In Cuomo v. Clearing House Ass'n, LLC, the New York Attorney General sought nonpublic lending records from national banks to investigate potential violations of state fair-lending laws, prompting the Office of the Comptroller of the Currency (OCC) and a banking trade group to sue for an injunction. The Supreme Court held that the OCC's regulation, which interpreted the National Bank Act (NBA) to preempt most state enforcement actions against national banks, was not a reasonable construction of the statute's bar on "visitorial powers." The Court reasoned that historical understandings, precedents, and statutory text distinguish between a sovereign's supervisory visitation (such as examinations) and ordinary judicial enforcement of valid state laws, and that the NBA does not bar the latter; states may therefore pursue enforcement through courts rather than administrative oversight. The decision reversed the lower courts' injunction that had broadly blocked the Attorney General's information request and related proceedings.
In Melendez-Diaz v. Massachusetts, the prosecution at a state drug trial introduced sworn certificates from laboratory analysts stating that seized material was cocaine of a certain quantity, which state law treated as prima facie evidence. The defendant objected that this violated his Sixth Amendment confrontation rights under Crawford v. Washington because the analysts did not testify in person. The Supreme Court held that admitting the certificates violated the Confrontation Clause. The Court reasoned that the certificates were affidavits falling within the core class of testimonial statements, prepared under circumstances indicating they would be used at trial, so the defendant was entitled to confront the analysts.
The case involved environmental organizations suing the U.S. Forest Service over regulations that exempted small timber salvage sales from standard notice, comment, and appeal procedures, initially tied to a specific project called Burnt Ridge. After the parties settled the Burnt Ridge dispute, the Supreme Court held that the organizations lacked standing to challenge the remaining regulations. The Court reasoned that Article III limits federal jurisdiction to actual or imminent concrete injuries to plaintiffs, and the groups failed to show any live application of the rules that threatened their members' specific recreational or aesthetic interests in national forests; generalized procedural harms or future possibilities were insufficient.
The case concerned whether, at a murder trial, unconfronted statements made by the victim to police could be admitted into evidence against the defendant under a forfeiture-by-wrongdoing theory. The Supreme Court held that the Sixth Amendment’s Confrontation Clause bars such evidence unless the defendant engaged in conduct specifically intended to prevent the witness from testifying. The Court reasoned that neither founding-era common law nor subsequent American jurisprudence recognized a forfeiture exception that applied merely because the defendant’s criminal act caused the witness’s unavailability, as opposed to conduct aimed at silencing testimony. The state courts were directed to consider the defendant’s intent on remand.
The case concerned the constitutionality of 18 U.S.C. §2252A(a)(3)(B), a federal statute enacted after Ashcroft v. Free Speech Coalition to criminalize pandering and solicitation of child pornography by prohibiting offers to provide or requests to obtain such material. Respondent Williams, who had pleaded guilty to the offense while preserving his challenge, argued that the provision was facially overbroad under the First Amendment and impermissibly vague under the Due Process Clause; the district court rejected the challenge, but the Eleventh Circuit reversed. The Supreme Court held that the statute is neither overbroad nor vague. It reasoned that the provision targets collateral speech offering or seeking material that matches the categories of child pornography already held unprotected in New York v. Ferber and Miller v. California, that offers to engage in unlawful transactions receive no First Amendment protection, and that the statute's scienter requirements and defined terms provide fair notice and avoid arbitrary enforcement.
In Virginia v. Moore, police arrested the defendant for the misdemeanor of driving on a suspended license despite state law requiring only a summons, and a search incident to the arrest uncovered crack cocaine that was used to convict him on drug charges. The trial court admitted the evidence, but the Virginia Supreme Court reversed on Fourth Amendment grounds, holding that the arrest and search were invalid because officers should have issued a citation. The U.S. Supreme Court reversed, ruling that an arrest based on probable cause is constitutionally reasonable under the Fourth Amendment even if prohibited by state law, and that a search incident to such an arrest is permissible. The Court reasoned from founding-era history and traditional standards of reasonableness that the Fourth Amendment does not incorporate state-law restrictions on arrest authority, preferring administrable bright-line rules over variable state policies.
