On Point: B. Opinions

Rodriguez v. United States, USSC No. 13-9972, 2015 WL 1780927 (April 21, 2015), reversing United States v. Rodriguez, 741 F.3d 905 (8th Cir. 2014); Scotusblog page (includes links to briefs and commentary)

Some lower courts have held that police may briefly prolong a completed traffic stop in order to conduct a dog sniff. The Supreme Court rejects that approach, and holds that a seizure justified only by a traffic violation “‘become[s] unlawful if it is prolonged beyond the time reasonably required to complete th[e] mission’ of issuing a ticket for the violation.” (Slip op. at 1, quoting Illinois v. Caballes, 543 U.S. 405, 407 (2005)). Thus, prolonging a traffic stop requires reasonable suspicion of criminal activity beyond the traffic infraction.

Grady v. North Carolina, USSC No. 14-593, 2015 WL 1400850, 3/30/15 (per curiam), reversing State v. Grady, 762 S.E.2d 460 (2014) (unpublished order); docket

The Supreme Court holds that a state conducts a search within the meaning of the Fourth Amendment when it attaches a device like a GPS bracelet to a person’s body without consent for the purpose of tracking the person’s movements.

Woods v. Donald, USSC No. 14-618, 2015 WL 1400852, 3/30/15 (per curiam), reversing Donald v. Rapelje, 580 Fed. Appx. 227 (6th Cir. 2014) (unpublished); docket

Trial counsel’s absence during about 10 minutes of testimony regarding evidence relating to Donald’s co-defendants—evidence trial counsel said he had “no interest in”—did not amount to a denial of counsel at a critical stage of trial justifying a presumption of prejudice under United States v. Cronic, 466 U.S. 648 (1984). Thus, the Sixth Circuit erred in granting Donald habeas relief on that ground.

Yates v. United States, USSC No. 13-7451, 2015 WL 773330 (February 25, 2015); reversing 733 F.3d 1059 (11th Cir. 2013); Scotusblog page

In a four-one-four decision that is chock-a-block with nautical references and features some sparring about the canons and methods of statutory interpretation, the Supreme Court holds that the “anti-shredding provision” of the Sarbanes-Oxley Act of 2002, 18 U.S.C. § 1519, applies only to records, documents, or similar types of “tangible objects” used to record or preserve information. Thus, Yates’s conviction—for destroying fish that were evidence of his alleged violation of federal fishing regulations—must be jettisoned: “A fish is no doubt an object that is tangible; fish can be seen, caught, and handled, and a catch, as this case illustrates, is vulnerable to destruction. But it would cut § 1519 loose from its financial-fraud mooring to hold that it encompasses any and all objects, whatever their size or significance, destroyed with obstructive intent.” (Plurality at 2).

Christeson v. Roper, USSC No. 14-6873, 2015 WL 232187 (January 20, 2015) (per curiam); docket

The Supreme Court holds that the lower courts failed to properly apply Martel v. Clair, 565 U. S. ___, 132 S. Ct. 1276 (2012), when they denied Christeson’s request to substitute appointed counsel in his federal habaeas case.

Holt v. Hobbs, USSC No. 13-6827, 2015 WL 232143 (January 20, 2015); reversing 509 Fed. Appx. 561 (8th Cir. 2013); Scotusblog page

An Arkansas prison regulation bans inmates from having beards except when they have a medical need based on a diagnosed dermatological condition (in which case they can grow a 1/4-inch beard). Citing this regulation, prison officials barred Holt (a.k.a. Abdul Maalik Muhammad) from growing a 1/2-inch beard in accordance with his religious beliefs. The Supreme Court holds that as applied in this case, the regulation violates the Religious Land Use and Institutionalized Persons Act (RLUIPA), 42 U.S.C. § 2000cc-1.

Jennings v. Stephens, USSC No. 13-7211, 2015 WL 159277 (January 14, 2015), reversing Jennings v. Stephens, 537 Fed. Appx. 326 (5th Cir. July 22, 2013); Scotusblog page (includes links to briefs and commentary)

A federal district court granted Jennings’s habeas relief, ordering a new sentencing hearing based on two of the three theories of ineffective assistance of counsel that Jennings raised. The state appealed, and Jennings defended the district court judgment on all three theories. The Fifth Circuit held that Jennings’s claim on the third theory was procedurally barred because it was rejected by the district court and Jennings hadn’t cross-appealed or obtained a certificate of appealability. In a majority opinion authored by Justice Scalia the Supreme Court reverses, holding that Jennings may defend the district court’s judgment based on the third theory.

Whitfield v. United States, USSC No. 13-9026, 2015 WL 144680 (January 13, 2015), affirming United States v. Whitfield, 695 F.3d 288 (4th Cir. 2012); Scotusblog page (includes links to briefs and commentary)

The Supreme Court unanimously holds that a bank robber forces a person to “accompany” him for purposes of the enhanced penalties under 18 U.S.C. § 2113(e) when he forces that person to go somewhere with him, even if the movement occurs entirely within a single building or over a short distance.

Heien v. North Carolina, USSC No. 13-604, 2014 WL 7010684 (December 15, 2014), affirming State v. Heien, 737 S.E.2d 351 (N.C. 2012); Scotusblog page (includes links to briefs and commentary)

Rejecting the position taken by Wisconsin and the clear majority of jurisdictions that have addressed the issue, the Supreme Court holds that a reasonable mistake of law may give rise to the reasonable suspicion necessary to justify an investigatory seizure under the Fourth Amendment. While a statement of the Court’s holding is simple, its decision doesn’t fully articulate how courts are to determine when a mistake of law is “reasonable,” leading the sole dissenting Justice (Sotomayor) to predict lower courts will have difficulty applying the Court’s decision.

Warger v. Shauers, USSC No. 13-517, 2014 WL 6885952 (December 9, 2014), affirming Warger v. Shauers, 721 F.3d 606 (8th Cir. 2013); Scotusblog page (includes links to briefs and commentary)

Resolving an issue that had split some federal circuit courts, the Supreme Court unanimously holds that Federal Rule of Evidence 606(b) precludes a party seeking a new trial from using one juror’s affidavit or testimony about what another juror said in deliberations to demonstrate the other juror was dishonest during voir dire.