[Unknown Act > Conclusion]
Yes. Justice Antonin Scalia delivered a 5-4 opinion affirming the Florida Supreme Court's decision. The Court held that the front porch of a home is part of the home itself for Fourth Amendment purposes. Typically, ordinary citizens are invited to enter onto the porch, either explicitly or implicitly, to communicate with the house's occupants. Police officers, however, cannot go beyond the scope of that invitation. Entering a person's porch for the purposes of conducting a search requires a broader license than the one commonly given to the general public. Without such a license, the police officers were conducting an unlawful search in violation of the Fourth Amendment.
Justice Elena Kagan wrote a concurring opinion in which she argued that the case dealt with privacy issues as well as the property issues the majority opinion addressed. People have a heightened expectation of privacy in their homes and the areas immediately surrounding their homes, and in this case, the police violated that expectation. Because the police officers used a device (a drug-sniffing dog) not in public use to learn details about the home, Justice Kagan argued that an illegal search had been conducted. Justice Ruth Bader Ginsburg and Justice Sonia Sotomayor joined in the concurrence.
Justice Samuel A. Alito dissented, arguing that the majority's interpretation of the public license to approach a person's front door is too narrow and should extend even to police officers collecting evidence against an occupant. The dissent argued that the common law of trespass does not limit the public license to a particular category of visitors approaching the door for a specific purpose. Chief Justice John G. Roberts, Justice Anthony M. Kennedy, and Justice Stephen G. Breyer joined in the dissent.
Learn more about the Roberts Court and the Fourth Amendment in Shifting Scales, a nonpartisan Oyez resource.


[Unknown Act > Facts]
Amgen, Inc. is an American pharmaceutical corporation. The Food and Drug Administration (FDA) approved two Amgen products that stimulate production of red blood cells and reduce the need for blood transfusions in anemic patients. Amgen allegedly made misrepresentations to the FDA about the safety of these products. Connecticut Retirement Plans & Trust Funds brought an action against Amgen alleging four counts of misrepresentation. Connecticut Retirement Plans specifically alleged that Amgen misrepresented the nature of several FDA committee meetings to shareholders. It sought to certify a class of persons who purchased Amgen stock between April 22, 2004 and May 10, 2007, the dates when two of the meetings in question occurred. On May 10, 2007, Amgen's stock value dropped by more than nine percent.
To certify a class under Rule 23 of the Federal Rules of Civil Procedure, a plaintiff must show that there are questions of law or fact common to the class, and that these questions predominate over questions affecting only individual members. Amgen opposed the class certification, arguing that the that the misrepresentations did not have any impact on the price of Amgen stock. The district court rejected Amgen's arguments and granted the class certification. The United States Court of Appeals, Ninth Circuit, affirmed, rejecting Amgen's argument that a plaintiff must give proof that the misrepresentations were material at the class certification stage.


[Unknown Act > Conclusion]
No, no. Justice Ruth Bader Ginsburg delivered the opinion of the 6-3 majority. The Supreme Court held that the issue of materiality is dealt with when the case is decided on the merits, not during class certification. For a class to be certified, the members of the class must show only that the questions they have in common predominate over questions affecting solely individual members of the class. The Supreme Court also held that the district court ruled appropriately in preventing Amgen from bringing in rebuttal evidence to prevent class certification. Such evidence dealt with material issues of the case that would be decided when the case was considered on the merits, and thus did not relate to the issue of class certification.
In his concurring opinion, Justice Samuel A. Alito, Jr. wrote that, while he joins the majority's opinion, recent economic evidence suggests that the fraud-on-the-market theory might rest on faulty economic presumptions that would be worth reexamining.
Justice Antonin Scalia wrote a dissenting opinion in which he argued that a presumption of materiality was necessary for class certification in a fraud-on-the-market case. Because such a case is predicated on the idea that the members of the class relied on faulty information, there cannot be a suit without evidence that the faulty information was material.
In his separate dissent, Justice Clarence Thomas argued that plaintiffs seeking to use the fraud-on-the-market theory must show evidence of all aspects of the theory, including materiality, to be certified as a class. Without proof of materiality along with the other elements, there is no evidence that the claim has class-wide relevance. Justice Anthony M. Kennedy and Justice Scalia joined in the dissent.


[Unknown Act > Facts]
Lamar Evans was accused of burning a vacant house in Detroit, Michigan. He was charged with "burning other real property." The trial court required the prosecution to prove that the building was not a dwelling, although that is not an element of the crime under Michigan law. As a result of this extra element, the court granted Evans' motion for a directed verdict of acquittal. The Court of Appeals of Michigan reversed the trial court decision and remanded for further proceedings. The court held that Double Jeopardy did not bar a retrial because the trial court did not resolve any factual element of the case. The directed verdict was based only on the prosecution's failure to prove an element that is not part of the crime. The Supreme Court of Michigan affirmed.


[Unknown Act > Conclusion]
Yes. Justice Sonia Sotomayor, in an 8-1 opinion, reversed the lower court's decision and held that the Double Jeopardy Clause under the Fifth Amendment of the U.S. Constitution bars Evans' retrial. Even though the trial judge arrived at his ruling by erroneously adding a statutory element, Evans was acquitted for double jeopardy purposes. In general, any ruling based on the prosecution's failure to establish criminal liability will result in an acquittal. However, the Court distinguishes between an acquittal granted for substantive purposes and one granted for procedural purposes. When determining whether double jeopardy applies, only an acquittal based on the culpability of the defendant will conclude the proceedings entirely. If the acquittal is merely procedural and unrelated to the factual guilt or innocence of the defendant, there is no expectation that double jeopardy will bar further proceedings. The Court held that the trial court's acquittal factually resolved whether Evans was guilty or not; therefore it would be unfair to prosecute him again for the same crime.
Justice Samuel A. Alito Jr. filed a dissenting opinion, arguing that the majority's ruling goes beyond the original intent of the Double Jeopardy Clause. The Double Jeopardy Clause is intended to protect people from prosecutors' repeat attempts to convict an individual for the same offense. Since Evans moved for the directed verdict himself, the typical fear of repeat prosecution by the State does not arise. Despite the trial judge's error, the State was entitled to one complete opportunity to convict the defendant.


[Unknown Act > Facts]
In 1992, Houston police officers found two homicide victims. The investigation led officers to Genovevo Salinas. Salinas agreed to accompany the officers to the police station where he was questioned for about one hour. Salinas was not under arrest at this time and had not been read his Miranda rights. Salinas answered every question until an officer asked whether the shotgun shells found at the scene of the crime would match the gun found in Salinas' home. According to the officer, Salinas remained silent and demonstrated signs of deception. A ballistics analysis later matched Salinas' gun with the casings at the scene. Police also found a witness who said Salinas admitted to killing the victims. In 1993, Salinas was charged with the murders, but could not be located.
15 years later, Salinas was finally captured. The first trial ended in a mistrial. At the second trial, the prosecution attempted to introduce evidence of Salinas' silence about the gun casings. Salinas objected, arguing that he could invoke his Fifth Amendment protection against self-incrimination whether he was in custody or not. The trial court admitted the evidence and Salinas was found guilty and sentenced to 20 years in prison and a $5,000 fine. The Fourteenth Court of Appeals, Harris County, Texas affirmed, noting that the courts that have addressed this issue are divided. The Court of Criminal Appeals of Texas affirmed.


[Unknown Act > Conclusion]
No. Justice Samuel A. Alito announced the judgment for a divided Court. Justice Alito, joined by Chief Justice Roberts and Justice Kennedy concluded that the Fifth Amendment's privilege against self-incrimination does not extend to defendants who simply decide to remain mute during questioning. Long-standing judicial precedent has held that any witness who desires protection against self-incrimination must explicitly claim that protection. This requirement ensures that the government is put on notice when a defendant intends to claim this privilege and allows the government to either argue that the testimony is not self-incriminating or offer immunity. The plurality reiterated two exceptions to this principle: 1) that a criminal defendant does not need to take the stand at trial in order to explicitly claim this privilege; and 2) that failure to claim this privilege must be excused when that failure was due to government coercion. The opinion declined to extend these exceptions to the situation in this case. Notwithstanding popular misconceptions, the Court held that the Fifth Amendment does not establish a complete right to remain silent but only guarantees that criminal defendant may not be forced to testify against themselves. Therefore, as long as police do not deprive defendants of the opportunity to claim a Fifth Amendment privilege, there is no Constitutional violation.
In a separate opinion, Justice Clarence Thomas wrote that Salinas' Fifth Amendment privilege would not have been applicable even if invoked because the prosecutor's testimony regarding his silence did not compel Salinas to give self-incriminating testimony. Justice Antonin Scalia joined in the opinion.
Justice Stephen G. Breyer wrote a dissent in which he argued that Salinas' silence was enough to claim the Fifth Amendment privilege and that the majority's decision raised clear problems for uneducated defendants who may not know the explicit language necessary to protect their rights. Justice Ruth Bader Ginsburg, Justice Sonia Sotomayor, and Justice Elena Kagan joined in the dissent.


[Unknown Act > Facts]
On November 2, 2004, Arizona passed Proposition 200, which required voters to provide proof of citizenship when registering to vote or casting a ballot. Shortly after the Proposition passed, a group of plaintiffs, including the Inter Tribal Council of Arizona sued the state. They argued that Proposition 200 violated the Voting Rights Act of 1965, is unconstitutional under the Fourteenth and Twenty-fourth Amendments, and is inconsistent with the National Voter Registration Act of 1993 (NVRA). The district court denied a preliminary injunction, and the plaintiffs appealed.
The U. S. Court of Appeals for the Ninth Circuit granted an emergency injunction to allow the case to proceed without allowing Proposition 200 to affect the 2006 election. The Supreme Court vacated the emergency injunction and remanded the case for consideration on the merits. The Court of Appeals affirmed the district court's denial of the preliminary injunction and held that the Proposition was not an unconstitutional poll tax and did not violate the NVRA. On remand, the district court granted summary judgment for Arizona. The U.S. Court of Appeals for the Ninth Circuit affirmed in part and reversed in part by holding that the Proposition was not an unconstitutional poll tax and did not violate the NVRA, but that the NVRA preempts the Proposition's requirements.


