John Paul Stevens

The case involved Cecil Johnson, who was convicted of three murders in 1981 and spent nearly 29 years on death row before challenging his execution as unconstitutionally cruel under the Eighth Amendment due to state-caused delay, including withheld evidence; he brought the claim via 42 U.S.C. § 1983 rather than habeas corpus. The Supreme Court denied both the application for a stay of execution and the petition for a writ of certiorari. The core reasoning for denial centered on the absence of grounds for further review of the procedural questions—whether a Lackey-type delay claim is cognizable under § 1983 or barred as successive in habeas—and the lack of precedent supporting an Eighth Amendment violation from extended incarceration alone.

criminal lawprocedurecivil rights

The case concerned whether police officers violated the Fourth Amendment by searching the passenger compartment of a car after arresting its recent occupant. Respondent Gant was arrested for driving with a suspended license, handcuffed, and secured in a patrol car; officers then searched his vehicle and found cocaine. The Supreme Court held that a vehicle search incident to a recent occupant's arrest is permissible only if it is reasonable to believe the arrestee could access the vehicle at the time of the search or that the vehicle contains evidence of the offense of arrest. The Court reasoned that the justifications from Chimel v. California—officer safety and preservation of evidence—did not apply here because Gant was already secured and his offense would not reasonably yield evidence in the car, distinguishing the facts from New York v. Belton. The Court affirmed the Arizona Supreme Court's ruling that the search was unreasonable.

criminal law

The case involved a patient who suffered severe injury after receiving the drug Phenergan via IV push, leading to a state-law failure-to-warn lawsuit against manufacturer Wyeth for inadequate labeling. The Vermont courts awarded damages, rejecting Wyeth's defense that FDA approval of the label preempted the state claims. The Supreme Court affirmed, holding that federal law does not preempt the claim because the manufacturer could have unilaterally strengthened the warning under the FDA's changes-being-effected regulation without prior approval, and nothing showed the FDA would have rejected it. The Court reasoned that the FDCA places primary responsibility for labeling on the manufacturer, Congress did not intend to preempt state tort actions, and an FDA preamble asserting preemption lacked the force of law or deference given its inconsistency with prior positions and lack of process.

healthcarefederal powerbusiness & regulatorytorts & liability

The case concerned whether Federal Rule of Criminal Procedure 32(h) requires a sentencing court to give advance notice before imposing a sentence outside the Federal Sentencing Guidelines range that is treated as a variance rather than a departure. Petitioner Irizarry had pleaded guilty to making a threatening interstate communication and received a 60-month sentence exceeding the recommended 41-to-51-month Guidelines range without prior notice of the court's intent. The Supreme Court held that Rule 32(h) applies only to Guidelines departures and does not extend to variances under 18 U.S.C. §3553(a). The core reasoning was that United States v. Booker rendered the Guidelines advisory, eliminating the mandatory regime and associated due-process expectations that had prompted the notice requirement in Burns v. United States when the Guidelines were binding. The Court concluded that existing Rule 32 procedures suffice to ensure fairness without mandating additional notice for variances.

criminal lawprocedure

The case involved Ahmed Ressam, who attempted to enter the United States with explosives hidden in his car while providing false information on a customs declaration form, leading to convictions under 18 U.S.C. §1001 for the false statement and under §844(h)(2) for carrying an explosive during the commission of that felony. The Ninth Circuit vacated the explosives conviction, interpreting "during" to require that the explosives be carried "in relation to" the underlying offense. The Supreme Court reversed, holding that the statute requires only a temporal connection. The Court reasoned that the plain meaning of "during" denotes a contemporaneous link between the carrying of explosives and the felony, supported by the statutory text and history showing no additional relational element was intended by Congress.

criminal law

The case concerned whether state courts must follow the federal retroactivity limits from Teague v. Lane when applying new constitutional rules of criminal procedure, such as the rule from Crawford v. Washington on testimonial statements, in state postconviction proceedings. Petitioner Danforth sought a new trial in Minnesota state court after his conviction became final, arguing that admitting certain evidence violated Crawford. The Minnesota Supreme Court held that states could not give broader retroactive effect to such new rules than the U.S. Supreme Court required. The Court reversed, deciding that Teague constrains only federal habeas review and does not limit state courts' authority to provide broader remedies for violations of new federal constitutional rules in their own postconviction cases. The reasoning was that Teague derives from interpretation of the federal habeas statute and reflects federalism principles allowing states independent authority over their criminal procedures as long as they respect federal constitutional guarantees.

criminal lawprocedurefederal power

The case involved a participant in a defined contribution pension plan who sued the plan administrator under ERISA §502(a)(2) for allegedly failing to follow his investment instructions, resulting in a $150,000 loss to his individual account. The lower courts had dismissed the claim, relying on precedent that limited remedies under that section to harms affecting the entire plan rather than individual participants. The Supreme Court vacated and remanded, holding that while the provision does not remedy individual injuries separate from the plan, it does authorize suits for fiduciary breaches that diminish the value of assets in a participant's account within a defined contribution plan, distinguishing such plans from traditional defined benefit plans where the entire plan's solvency is at issue.

