Justia Constitutional Law Opinion Summaries

Respondents, representing the video game and software industries, filed a preenforcement challenge to California Assembly Bill 1179 (Act), Cal. Civ. Code Ann. 1746-1746.5, which restricted the sale or rental of violent video games to minors. At issue was whether the Act comported with the First Amendment. The Court held that, because the Act imposed a restriction on the content of protected speech, it was invalid unless California could demonstrate that it passed strict scrutiny. The Court held that California had a legitimate interest in addressing a serious social problem and helping concerned parents control their children. The Court held, however, that as a means of protecting children from portrayals of violence, the legislation was seriously underinclusive, not only because it excluded portrayals other than video games, but also because it permitted a parental or avuncular veto. The Court also held that, as a means of assisting concerned parents, it was seriously overinclusive because it abridged the First Amendment rights of young people whose parents think violent video games were a harmless pastime. The Court further held that the overbreadth in achieving one goal was not cured by the overbreadth in achieving the other and therefore, the legislation could not survive strict scrutiny. Accordingly, the court affirmed the judgment of the Ninth Circuit enjoining the Act's enforcement.

The Sentencing Reform Act of 1984 ("Act"), 18 U.S.C. 3551 et seq., called for the creation of Sentencing Guidelines to inform judicial discretion in order to reduce unwarranted disparities in federal sentencing. The Act allowed retroactive amendments to the Guidelines for cases where the Guidelines became a cause of inequality. When a retroactive Guideline amendment was adopted, section 3682(c)(2) permitted defendants sentenced based on a sentencing range that had been modified to move for a reduced sentence. In this case, petitioner was indicted for various crimes, including possessing with intent to distribute cocaine base, and entered into a Federal Rule of Criminal Procedure 11(c)(1)(C) agreement to plead guilty to all charges where the Government, in return, agreed to a 106 month sentence. At issue was whether defendants who enter into plea agreements that recommended a particular sentence as a condition of the guilty plea could be eligible for relief under section 3682(c)(2). The Court held that the text and purpose of the statute, Rule 11(c)(1)(C), and the governing Guidelines policy statements compelled the conclusion that the district court had authority to entertain section 3582(c)(2) motions when sentences were imposed in light of the Guidelines, even if the defendant entered into an Rule 11(c)(1)(C) agreement. The Court also held that petitioner's sentencing hearing transcript revealed that the District Court expressed its independent judgment that the sentence was appropriate in light of the applicable Guidelines range. Therefore, the District Court's decisions was "based on" that range within section 3682(c)(2)'s meaning. Accordingly, the judgment of the Court of Appeals was reversed and the case remanded for further proceedings.

Petitioner was arrested on charges of driving while intoxicated ("DWI") and the principal evidence against him was a forensic laboratory report certifying that his blood alcohol concentration was well above the threshold for aggravated DWI. At trial, the prosecution did not call as a witness the analyst who signed the certification and, instead, called another analyst who was familiar with the laboratory's testing procedures but had neither participated in nor observed the test on petitioner's blood sample. At issue was whether the Confrontation Clause permitted the prosecution to introduce a forensic laboratory report containing a testimonial certification, made for the purpose of proving a particular fact, through the in-court testimony of a scientist who did not sign the certification or perform or observe the test reported in the certification. The Court held that surrogate testimony of that order did not meet the constitutional requirement where the accused's right was to be confronted with the analyst who made the certification, unless that analyst was unavailable at trial and the accused had an opportunity, pretrial, to cross-examine that particular scientist. Accordingly, the judgment of the New Mexico Supreme Court was reversed and the case remanded for further proceedings.

Vermont's Prescription Confidentiality Law, Vt. Stat. Ann., Tit. 18, 4631(d), restricted the sale, disclosure, and use of pharmacy records that revealed the prescribing practices of individual doctors. Respondents, Vermont data miners and an association of brand-name drug manufacturers, sought declaratory and injunctive relief against state officials, contending that section 4631(d) violated their rights under the Free Speech Clause of the First Amendment. At issue was whether section 4631(d) must be tested by heightened judicial scrutiny and, if so, whether Vermont could justify the law. The Court held that the Vermont Statute, which imposed content-based and speaker-based burdens on protected expression, was subject to heightened judicial scrutiny. The Court also held that Vermont's justifications for section 4631(d) did not withstand such heightened scrutiny and therefore, affirmed the Second Circuit's judgment that section 4631(d) unconstitutionally burdened the speech of pharmaceutical marketers and data miners without adequate justification.

This case stemmed from petitioner's civil contempt proceedings where South Carolina's Family Court enforced child support orders against him. At issue was whether the Fourteenth Amendment's Due Process Clause required the State to provide counsel at the civil contempt hearing to an indigent person potentially faced with incarceration. The Court held that even though petitioner had completed his 12 month prison sentence, and there were not alleged to be collateral consequences of the contempt determination that might keep the dispute alive, this case was not moot because it was capable of repetition while evading review. The Court held that the Fourteenth Amendment's Due Process Clause did not automatically require the State to provide counsel at civil contempt proceedings to an indigent noncustodial parent who was subject to a child support order, even if that individual faced incarceration. In particular, that Clause did not require that counsel be provided where the opposing parent or other custodian was not represented by counsel and the State provided alternative procedural safeguards equivalent to adequate notice of the importance of the ability to pay, a fair opportunity to present, and to dispute, relevant information, and express court findings as to the supporting parent's ability to comply with the support order. Under the circumstances, petitioner's incarceration violated due process because he received neither counsel nor the benefit of alternative procedures like those the Court described. Accordingly, the Court vacated the judgment and remanded for further proceedings.

