Justia U.S. Supreme Court Opinion Summaries

In 1998, defendant allegedly forced his way into the apartment of his former girlfriend, Heathmon,raped and hit her, stole a ring, and dragged her outside by the neck and hair. A witness confronted him and defendant fled. Police observed injuries to Heathmon’s neck and scalp, consistent with her account. Defendant was arrested. Although he did not testify at trial, his statements to police were admitted into evidence. He claimed that the sex was consensual and denied dragging Heathmon, but admitted that she might have felt threatened and that he hit her. Before trial, Heathmon sent the judge a letter recanting her accusations and stating that she would not testify. She went into hiding, but police took her into custody as a material witness. Heatthmon disavowed the letter and agreed to testify. She stated that defendant’s associates had forced her to write the letter and had threatened to hurt her if she testified. At trial, the defense sought to introduce testimony and police reports showing that Heathmon had called the police on prior occasions claiming that defendant had raped or assaulted her. Police were unable to corroborate many of those allegations. Although the court gave the defense wide latitude to cross¬examine Heathmon, it refused to admit the police reports or to allow the defense to call involved officers as witnesses. Defendant was sentenced to life imprisonment. After exhausting state remedies, defendant filed a federal habeas petition, 28 U.S.C. 2254(d). The district court denied relief, but a divided Ninth Circuit reversed, finding violation of defendant’s constitutional right to present a defense, and that the Nevada Supreme Court’s decision to the contrary was an unreasonable application of Supreme Court precedent. The Supreme Court reversed, holding that the Nevada Supreme Court’s decision was reasonable. The Constitution grants broad latitude in establishing rules excluding evidence from criminal trials. The Nevada statute generally precludes admission of extrinsic evidence of specific instances of the conduct of a witness, for the purpose of attacking or supporting the witness’ credibility, other than conviction of crime, Nev. Rev. Stat. 50.085(3). The state has “good reason[s]” for limiting use of extrinsic evidence, and its statute is akin to the widely accepted rule of evidence. The statute has an exception for previous fabricated sexual assault accusations, but the defendant must file written notice, and the trial court must hold a hearing. Defendant did not file the requisite notice. No decision of the Supreme Court clearly establishes that the notice requirement is unconstitutional. Some of the evidence that defendant sought to introduce concerned prior incidents that did not involve alleged sexual assault; the state court reasoned that the proffered evidence had little impeachment value because it showed simply that the victim’s reports could not be corroborated. The admission of extrinsic evidence of specific instances of a witness’ conduct to impeach the witness may confuse the jury, unfairly embarrass the victim, surprise the prosecution, and unduly prolong a trial. The Supreme Court has never held that the Confrontation Clause entitles a criminal defendant to introduce extrinsic evidence for impeachment. View "Nevada v. Jackson" on Justia Law

After his arrest on first- and second-degree assault charges, King was processed through a Wicomico County, Maryland, facility, where personnel used a cheek swab to take a DNA sample pursuant to the Maryland DNA Collection Act (Act), which authorizes officers to collect DNA samples from persons charged with violent crimes. A sample may not be added to a database before an individual is arraigned, and it must be destroyed if he is not convicted. Only identity information may be added to the database. King’s swab was matched to an unsolved 2003 rape. He unsuccessfully moved to suppress the DNA match. The Maryland Court of Appeals set aside his conviction, finding portions of the Act authorizing DNA collection from felony arrestees unconstitutional. The Supreme Court reversed. Taking and analyzing a cheek swab of the arrestee’s DNA is, like fingerprinting and photographing, a legitimate police booking procedure that is reasonable under the Fourth Amendment when officers make an arrest supported by probable cause to hold and bring the suspect to the station to be detained in custody, for a serious offense. DNA testing involves minimal intrusion that may significantly improve both the criminal justice system and police investigative practices; it is quick and painless and requires no intrusion beneath the skin. When probable cause exists to remove an individual from the normal channels of society and hold him in legal custody, DNA identification plays a critical role in serving interests in properly identifying who has been arrested, ensuring that the custody of an arrestee does not create inordinate risks for staff, for the existing detainee population, and for a new detainee, and in ensuring that persons accused of crimes are available for trials. Identifying an arrestee as the perpetrator of some heinous crime may have the salutary effect of freeing a person wrongfully imprisoned. The Court noted that the test does not reveal an arrestee’s genetic traits and is unlikely to reveal any private medical information. View "Maryland v. King" on Justia Law