[Unknown Act > Conclusion]
No, yes. Justice Antonin Scalia delivered the opinion for the 7-2 majority. The Supreme Court held that NVRA preempts other voter registration requirements. To allow states to impose additional requirements would allow them to reject voter registrations applicants who met the federal requirements to vote, which would defeat the purpose of the Act. However, the Court also held that Arizona may petition to have more requirements added to the federal standard.
In his opinion concurring in part and dissenting in part, Justice Anthony M. Kennedy wrote that there is no judicial basis for the majority's opinion that sometimes federal law preempts state law and sometimes it does not. However, he also argued that a presumption against preemption was not necessarily the best formulation of the relationship between state laws and federal ones. In this case, Kennedy agreed with the majority's opinion regarding the NVRA preempting the Arizona statute but not regarding the presumption of preemption.
Justice Clarence Thomas wrote a dissenting opinion in which he argued that the states have the right to determine voter qualifications for federal elections. He also argued that the NVRA only requires the states to use the federal requirements as part of the state's voter registration process. In his separate dissent, Justice Samuel A. Alito, Jr. argued that the Constitution grants the power to decide voter qualifications in federal elections to the states. He wrote that the NVRA does not require the states to treat the federal requirements as the sole requirements for voter registration. He also argued that the majority's opinion should have applied the presumption against preemption to this case because states have a vested interest in preserving the integrity of the election process.


[Unknown Act > Facts]
On July 28, 2005, an informant told Officer Richard Sneider of the Suffolk County Police Department that he had purchased six grams of crack cocaine at 103 Lake Drive, Wyandanch, New York, from an individual named "Polo." Officer Sneider obtained a warrant to search the basement apartment at that address; the warrant provided that the apartment was occupied by a heavy set black male with short hair, known as "Polo." That evening during surveillance, officers observed two men -later identified as Chunon L. Bailey and Bryant Middleton-exiting the gate that led to the basement apartment at 103 Lake Drive. The officers followed Bailey and Middleton as they left the premises in a black Lexus, and pulled the Lexus over about one mile from the apartment.
The officers patted down Bailey and Middleton, finding keys in Bailey's front left pocket. They placed both men in handcuffs and informed them that they were being detained, not arrested. Bailey insisted that he did not live in the basement apartment at 103 Lake Drive, but his driver's license address in Bay Shore was consistent with the informant's description of Polo. The police searched the apartment while Bailey and Middleton were in detention, finding a gun and drugs in plain view. The police arrested Bailey, and seized his house keys and car key incident to his arrest; later, an officer discovered that one of the house keys opened the door to the basement apartment.


[Unknown Act > Conclusion]
No. Justice Anthony M. Kennedy, writing for a 6-3 majority, reversed and remanded. The Supreme Court held that the rule from Michigan v. Summers did not apply because Bailey was not in or immediately outside the residence being searched when he was detained. Also, none of the law enforcement interests mentioned in Summers were served by detaining Bailey. Arrests incident to the execution of a search warrant are lawful under the Fourth Amendment, but once an individual leaves the premises being searched, any detention must be justified by another means. On remand, the Second Circuit should consider whether stopping Bailey was proper under Terry v. Ohio.
Justice Antonin Scalia concurred, emphasizing that Summers provides a bright line rule for law enforcement to follow. The Second Circuit's balancing test was an improper and would make it harder for officers to decide whether a seizure is constitutionally permissible before carrying it out. Justice Ruth Bader Ginsburg and Justice Elena Kagan joined in the concurrence.
Justice Stephen G. Breyer dissented, arguing that the majority applied an arbitrary geographical line instead of weighing actual Fourth Amendment concerns. Justice Clarence Thomas and Justice Samuel A. Alito, Jr. joined in the dissent.


[Unknown Act > Facts]
In 1997, the Texas legislature enacted a law requiring the University of Texas to admit all high school seniors who ranked in the top ten percent of their high school classes. After finding differences between the racial and ethnic makeup of the university's undergraduate population and the state's population, the University of Texas decided to modify its race-neutral admissions policy. The new policy continued to admit all in-state students who graduated in the top ten percent of their high school classes. For the remainder of the in-state freshman class the university would consider race as a factor in admission.
Abigail N. Fisher, a Caucasian female, applied for undergraduate admission to the University of Texas in 2008. Fisher was not in the top ten percent of her class, so she competed for admission with other non-top ten percent in-state applicants. The University of Texas denied Fisher's application.
Fisher filed suit against the university and other related defendants, claiming that the University of Texas' use of race as a consideration in admission decisions was in violation of the equal protection clause of the Fourteenth Amendment. The university argued that its use of race was a narrowly tailored means of pursuing greater diversity. The district court decided in favor of the University of Texas, and the United States Court of Appeals for the Fifth Circuit affirmed the district court's decision. Fisher appealed the appellate court's decision.


[Unknown Act > Conclusion]
Yes, but only under a standard of strict judicial scrutiny. Justice Anthony M. Kennedy delivered the opinion for the 7-1 majority. The Supreme Court held that, in affirming the lower court's decision, the Court of Appeals did not hold the University's admission policies to a standard of strict scrutiny, so the judgment was incorrect. Based on previous judicial precedent in cases dealing with minority admissions, the Court has held that such cases are reviewable under the Fourteenth Amendment and that they must be reviewed under a standard of strict scrutiny to determine whether the policies are "precisely tailored to serve a compelling governmental interest." If the policy does not meet this standard, race may not be considered in the admissions process. The Court held that it was the duty of the reviewing court to "verify" that the University policy in question was necessary to achieve the benefits of diversity and that no race-neutral alternative would provide the same benefits. The Supreme Court held that the lower courts did not conduct a sufficient strict scrutiny examination in this case.
Justice Antonin Scalia wrote a concurring opinion in which he argued that the Constitution prohibits governmental discrimination on the basis of race. However, because this case did not ask the Court to overrule precedent that allowed universities to consider diversity a compelling interest that justified race-based admission policies, he joined the majority's opinion in full. In his separate concurrence, Justice Clarence Thomas wrote that he joined the majority's opinion that the lower courts did not sufficiently apply strict scrutiny, but he also argued that the Equal Protection Clause of the Fourteenth Amendment prohibits a state's use of race as a factor in higher education admissions. He further argued that there is nothing "necessary" about the benefits that flow from racial diversity in higher education, so there in no compelling state interest to promote it.
Justice Ruth Bader Ginsburg wrote a dissenting opinion in which she argued that the University's admission policy treats race as merely one factor in the overall decision to admit a student, which is permissible under previous judicial precedent. She also argued that the Equal Protection Clause does not require that state universities be blind to the history of overt discrimination and that it is preferable that they explicitly include race as a factor in admission decisions rather than attempt to obfuscate its role.
Justice Elena Kagan did not participate in the discussion or decision of the case.


[Unknown Act > Facts]
While a student at the University of Missouri, Dr. Melissa Cloer was vaccinated for Hepatitis B in 1996 and 1997. Soon after, she began developing symptoms of multiple sclerosis (MS). Several years later, Dr. Cloer learned about a possible connection between the vaccine and MS. Dr Cloer sued under the National Childhood Vaccine Injury Act of 1986 (the Act). The Chief Special Master denied her claim as untimely because she brought it more than 36 months after the onset of symptoms. The Court of Federal Claims affirmed. Dr. Cloer appealed, and the U.S. Court of Appeals for the Federal Circuit reversed. The Federal Circuit granted the government's petition for rehearing and held that the Act's statute of limitations can be paused in certain circumstances, but Dr. Cloer's case did not meet the requirements. Her claims were again dismissed as untimely, but she filed a petition for attorney fees and costs incurred in the appeal. The Act provides that a claimant may recover attorney fees in connection with any proceeding under the Act brought in good faith with a reasonable basis for the claim even if the claimant does not win the case. The Federal Circuit held that Dr. Cloer was entitled to attorney fees if her claim was brought in good faith with a reasonable basis. The court remanded the case with instructions to decide those issues


[Unknown Act > Conclusion]
Yes. Justice Sonia Sotomayer delivered the opinion for the 9-0 majority. The Supreme Court held that the National Childhood Vaccine Injury Act made eligibility for attorney's fees contingent on the filing of a petition, rather than its ultimate success. According to the plain text of the Act, as long as the petition was filed in good faith and a reasonable basis, the petitioner is eligible for an award of attorney's fees. To limit the ability of good-faith petitioners to obtain assistance with attorney's fees would run counter to Congress' express goals in the fees provision of the Act.


[Unknown Act > Facts]
Hospitals receive compensation from the federal government based on the number of low-income patients they serve. The Center for Medicare & Medicaid Services (CMS) decides how much this payment will be. In an unrelated case, it came out that CMS miscalculated this payment between 1993 and 1996 so hospitals received less than they were due. In 2006, a group of hospitals filed claims with the Provider Reimbursement Review Board (PRRB) for full payment from the Department of Health and Human Services for years 1987-1994. Although the statute of limitations for such claims is 180 days, the hospitals argued that the limitations period should be tolled because CMS knowingly and unlawfully failed to disclose its error. The PRRB held that it did not have the authority to toll the statute of limitations, so the claims were untimely.
The hospitals sued in district court, but the district court held that it did not have jurisdiction because the PRRB's decision was not final. The court also held that the relevant statute does not allow for tolling the statute of limitations. The U.S. Court of Appeals for the District of Columbia Circuit reversed, holding that it did have jurisdiction because the PRRB decision was final. It also held that tolling the statute of limitations for "good cause" is possible, but whether it is appropriate in this case is a question for remand. The court of appeals denied a petition for a rehearing en banc.


