. After questioning the jurors as a group, the judge determined that none had spoken about the case and ordered them to return the next morning. After receiving clarifying instructions, the jury returned a verdict awarding Dietz $15,000. The Ninth Circuit and Supreme Court affirmed. A court has a limited inherent power to rescind a jury discharge order and recall a jury in a civil case for further deliberations after identifying an error in the verdict. The court did not abuse that power here. The jury was out for only minutes, and, with the exception of one juror, remained inside the courthouse. They did not speak about the case; there is no indication that the verdict generated any emotional reaction or electronic exchanges that could have tainted the jury. There would be no benefit to imposing a categorical rule that as soon as a jury is free to go, a judge cannot rescind that order to correct an easily fixable mistake. View "Dietz v. Bouldin" on Justia Law

Williams was convicted of a 1984 murder and sentenced to death. Philadelphia District Attorney Castille approved a request to seek the death penalty. Williams’s conviction and sentence were upheld on direct appeal, state post-conviction review, and federal habeas review. In 2012, Williams filed a successive petition under Pennsylvania’s Post-Conviction Relief Act (PCRA), arguing that the prosecutor had obtained false testimony from his codefendant and suppressed exculpatory evidence. Finding that the prosecutor had committed Brady violations, the court stayed Williams’s execution. The Commonwealth asked the Pennsylvania Supreme Court, whose chief justice was former District Attorney Castille, to vacate the stay. Without explanation, Castille denied Williams’s motion for recusal and request for referral to the full court; Castille joined an opinion vacating PCRA relief and reinstating Williams’s death sentence. Two weeks later, Castille retired. The U.S. Supreme Court vacated, holding that Castille’s participation violated the Due Process Clause. There is an impermissible risk of actual bias when a judge earlier had significant, personal involvement as a prosecutor in a critical decision regarding the defendant’s case. No attorney is more integral to the accusatory process than a prosecutor who participates in a major adversary decision; the decision to pursue the death penalty is a critical choice. Neither the involvement of multiple actors nor the passage of time relieves the former prosecutor of the duty to withdraw. An unconstitutional failure to recuse constitutes structural error, “not amenable” to harmless-error review, regardless of whether the judge’s vote was dispositive. The Court noted that many jurisdictions, including Pennsylvania, have statutes and professional codes that already require recusal under these circumstances. View "Williams v. Pennsylvania" on Justia Law

Guards (Madigan and Ross) undertook to move Blake, a Maryland inmate, to the prison’s segregation unit. Madigan assaulted Blake, punching him in the face. The prison system’s Internal Investigative Unit (IIU), issued a report condemning Madigan’s actions. Blake sued both guards under 42 U.S.C. 1983, alleging excessive force and failure to take protective action. A jury found Madigan liable. Ross raised the Prison Litigation Reform Act (PLRA) requirement that an inmate exhaust “such administrative remedies as are available” before bringing suit. Blake argued that the IIU investigation was a substitute for those procedures. The Fourth Circuit reversed dismissal of the suit, holding that “special circumstances” can excuse a failure to comply with administrative procedural requirements, particularly where the inmate reasonably, although mistakenly, believed he had sufficiently exhausted his remedies. The Supreme Court vacated: “The Fourth Circuit’s unwritten ‘special circumstances’ exception is inconsistent with the text and history of the PLRA.” Mandatory exhaustion statutes like the PLRA foreclose judicial discretion. There are, however, circumstances in which an administrative remedy, although officially on the books, is not available. An administrative procedure is unavailable when it operates as a dead end, with officers unable or consistently unwilling to provide relief. An administrative scheme might be so opaque that it becomes, practically speaking, incapable of use. Finally, a grievance process is rendered unavailable when prison administrators thwart inmates from taking advantage of it through misrepresentation, or intimidation. The record raised questions about whether Blake had an “available” administrative remedy to exhaust. View "Ross v. Blake" on Justia Law

Himmelreich, a federal prisoner, sued the United States, alleging that he was severely beaten by a fellow inmate as the result of negligence by prison officials. The government treated the suit as a claim under the Federal Tort Claims Act (FTCA), 28 U.S.C. 1346(b). The court granted the defendants summary judgment on the ground that the claim fell into the exception for “[a]ny claim based upon . . . the exercise or performance . . . [of] a discretionary function,” namely, deciding where to house inmates. While the motion was pending, Himmelreich filed a second suit: a constitutional tort suit against individual Bureau of Prison employees, again alleging that his beating was the result of officials’ negligence. After the dismissal of Himmelreich’s first suit, the court dismissed the second suit as foreclosed by the FTCA’s judgment bar provision. The Sixth Circuit reversed. The Supreme Court affirmed. The FTCA “Exceptions” section’s plain text dictates that the judgment bar does “not apply” to cases that, like Himmelreich’s first suit, are based on the performance of a discretionary function. Had the court dismissed Himmelreich’s first suit because, e.g., the employees were not negligent, it would make sense that the judgment bar provision would prevent a second suit against the employees. Where an FTCA claim is dismissed because it falls within one of the “Exceptions,” the dismissal signals merely that the United States cannot be held liable for the claim; it has no logical bearing on whether an employee can be liable instead. View "Simmons v. Himmelreich" on Justia Law