The Federal Employees’ Group Life Insurance Act (FEGLIA) permits an employee to name a beneficiary of life insurance proceeds, and specifies an “order of precedence” providing that an employee’s death benefits accrue first to that beneficiary ahead of other potential recipients, 5 U.S.C. 8705(a). A Virginia statute revokes a beneficiary designation in any contract that provides a death benefit to a former spouse where there has been a change in the decedent’s marital status, Va. Code 20–111.1(A). When the provision is preempted by federal law, Section D of that law provides a cause of action rendering the former spouse liable for the proceeds to the party who would have received them were Section A not preempted. Hillman named then-spouse, Maretta, as beneficiary of his FEGLI policy. After their divorce, he married Jacqueline but never changed his named FEGLI beneficiary. After Hillman’s death, Maretta, still the named beneficiary,collected the FEGLI proceeds. A Virginia Circuit Court found Maretta liable to Jacqueline under Section D for the FEGLI policy proceeds. The Virginia Supreme Court reversed, concluding that Section D is preempted by FEGLIA because it conflicts with the purposes and objectives of Congress. The Supreme Court affirmed. FEGLIA creates a scheme that gives highest priority to an insured’s designated beneficiary and underscores that the employee’s “right” of designation “cannot be waived or restricted.” Section D interferes with this scheme, because it directs that the proceeds actually belong to someone other than the named beneficiary by creating a cause of action for their recovery by a third party. FEGLIA establishes a clear and predictable procedure for an employee to indicate who the intended beneficiary shall be and evinces Congress’ decision to accord federal employees an unfettered freedom of choice in selecting a beneficiary and to ensure the proceeds actually belong to that beneficiary. View "Hillman v. Maretta" on Justia Law

Trevino was convicted of capital murder in Texas state court and sentenced to death. Neither new counsel appointed for direct appeal nor new counsel appointed for state collateral review raised the claim that trial counsel provided ineffective assistance during the penalty phase by failing to adequately investigate and present mitigating circumstances. When that claim was finally raised in Trevino’s federal habeas petition, the district court stayed proceedings so Trevino could raise it in state court. The state court found the claim procedurally defaulted. The federal court concluded that this failure was an independent and adequate state ground barring federal courts from considering the claim. The Fifth Circuit affirmed. The Supreme Court subsequently held, in Martinez v. Ryan, that “a procedural default will not bar a federal habeas court from hearing a substantial claim of ineffective assistance at trial if, in the [State’s] initial-review collateral proceeding, there was no counsel or counsel in that proceeding was ineffective.” Martinez concerned a prisoner from Arizona, where state law required the prisoner to raise the claim during his first state collateral review proceeding. Texas law does not require a defendant to raise his ineffective-assistance claim on collateral review and the Fifth Circuit subsequently held that Martinez was inapplicable to Texas cases. The Supreme Court vacated and remanded. Where, as here, state procedures make it highly unlikely in a typical case that a defendant will have a meaningful opportunity to raise an ineffective-¬assistance-of-trial-counsel claim on direct appeal, the Martinez exception applies. Texas procedures make it nearly impossible for an ineffective-assistance claim to be presented on direct review; a writ of habeas corpus is normally needed to gather the facts necessary for evaluating such claims. Were Martinez not to apply, the Texas procedural system would create significant unfairness. The Court noted Texas courts’ own “well-supported determination that collateral review normally is the preferred procedural route for raising an ineffective-assistance-of-trial-counsel claim.” Failure to consider a lawyer’s “ineffectiveness” during an initial-review collateral proceeding as a potential “cause” for excusing a procedural default will deprive the defendant of any opportunity for review of an ineffective-assistance-of-trial-counsel claim. View "Trevino v. Thaler" on Justia Law

Henderson was stabbed to death after leaving a party with Perkins and Jones. Perkins was charged with murder. Jones testified that Perkins alone committed the murder while Jones watched. Perkins testified that Jones and Henderson left him during the evening, and that he later saw Jones with blood on his clothing. Perkins was convicted and sentenced to life in prison without the possibility of parole. The Antiterrorism and Effective Death Penalty Act of 1996 gives a state prisoner one year to file a federal habeas corpus petition, 28 U. S. C. 244(d)(1)(A). If the petition alleges newly-discovered evidence, the filing deadline is one year from “the date on which the factual predicate of the claim ... could have been discovered through ... due diligence.” More than 11 years after his conviction became final in 1997, Perkins filed his federal habeas petition, alleging ineffective assistance of trial counsel. To overcome AEDPA’s time limitations, he asserted newly discovered evidence of actual innocence in the form of three affidavits, the most recent dated July 16, 2002, each pointing to Jones as the murderer. The district court found that, even if the affidavits could be characterized as evidence newly discovered, Perkins had failed to show diligence entitling him to equitable tolling of AEDPA’s limitations period, and, alternatively, that Perkins had not shown that, taking account of all the evidence, no reasonable juror would have convicted him. The Sixth Circuit reversed, holding that Perkins’ actual-innocence claim allowed him to present his ineffective-assistance claim as if it had been filed on time. The Supreme Court vacated and remanded. A federal habeas court, faced with an actual-innocence gateway claim, should count unjustifiable delay on a habeas petitioner’s part, not as an absolute barrier to relief, but as a factor in determining whether actual innocence has been reliably shown. A petitioner invoking the miscarriage of justice exception must show that it is more likely than not that no reasonable juror would have convicted him in light of the new evidence.” Unexplained delay in presenting new evidence bears on the determination whether the petitioner has made the requisite showing. The district court’s appraisal of Perkins’ petition as insufficient to meet the demanding Schlup standard for actual innocence should be dispositive, absent cause to upset that evaluation. View "McQuiggin v. Perkins" on Justia Law