[Unknown Act > Conclusion]
Yes, but only up to 3 years. Justice Ruth Bader Ginsburg, writing for a unanimous court, reversed the lower court and remanded. The Supreme Court held that the 180-day statute of limitations is not "jurisdictional" so it may be extended in some cases. Unless Congress has clearly stated that a statutory limitation is jurisdictional it is presumed to be non-jurisdictional. The Secretary of Health and Human Services regulation allowing a 3-year extension for good cause was permissible, as courts must defer to agency regulations unless they are "arbitrary, capricious, or manifestly contrary to the statute." The general presumption in favor of equitable tolling does not apply to an agency's internal deadline, absent evidence of congressional intent, so the Court could not extend the deadline indefinitely. Justice Sonia Sotomayor concurred, noting that the majority's opinion does not establish that equitable tolling is never applicable to internal administrative deadlines.


[Unknown Act > Facts]
The State of Florida charged Clayton Harris with possession of pseudoephedrine with intent to manufacture methamphetamine. At trial, Harris moved to suppress evidence obtained during a warrantless search of his car. Police searched the car during a traffic stop for expired registration when a drug detection dog alerted the officer. This dog was trained to detect several types of illegal substances, but not pseudoephedrine. During the search, the officer found over 200 loose pills and other supplies for making methamphetamine. Harris argued that the dog's alert was false and did not provide probable cause for the search. The trial court denied Harris motion, holding that the totality of the circumstances indicated that there was probable cause to conduct the search. The First District Court of Appeal affirmed, but the Florida Supreme Court reversed, holding that the State did not prove the dog's reliability in drug detection sufficiently to show probable cause.


[Unknown Act > Conclusion]
Yes. Justice Elena Kagan, writing for a unanimous court, reversed the Florida Supreme Court. The U.S. Supreme Court rejected the lower court's rigid requirement that police officers show evidence of a dog's reliability in the field to prove probable cause. Probable cause is a flexible common sense test that takes the totality of the circumstances into account. A probable cause hearing for a dog alert should proceed like any other, allowing each side to make their best case with all evidence available. The record in this case supported the trial court's determination that police had probable cause to search Harris' car.
Learn more about the Roberts Court and the Fourth Amendment in Shifting Scales, a nonpartisan Oyez resource.


[Unknown Act > Facts]
The Defense of Marriage Act (DOMA), enacted in 1996, states that, for the purposes of federal law, the words "marriage" and "spouse" refer to legal unions between one man and one woman. Since that time, some states have authorized same-sex marriage. In other cases regarding the DOMA, federal courts have ruled it unconstitutional under the Fifth Amendment, but the courts have disagreed on the rationale.
Edith Windsor is the widow and sole executor of the estate of her late spouse, Thea Clara Spyer, who died in 2009. The two were married in Toronto, Canada, in 2007, and their marriage was recognized by New York state law. Thea Spyer left her estate to her spouse, and because their marriage was not recognized by federal law, the government imposed $363,000 in taxes. Had their marriage been recognized, the estate would have qualified for a marital exemption, and no taxes would have been imposed.
On November 9, 2010 Windsor filed suit in district court seeking a declaration that the Defense of Marriage Act was unconstitutional. At the time the suit was filed, the government's position was that DOMA must be defended. On February 23, 2011, the President and the Attorney General announced that they would not defend DOMA. On April 18, 2011, the Bipartisan Legal Advisory Group of the House of Representatives filed a petition to intervene in defense of DOMA and motioned to dismiss the case. The district court denied the motion, and later held that DOMA was unconstitutional. The U.S. Court of Appeals for the Second Circuit affirmed.


[Unknown Act > Conclusion]
No, unanswered, yes. Justice Anthony M. Kennedy delivered the opinion of the 5-4 majority. The Supreme Court held that the United States Government, despite the executive branch's agreement regarding DOMA's unconstitutionality, retains a significant enough stake in the issue to support Supreme Court's jurisdiction. Because the judgment in question orders the U.S. Treasury to refund tax money, the Government stands to suffer a real economic injury and therefore maintains standing in the case. The Bipartisan Legal Advisory Group (BLAG) presented substantial arguments for the constitutionality of DOMA that reflected an actual controversy under Article III, which allowed the Supreme Court to address the case without needing to decide whether BLAG would have had standing before a lower court. The Court also held that states have the authority to define marital relationships and that DOMA goes against legislative and historical precedent by undermining that authority. The result is that DOMA denies same-sex couples the rights that come from federal recognition of marriage, which are available to other couples with legal marriages under state law. The Court held that the purpose and effect of DOMA is to impose a "disadvantage, a separate status, and so a stigma" on same-sex couples in violation of the Fifth Amendment's guarantee of equal protection.
Chief Justice John G. Roberts wrote a dissent in which he argued that the Court lacked the jurisdiction to review the case and that interests in uniformity and stability justified Congress' enactment of DOMA. He also argued that the majority's opinion did not address the issue of state definitions of marriage affecting same-sex couples. In his separate dissent, Justice Antonin Scalia wrote that the Supreme Court had neither the jurisdiction to review the case nor the power to invalidate democratically enacted legislation. He argued that the majority's opinion wrongly asserted the supremacy of the Supreme Court as the final arbiter of government. However, the majority opinion did not address the issue of whether or not the Equal Protection Clause required laws restricting the definition of marriage to be reviewed under a rational basis or strict scrutiny standard. He also argued that the majority misconstrued DOMA's insidious intent and should not rule based on that presumption. Justice Clarence Thomas and Chief Justice Roberts joined in the dissent. Justice Samuel A. Alito, Jr. also wrote a separate dissent in which he argued that the United States Government did not have standing in the case because the executive branch declined to defend the statute, but that BLAG did have standing because it chose to defend the otherwise undefended statute. He also argued that the Constitution does not guarantee the right to enter into a same-sex marriage because that right is not "deeply rooted in this Nation's history and tradition." Instead, the issue of the definition of marriage is left to the people to decide, a decision in which DOMA does not interfere. Justice Clarence Thomas partially joined in the dissent.


[Unknown Act > Facts]
Maetta Vance began working for University Dining Services at Ball State University in 1989 as a substitute server. She was the only African-American working in the department. Vance submitted a complaint to the University when a coworker used a racial epithet directed at her and African-American students at the University. The University issued the coworker a written warning, but following a series of incidents that resulted in Vance reporting that she felt unsafe in her workplace, the University investigated but found no basis for action. On October 3, 2006, Vance sued Ball State University in federal district court for lessening her work duties and ability to work overtime, forcing her to work through her breaks, and unjustly disciplining her. After filing the suit, Vance claimed her work environment continued to worsen, but the University's investigations did not yield enough evidence to discipline anyone.
The University moved for summary judgment. The district court granted the motion and held that there was not enough evidence to prove a hostile work environment and that the University was not liable for the actions of individual coworkers. Vance appealed, and the U.S. Court of Appeals for the Seventh Circuit affirmed the judgment of the lower court.


[Unknown Act > Conclusion]
No. Justice Samuel A. Alito, Jr. delivered the opinion for the 5-4 majority. The Court held that, for the purposes of liability for workplace harassment under Title VII, the definition of a "supervisor" is limited to a person empowered to take tangible employment action against the victim. Because Title VII creates a distinction between an employer's liability for the actions of a coworker and the actions of a supervisor, it is important to have clear distinction between the two definitions to aid in the application of the Title VII guidelines. Allowing the colloquial usage of "supervisor" that tends to conflate the concept of supervisor and coworker lacks the necessary specificity. The Court held that, to be considered a supervisor for the purposes of workplace employer liability, an individual must have the power to hire, fire, fail to promote, reassign to a task with significantly different duties, or cause a significant change in benefits available to the victim.
In his concurring opinion, Justice Clarence Thomas wrote that the majority's opinion establishes the "narrowest and most workable rule" for ruling on an employer's liability for harassment.
Justice Ruth Bader Ginsburg wrote a dissent in which she argued that the majority's opinion ignores the conditions of the modern workforce and that a more workable definition of a supervisor would be that offered by the Equal Employment Opportunity Commission (EEOC): anyone with the authority to direct an employee's daily activities. She argued that although a supervisor may not have the authority to discharge or demote the victim, a supervisor who can effect change in the victim's working conditions has similar power over the victim. The EEOC's definition reflects the agency's informed experience of the modern workplace and the importance of the specific facts of an employee's duties and relationship to other workers who can enable harassment. The majority's opinion, however, adopts an inflexible standard that is not responsive to these concerns. Justice Stephen G. Breyer, Justice Sonia Sotomayor, and Justice Elena Kagan joined in the dissent.


[Unknown Act > Facts]
Ernest Valencia Gonzales was convicted for the murder of Darrel Wagner. His conviction and death sentence became final on January 8, 1996. Gonzalez exhausted his state-court post-conviction relief opportunities before challenging his conviction in federal court.
In November 1999, Gonzales initiated a federal habeas proceeding, which raised 60 claims for federal habeas relief, including claims relating to Gonzales' competence and ability to rationally communicate with his court-appointed attorneys. The federal court stayed Gonzales' execution pending resolution of those proceedings. Ultimately, the district court denied Gonzales' motion for a competency hearing and a stay of proceedings. Even though it determined that Gonzales was incompetent, the court considered this irrelevant because Gonzales' claims could not benefit from rational communication with counsel.
Gonzales appealed to the U.S. Court of Appeals for the Ninth Circuit. It disagreed with the lower court and held that Gonzales was entitled to a stay pending a competency determination. The Arizona Department of Corrections appealed.
The related case, Tibbals v. Carter, was a similar capital murder appeal from the U.S. Court of Appeals for the Sixth Circuit. Sean Carter, the defendant, was adjudged incompetent to assist his attorneys following his murder conviction. The district court granted Carter a stay on his habeas corpus proceedings based on a right to competence in such proceedings. After the appellate court affirmed, the State appealed further and the Court granted certiorari to answer the same question as in Ryan v. Gonzales.


