William Hubbs Rehnquist

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.

criminal lawprocedure

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.

criminal lawprocedure

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.

immigrationcriminal law

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.

criminal lawcivil rightsfederal power

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.

criminal lawprocedure

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.

proceduretorts & liability

The case concerned whether a former student could sue Gonzaga University under 42 U.S.C. § 1983 for damages based on the university's alleged release of personal information in violation of the Family Educational Rights and Privacy Act (FERPA), a federal statute that conditions receipt of federal education funds on institutions maintaining certain policies regarding student records. The Supreme Court held that no such lawsuit is permitted because FERPA's provisions do not create enforceable personal rights under § 1983. The Court reasoned that FERPA is spending legislation focused on institutional compliance with funding conditions, enforced administratively by the Secretary of Education through investigations and fund termination rather than through private damages actions. The decision reversed the Washington Supreme Court's ruling that had allowed the § 1983 claim to proceed.

civil rightsfederal power

In Bell v. Cone, the Supreme Court considered a habeas corpus challenge to a Tennessee death sentence in which the defendant claimed his counsel rendered ineffective assistance by waiving closing argument at the sentencing hearing. The Tennessee courts had denied relief under the Strickland v. Washington standard for ineffective assistance claims, but the Sixth Circuit granted a conditional writ on the ground that United States v. Cronic should have applied instead. The Court held that Strickland governed the analysis and that the state court's decision was neither contrary to nor an unreasonable application of clearly established federal law under 28 U.S.C. § 2254(d)(1). The core reasoning was that Cronic's presumption of prejudice is limited to cases in which counsel entirely fails to function as an advocate, which did not occur here because counsel had participated actively throughout the proceedings.

criminal lawprocedure

In United States v. Cotton, the case concerned whether federal defendants' enhanced drug sentences under 21 U.S.C. § 841(b)(1)(A) must be vacated because the indictment omitted drug quantity allegations required by Apprendi v. New Jersey, even though the defendants raised no objection at trial. The Supreme Court reversed the Fourth Circuit, holding that the omission was not a jurisdictional defect that automatically invalidated the sentences. The Court reasoned that modern precedent treats indictment defects as non-jurisdictional and subject to plain-error review under Federal Rule of Criminal Procedure 52(b), and that the error did not seriously affect the fairness or integrity of the proceedings given the overwhelming, uncontroverted evidence of the drug quantities involved. The opinion also rejected reliance on older cases like Ex parte Bain that had treated such defects as depriving courts of jurisdiction.

criminal lawprocedure

The case involved whether the National Labor Relations Board could award backpay to an undocumented worker fired for supporting a union, after the worker admitted using fraudulent documents to obtain employment in violation of immigration laws. The Supreme Court held that the Board could not award such backpay because it would conflict with the Immigration Reform and Control Act of 1986, which prohibits employers from hiring undocumented aliens and employees from using false documents. The Court reasoned that the Board's broad discretion to fashion remedies under the National Labor Relations Act is limited by federal immigration policy, as established in prior precedent like Sure-Tan, and that allowing backpay would undermine Congress's intent to deter illegal employment.

immigrationlabor & employment

The case involved whether federal law allows public housing authorities to evict tenants for drug-related criminal activity by household members or guests, regardless of the tenant's knowledge or involvement. The Supreme Court held that 42 U.S.C. § 1437d(l)(6) unambiguously requires lease terms authorizing such evictions without a knowledge requirement. The core reasoning rested on the statute's plain language stating that any drug-related criminal activity by a tenant, household member, guest, or person under the tenant's control shall be cause for termination of tenancy, reinforced by legislative history rejecting knowledge-based limits and a 1996 amendment broadening the provision's reach.

criminal lawproperty

The case involved a border patrol agent stopping Ralph Arvizu's minivan on a remote road in Arizona after sensors indicated possible smuggling activity to avoid a checkpoint, leading to the discovery of over 100 pounds of marijuana. The District Court denied Arvizu's motion to suppress the evidence, but the Ninth Circuit reversed, finding insufficient reasonable suspicion by categorically excluding certain factors. The Supreme Court reversed the Ninth Circuit, holding that under the totality of the circumstances—including the vehicle's type, the driver's rigid posture, the children's unusual waving, the timing with shift changes, and the route—the stop was justified by reasonable suspicion and did not violate the Fourth Amendment.

criminal lawimmigration

The case concerned whether the FBI provided adequate notice to federal prisoner Larry Dusenbery of its intent to administratively forfeit cash seized during his 1986 arrest for drug offenses, after sending certified mail to the prison where he was held but receiving no response. The district court and appeals court proceedings focused on whether this notice satisfied due process, leading to the Supreme Court's review of the forfeiture procedures under the Controlled Substances Act. The Court held that the notice was constitutionally sufficient because it was reasonably calculated to inform the prisoner of the proceedings, consistent with prior precedents like Mullane v. Central Hanover Bank & Trust Co. The core reasoning emphasized that certified mail to the prison, combined with the facility's internal mail distribution practices, met the fairness and practicality standards without requiring proof of actual receipt by the inmate.