This case concerned the extent of the protection, if any, that the Petition Clause granted public employees in routine disputes with government employers where petitioner filed a 42 U.S.C. 1983 suit after respondent's termination of petitioner as police chief and where petitioner was subsequently reinstated, with directives instructing petitioner in the performance of his duties. Petitioner alleged that the directives were issued in retaliation for the filing of his first grievance and violated his First Amendment right to "petition the Government for a redress of grievances." At issue was whether the public concern test applied when the employee invoked the Petition Clause. The Court held that a government employer's allegedly retaliatory actions against an employee did not give rise to liability under the Petition Clause unless the employee's petition related to a matter of public concern. Therefore, the Court held that the Third Circuit's conclusion that the public concern test did not limit public employees' Petition Clause claims was incorrect. Accordingly, the Court concluded that, absent full briefs by the parties, the Court need not consider how the foregoing framework would apply to this case and therefore, vacated the judgment and remanded for further proceedings.

Petitioner was indicted for violating 18 U.S.C. 229, which forbid knowing possession or use, for nonpeaceful purposes, of a chemical that "can cause death, temporary incapacitation or permanent harm to humans," and which was part of a federal act implementing a chemical weapons treaty ratified by the United States. At issue was whether a person indicted for violating a federal statute had standing to challenge its validity on grounds that, by enacting it, Congress exceeded its powers under the Constitution, thus intruding upon the sovereignty and authority of the States. The Court held that petitioner had standing to challenge the federal statute where there was no basis in precedent or principle to deny petitioner's standing to raise her claims. The ultimate issue of the statute's validity turned in part on whether the law could be deemed "necessary and proper for carrying into Execution" the President's Article II, section 2 Treaty Power. Accordingly, the Court expressed no view on the merits of the argument and noted that it could be addressed by the Court of Appeals on remand. Therefore, the judgment of the Court of Appeals was reversed and the case remanded for further proceedings.

While conducting a routine vehicle stop, police arrested petitioner, a passenger of the vehicle, for giving a false name. After handcuffing him and securing the scene, the police searched the vehicle and found petitioner's revolver. Petitioner was subsequently indicted on charges of being a felon in possession of a firearm. In a suppression motion, petitioner acknowledged that the search of the vehicle complied with existing Eleventh Circuit precedent interpreting New York v. Belton, but he raised a Fourth Amendment challenge to preserve the issue on appeal. The District Court denied the motion and petitioner was convicted. While his appeal was pending, the Court announced, in Arizona v. Gant, a new rule governing automobile searches incident to arrests of recent occupants. At issue was whether to apply the exclusionary rule when the police conducted a search in compliance with binding precedent that was later overruled. Because the suppression would do nothing to deter police misconduct in these circumstances, and because it would come at a high cost to both the truth and the public safety, the Court held that the searches conducted in objectionable reliance on binding appellate precedent were not subject to the exclusionary rule. Accordingly, the Court affirmed the suppression of the revolver and petitioner's conviction.

J.D.B., a thirteen-year-old seventh-grade student, was taken from his classroom to a closed-door conference room where uniformed police and school administrators questioned him for at least 30 minutes regarding two home break-ins nearby. Before beginning, they did not give J.D.B. Miranda warnings, the opportunity to call his legal guardian, or tell him he was free to leave the room. After J.D.B. subsequently confessed to the break-ins and wrote a statement at the request of police, two juvenile petitions were filed against him. J.D.B.'s public defender moved to suppress his statements and the evidence derived therefrom, arguing that he had been interrogated in a custodial setting without being afforded Miranda warnings and that his statements were involuntary. At issue was whether the age of a child subjected to police questioning was relevant to the custody analysis of Miranda v. Arizona. The Court held that it was beyond dispute that children would often feel bound to submit to police questioning when an adult in the same circumstances would feel free to leave. Seeing no reason for police officers or courts to blind themselves to that commonsense reality, the Court held that a child's age group properly informed the Miranda custody analysis. Accordingly, the Court reversed and remanded to the state courts to address whether J.D.B. was in custody when he was interrogated, taking account of all of the relevant circumstances of the interrogation, including his age at the time.

Petitioner was convicted of, inter alia, smuggling unauthorized aliens into the United States. The District Court imposed a 51 month prison sentence, reasoning that petitioner should serve that long in order to qualify for and complete the Bureau of Prisons' Residential Drug Abuse Program ("RDAP"). At issue was whether the Sentencing Reform Act ("SRA"), 18 U.S.C. 3582(a), precluded federal courts from imposing or lengthening a prison term in order to promote a criminal defendant's rehabilitation. The Court held that the text, context, and history of section 3582(a) precluded sentencing courts from imposing or lengthening a prison term to promote an offender's rehabilitation. The Court also held that Amicus' attempts to recast what the SRA said about rehabilitation were unavailing. The court further held that the record indicated that the District Court may have increased the length of petitioner's sentence to ensure her completion of RDAP, something a court could not do. Accordingly, the Court reversed and remanded for further proceedings and held that the Ninth Circuit was left to consider on remand the effect of petitioner's failure to object to the sentence when imposed.