[Unknown Act > Conclusion]
No. In a unanimous opinion, Justice Clarence Thomas reversed the judgment of the Ninth Circuit and vacated the judgment of the Sixth Circuit. The Court reasoned that neither a statutory nor a constitutional right to competence exists during federal habeas corpus proceedings. Though the district court has broad discretion to grant a stay on habeas proceedings, this discretion is not without its limitations. In both cases, a stay was unwarranted because communication between the defendant and his attorney was unnecessary. The record provided adequate information for an attorney to handle habeas proceedings on his own, regardless of a client's incompetence. Even if the district court were to decide that the defendant's competence was necessary, it should only grant a stay if the defendant is likely to regain competence in the foreseeable future. Otherwise, allowing a stay on their proceedings would unreasonably burden the judicial system.


[Unknown Act > Facts]
In 1997, the Port of Los Angeles ("the Port") introduced a plan to expand its cargo terminals to better accommodate its high shipping volume. Following public concern that the plan could significantly increase air pollution, the Board of Harbor Commissioners adopted a Clean Air Action Plan ("CAAP"). The CAAP aimed to reduce emissions and specifically targeted the Port's drayage truck business. Roughly 16,000 drayage trucks regularly serve the Port, transporting goods between customers and the cargo terminals. Beginning in 2008, the CAAP banned drayage trucks from the Port, unless the carriers entered into a series of concession agreements. These agreements imposed a progressive ban on older trucks and provided incentives for drayage truck operators to convert their aging fleets to cleaner trucks.
American Trucking Associations ("ATA"), a national association of motor carriers, challenged several provisions within the concession agreements and brought suit against the City of Los Angeles and its Harbor Department. ATA argued that the Federal Aviation Administration Authorization Act ("FAAA") preempted the agreements. The FAAA Act prohibits a state from enacting any regulation related to the "price, route, or service of any motor carrier." ATA claimed that the concession agreements amounted to such a regulation. ATA further argued that the State could not limit a federally licensed motor carrier's access to a port.
The district court disagreed with ATA and held that none of the provisions were preempted; ATA appealed. The United States Court of Appeals for the Ninth Circuit affirmed in part and reversed in part. The appellate court determined that when the Port was acting as a market participant, rather than a market regulator, the FAAA Act did not apply. ATA appealed to the Supreme Court of the United States, which granted certiorari limited to the two questions below.


[Unknown Act > Conclusion]
No, and the Court declined to address the issue of whether a municipal government can ban federally licensed motor carriers' access to the ports. Justice Elena Kegan delivered the opinion for a unanimous Court. The Court held that the FAAA Act draws a rough line between a government's exercise of regulatory power and its own contract-based participation in a market. In this case, the government was not acting as a private participant in a contract but was wielding coercive power over private companies by threatening criminal punishment. The Court held that these actions clearly fit within the FAAA Act's prohibition on government regulating the "price, route, or service of any motor carrier." Contractual commitments resulting from the threat of criminal sanctions rather than ordinary bargaining clearly represent the government taking on a regulatory role.
Justice Clarence Thomas wrote a concurring opinion in which he noted that the FAAA Act's provision giving the federal government authority over intrastate commerce raises serious Constitutional concerns because the Constitution explicitly limits Congress' regulatory power to interstate commerce. However, because neither party raised a constitutional challenge to the FAAA Act, Justice Thomas joined with the majority.


[Unknown Act > Facts]
In 1996, Marvin Peugh and Steven Hollewell formed two companies: the Grainary, Inc., which bought, stored and sold grain; and Agri-Tech, Inc., which provided custom farming services to landowners and tenants. From January 1999 to August 2000, the two obtained bank loans by falsely representing future contracts and inflating the bank accounts by writing bad checks between the two accounts. Peugh pleaded not guilty to all counts, while Hollewell pleaded guilty to one count and agreed to testify against Peugh in exchange for the other charges being dropped. After a jury trial, Peugh was convicted on five counts of bank fraud. At sentencing, Peugh argued that he should be sentenced under the 1999 U.S. Sentencing Guidelines that were in effect at the time of the offense, rather than the 2009 Guidelines that were in effect at the time of sentencing. He argued that use of the later Guidelines violated the Ex Post Facto Clause. He was sentenced to 70 months in prison, and he and Hollewell were jointly ordered to pay nearly $2 million. The U.S. Court of Appeals for the Seventh Circuit affirmed.


[Unknown Act > Conclusion]
Yes. Justice Sonia Sotomayor delievered the opinion for the 5-4 majority. The Court held that Peugh's sentencing violated the ex post facto clause because, although the Supreme Court has held that the Sentencing Guidelines are not binding on lower courts, the Guidelines still must be used as an initial benchmark for sentencing. By setting an initial benchmark, the Guidelines forbid the government from altering the formula used to calculate an appropriate sentencing range. The lower court's refusal to apply the previous Guidelines in this case created a type of ex post facto law that changed the nature of a crime by inflicting a greater punishment than would be applied when the crime was committed.
In his dissent, Justice Clarence Thomas wrote that the Guidelines are not binding on lower courts, so they have no legal effect on a defendant's sentences. He also argued that any risk that a defendant might receive a harsher sentence results from the Guidelines' persuasive power, not any legal effect. Chief Justice John G. Roberts, Jr., Justice Samuel A. Alito, Jr., and Justice Antonin Scalia joined in the dissent. Justice Alito, joined by Justice Scalia, also filed a separate dissent in which he argued that retroactive application of advisory guidelines do not violate the test established in California Dept. of Corrections v. Morales. Under that test, laws only violate the ex post facto clause if they create a "sufficient risk" of increasing the measure of punishment attached to a crime.


[Unknown Act > Facts]
On March 10, 2010, Greg Knowles' home was damaged in a hailstorm, and he requested payment from his insurer, Standard Fire Insurance Company, for the full amount of the damage. On April 13, 2011, Knowles filed a class action lawsuit against Standard Fire Insurance Company alleging that he and others had been denied the full payment for damages that their contracts provided.
According to the Class Action Fairness Act of 2005 (CAFA), defendants in a class action lawsuit can move the case to federal court if the potential damages exceed $5 million. In the past, plaintiffs have attempted to avoid federal jurisdiction by stipulating that the potential damages in a given case are worth less than $5 million, and the U.S. Court of Appeals for the Eighth Circuit has allowed such a stipulation.
The defendant, Standard Fire Insurance Company moved the case from the Miller County Circuit Court to the Western District of Arkansas. The district court held that the plaintiffs' stipulation that the potential damages were less than $5 million was sufficient to prove with "legal certainty" that was the case. The U.S. Court of Appeals for the Eighth Circuit affirmed.


[Unknown Act > Conclusion]
No. Justice Stephen G. Breyer, writing for a unanimous court, vacated the lower court decision and remanded. To defeat jurisdiction the stipulation must be binding, and a plaintiff bringing a proposed class action cannot bind members of the proposed class before the class is certified. Knowles only has the authority to bind himself to a stipulated claim amount. Federal jurisdiction cannot be based on contingent future events, and the non-binding stipulation may not survive the certification process. For example, the complaint may clearly show an amount in controversy over $5 million, Knowles may be an inadequate class representative, or another party might intervene with an amended complaint. Individual plaintiffs may control jurisdiction through stipulation, but a named plaintiff in a not yet certified class action cannot.


[Unknown Act > Facts]
Carolyn Kloeckner filed a complaint with the Equal Employment Opportunity Commission (EEOC) alleging hostile work environment as well as sex and age discrimination. When her employer charged her with being "absent without leave," she amended her complaint to include retaliation. Kloeckner never returned to work, and eventually her employer terminated her. Kloeckner challenged the termination while her initial complaint was still pending, making it a "mixed case." Kloeckner appealed the termination to the Merit Systems Protection Board (MSPB), but then requested a dismissal so she could amend her EEOC complaint. The MSPB granted the dismissal, giving her a set period to refile.
When the EEOC found there had been no discrimination or retaliation, Kloeckner appealed the decision to the MSPB. While the appeal was within 30 days of the EEOC decision, it was 10 months after the refilling period set by the MSPB. The MSPB dismissed the case as untimely. Kloeckner filed an appeal in the District Court for the District of Columbia. The case was removed to the District Court for the Eastern District of Missouri, which held that the U.S. Court of Appeals for the Fifth Circuit had exclusive jurisdiction because the MSPB had not ruled on the merits of the case.


[Unknown Act > Conclusion]
Yes, the district court has jurisdiction. Justice Elena Kagan delivered the opinion of the unanimous Court. The Court held that the two relevant sections of Civil Service Reform Act both direct mixed cases to the district court rather that the Court of Appeals for the Federal Circuit. There was no legislative history to support a reading of the statutes as creating a distinction between merits-based as opposed to procedural appeals. The Court also held that Kloeckner's appeal was timely because it was filed within 30 days of her received notice of a "judicially reviewable action."


