Justia Constitutional Law Opinion Summaries

Respondent was convicted of capital murder and subsequently commenced federal habeas proceedings by filing a request for appointment of counsel under 18 U.S.C. 3599. Section 3599(e) contemplated that appointed counsel could be "replaced . . . upon motion of the defendant," but did not specify the standard that district courts should use in evaluating those motions. The Court held that courts should employ the same "interests of justice" standard that they apply in non-capital cases under a related statute, 18 U.S.C. 3006A. The Court also held that the district court here did not abuse its discretion in denying respondent's motion to change counsel.

George Corson and his wife sued respondents, claiming injury from Corson's exposure to asbestos in locomotives and locomotive parts distributed by respondents. The Corsons alleged state-law claims of defective design and failure to warn of the dangers posed by asbestos. After Corson died, his wife was substituted as a party. Respondents removed the case to the Federal District Court, which granted respondents summary judgment, ruling that the state-law claims were pre-empted by the Locomotive Inspection Act (LIA), 49 U.S.C. 20701, et seq. The Third Circuit affirmed. The Court held that petitioners' state-law design-defect and failure-to-warn claims fell within the field of locomotive equipment regulation pre-empted by the LIA, as that field was defined in Napier v. Atlantic Coast Line. R. Co. Accordingly, the judgment of the Court of Appeals was affirmed.

The Court granted certiorari in these cases to decide whether Medicaid providers and recipients could maintain a cause of action under the Supremacy Clause to enforce a federal Medicaid law. Since the Court granted certiorari, however, the relevant circumstances have changed. The federal agency in charge of administering Medicaid, CMS, approved the state statutes as consistent with the federal law. In light of the changed circumstances, the Court believed that the question before it was whether, once the agency approved the state statutes, groups of Medicaid providers and beneficiaries could still maintain a Supremacy Clause action asserting that the state statutes were inconsistent with the federal Medicaid law. Given the present posture of the cases, the Court did not address whether the Ninth Circuit properly recognized a Supremacy Clause action to enforce the federal law before the agency took final action. To decide whether these cases could proceed under the Supremacy Clause now that the agency has acted, it would be necessary on remand to consider at least the matters addressed by the Court. Accordingly, the Court vacated the judgment and remanded for further proceedings.

Respondents filed an action under 42 U.S.C. 1983 against petitioners, police officers, alleging that the officers had subjected them to an unreasonable search in violation of the Fourth Amendment. The district court granted summary judgment to respondents and the Ninth Circuit affirmed the denial of qualified immunity. The Court held, however, that the officers were entitled to qualified immunity. The Court concluded that the case did not fall within the narrow exception to allowing suit where it would not be entirely unreasonable for an officer to believe that there was probable cause to search for all firearms and firearm-related materials. Regarding the warrant's authorization to search for gang-related materials, a reasonable officer could view Jerry Ray Bowen's attack as motivated not by the souring of his romantic relationship with Shelly Kelly but by a desire to prevent her from disclosing details of his gang activity to the police. The fact that the officers sought and obtained approval of the warrant application from a superior and a deputy district attorney before submitting it to the magistrate provided further support for the conclusion than an officer could reasonably have believed that the scope of the warrant was supported by probable cause. In holding that the warrant in this case was so obviously defective that no reasonable officer could have believed it to be valid, the court below erred in relying on Groh v. Ramirez. Accordingly, the judgment was reversed.

This case concerned three rivers which flow through Montana and then beyond its borders. At issue was whether discrete, identifiable segments of these rivers in Montana were nonnavigable, as federal law defined that concept for purposes of determining whether the State acquired title to the riverbeds underlying those segments, when the State entered the Union in 1989. Montana contended that the rivers must be found navigable at the disputed locations. The Court held that the Montana Supreme Court's ruling that Montana owned and could charge for use of the riverbeds at issue was based on an infirm legal understanding of the Court's rules of navigability for title under the equal-footing doctrine. The Montana Supreme Court erred in its treatment of the question of river segments and portage and erred as a matter of law in relying on evidence of present-day primarily recreational use of the Madison River. Because this analysis was sufficient to require reversal, the Court declined to decide whether the State Supreme Court also erred as to the burden of proof regarding navigability. Montana's suggestion that denying the State title to the disputed riverbeds would undermine the public trust doctrine underscored its misapprehension of the equal-footing and public trust doctrines. Finally, the reliance by petitioner and its predecessors in title on the State's long failure to assert title to the riverbeds was some evidence supporting the conclusion that the river segments over those beds were nonnavigable for purposes of the equal-footing doctrine. Accordingly, the judgment was reversed.