criminal lawprocedureproperty

The case involved whether a warrantless search of a probationer's apartment, conducted pursuant to a probation condition allowing searches by law enforcement officers at any time and supported by reasonable suspicion of criminal activity, violated the Fourth Amendment. The Supreme Court held that the search was reasonable and thus constitutional. The Court reasoned that the probation condition significantly diminished the probationer's reasonable expectation of privacy, and the state's interest in supervising probationers justified searches based on reasonable suspicion rather than probable cause. The decision rejected any distinction between probationary and investigatory purposes for such searches.

criminal law

In Florida v. Thomas, the case concerned whether the bright-line rule from New York v. Belton allowing a vehicle search incident to the arrest of its occupant applies when police first contact the person after they have exited the car. The Florida Supreme Court ruled that Belton did not apply because the officer initiated contact outside the vehicle, and it remanded the case for the trial court to determine if the search was justified under the Chimel factors regarding officer safety or evidence preservation. The U.S. Supreme Court dismissed the writ of certiorari, holding that it lacked jurisdiction under 28 U.S.C. § 1257 because the Florida judgment was not final; further factfinding and proceedings were required before the suppression issue would be conclusively resolved, and none of the Cox v. Cohn exceptions for treating nonfinal state judgments as final applied.

criminal lawprocedure

The case was about whether plaintiffs who achieve their desired outcome through a defendant's voluntary change in conduct, without a court judgment or consent decree, qualify as "prevailing parties" eligible for attorney's fees under the Fair Housing Amendments Act and Americans with Disabilities Act. The Supreme Court decided that such plaintiffs do not qualify, rejecting the "catalyst theory." The core reasoning was that the term "prevailing party" requires a court-ordered change in the legal relationship between the parties, consistent with the American Rule that parties generally bear their own attorney's fees absent explicit statutory authorization for fee-shifting to a prevailing party.

civil rightsprocedure

The case concerned whether the Navajo Nation could impose an 8% hotel occupancy tax on non-Indian guests staying at a hotel owned by non-Indians on non-Indian fee land within the boundaries of the Navajo Reservation. The Supreme Court held that the tribe lacked authority to impose the tax. Applying the rule from Montana v. United States, the Court determined that Indian tribes generally lack civil authority over nonmembers on non-Indian fee land within a reservation, and neither of Montana's two exceptions applied: there was no consensual relationship between the tribe and the nonmember guests that would justify the tax, nor did the guests' activities directly affect the tribe's political integrity, economic security, health, or welfare. The Court rejected arguments that the tax was authorized by prior precedent or that land status was merely one factor among others.

federal powertaxesbusiness & regulatory

The case involved a challenge to provisions of the California Labor Code that authorize the state to direct withholding of payments due to contractors on public works projects when a subcontractor fails to pay prevailing wages or comply with recordkeeping requirements, allowing the contractor to then withhold from the subcontractor. G & G Fire Sprinklers, a subcontractor, sued state officials under 42 U.S.C. §1983, arguing that the withholding without a pre- or post-deprivation hearing violated the Due Process Clause of the Fourteenth Amendment. The district court and Ninth Circuit agreed, finding a property interest in full payment and insufficient procedural protections. The Supreme Court reversed, holding that the scheme does not violate due process because the subcontractor retains the ability to recover the withheld amounts through a breach-of-contract action against the contractor in state court, which provides an adequate opportunity to contest the underlying violations.

labor & employmentcivil rightsprocedure

Texas v. Cobb concerned whether a defendant's Sixth Amendment right to counsel, after attaching upon indictment for burglary, also covered uncharged but factually related capital murder offenses arising from the same incident. The Supreme Court reversed the Texas Court of Criminal Appeals and held that the right is offense-specific, applying only to the charged offense and not to other crimes even if closely related in fact. The Court reasoned that its precedent in McNeil v. Wisconsin meant exactly that the Sixth Amendment does not extend beyond the specific offense charged, using the Blockburger double-jeopardy test to determine distinct offenses.

criminal lawprocedure

The case concerned whether state employees could sue states for money damages under Title I of the Americans with Disabilities Act for alleged employment discrimination based on disability. The Supreme Court held that such suits against states are barred by the Eleventh Amendment. The Court reasoned that Congress lacked authority under Section 5 of the Fourteenth Amendment to abrogate state sovereign immunity, as the ADA's requirements exceeded the constitutional protections against irrational discrimination and the legislative record did not demonstrate a widespread pattern of unconstitutional state conduct in employment. The opinion noted that while the ADA sets standards for states, private damage actions are not permitted, though other enforcement mechanisms remain available.

civil rightsfederal powerlabor & employment