[Unknown Act > Facts]
On the night of June 9, 1996, Carlos Trevino and four others drove to a nearby store to pick up beer for a party. One of the men noticed 15-year old Linda Salinas and offered to drive her to a nearby restaurant. Instead, the group drove Linda to Espada Park in San Antonio, Texas where they started to sexually assault her. Trevino's cousin, Juan Gonzalez, refused to participate and returned to the car; meanwhile, Trevino and the three other men continued the assault. Linda's body was discovered in the park the next day with fatal stab wounds to her neck.
After their investigation, the San Antonio Police arrested Trevino and a grand jury indicted him on one count of intentional murder and attempt to commit aggravated sexual assault. At trial, Trevino's cousin Gonzalez testified against him. Gonzalez testified that the men returned to the car with blood on their shirts discussing the murder, with Trevino bragging about how he learned to kill in prison. With this evidence, the jury found Trevino guilty and was left to decide on an appropriate punishment. They determined that Trevino intended to kill Linda and was likely to commit such violent acts in the future. At the jury's suggestion, the trial court sentenced Trevino to death.
Through both the punishment phase of the trial and the first state habeas corpus proceeding, Trevino's attorney did not investigate or present any mitigating evidence that could have reduced Trevino's sentence. During the federal habeas proceeding that followed, Trevino's attorney withdrew and the court appointed new counsel. Trevino's new counsel undertook his own investigation and discovered several pieces of evidence that the jury could have found relevant during the punishment phase of the trial.
Trevino returned to state court and filed a second habeas corpus application on the basis that his first attorney had a duty to investigate and present the mitigating evidence. Since the attorney failed to do so, Trevino claimed that his Sixth Amendment right to a competent attorney had been denied. The state court denied his application, stating that Trevino should have presented the ineffective assistance of counsel claim during the first state habeas proceeding. Trevino returned to the federal district court to reassert this claim, but that court also denied his claim because it was never properly raised in state court. The district court went on to explain that the allegedly ineffective performance of his first attorney during state habeas proceedings did not excuse his failure to present an ineffective assistance of counsel claim during those proceedings. The United States Court of Appeals for the Fifth Circuit affirmed the district court's decision and Trevino appealed further. The Supreme Court granted certiorari limited to the question below.


[Unknown Act > Conclusion]
Yes. Justice Stephen G. Breyer delivered the opinion for the 5-4 majority. The Court vacated the lower courts' decisions and held that a procedural default will not bar a federal court from hearing a claim of ineffective assistance of trial counsel. The Court upheld a previous precedent established in Martinez v. Ryan that stated that an attorney's ignorance in a post-conviction hearing did not qualify as a reason to excuse a procedural default ruling. Because Texas' law made it virtually impossible for a defendant to present an ineffective assistance of counsel claim during an appeal, it was highly unlikely that a typical defendant could raise a claim of ineffective assistance of counsel
Chief Justice John Roberts, joined by Justice Samuel A. Alito, Jr., dissented, and argued that the rule established in Martinez was specifically designed to be applied in a very narrow fashion and that the majority's opinion represented an inconsistent expansion of that holding. Justice Antonin Scalia, joined by Justice Clarence Thomas, wrote a separate dissent in which he argued the rulings in both this case and Martinez drastically altered habeas corpus jurisprudence without providing clear benefits to the judicial process.


[Unknown Act > Facts]
Generally, wireless phone service providers must obtain zoning approvals from state and local governments before building wireless towers or attaching wireless equipment to buildings. To speed up the process, Congress amended the 1934 Communications Act and required local governments to respond to zoning requests within a reasonable period of time. Despite this law, the zoning approval process still dragged on and severely delayed construction. In 2008, the Wireless Association petitioned the Federal Communications Commission ("FCC") to bring an end to these unreasonable delays. The Association recommended placing time limits on how long these zoning requests could take. The FCC agreed and in November 2009 set the following "reasonable time" limits for zoning requests: 90 days for attachments to current buildings and a 150 days for new structures.
The local governments claimed that the FCC cannot set these limits because the FCC cannot determine its own power under the Communications Act. When Congress passed the Act, it granted a certain amount of power to the FCC to enforce and define the rules under the Act. Under the long-standing Chevron doctrine of interpretation, courts should always defer to an agency's interpretation of a particular act. However, the Supreme Court had never determined whether this applies to situations where the agency defines its own power under a particular law. The U.S. Court of Appeals for the Fifth Circuit nevertheless deferred to the FCC and affirmed the declaratory ruling. The local governments appealed to the Supreme Court, which granted certiorari exclusively to answer whether the Chevron doctrine applies in this situation.


[Unknown Act > Conclusion]
Yes. Justice Antonin Scalia, writing himself and four other justices, held that courts must apply the Chevron doctrine and defer to an agency's interpretation of its jurisdiction when that jurisdiction is called into question. The Chevron doctrine is supported Congressional intent that an agency should determine its jurisdiction when there is ambiguity in a statute. The Court held that there was no significant difference between "run-of-the-mill" ambiguity and important, "jurisdictional" ambiguity. Instead, every new application of an ambiguous statutory term could be reframed as a jurisdictional issue concerning the who, what, where, or when questions of an agency's regulatory power. The test should look at whether the statute's language prevents the agency's assertion of authority. If the agency's assertion is based on a permissible interpretation of the statute, then the courts must defer to the agency.
Justice Stephen G. Breyer concurred in part and concurred in the judgment. Although he agreed that courts should not get involved where Congress has deferred to an agency's judgment, he argued that the mere existence of ambiguity should not be considered conclusive evidence of Congress' intent to defer to that agency. Where Congressional intent is not clear, the courts should be permitted to interpret the statute accordingly.
Chief Justice John Roberts dissented and argued that a court should not defer to an agency until that court decides, on its own, that the agency is entitled to deference. However, once a court has made such a determination, Chevron deference may be warranted. Justice Anthony M. Kennedy and Justice Samuel A. Alito, Jr. joined in the dissent.


[Unknown Act > Facts]
In 2003, Congress enacted the United States Leadership Against HIV/AIDS, Tuberculosis, and Malaria Act ("the Act"). Through the Act, Congress apportioned billions of dollars towards the funding of non-governmental organizations ("NGOs") involved in the fight against HIV/AIDS. NGOs qualify to receive this funding only if they satisfy certain conditions. One of these conditions requires that all federally funded NGOs implement a policy explicitly opposing prostitution.
The Alliance for Open Society International, Inc., Pathfinder International, Global Health Council, and InterAction are NGOs that receive funding under the Act. The NGOs brought suit against the Agency for International Development and the other agencies responsible for enforcing the Act, challenging the constitutionality of the Act's funding provisions. The NGOs argued that the funding provisions violate the First Amendment by restricting the organizations' speech and forcing them to promote the government's viewpoint on prostitution. The district court agreed with the NGOs and held that the provisions were too broad of a restriction on free speech. The agencies appealed and the United States Court of Appeals for the Second Circuit affirmed.


[Unknown Act > Conclusion]
Yes. Chief Justice John G. Roberts, Jr. delivered the majority opinion. The Court held 6-2 that the government may not use funding and the threat of the loss of funding as a method for the regulation of speech and policies of non-governmental organizations. Because the Act's funding provisions represent an ongoing condition on the actions of the group receiving funding, the provisions essentially act as government coercion. The Court held that the funding provisions require the groups to accept the beliefs of the government, which infringes on their First Amendment rights.
Justice Antonin Scalia wrote a dissent in which he argued that the government has the right to choose to give financial support only to groups which share its views on how to address a particular issue. The fact that the government must often choose among many policy options does not mean that the government is coercing groups to adopt its views. Justice Clarence Thomas joined in the dissent.
Justice Elena Kagan did not participate in the discussion or decision in this case.


[Unknown Act > Facts]
Since 1982, Nike Inc. sold a shoe called the Air Force 1. The shoe has a distinctive appearance and Nike owns multiple federal trademark registrations for the shoe's design. In July 2009, Nike filed suit against Already, LLC for selling shoes that were confusingly similar to the Air Force 1 shoe. In November 2009, Already counterclaimed and requested cancellation of Nike's trademark on the basis that it interfered with Already's ability to continue selling its shoes.
To avoid further litigation, Nike provided Already with a covenant not to sue. The agreement promised that Nike would not pursue any legal action against Already with regard to trademark infringement. The District Court held a hearing to determine whether the covenant caused the court to lose subject matter jurisdiction over Already's counterclaims. Following the hearing, the District Court determined that it no longer had subject matter jurisdiction and dismissed the case. The U.S. Court of Appeals for the Second Circuit affirmed the decision, holding that the counterclaim alone did not create a case or controversy before the court; therefore the court did not have subject matter jurisdiction over the claim.


[Unknown Act > Conclusion]
No. Chief Justice John G. Roberts, Jr., writing for a unanimous court, affirmed the Ninth Circuit. The Supreme Court held that Nike's covenant not to sue made the case moot. Nike met its burden to show that it "could not reasonably be expected" to resume trademark enforcement action against Already. The language of the covenant was broad enough that the Court could not conceive of a shoe that would fall outside of its scope. The Court also rejected Already's assertion that dismissing the case would allow Nike to enforce invalid trademarks against any competitor by continually issuing covenants not to sue. Nike has an incentive not to do this because allowing many competitors to use Nike's marks, or confusingly similar ones, could lessen the strength of Nike's mark.
Justice Anthony M. Kennedy concurred, emphasizing that covenants not to sue should not be a first reaction to trademark litigation. Courts should be wary of large companies intentionally burdening smaller competitors with infringement actions only to turn around and promise not to sue after learning valuable future business information. A covenant not to sue should only terminate litigation when it meets the high burden required by in this case. Justice Clarence Thomas, Justice Samuel A. Alito, Jr., and Justice Sonia Sotomayor joined in the concurrence.


[Unknown Act > Facts]
The Maryland DNA Collection Act (MDCA) allows state and local law enforcement officers to collect DNA samples from individuals who are arrested for a crime of violence, an attempted crime of violence, burglary, or attempted burglary. Alonzo Jay King, Jr. was arrested on first and second degree assault charges. While under arrest, but prior to conviction, King's DNA was collected and logged in Maryland's DNA database. That database matched King's DNA to a DNA sample from an unsolved rape case. This sample was the only evidence linking King to the rape. The trial judge denied King's motion to suppress the DNA evidence and he was convicted of first-degree rape and sentenced to life in prison.
King appealed the conviction, arguing that the MDCA was an unconstitutional infringement of his Fourth Amendment privilege against warrantless searches. The Court of Appeals of Maryland reversed, holding that the MDCA was unconstitutional. The court held that King's expectation of privacy was greater than Maryland's interest in using the DNA for identification purposes.


