On Point: 44. SCOTUS

City and County of San Francisco, et al. v. Teresa Sheehan, USSC No. 13-1412, 2015 WL 2340839 (May 18, 2015), certiorari dismissed in part, and reversing in part and remanding Sheehan v. City and County of San Francisco, 743 F.3d 1211 (9th Cir. 2014); Scotusblog page (includes links to briefs and commentary)

Because there was no precedent clearly establishing that it unreasonable to forcibly enter the home of a mentally ill person who is armed and potentially violent, the officers who entered Sheehan’s apartment are entitled to qualified immunity.

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Carolina, USSC No. 14-593, 2015 WL 1400850, 3/30/15 (per curiam), reversing State v. Grady, 762 S.E.2d 460 (2014) (unpublished order); docket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 Appx. 227 (6th Cir. 2014) (unpublished); docket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.

Questions presented:

Whether the Eighth Amendment requires that a capital-sentencing jury be affirmatively instructed that mitigating circumstances “need not be proven beyond a reasonable doubt,” as the Kansas Supreme Court held here, or instead whether the Eighth Amendment is satisfied by instructions that, in context, make clear that each juror must individually assess and weigh any mitigating circumstances

Whether the trial court’s decision not to sever the sentencing phase of the co-defendant brothers’ trial here—a decision that comports with the traditional approach preferring joinder in circumstances like this—violated an Eighth Amendment right to an “individualized sentencing” determination and was not harmless in any event.

Questions Presented:

1) Did the rule announced in Miller v. Alabama, 567 U. S. ____, 132 S.Ct. 2455 (2012), adopt a new substantive rule that applies retroactively on collateral review to people sentenced as juveniles to life in prison without parole?

2) Does the Supreme Court have jurisdiction to decide whether the Supreme Court of Louisiana correctly refused to give retroactive effect to Miller?

Question presented:

Whether Florida’s death sentencing scheme violates the Sixth Amendment or the Eighth Amendment in light of this Court’s decision in Ring v. Arizona, 536 U.S. 584 (2002).

Question presented:

Does a conspiracy to commit extortion in violation of the Hobbs Act, 18 U.S.C. § 1951(b)(2), require that the conspirators agree to obtain property from someone outside the conspiracy?

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.