The case involved Arthur Andersen LLP, Enron's auditor, which directed its employees to destroy documents under its retention policy as Enron faced SEC scrutiny and potential litigation in 2001. A jury convicted Andersen of violating 18 U.S.C. §§ 1512(b)(2)(A) and (B) by corruptly persuading others to withhold or alter documents for an official proceeding, and the Fifth Circuit affirmed. The Supreme Court reversed, holding that the jury instructions failed to properly convey the statutory elements of corrupt persuasion. The Court reasoned that the instructions did not require the government to prove the defendant acted with consciousness of wrongdoing or a specific intent to affect an official proceeding.
In Pace v. DiGuglielmo, the Supreme Court considered whether a state postconviction petition dismissed by the state court as untimely could still toll AEDPA's one-year statute of limitations for filing a federal habeas corpus petition under 28 U.S.C. § 2244(d)(2). Petitioner John Pace had been convicted in Pennsylvania state court in 1986 and filed a later PCRA petition that the state courts rejected as untimely under the PCRA's statute of limitations. The Court held that an untimely state petition is not "properly filed," so it does not toll the federal limitations period and Pace's habeas petition was time-barred. The core reasoning followed from Artuz v. Bennett, which treated state time limits as conditions to filing rather than conditions to obtaining relief, meaning a petition rejected as untimely cannot be considered properly filed for tolling purposes.
The case concerned whether a lawful permanent resident's state conviction for driving under the influence causing serious bodily injury qualified as a "crime of violence" under 18 U.S.C. §16 and thus an "aggravated felony" under the Immigration and Nationality Act, rendering him deportable. The Supreme Court held that the Florida DUI offense did not meet the definition of a crime of violence. The Court reasoned that §16(a) requires an offense with the use, attempted use, or threatened use of physical force as an element, while §16(b) requires a felony that by its nature involves a substantial risk that physical force will be used in committing the offense; a DUI statute based on negligence or no mens rea creates only a risk of accidental injury, not the required risk of using force. The Court also applied the rule of lenity to resolve any ambiguity against a broader reading that would trigger deportation.
The case concerned customs officials at the U.S.-Mexico border who removed and disassembled the gas tank of respondent's vehicle during a secondary inspection, discovering 37 kilograms of marijuana hidden inside. Respondent was indicted on federal charges of importing marijuana and possessing it with intent to distribute; he moved to suppress the evidence on Fourth Amendment grounds, arguing that the search required reasonable suspicion. Lower courts agreed and granted suppression, but the Supreme Court reversed, holding that suspicionless searches of vehicles at the international border, including removal and reassembly of a gas tank, are reasonable under the Fourth Amendment. The Court's reasoning emphasized the government's plenary authority to conduct border searches to protect against unlawful entry of persons and effects, noted that vehicle searches do not implicate the same dignity and privacy concerns as highly intrusive searches of the person, and rejected any requirement for a case-by-case balancing test to classify searches as routine or nonroutine.
In Maryland v. Pringle, a police officer stopped a car for speeding, found $763 in cash in the glove compartment and five baggies of cocaine behind the back seat armrest during a consent search, and arrested all three occupants after none claimed ownership of the drugs. The Supreme Court held that the officer had probable cause to arrest Pringle, the front-seat passenger, for possession of a controlled substance. The Court reasoned that probable cause is a practical standard based on the totality of circumstances, and the presence of drugs and a large amount of cash in a small vehicle occupied by three men who all denied ownership supported a reasonable inference that all were involved in the crime. This reversed the Maryland Court of Appeals, which had found insufficient facts linking Pringle specifically to the drugs.
In Syngenta Crop Protection, Inc. v. Henson, the respondent filed various tort claims in Louisiana state court against the petitioners related to an insecticide product, but the action was stayed after he intervened in a parallel federal class action in Alabama that settled with a stipulation requiring dismissal of the state suit. Following a state-court hearing where the action was allowed to proceed based on counsel's representation about the scope of the settlement, the petitioners removed the case to federal district court, asserting jurisdiction under the All Writs Act and supplemental jurisdiction to enforce the prior federal order. The Supreme Court unanimously affirmed the Eleventh Circuit's ruling that the removal was improper, reasoning that 28 U.S.C. § 1441 authorizes removal only for actions over which federal courts have original jurisdiction, which the All Writs Act does not independently provide and which ancillary enforcement jurisdiction also cannot supply.