[Unknown Act > Conclusion]
Yes. Justice Anthony M. Kennedy delivered the opinion of the 5-4 majority. The Court held that conducting a DNA swab test as a part of the arrest procedure does not violate the Fourth Amendment because the test serves a legitimate state interest and is not so invasive so as to require a warrant. The routine administrative procedures that occur during a booking for an arrest do not require the same justification and the search of a location. The Court held that ascertaining an arrestee's identity and criminal history is a crucial part of the arrest procedure and that a DNA test is just as valid and informative as fingerprinting. Determining an arrestee's criminal history also serves the legitimate state interest of determining what level of risk the individual poses to the public and what conditions should be set on his/her release from custody.
Justice Antonin Scalia wrote a dissent in which he argued that the Fourth Amendment categorically prevents searching a person for evidence of a crime without cause. Because the majority's opinion allows for DNA tests to be conducted in the absence of evidence linking the arrestee to a specific DNA-related crime, these tests fall within the boundaries of the British "general warrants" the Fourth Amendment was intended to prohibit. He also argued that the procedural safeguards on the DNA evidence make it an ineffective and redundant identification tool. Justice Ruth Bader Ginsburg, Justice Sonia Sotomayor, and Justice Elena Kagan joined in the dissent.
Learn more about the Roberts Court and the Fourth Amendment in Shifting Scales, a nonpartisan Oyez resource.


[Unknown Act > Facts]
On March 12, 2003, Steven Levin was scheduled to undergo cataract surgery performed by Lieutenant Commander Frank Bishop, M.D., a United States Navy surgeon in Guam. Levin previously gave his written consent to the procedure but claims that he attempted to orally withdraw it prior to the surgery. He suffered complications from the surgery and faces continuing treatment with unclear likelihood of success. Levin sued Dr. Bishop for battery and negligent medical malpractice. The United States substituted itself for Dr. Bishop and filed a motion for summary judgment. The district court granted summary judgment for the negligent medical malpractice claim, not the battery claim. The United States then filed for dismissal of the battery claim and alleged that the Federal Tort Claims Act preserved sovereign immunity against battery claims. The district court dismissed the claim. The United States Court of Appeals for the Ninth Circuit affirmed.


[Unknown Act > Conclusion]
No. Justice Ruth Bader Ginsburg delivered a unanimous opinion reversing the Ninth Circuit's judgment and remanding for further proceedings. In general, the Federal Tort Claims Act ("FTCA") allows a plaintiff to bring a tort claim against the United States, unless that claim alleges an intentional tort, such as battery. However, the Medical Malpractice Immunity Act, also known as the Gonzalez Act, carved out a specific exception to this rule. The Gonzalez Act states that the intentional tort exception to the FTCA "shall not apply" to certain tort claims alleging wrongful or negligent medical care. The Court applied the plain meaning of the statute and held that the Gonzalez Act nullifies the FTCA's intentional tort exception when a plaintiff alleges medical battery by an armed forces physician. Since the intentional tort exception does not apply, Levin should be allowed to proceed with his suit against the United States.


[Unknown Act > Facts]
In early 2010, Anthony Davila was tried for defrauding the federal government by filing false tax returns. During a hearing before the magistrate judge, Davila requested to discharge his court-appointed attorney. Davila was concerned that the attorney had not discussed any possible trial strategies with him; the attorney merely insisted that Davila plead guilty. The magistrate judge explained to Davila that there might not be another viable option and that pleading guilty may be the best advice his attorney could have given him. Following the judge's advice, Davila plead guilty and was subsequently sentenced to 115 months imprisonment.
Davila appealed to the United States Court of Appeals for the Eleventh Circuit. Davila argued that the magistrate judge's advice to plead guilty warranted a new trial. Under the Federal Rules of Criminal Procedure, the court must not be involved in any plea discussions. Since the judge commented on the weight of the evidence against Davila and suggested that a guilty plea would result in a more lenient sentence, he participated in such a plea discussion. As a result of this violation, Davila claimed that the court should vacate the judgment. The appellate court agreed with Davila, vacated the judgment, and remanded the case for further proceedings.


[Unknown Act > Conclusion]
No. Justice Ruth Bader Ginsberg delivered the opinion for the 7-2 majority. The Court held that a judge's improper participation in plea discussions does not belong in the "highly exceptional" category of errors that trigger an automatic reversal of a defendant's guilty plea. Instead, such misconduct falls within the category of "harmless error." Because Davila failed to raise the issue of the magistrate judge's comments at his hearing, he had the burden to show that, but for the misconduct, he would not have pled guilty. In this case, the three-month window between Davila's conversation with the magistrate and his guilty plea de-emphasized the role of the judge's comments in affecting the plea.
Justice Antonin Scalia wrote an opinion concurring in part and concurring in the judgment. He argued that the case could be decided based simply on the text of the harmless error rule, which states that a harmless error is one that "does not affect substantial rights." According to Scalia, the majority's analysis of legislative history to discern the scope of the harmless error rule was unnecessary. Justice Clarence Thomas joined in the partial concurrence and concurrence in judgment.


[Unknown Act > Facts]
Emily M. Armstrong, daughter of Sandra and William Earl Armstrong, was born on February 25, 2000. She was seriously injured during her delivery resulting in mental retardation, cerebral palsy and several other medical conditions. Emily's mother applied for Medicaid two months after her daughter's birth. Since then the North Carolina state Medicaid program had paid over $1.9 million in medical expenses on Emily's behalf. Emily's parents and guardian sued the physicians for negligently delivering their child and won a settlement of $2.8 million. As a result, the North Carolina Department of Health and Human Services ("DHHS") placed a lien on Emily's settlement, looking to recover some of the money it paid for Emily's health care services. Under the North Carolina third-party liability statutes, when a patient wins an award of medical expenses, the DHHS has the right to recover either the total amount spent on the patient's health care, or one third of the patient's recovery payment, which ever is less.
Emily's parents and guardian brought suit against the DHHS, claiming that federal Medicaid law prevents the DHHS from taking her proceeds. Federal law prohibits recovery from any payments not made for past medical expenses. Since under North Carolina law a minor child is not allowed to recover for past medical expenses, Emily's settlement could not include such expenses. The United States District Court for the Western District of North Carolina disagreed with this argument and granted summary judgment to the state.
The Armstrongs appealed, and the United States Court of Appeals for the Fourth Circuit vacated the lower court's decision. While the appellate court agreed with the lower court that the DHHS has the right to recover from Emily's settlement, it remanded the case because the state failed to provide a mechanism for determining what part of a settlement covers past medical expenses. Since the North Carolina statutes do not attempt to recover payment for past medical expenses, they violate federal Medicaid law.


[Unknown Act > Conclusion]
Yes. Justice Anthony M. Kennedy, writing for a 6-3 majority, affirmed the lower court. The North Carolina law is preempted by federal law to the extent that it would allow the state to recover part of a Medicaid beneficiary's tort judgment or settlement not designated for medical expenses. Arbitrarily designating one-third of a judgment as recoverable medical expenses lacks any limiting principle. If upheld, nothing could stop a state from arbitrarily designating one-half or all of a judgment as medical expenses. Calculating the actual amount of medical expenses in each case may be more difficult than the one-third rule, but similar allocation procedures are already used other circumstances, such as worker's compensation and separating compensatory and non-compensatory damages for tax purposes. Justice Stephen G. Breyer concurred, stating that he agreed with the majority because the Centers for Medicare and Medicaid Services had already reached the same conclusion.
Chief Justice John G. Roberts, Jr. dissented, arguing that no regulation or prior case law requires a specific allocation of damages recovered for medical expenses. States should be allowed more leeway to come up with a workable regulation to recoup Medicaid payments. Justice Antonin Scalia and Justice Clarence Thomas joined in the dissent.


[Unknown Act > Facts]
The Fourteenth Amendment protects every person's right to due process of law. The Fifteenth Amendment protects citizens from having their right to vote abridged or denied due to "race, color, or previous condition of servitude." The Tenth Amendment reserves all rights not granted to the federal government to the individual states. Article Four of the Constitution guarantees the right of self-government for each state.
The Voting Rights Act of 1965 was enacted as a response to the nearly century-long history of voting discrimination. Section 5 prohibits eligible districts from enacting changes to their election laws and procedures without gaining official authorization. Section 4(b) defines the eligible districts as ones that had a voting test in place as of November 1, 1964 and less than 50% turnout for the 1964 presidential election. Such districts must prove to the Attorney General or a three-judge panel of a Washington, D.C. district court that the change "neither has the purpose nor will have the effect" of negatively impacting any individual's right to vote based on race or minority status. Section 5 was originally enacted for five years, but has been continually renewed since that time.
Shelby County, Alabama, filed suit in district court and sought both a declaratory judgment that Section 5 and Section 4(b) are unconstitutional and a permanent injunction against their enforcement. The district court upheld the constitutionality of the Sections and granted summary judgment for the Attorney General. The U.S. Court of Appeals for the District of Columbia Circuit held that Congress did not exceed its powers by reauthorizing Section 5 and that Section 4(b) is still relevant to the issue of voting discrimination.


[Unknown Act > Conclusion]
Yes, Section 4 of the Voting Rights Act is unconstitutional. Chief Justice John G. Roberts, Jr. delivered the opinion of the 5-4 majority. The Court held that Section 4 of the Voting Rights Act imposes current burdens that are no longer responsive to the current conditions in the voting districts in question. Although the constraints this section places on specific states made sense in the 1960s and 1970s, they do not any longer and now represent an unconstitutional violation of the power to regulate elections that the Constitution reserves for the states. The Court also held that the formula for determining whether changes to a state's voting procedure should be federally reviewed is now outdated and does not reflect the changes that have occurred in the last 50 years in narrowing the voting turnout gap in the states in question.
In his concurring opinion, Justice Clarence Thomas argued that Section 5 of the Voting Rights Act is unconstitutional in addition to Section 4. He wrote that the blatant discrimination against certain voters that Section 5 was intended to prohibit is no longer evident. Without such extraordinary circumstances, Congress cannot constitutionally justify placing the burden of Section 5 on the states in question.
Justice Ruth Bader Ginsburg wrote a dissent in which she argued that Congress' power to enforce the Fourteenth and Fifteenth Amendments encompasses legislative action such as the Voting Rights Act. The legislative history and text of the Amendments as well as previous judicial precedent support Congress' authority to enact legislation that specifically targets potential state abuses. However, Congress does not have unlimited authority but must show that the means taken rationally advance a legitimate objective, as is the case with the Voting Rights Act. The evidence Congress gathered to determine whether to renew the Voting Rights Act sufficiently proved that there was still a current need to justify the burdens placed on the states in question. She also argued that, by holding Section 4 unconstitutional, the majority's opinion makes it impossible to effectively enforce Section 5. Justice Stephen G. Breyer, Justice Sonia Sotomayor, and Justice Elena Kagan joined in the dissent.