Lynch was convicted of first-degree murder, kidnapping, armed robbery, and burglary for a 2001 killing. The state sought the death penalty. Before Lynch’s penalty phase trial began, Arizona successfully moved to prevent his counsel from informing the jury that the only alternative sentence to death was life without the possibility of parole. The jury failed to reach a unanimous verdict. A second jury was convened and sentenced Lynch to death. The Arizona Supreme Court vacated the sentence because the jury instructions improperly described Arizona law, but did not address Lynch’s argument that the trial court violated the 1994 Supreme Court holding, Simmons v. South Carolina, “where a capital defendant’s future dangerousness is at issue, and the only sentencing alternative to death available to the jury is life imprisonment without possibility of parole,” the Due Process Clause “entitles the defendant ‘to inform the jury of [his] parole ineligibility.’” .On remand, a third penalty phase jury sentenced Lynch to death. The Arizona Supreme Court affirmed, rejecting Lynch’s Simmons claim, while acknowledging that the state suggested that Lynch could be dangerous. The Supreme Court, per curiam, reversed. Under state law, the only kind of release for which Lynch would be eligible is executive clemency. Simmons expressly rejected the argument that the possibility of clemency diminishes a capital defendant’s right to inform a jury of his parole ineligibility. The Court rejected Arizona’s argument that “nothing prevents the legislature from creating a parole system in the future" for which Lynch would be eligible. View "Lynch v. Arizona" on Justia Law

Lee and her boyfriend stabbed two women to death and were convicted of first-degree murder. Lee received a sentence of life without the possibility of parole. In 1999, Lee unsuccessfully raised four claims on appeal. After California appellate courts affirmed, Lee filed a federal habeas petition, 28 U.S.C. 2254(a), raising mostly claims not raised on direct appeal. The court stayed federal proceedings to allow Lee to pursue her new claims in a state habeas petition. The California Supreme Court denied Lee’s petition, citing California’s “Dixon bar,” under which a defendant procedurally defaults a claim raised for the first time on state collateral review if he could have raised it earlier on direct appeal. The federal court then dismissed her new claims as procedurally defaulted. For the first time, Lee challenged the Dixon bar, citing the California Supreme Court’s state habeas denials on a single day. Lee claimed that out of the 210 summary denials on December 21, 1999, the court failed to cite Dixon in nine cases where it should have been applied. The court denied those nine petitions without any citation. Without evaluating that evidence, the Ninth Circuit reversed and remanded “to permit the Warden to submit evidence.” On remand, the warden submitted a study analyzing about 4,700 summary habeas denials during a two-year period around the same date: the California Supreme Court cited Dixon in approximately 12% of all denials—more than 500 times. The district court held that the Dixon bar is adequate. The Ninth Circuit again reversed. The Supreme Court, per curiam, reversed, stating that the decision “profoundly misapprehends” what makes a state procedural bar “adequate.” California’s procedural bar is longstanding, oft-cited, and shared by habeas courts across the country. View "Johnson v. Lee" on Justia Law

Peat mining companies sought a Clean Water Act, 33 U.S.C. 1311(a), 1362, permit from the Army Corps of Engineers, to discharge material onto wetlands on property that they own and hope to mine. The Corps issued a jurisdictional designation (JD) stating that the property contained “waters of the United States” because its wetlands had a “significant nexus” to the Red River of the North, located 120 miles away. The district court dismissed their appeal for want of jurisdiction, holding that the JD was not a “final agency action for which there is no other adequate remedy,” 5 U.S.C. 704. The Eighth Circuit reversed. The Supreme Court affirmed. The Corps’ approved JD is a final agency action judicially reviewable under the Administrative Procedures Act. An approved JD clearly “mark[s] the consummation” of the Corps’ decision-making on whether particular property contains “waters of the United States.” It is issued after extensive fact-finding regarding the property’s physical and hydrological characteristics and typically remains valid for five years. The Corps describes approved JDs as “final agency action.” The definitive nature of approved JDs gives rise to “direct and appreciable legal consequences.” A “negative” creates a five-year safe harbor from governmental civil enforcement proceedings and limits the potential liability for violating the Act. An “affirmative” JD, like issued here, deprives property owners of the five-year safe harbor. Parties need not await enforcement proceedings before challenging final agency action where such proceedings carry the risk of “serious criminal and civil penalties.” The permitting process is costly and lengthy, and irrelevant to the finality of the approved JD and its suitability for judicial review. View "Army Corps of Eng'rs v. Hawkes Co." on Justia Law

During jury selection at Foster’s trial, the state (Georgia) used peremptory challenges to strike all four qualified black prospective jurors. Foster was convicted of capital murder and sentenced to death. The trial court rejected an argument that the strikes were racially motivated, in violation of Batson v. Kentucky. While his state habeas petition was pending, Foster obtained copies of the prosecution’s trial file, including the jury venire list with the names of each black prospective juror highlighted; an investigator's statement comparing black prospective jurors and concluding, “If it comes down to having to pick one of the black jurors, [this one] might be okay”; notes with “N” (for “no”) appearing next to the names of all black prospective jurors; a document with notes about a church, annotated "No. Black Church”; and questionnaires, on which each juror’s response indicating race was circled. The state court denied relief. The Georgia Supreme Court denied a certificate of appeal. The U.S. Supreme Court reversed, first holding that it had jurisdiction to review the denial of a Certificate of Probable Cause; there was no indication that denial rested on state law “independent of the merits” of Foster’s Batson claim. The lower court’s application of res judicata depended on a federal constitutional ruling; its decision that Foster failed to show purposeful discrimination was clearly erroneous. Though the trial court accepted the prosecution’s justifications for the strikes, "the record belies much of the prosecution’s reasoning." That a prosecutor’s reasons for striking a black prospective juror apply equally to an otherwise-similar nonblack prospective juror, who is allowed to serve, suggests purposeful discrimination. The Court noted “the prosecution’s shifting explanations, misrepresentations of the record, and persistent focus on race.” Because Batson was decided only months before Foster’s trial, the state argued that the prosecution’s file was an effort to maintain a detailed account should the prosecution need a defense against any suggestion that its reasons were pretextual. That argument, having never before been raised in the 30 years since Foster’s trial, “reeks of afterthought.” View "Foster v. Chatman" on Justia Law