Respondent, a prison inmate, sought to suppress his confession under Miranda v. Arizona after he was subjected to custodial interrogation when he was escorted from his prison cell by a corrections officer to a conference room where he was questioned by two sheriff's deputies about criminal activity he had allegedly engaged in before coming to prison. The Sixth Circuit subsequently held that precedent clearly established that a prisoner was in custody within the meaning of Miranda if the prisoner was taken aside and questioned about events that occurred outside the prison walls. The Court's decision, however, did not clearly establish such a rule, and therefore the Court of Appeals erred in holding that this rule provided a permissible basis for federal habeas relief under the relevant provision of the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA), 28 U.S.C. 2254(d)(1). The rule applied by the lower court did not represent a correct interpretation of the Court's Miranda law. Therefore, taking into account all of the circumstances of the questioning - including especially the undisputed fact that respondent was told he was free to end the questioning and to return to his cell - the Court held that respondent was not in custody within the meaning of Miranda.

Respondent was convicted of drug trafficking and conspiracy charges. The District Court suppressed GPS data from a vehicle parked outside of respondent's residence, but held the remaining data admissible because respondent had no reasonable expectation of privacy when the vehicle was on a public street. The D.C. Circuit reversed, concluding that admission of the evidence obtained by warrantless use of the GPS device violated the Fourth Amendment. The Court held that the Government's installation of a GPS device on a target's vehicle, and its use of that device to monitor the vehicle's movements, constituted a search under the Fourth Amendment. Accordingly, the judgment of the Court of Appeals was affirmed.

This case concerned the Sex Offender Registration and Notification Act (Act), 18 U.S.C. 2250(a), which required convicted sex offenders to provide state governments with, and to update, information for state and federal sex offender registries. Petitioner, a pre-Act offender, registered in Missouri in 2005 but moved to Pennsylvania in September 2007 without updating the Missouri registration or registering in Pennsylvania. The question before the Court was the date on which the federal registration requirement took effect with respect to sex offenders convicted before the Act became law. The Court held that the Act did not require pre-Act offenders to register before the Attorney General validly specified that the Act's registration provisions applied to them. Accordingly, the Court reversed a Court of Appeals determination that, in effect, held the contrary.

Petitioner, a trade association representing meatpackers and processors, sued to enjoin enforcement of a California law against swine slaughterhouses, arguing that the Federal Meat Inspection Act (FMIA), 21 U.S.C. 601, et seq., preempted application of the law. The California law dictated what slaughterhouses must do with pigs that could not walk, known in the trade as nonambulatory pigs. The Court concluded that the FMIA regulated slaughterhouses' handling and treatment of nonambulatory pigs from the moment of their delivery through the end of the meat production process. California's law endeavored to regulate the same thing, at the same time, in the same place - except by imposing different requirements. The FMIA expressly preempted such a state law. Accordingly, the Court reversed the judgment of the Ninth Circuit and remanded for further proceedings.

Petitioner was found guilty of murder and sentenced to death in Alabama state court. Petitioner sought postconviction relief in state court under Alabama Rule 32, alleging, among other things, that his trial attorneys failed to afford him the effective assistance guaranteed by the Sixth Amendment. At issue was whether the extraordinary facts of petitioner's case were "cause" to excuse petitioner's procedural default in state court, i.e., petitioner's failure to timely appeal the Alabama trial court's order denying him postconviction relief. The court held that petitioner had shown the requisite "cause" to excuse his procedural default where he was abandoned by counsel and left unrepresented at a critical time for his state postconviction petition, and he lacked a clue of any need to protect himself pro se.