Justia Constitutional Law Opinion Summaries

The State appealed a three-judge district court order directing California to remedy two ongoing violations of the Cruel and Unusual Punishments Clause, a guarantee binding on the States by the Due Process Clause of the Fourteenth Amendment, by reducing the prison system population where the violations were the subject of two class actions involving a class of prisoners with serious mental disorders and a class of prisoners with serious medical conditions. At issue was whether the remedial order issued by the three-judge court was consistent with requirements and procedures set forth in a congressional statute, the Prison Litigation Reform Act of 1995 ("PLRA"), 18 U.S.C. 3626. The Court held that the court-mandated population limit was necessary to remedy the violation of prisoners' constitutional rights and was authorized by the PLRA.

Respondent entered a conditional guilty plea to charges of trafficking in marijuana, first-degree trafficking in a controlled substance, and second-degree persistent felony offender status and appealed the denial of his motion to suppress evidence from a warrantless search. At issue was whether the exigent circumstances rule applied when police officers, by knocking on the door of a residence and announcing their presence, caused the occupants to attempt to destroy evidence. The Court held that the exigent circumstances rule applied when the police did not create the exigency by engaging or threatening to engage in conduct that violated the Fourth Amendment. The Court also held that, assuming than an exigency existed in this case, there was no evidence that the officers either violated the Fourth Amendment or threatened to do so prior to the point when they entered the apartment. Therefore, the Court reversed and remanded for further proceedings.