Bond v. United States, 09-1227, June 16, 2011
The 10th Amendment reserves to the states that authority not specifically granted to the Federal Government, and prior Supreme Court cases have suggested that only states may challenge federal action on 10th Amendment grounds. The Petitioner assaulted her romantic rival with caustic chemicals, and the trial court convicted her under a federal statute enacted to comply with a treaty banning chemical warfare. The circuit court dismissed her appeal, finding that she did not have standing to make a 10th Amendment challenge to the federal law. A unanimous Court (J. Kennedy wrote the opinion; J. Ginsburg filed a concurring opinion, joined by J. Breyer) held that a private citizen does have the right to assert a 10th Amendment challenge against a federal law used to convict her. PhillyBurbs covered this case about their hometown girl. Lyle Denniston at SCOTUS Blog considered Justice Kennedy’s federalist philosophy, and examined this case in that context.
Smith v. Bayer Corp., 09-1205, June 16, 2011
A group of plaintiffs sued a drug company for product liability in federal court, but were denied class action certification. A different group of plaintiffs then made the same claim in a West Virginia state court, and were granted class action status. The federal court enjoined the state-court law suit. Justice Kagan delivered the opinion of a unanimous Court, finding that the federal court had exceeded its authority. The blog Insurance Class Actions Insider (no kidding) looked at the nuts and bolts of the decision. Supreme Court Haiku of the Day took a different approach.
Davis v. United States, 09-11328, June 16, 2011
Police arrested the Petitioner for fire arms possession following a search that complied with relevant circuit precedent. During the Petitioner’s appeal, the Court decided Arizona v. Gant, a case that effectively invalidated that precedent. The Court (J. Alito wrote the opinion; Sotomayor filed a concurring opinion; J. Breyer filed a dissent, joined by J. Ginsburg) held that since the police acted in a good-faith reliance on binding law, the exclusionary rule should not apply. The ABA Journal noted that two of the new “liberal” justices joined the conservatives in the holding. Orin Kerr in The Volokh Conspiracy wonders about the future of the exclusionary rule.
J.D.B. v. North Carolina, 09-11121, June 16, 2011
A police detective and school officials questioned 13-year old J.D.B. about a burglary. The adults spoke with JDB about telling the truth and about juvenile detention, and he eventually confessed. JDB’s lawyer objected to the statement, arguing that the police should have considered J.D.B.’s age, assumed that J.D.B. would believe he was in custody, and given him a Miranda warning. The trial court disagreed and adjudicated J.D.B. delinquent. The Court (J. Sotomayor wrote the opinion; J. Alito filed a dissent, joined by C.J. Roberts, J. Scalia, and J. Thomas) held that Miranda’s custody analysis includes a consideration of the suspect’s age. Lyle Denniston in SCOTUS Blog predicted that “the practical effect of the ruling may be that officers, to be on the safe side legally, would give warnings to any suspect who does not appear to be close to age 18.”
Tapia v. United States, 10-5400, June 16, 2011
Following the Petitioner’s conviction for smuggling aliens, the trial judge imposed the longest sentence available under the guideline range for the expressed reason that the sentence would allow the Petitioner to participate in a lenghty drug rehabilitation program. A unanimous Court (J. Kagan wrote the opinion; J. Sotomayor filed a concurring opinion, joined by J. Alito) held that the Sentencing Reform Act prohibits federal courts “from imposing or lengthening a prison term in order to promote a criminal defendant’s rehabilitation.” The Texas legal blog Grits for Breakfast examined the opinion next to that state’s drug court programs. The Sacramento Bee looked at the life of the young woman at the center of this case.