labor & employmentbusiness & regulatory

In Gall v. United States, the petitioner pleaded guilty to participating in a conspiracy to distribute ecstasy while in college, though he had withdrawn from the scheme after seven months, ceased all drug use, and maintained steady employment for years afterward. The district court imposed 36 months of probation instead of the 30-37 month prison term recommended by the Federal Sentencing Guidelines, finding that the defendant's post-offense conduct showed he posed no danger to society and that imprisonment was unnecessary. The Eighth Circuit reversed, holding that a sentence outside the Guidelines range required extraordinary circumstances. The Supreme Court held that appellate courts must review all sentences—inside or outside the Guidelines—under a deferential abuse-of-discretion standard for reasonableness, without presuming unreasonableness for variances or demanding extraordinary justifications, and that the district court's individualized assessment under 18 U.S.C. §3553(a) supported the probation sentence here.

criminal law

The case involved a former employee of Senator Mark Dayton suing the Senator's office under the Congressional Accountability Act of 1995, alleging violations of federal employment statutes including the Family and Medical Leave Act, Americans with Disabilities Act, and Fair Labor Standards Act. The office moved to dismiss based on immunity under the Constitution's Speech or Debate Clause, but the district court and D.C. Circuit rejected the motion. The Supreme Court held that it lacked appellate jurisdiction under section 412 of the Act because the lower courts' rulings addressed the scope of the Clause rather than the constitutionality of any provision of the Act itself. The Court dismissed the appeal for want of jurisdiction and denied certiorari, noting that the Act expressly preserves Senators' privileges under the Clause and finding no special circumstances warranting discretionary review.

labor & employmentfederal powerprocedurecivil rights

The case involved petitioner Abdul-Kabir, who was convicted of capital murder in Texas and sentenced to death after a jury answered two special issues in the affirmative regarding deliberateness and future dangerousness. At sentencing, he presented mitigating evidence of an abusive childhood and neurological damage to argue for reduced moral culpability, but the trial court refused requested instructions that would have allowed the jury to consider this evidence as a basis for a life sentence rather than death. The Texas Court of Criminal Appeals upheld the sentence on direct appeal and denied habeas relief. In federal habeas proceedings, the Supreme Court held that there was a reasonable likelihood the jury instructions prevented meaningful consideration of constitutionally relevant mitigating evidence, making the state court's decision contrary to clearly established federal law under precedents such as Penry v. Lynaugh and Lockett v. Ohio, and thus warranting relief under 28 U.S.C. § 2254(d)(1).

criminal lawprocedure

In Brewer v. Quarterman, the petitioner was convicted of murder during a robbery and sentenced to death after the jury answered Texas special issues on whether the crime was deliberate and whether he posed a future danger to society. At sentencing, Brewer presented mitigating evidence of mental illness, childhood abuse, and substance abuse, but the trial court rejected proposed instructions that would have allowed the jury to give it independent effect beyond the special issues. The Supreme Court held that the Texas statute, as applied by the state courts, impermissibly prevented the jury from giving meaningful consideration to this constitutionally relevant mitigating evidence. The core reasoning was that the evidence functioned as a two-edged sword that could diminish moral culpability even while indicating future dangerousness, making the denial of relief contrary to Penry v. Lynaugh and unreasonable under AEDPA standards.

criminal law

The case involved a debtor who filed for Chapter 7 bankruptcy but misrepresented the value and transfer of his property, prompting the trustee to seek recovery of the asset. When the debtor moved to convert the case to Chapter 13, the trustee and primary creditor objected on grounds of bad faith, and the bankruptcy court denied the motion. The Supreme Court affirmed, holding that the debtor forfeited his right to convert under §706(a) because his bad-faith conduct disqualified him from qualifying as a Chapter 13 debtor. The Court reasoned that §706(d) conditions conversion on eligibility under the target chapter, and §1307(c) authorizes dismissal or conversion 'for cause' based on prepetition misconduct, with bankruptcy courts empowered under §105(a) to prevent abuse of process.

business & regulatoryprocedure

The case involved a Mexican citizen charged under 8 U.S.C. §1326(a) with attempting to reenter the United States after prior deportation. The district court upheld the indictment despite its lack of a specific overt act, but the Ninth Circuit reversed the conviction, finding the omission fatal and not subject to harmless-error review. The Supreme Court reversed the Ninth Circuit, holding that the indictment was not defective. It reasoned that the word "attempted" in the indictment implicitly alleged the necessary overt act element of the offense, along with the intent element, and that specifying the time, place, and statute satisfied the constitutional requirements for indictments to inform the defendant of the charge and protect against double jeopardy.