[Unknown Act > Facts]
Two logging roads in Oregon, Trask River Road and Sam Downs Road, are owned by the Oregon Department of Forestry and the Oregon Board of Forestry. The roads are used primarily by various logging companies. These roads run parallel to rivers and use a series of ditches, culverts, and channels to direct storm water runoff into the nearby rivers. This runoff deposits large amounts of sediment in the rivers, which adversely affects the fish and other wildlife that relies on the water.
The Northwest Environmental Defense Center (NEDC) sued the Oregon State Forester, the Oregon Board of Forestry and several timber companies. The NEDC alleged that, since the runoff ditches and channels can be defined as "point sources," the petitioners violated the Clean Water Act by failing to obtain permits under the National Pollutant Discharge Elimination System. In district court, the petitioners moved for dismissal by arguing that the runoff was exempt from the permits. The district court granted the motion. The NEDC appealed the case to the United States Court of Appeals for the Ninth Circuit, which reversed the decision based on precedent that supported the NEDC interpretation of both the "point source" and the permit requirement.


[Unknown Act > Conclusion]
No and yes. Justice Anthony M. Kennedy, writing for a 7-1 majority, reversed the Ninth Circuit's decision and remanded for further proceedings. The Court held that the Clean Water Act exempts the storm water runoff from the permitting scheme because the runoff is not associated with industrial activity. Even though the roads are used for the transport of raw materials, they are not used for the manufacturing, processing, or storage of those materials. The Court deferred to the Environmental Protection Agency's own reasonable interpretation that the permit requirement extends only to traditional industrial sites, such as factories. Therefore, the runoff ditches and channels did not constitute point sources that require permits under the Act.


[Unknown Act > Facts]
Roselva Chaidez came to the United States from Mexico in 1971; she became a lawful permanent resident in 1977. In 2003, she was indicted in the U.S. District Court for the Northern District of Illinois on three counts of mail fraud in connection with an insurance scheme. On the advice of her attorney, Chaidez pleaded guilty and received a sentence of four years of probation. The U.S. government initiated removal proceedings in 2009 under a federal law that allows deportation of any alien who commits an aggravated felony. Chaidez's attorney never told her that pleading guilty could lead to her deportation.
Chaidez filed for a writ of coram nobis, arguing ineffective assistance of counsel. While this motion was pending before the district court, the U.S. Supreme Court issued its decision in Padilla v. Kentucky, holding that it is ineffective assistance of counsel when an attorney fails to advise a client that he or she may face deportation as a result of pleading guilty. The district court concluded that Padilla did not announce a new rule, so its holding applied to Chaidez's case. The U.S. Court of Appeals for the Seventh Circuit reversed, holding that Padilla does announce a new rule and is not retroactively applicable in this case.


[Unknown Act > Conclusion]
No. Justice Elena Kagan delivered the opinion for the 7-2 majority. The Supreme Court held that the Padilla ruling created an entirely new rule relating to whether advice about deportation fell under the scope of the Sixth Amendment right to counsel. Because the Court considered this rule separately from previous cases, it was considered a new rule and therefore could not retroactively apply to already decided cases.
Justice Clarence Thomas wrote an opinion concurring in the judgment only arguing that the Sixth Amendment provides for adequate assistance of counsel in the charged offense and does not extend to advice regarding possible consequences, such as deportation. He dissented in the Padilla case and therefore concurred only in the judgment in this case.
Justice Sonia Sotomayor wrote a dissenting opinion in which she argued that the decision in Padilla did not create a new rule but only extended previous analysis of Sixth Amendment rights to a new set of facts. Because the Padilla decision only clarified an attorney's responsibility to a client and did not create any new distinctions, the ruling should apply retroactively to previously decided cases. Justice Ruth Bader Ginsburg joined in the dissent.


[Unknown Act > Facts]
Defendant Mark Gabelli was the portfolio manager for the Gabelli Global Growth Fund (GGGF), as well as several affiliated funds, from 1997 until 2004. Defendant Bruce Alpert had been the Chief Operating Officer of Gabelli Funds, a company that advises GGGF, since 1988. Beginning in 1999, Gabelli permitted another company, Headstart, to engage in "market-time" trading with GGGF. "Market-time" trading is premised on the fact that price movements during the New York trading day can cause corresponding movements in the international markets that will not be incorporated into new stock prices until the following day. Traders can then buy and sell at artificially low and high prices, respectively. By early 2002, Alpert became concerned about the effects of market-timing and instructed Headstart to reduce the number of those transactions. On August 7, 2002, Gabelli announced that all market-timing must stop, and Headstart pulled its money from GGGF.
On September 3, 2003, the New York Attorney General announced an inquiry into market-timing. On April 24, 2008, the SEC sued the defendants and alleged that Gabelli and Alpert knew of Headstart's market-timing but deliberately mislead GGGF's Board and shareholders in violation of the Securities and Exchange Act of 1934. The district court dismissed the SEC's claims for failure to bring the suit within the five-year statute of limitations, and the SEC appealed. The United States Court of Appeals for the Second Circuit reversed.


[Unknown Act > Conclusion]
When the alleged violation is committed. Chief Justice John G. Roberts, Jr., writing for a unanimous Court, reversed the Second Circuit and remanded. Starting the limitations period at the time of the violation is the most natural reading of the statute. This reading is supported by past precedent and dictionary definitions. In the past, the "discovery rule", which pauses the statute of limitations until fraud is discovered, has been applied when the victims of the fraud would be denied relief. The protection that the rule provides for the injured is not relevant to a Government enforcement action such as this one. It would also be nearly impossible to determine when the Government "knows" of a violation and Congress did not require that determination.


[Unknown Act > Facts]
Dr. Naiel Nassar, who is of Middle Eastern descent, was hired by the University of Texas Southwestern Medical Center (UTSW) in 1995 to work at the Amelia Court Clinic (Clinic), which specializes in HIV/AIDS treatment. After three years there, he left to pursue additional training and returned in 2001 as an Assistant Professor of Internal Medicine and Infectious Diseases and Associate Medical Director of the Clinic. His immediate supervisor at the Clinic was Dr. Philip Keiser, whose supervisor at UTSW was Dr. Beth Levine. After being hired in 2004, Levine immediately began inquiring into Nassar's productivity and billing practices. In 2005, after interviewing a candidate who was of Middle Eastern descent, Levine stated in Nassar's presence, "Middle Easterners are lazy." In 2006, after hiring the candidate, Levine made a similar statement in Keiser's presence. Keiser informed Nassar of these comments as well as the fact that Levine scrutinized Nassar's productivity more than any other doctor. Around this time, Nassar applied for a promotion that Levine actively undermined. In 2006, Nassar resigned from the UTSW faculty and cited Levine's harassment and the creation of an unhealthy work environment in his resignation letter. Nassar resigned with the understanding that he would be offered a position at the Amelia Court Clinic unaffiliated with the UTSW, but the Clinic was forced to withdraw its offer after heavy opposition from the UTSW faculty, who have an agreement with the Clinic regarding positions to be filled by faculty doctors.
In 2008, Nassar sued UTSW under Title VII of the Civil Rights Act of 1964 and argued that UTSW had constructively discharged and retaliated against him. The jury found in favor of Nassar and awarded him back pay and compensatory damages. The U.S. Court of Appeals for the Fifth Circuit affirmed in part and reversed in part, holding that there was sufficient evidence to support the retaliation claim but insufficient evidence to support the claim of constructive discharge.


[Unknown Act > Conclusion]
The retaliation provision of Title VII requires the plaintiff to prove than an employer would not have taken an action but for the existence of improper motives. Justice Anthony M. Kennedy delivered the opinion for the 5-4 majority. The Court held that there must be a demonstrable causal link between the injury sustained and the wrong alleged. A standard understanding of causation supports the view that an action cannot be the cause of an event unless it can be shown that the event would not have occurred without the action in question. Because there is no language in the retaliation provision that states otherwise, it must be assumed that Congress intended to support the standard understanding of causation. The Court also held that lessening the causation standard would increase the number of frivolous claims and decrease the ability of employers and the courts to deal with the pressing issues of real workplace harassment.
Justice Ruth Bader Ginsburg wrote a dissenting opinion in which she argued that the majority's decision creates an unnecessary dichotomy between discrimination cases and retaliation cases by restricting retaliation cases to a stricter standard of proof. In doing so, the majority's opinion ignores extensive judicial precedent that supports the close connection between anti-discrimination and anti-retaliation provisions. Additionally, there is no evidence that Congress intended to provide less protection from discrimination than from retaliation, as the majority's reading of the provision suggests. She also argued that the "but-for" causation test is particularly difficult to implement in employment discrimination cases as it requires trial courts to reach conclusions as to what would have happened had the employer's thoughts been different. Justice Stephen G. Breyer, Justice Sonia Sotomayor, and Justice Elena Kagan joined in the dissent.