The National Childhood Vaccine Injury Act of 1986 established a no-fault compensation system to stabilize the vaccine market and expedite compensation to injured parties. Under the Act, a proceeding for compensation is “initiated” by service upon the Secretary of Health and Human Services and “the filing of a petition containing” specified documentation with the clerk of the Court of Federal Claims, who forwards the petition for assignment to a special master. 42 U. S. C. 300aa–11(a)(1). An attorney may not charge a fee for services in connection with such a petition, but a court may award attorney’s fees and costs incurred by a claimant in any proceeding on an unsuccessful petition, if that petition was brought in good faith. In 1997, shortly after receiving her third Hepatitis-B vaccine, Cloer began to experience symptoms that led to a multiple sclerosis (MS) diagnosis in 2003. In 2004, she learned of a link between MS and the Hepatitis-B vaccine, and in 2005, she filed a NCVIA claim. The special master concluded that Cloer’s claim was untimely because the Act’s 36-month limitations period began to run when she had her first MS symptoms in 1997.The Federal Circuit agreed. Cloer then sought attorney’s fees and costs. The Federal Circuit ruled in Cloer’s favor. The Supreme Court affirmed. Nothing in the attorney’s fees provision suggests that the reason for the subsequent dismissal of a petition, such as untimeliness, nullifies the initial filing. An NCVIA petition delivered to the court clerk, forwarded for processing, and adjudicated before a special master is a “petition filed under section 300aa–11.” The government’s contrary position is inconsistent with the fees provision’s purpose, which was to avoid limiting petitioners’ ability to obtain qualified assistance by making awards available for “non-prevailing, good-faith claims.” View "Sebelius v. Cloer" on Justia Law

In 1997, the United Kingdom imposed a one-time “windfall tax” on 32 U. K. companies privatized between 1984 and 1996 by the Conservative government. The companies had been sold to private parties through an initial sale of shares, known as “flotation.” Many of the companies became more efficient and earned substantial profits in the process. PPL, part owner of a privatized company, claimed a credit for its share of the bill in its 1997 federal income-tax return, relying on IRC section 901(b)(1), which states that any “income, war profits, and excess profits taxes” paid overseas are creditable against U. S. income taxes. Treasury Regulation 1.901–2(a)(1) states that a foreign tax is creditable if its “predominant character” “is that of an income tax in the U. S. sense.” The IRS rejected PPL’s claim, but the Tax Court held that the U. K. windfall tax was creditable. The Third Circuit reversed. A unanimous Supreme Court reversed, holding that the U. K. tax is creditable under section 901. Creditability depends on whether the tax, if enacted in the U. S., would be an income, war profits, or excess profits tax. A tax’s predominant character is that of an income tax “[i]f ... the foreign tax is likely to reach net gain in the normal circumstances in which it applies.” The windfall tax’s predominant character is that of an excess profits tax, a category of income tax in the U. S. sense. The Labour government’s conception of “profit-making value” as a backward¬-looking analysis of historic profits is not a typical valuation method; it is a tax on realized net income disguised as a tax on the difference between two values, one of which is a fictitious value calculated using an imputed price-to-earnings ratio. The windfall tax is economically equivalent to the difference between the profits each company actually earned and the amount the Labour government believed it should have earned given its flotation value. For most companies, the substantive effect was a 51.71 percent tax on all profits above a threshold, “a classic excess profits tax.” View "PPL Corp. v. Comm'r of Internal Revenue" on Justia Law