immigrationcriminal lawprocedure

The case involved a Medicaid recipient who settled a tort lawsuit for injuries from a car accident, and the state Medicaid agency sought to recover the full amount it had paid for her medical care ($215,645.30) from the $550,000 settlement, even though the settlement was not allocated among different types of damages. The Supreme Court held that federal law limits the state's recovery to only the portion of the settlement representing payment for medical expenses, which the parties stipulated was about $35,581.47, and that the state cannot impose a lien on other parts of the settlement such as those for pain and suffering or lost wages. The core reasoning was that the Medicaid statute requires recipients to assign only their rights to payment for medical care from third parties, not rights to other damages, and the federal anti-lien provision prohibits states from claiming more than that.

healthcaretorts & liabilityfederal power

The case involved a state-law securities fraud class action brought by a former Merrill Lynch broker and others who claimed the firm fraudulently manipulated stock prices, inducing them and their clients to retain overvalued securities rather than sell. The district court dismissed the claims as preempted by the Securities Litigation Uniform Standards Act of 1998 (SLUSA), which bars certain state-law class actions alleging misrepresentations in connection with the purchase or sale of covered securities. The Second Circuit reversed in part, holding that holder claims fell outside SLUSA's scope. The Supreme Court held that SLUSA preempts such state-law holder class actions, reasoning that the statute's text, history, and purpose require a broad reading of the 'in connection with the purchase or sale' language that incorporates prior judicial interpretations and aims to prevent circumvention of federal securities reforms through state-court class actions.

business & regulatoryprocedurefederal power

The case concerned whether petitioners' practice of selling patented printing systems on the condition that buyers use only their unpatented ink violated antitrust law by constituting an illegal tying arrangement under Sherman Act §1. The Supreme Court held that a patent does not necessarily confer market power on the patentee, so in all tying cases the plaintiff must prove that the defendant has market power in the tying product rather than relying on a presumption. The Court reasoned that its prior decisions had moved away from assumptions about tying arrangements and that Congress had eliminated the market power presumption in the related patent misuse context, requiring instead a showing of actual market power under standards from cases like Jefferson Parish. The judgment of the Federal Circuit was vacated and the case remanded to allow the plaintiff an opportunity to present evidence on market power.

business & regulatory

This case concerned a bankruptcy trustee's effort to recover alleged preferential transfers made by a debtor to state community colleges under sections 547(b) and 550(a) of the Bankruptcy Code. The state agencies moved to dismiss on sovereign immunity grounds, but lower courts rejected that defense based on prior precedent regarding Congress's abrogation of state immunity in bankruptcy matters. The Supreme Court held that the trustee's proceeding was not barred by sovereign immunity. The decision rested on the history and purpose of the Bankruptcy Clause, which the Court concluded was designed to permit limited subordination of state sovereign immunity to enable uniform federal bankruptcy laws, including ancillary orders for avoiding and recovering preferential transfers in the context of in rem bankruptcy jurisdiction.

federal powerprocedure

This case involved consolidated appeals addressing whether time spent by employees donning protective clothing on employer premises, walking to production areas, and waiting to don such gear is compensable under the Fair Labor Standards Act as amended by the Portal-to-Portal Act. The Supreme Court held that walking time between changing areas and production areas after the start of the workday is compensable, while waiting time before donning protective gear is not. The principal question concerned walking time in both cases, with the secondary question on waiting time limited to one appeal, resolving a circuit split. The core reasoning relied on the statutory distinction between preliminary activities before the first principal activity and activities within the workday, which begins upon commencement of integral tasks like donning required gear, drawing from prior interpretations of the FLSA and the Portal-to-Portal Act's exceptions.

labor & employment

The case concerned whether the City of New London could use eminent domain to seize private property from unwilling owners as part of an economic development plan aimed at revitalizing a distressed area. The Supreme Court held that the proposed takings satisfied the Fifth Amendment's public use requirement. The Court reasoned that its precedents have long interpreted public use broadly to mean public purpose, that promoting economic development is a legitimate governmental function, and that courts owe deference to legislative judgments about the public benefits of integrated development plans. It rejected calls for a stricter rule requiring proof that benefits would actually materialize or excluding economic development from public use.

property

The case involved hotel owners who challenged a San Francisco ordinance imposing a $567,000 fee for converting residential hotel rooms to tourist use, claiming it violated the Fifth Amendment Takings Clause. The owners first pursued state mandamus relief, which was stayed while they filed a federal suit raising facial and as-applied takings claims; after the Ninth Circuit abstained under Pullman on the facial claim and found the as-applied claim unripe, the owners litigated their state-law takings claims in California courts. Those courts rejected the claims, and when the owners returned to federal court, their federal claims were held barred by issue preclusion under 28 U.S.C. §1738. The Supreme Court affirmed, holding that no exception to the full faith and credit statute exists for federal takings claims, that England reservations do not permit de novo federal review when state courts have decided identical issues, and that Williamson County's state-litigation requirement does not override ordinary preclusion rules.

propertyprocedure