[Unknown Act > Facts]
In 1994, Coy A. Koontz requested a permit from St. John's River Water Management to develop more of his land than the original permit allowed. St. John's had jurisdiction over Koontz's land. St. John's agreed to issue the permit on the condition that Koontz deed the rest of his property into a conservation area and do some mitigation work on the surrounding areas. Koontz agreed to the deed but not to the mitigation work. St. John's denied the permit application.
Koontz sued St. John's River Water Management, and the trial court found in favor of Koontz. A Florida trial court held that St. John's actions effected a taking of Koontz land and that imposing requirements for the issuance of a permit is only constitutional if the required action serves the same governmental purpose as the ban on development. Florida's Fifth District Court of Appeal affirmed. The Supreme Court of Florida reversed.


[Unknown Act > Conclusion]
Yes. Justice Samuel A. Alito Jr. delivered the opinion of the 5-4 majority. The Court held that the government may not conditionally approve land-use permits unless the conditions are connected to the land use and approximately proportional to the effects of the proposed land use. This standard even applies when the government does not approve the permit but instead demands that the condition be met before granting the permit. Such demands, which amount to asking for property or money from an applicant, place a burden the applicant’s ownership of the land. This burden diminishes the value of the land, which violates the Constitutional protections against having property taken without just compensation.
Justice Elena Kagan filed a dissenting opinion in which she argued that the limitations on the government’s ability to conditionally approve land-use permits do not apply to monetary exactions. She also wrote that applying those limits would likely inhibit local governments’ ability to charge reasonable permitting fees. Justice Ruth Bader Ginsburg, Justice Stephen G. Breyer, and Justice Sonia Sotomayor joined in the dissent.


[Unknown Act > Facts]
Armarcion D. Henderson pleaded guilty to being a felon in possession of a firearm in violation of federal law. The sentencing guideline range was 33-41 months, but the judge sentenced Henderson to 60 months to ensure that he had the opportunity to enroll in the Bureau of Prisons drug program. Henderson did not object to the sentence. Eight days after sentencing, Henderson filed a motion to correct the sentence. The district court denied the motion.
The U.S. Court of Appeals for the Fifth Circuit affirmed, holding that Henderson did not preserve the error for correction under the Federal Rules of Criminal Procedure, so the court reviewed the decision for plain error. Henderson did not show plain error because the error was not clear under current law at the time of trial. The court of appeals denied a petition for rehearing en banc.


[Unknown Act > Conclusion]
Yes and yes. Justice Stephen G. Breyer delivered the opinion for a 6-3 majority. The Supreme Court held that that an error is deemed to be a "plain error" based on the law at the time of the appellate review of the case, not at the time of the trial. It is unreasonable to expect either the defendant or the trial court to predict the outcome of unsettled issues of law, therefore it is the role of the appellate court to review what is considered "plain error" at the time of the appellate review.
Justice Antonin Scalia wrote a dissenting opinion in which he argued that an issue of law that is unsettled at the time of the trial cannot be considered "plain error" for the purposes of appellate review. An error can only be plain if it should have been obvious to the court and the prosecution at the time of the trial. Justice Clarence Thomas and Justice Samuel A. Alito, Jr. joined in the dissent.


[Unknown Act > Facts]
On October 3, 2010, Missouri state police officer Mark Winder saw Tyler McNeely driving above the speed limit. When Winder followed McNeely to pull him over, he saw McNeely cross the center line three times. Upon making contact with McNeely, Wilder observed that his eyes were red and glassy, and that his breath smelled like alcohol. McNeely performed poorly on four field sobriety tests and refused to submit to a portable breath test. Wilder arrested McNeely for driving while intoxicated and transported him to a hospital to obtain a blood sample. Wilder read McNeely the Missouri Implied Consent statement, and McNeely still refused to submit the sample. Wilder ordered the sample taken anyway, and the blood test revealed McNeely's blood alcohol level was far above the legal limit.
The state charged McNeely with driving while intoxicated, and McNeely moved to suppress the evidence of the blood sample because it was obtained without a warrant. The trial court granted the defendant's motion. The state appealed and argued that the risk of McNeely's blood alcohol level decreasing over time represented an exigent circumstance requiring a blood draw. The Missouri Court of Appeals held that the trial court erred, but that the case represented a departure from current case law; it transferred the case to the Missouri Supreme Court. The Supreme Court of Missouri affirmed the trial court's decision.


[Unknown Act > Conclusion]
Yes. Justice Sonia Sotomayor delivered the opinion of the 5-4 plurality. The Supreme Court held that the Fourth Amendment’s protection against warrantless searches applies to blood alcohol tests unless specific exigent circumstances exist. Because each case must be considered based on its individual facts, there are cases in which the natural dissipation of alcohol in the blood would be considered an exigent circumstance, but there is no reason to create a categorical rule. The Court also held that the Fourth Amendment’s protection against bodily intrusions outweighs the state’s interest in gaining evidence quickly.
In his partial concurrence, Justice Anthony M. Kennedy wrote that the case in question does not provide the basis for any categorical rule on the issue of conducting a blood alcohol test without a warrant. He also wrote that the Fourth Amendment does not allow the warrant requirement to be entirely ignored in drunk driving arrests. Chief Justice John G. Roberts, Jr. wrote an opinion concurring in part and dissenting in part in which he argued that there must be a categorical rule on this issue to provide appropriate guidance to law enforcement officials. He argued that exigent circumstances exist and justify a warrantless blood test if the officer believes there is not sufficient time to obtain a warrant before critical evidence is lost through natural metabolic processes. If there is time to secure a warrant, the officer must do so. Justice Stephen G. Breyer and Justice Samuel A. Alito, Jr. joined in the partial concurrence and partial dissent.
Justice Clarence Thomas wrote a dissenting opinion in which he argued that the body’s natural metabolization of alcohol constitutes the destruction of evidence and represents an exigent circumstance. The importance of obtaining evidence allows the police to conduct a warrantless blood alcohol test without violating the Fourth Amendment.
Learn more about the Roberts Court and the Fourth Amendment in Shifting Scales, a nonpartisan Oyez resource.


[Unknown Act > Facts]
Kim Millbrook was an inmate at the United States Penitentiary, Lewisburg, Pennsylvania. Millbrook alleges that a correctional officer took him to the basement of the Special Management Unit and sexually assaulted him while other officers stood by. Millbrook filed a complaint under the Federal Tort Claims Act (FTCA) alleging sexual assault. Under 28 U.S.C. §2680(h), the United States is not liable for the intentional torts of its employees, except for certain torts committed by law enforcement officials. Pooler v. United States, 787 F.2d. 868 (1986) limited claims that arise under §2680(h) to intentional torts by a law enforcement officer while executing a search, seizing evidence, or making arrests for violations of federal law. The district court granted summary judgment in favor of the United States, holding that Millbrook's claim was precluded by Pooler. The U.S. Court of Appeals for the Third Circuit affirmed, noting that the definition of seizure is limited to seizure of evidence.


[Unknown Act > Conclusion]
Yes. Justice Clarence Thomas delivered the opinion of the unanimous Supreme Court. The Court held that nothing in the text of the proviso itself implies a more specific reading than that a tort law claim may be filed when a law enforcement officer’s actions fall within the scope of his employment. The text indicates that Congress intended the proviso to focus on the status of the individual rather than the type of action.


[Unknown Act > Facts]
On October 1, 2009, Allen Ryan Alleyne and two accomplices robbed the store manager of a Mapco/East Coast convenience store in Petersburg, Virginia as he was dropping off the nightly deposit at the bank. In April 2010, after an extensive investigation, the authorities arrested Alleyne and a grand jury indicted him for robbery and possessing a firearm. On September 7, 2010, after a week-long trial, the jury convicted Alleyne on both counts and the United States District Court for the Eastern District of Virginia sentenced him to 130 months imprisonment.
Alleyne appealed to the United States Court of Appeals for the Fourth Circuit, claiming the district court made three specific errors: 1) the evidence against him wasn't strong enough to support his convictions; 2) he was convicted of aiding and abetting the robbery and not carrying it out, which changed his original indictment; and 3) he should not have received a mandatory 7 year sentence for possession of a firearm. The Fourth Circuit rejected all three of his claims. First, the appellate court refused to overrule the jury's decision on the strength of the evidence because a jury is best equipped to determine whether evidence is credible. Second, since aiding and abetting a crime is not itself a separate offense, it does not need to be included in the indictment and does not change the original charge. Finally, there was no indication that the district court should not have imposed the minimum sentence for possessing a firearm.


[Unknown Act > Conclusion]
No, yes, no. Justice Clarence Thomas delivered the opinion for the 5-4 majority. The Court held that the Sixth Amendment guarantees the accused a right to a trial by a fair and impartial jury, which can only be accomplished if all of the facts that are elements of the crime are presented to the jury. If an element of the crime increases the mandatory minimum punishment, it must be submitted to the jury and found to be true beyond a reasonable doubt. The Court also held that, because an indictment must contain every allegation legally essential to punishment, a defendant cannot be found guilty of a crime not included in the indictment.
In her concurring opinion, Justice Sonia Sotomayor wrote that, although the Court generally follows precedent, when the analysis supporting a previous decision has been sufficiently undermined, it is appropriate to overturn it. She argues that the majority's opinion is not the result of judicial sentiment but rather a recognition of shifting Sixth Amendment jurisprudence. Justice Ruth Bader Ginsburg and Justice Elena Kagan joined in the concurrence. Justice Stephen G. Breyer wrote an opinion concurring in part and dissenting in part in which he argued that jury factfinding would serve as a check on judicial power to impose maximum or minimum sentences.
Chief Justice John G. Roberts, Jr. wrote a dissent in which he argued that the Sixth Amendment was intended to protect defendants from the government but does not limit a judge's discretion within the limits set by the jury. Once a jury finds a defendant guilty, it is the judge's duty to set a punishment within the appropriate limits, and there is no risk of judicial overreach within those limits. He also argued that the majority's decision does not have a basis in judicial history. Justice Antonin Scalia and Justice Anthony M. Kennedy joined in the dissent. In his separate dissent, Justice Samuel A. Alito, Jr. wrote that the majority's opinion alters judicial precedent simply because a majority disagrees with it, without the proper justification.