October 2012 Term (Oct. 2012 - July 2013)
(1) Henderson v. United States (6-3 Opinion by Justice Breyer on
February 20, 2013. Dissent by Justice Scalia with Justices Thomas and Alito
joining)
Summary: The Court reversed and remanded the decision of the
U.S. Court of Appeals for the Fifth Circuit. In a decision written by Justice
Breyer, the Court held that “regardless of whether a legal question was settled
or unsettled at the time of trial, an error is ‘plain’ within the meaning of
Rule 52(b) so long as the error was plain at the time of appellate review.”
Decision is available at:
http://www.supremecourt.gov/opinions/12pdf/11-9307_jhek.pdf
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(2) Johnson v. Williams (9-0 Opinion by Justice Alito on
February 20, 2013)
Summary: The Court reversed and remanded the decision of
the U.S. Court of Appeals for the Ninth Circuit. In a unanimous decision,
written by Justice Alito, the Court held that under the Antiterrorism and
Effective Death Penalty Act of 1996 §2254(d), when a defendant attempts to raise
a federal claim, and the state court rules against the defendant, but does not
expressly address the federal claim, a federal habeas court must presume,
subject to rebuttal, that a federal issue was adjudicated on the merits and rule
on granting habeas relief based on the deferential standard of review
§2254(d).
Decision is available at:
http://www.supremecourt.gov/opinions/12pdf/11-465_g314.pdf
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(3) Bailey v. United States, (6-3 Opinion by Justice Kennedy on
February 19, 2013. Concurring opinion by Justice Scalia with Ginsburg and Kagan
joining. Dissent by Justice Breyer with Justices Thomas and Alito joining.)
Summary: The Court reversed and remanded the decision of the
U.S. Court of Appeals for the Second Circuit. In a decision written by Justice
Kennedy, the Court held that the ruling in
Michigan v. Summers, that
allows detention pursuant to the execution of a search warrant, is limited to
the immediate vicinity of the area being searched.
Decision is available at:
http://www.supremecourt.gov/opinions/12pdf/11-770_j4ek.pdf
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(4) Chaidez v. United States, (7-2, Opinion by Justice Kagan on
February 20, 2013. Justice Thomas concurring in the judgment. Justices
Sotomayor and Ginsburg dissenting.)
Summary: The Court affirmed the decision of the U.S. Court
of Appeals for the Seventh Circuit. In a decision, written by Justice Kagan, the
Court held that their holding in
Padilla v. Kentucky, that defense
attorneys are required to inform their clients of potential deportation risks
associated with guilty pleas,does not apply retroactively to cases already final
on direct review.
Decision is available at:
http://www.supremecourt.gov/opinions/12pdf/11-820_j426.pdf
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(5) Evans v. Michigan (8-1 Opinion by Justice Sotomayor on
February 20, 2013. Dissent by Justice Alito.)
Summary: The Court reversed the decision of the Supreme
Court of Michigan. In a decision written by Justice Sotomayor, the Court held
that the Double Jeopardy Clause bars a defendant from being retried where the
trial court granted a directed verdict of acquittal when the prosecution failed
to prove an element of the offense that, in actuality, it did not have to
prove.
Decision is available at:
http://www.supremecourt.gov/opinions/12pdf/11-1327_7648.pdf
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(6) Florida v. Harris, (9-0, Opinion by Justice Kagan, on
February 19, 2013)
Summary: In a unanimous decision, written by Justice Kagan,
the Court reversed the judgment of the Florida Supreme Court. The Court held
that the State has met its probable cause standard if a drug-detection dog gives
an alert, even if that alert is a false positive and the State produces training
and testing records supporting the dog’s reliability in detecting drugs and the
defendant does not contest that showing.
Decision is available at:
http://www.supremecourt.gov/opinions/12pdf/11-817_5if6.pdf
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(7) Smith v. United States (9-0, Opinion by Justice Scalia, on
January 9, 2013)
Summary: Justice Scalia, delivering the unanimous opinion of
the Court, affirmed the decision of the U.S. Court of Appeals for the District
of Columbia Circuit. The Court held that a defendant bears the burden of proving
a defense of withdrawal. The Court explained that unless an affirmative defense
negates an element of the crime, the Government has no constitutional duty to
overcome the defense beyond a reasonable doubt. Thus, although union of
withdrawal with a statute-of-limitations defense can free the defendant of
criminal liability, it does not place upon the prosecution a constitutional
responsibility to prove that he did not withdraw.
Decision is available at:
http://www.supremecourt.gov/opinions/12pdf/11-8976_k5fl.pdf
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(8) Ryan v. Valencia Gonzales (No. 10-930) (9-0, Opinion by
Justice Thomas, decided on January 8, 2013 together with
Tibbals, Warden
v. Carter (No. 11-218)).
Summary: Justice Thomas, delivering the unanimous opinion
of the Court, reversed the judgment of the Ninth Circuit Court of Appeals and
vacated the judgment of the Sixth Circuit Court of Appeals, remanding that case
for proceedings consistent with its opinion. The Court held that 18 U.S.C. §3599
does not provide a state prisoner a right to suspension of his federal habeas
proceedings when he is adjudged incompetent, noting a lack of textual basis for
such a right and that such an assertion is difficult to square with
constitutional precedent and Congressional intent. The Court further noted that
the very nature of §2254 proceedings -- backward-looking and record-based --
means that counsel can generally provide effective representation to petitioners
regardless of the petitioner's level of competence.
The Court also held that 18 U.S.C. §4241 does not provide a statutory right
to competence in federal habeas proceedings, noting that the Sixth Circuit's
conclusion was based on a misreading of case law and that §4241, by its terms,
applies only to trial proceedings prior to sentencing and at any time after the
commencement of probation or supervised release. Because federal habeas
proceedings commence after sentencing and habeas petitioners are by definition
incarcerated, §4241 is inapplicable. Further, the Court stated that all of
Title 18 applies to federal prisoners, not state defendants.
Finally, the Court concluded that for the purpose of resolving the two habeas
cases at issue, it was sufficient to address the outer limits of the district
courts' discretion to issue stays and unnecessary to determine "the precise
contours of that discretion." The Court held that the District Court in the
Gonzales case did not abuse its discretion in denying Gonzalez a stay after a
finding that the claims were all record based or resolvable as a matter of law,
regardless of the petitioner's competence. Any evidence that Gonzales would
have had, had he been competent would have been inadmissible, because subject to
§2254(d) such evidence was not part of the record before the state court that
heard the merits of the case. In the Carter case, the Court held that three of
the petitioner?s would not have warranted a stay because they were adjudicated
on the merits in state post-conviction proceedings and would have been
inadmissible. The Court further stated that even if evidence from a fourth
claim were unexhausted and not procedurally defaulted that a stay by the
District Court would have been inappropriate, since it would permit the
petitioners to frustrate the AEDPA goal of finality by dragging out federal
habeas review indefinitely.
Decision is available at:
http://www.supremecourt.gov/opinions/12pdf/10-930_7k47.pdf
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