In 1993, Lancaster, a former police officer with a long history of severe mental-health problems, killed his girlfriend. At his jury trial in Michigan state court, Lancaster asserted a defense of diminished capacity. Under then-prevailing Michigan Court of Appeals precedent, the diminished-capacity defense permitted a legally sane defendant to present evidence of mental illness to negate the specific intent required to commit a particular crime. The jury convicted him of first-degree murder. Lancaster later obtained federal habeas relief. By the time of Lancaster’s retrial, the Michigan Supreme Court had rejected the diminished-capacity defense in its 2001 decision, Carpenter. The judge at his second trial applied Carpenter and disallowed renewal of his diminished-capacity defense. Lancaster was again convicted. The Michigan Court of Appeals rejected Lancaster’s argument that retroactive application of Carpenter violated due process. Lancaster reasserted his due process claim in a federal habeas petition. The district court denied the petition, but the Sixth Circuit reversed. A unanimous Supreme Court reversed, holding that Lancaster is not entitled to federal habeas relief. The Michigan Court of Appeals’ rejection of Lancaster’s due process claim does not represent an unreasonable application of Supreme Court precedent, 28 U. S. C.2254(d)(1). In Carpenter, the Michigan Supreme Court rejected a diminished-capacity defense, reasonably finding the defense to have no origin in an on-point statute. The Supreme Court has never found a due process violation where a state supreme court, squarely addressing a particular issue for the first time, rejected a consistent line of lower court decisions based on the supreme court’s reasonable interpretation of a controlling statute. Fair-minded jurists could conclude that a state supreme court decision of that order is not “unexpected and indefensible by reference to [existing] law.” View "Metrish v. Lancaster" on Justia Law

The Communications Act of 1934 requires state or local governments to act on siting applications for wireless facilities “within a reasonable period of time after the request is duly filed.” 47 U.S.C. 332(c)(7)(B)(ii). The FCC issued a Declaratory Ruling concluding that the phrase “reasonable period of time” is presumptively (but rebuttably) 90 days to process an application to place a new antenna on an existing tower and 150 days to process all other applications. The cities of Arlington and San Antonio challenged the Ruling. The Fifth Circuit found the statute ambiguous and upheld the FCC’s determination that section 201(b)’s broad grant of regulatory authority empowered it to administer section 332(c)(7)(B). The Supreme Court affirmed. Courts must apply the Chevron framework to an agency’s interpretation of a statutory ambiguity that concerns the scope of the agency’s statutory authority (i.e., its jurisdiction). The Court rejected a contention that Chevron deference was not appropriate because the FCC asserted jurisdiction over matters of traditional state and local concern. The statute explicitly supplants state authority. There is no case in which a general conferral of rule-making or adjudicative authority has been held insufficient to support Chevron deference for an exercise of that authority within the agency’s substantive field. A general conferral of rule-making authority validates rules for all the matters the agency is charged with administering. It is sufficient that the preconditions to deference under Chevron are satisfied because Congress has unambiguously vested the FCC with general authority to administer the Communications Act through rule-making and adjudication, and the interpretation at issue was promulgated in the exercise of that authority. View "Arlington v. Fed. Commc'n Comm'n" on Justia Law

The Federal Aviation Administration Authorization Act (FAAAA) preempts state laws “related to a price, route, or service of any motor carrier ... with respect to the transportation of property.” 49 U. S. C. 14501(c)(1). Pelkey sued in New Hampshire state court, alleging that Dan’s towing company towed his car from a parking lot without Pelkey’s knowledge, failed to notify him of its plan to auction the car, held an auction despite Pelkey’s notice that he wanted to reclaim the car, and traded the car away without compensating Pelkey. Pelkey alleged Dan’s did not meet the requirements of New Hampshire statutes, chapter 262, which regulates disposal of abandoned vehicles by a “storage company;” violated New Hampshire’s Consumer Protection Act; and violated its duties as a bailee The court granted Dan’s summary judgment, concluding that the FAAAA preempted Pelkey’s claims. The New Hampshire Supreme Court reversed, finding FAAAA preemption inapplicable to claims related to conduct in post-storage disposal, as opposed to conduct concerning “transportation of property,” or a “service.” The Supreme Court affirmed. Section 14501(c)(1) does not preempt state-law claims stemming from the storage and disposal of a towed vehicle. Pelkey’s claims are not related to “transportation of property” nor the “service” of a motor carrier. The words “with respect to the transportation of property” limit the FAAAA’s preemptive scope. Transportation of Pelkey’s car from his landlord’s parking lot was a service that ended months before the conduct on which Pelkey’s claims are based. The New Hampshire prescriptions Pelkey invokes hardly constrain participation in interstate commerce by requiring a motor carrier to offer services not available in the market. Nor do they “freez[e] into place services that carriers might prefer to discontinue in the future.” View "Dan's City Used Cars, Inc. v. Pelkey" on Justia Law