Justia Criminal Law Opinion Summaries

Arizona prisoners could raise claims of ineffective assistance of trial counsel only in state collateral proceedings, not on direct review. In petitioner's first state collateral proceeding, his counsel did not raise such a claim. On federal habeas review with new counsel, petitioner argued that he received ineffective assistance both at trial and in his first state collateral proceeding. He also claimed that he had a constitutional right to an effective attorney in the collateral proceeding because it was the first place to raise his claim of ineffective assistance at trial. The Court held that where, under state law, ineffective-assistance-of-trial-counsel claims must be raised in an initial-review collateral proceeding, a procedural default would not bar a federal habeas court from hearing those clams if, in the initial-review collateral proceeding, there was no counsel or counsel in the proceeding was ineffective. Therefore, the Court reversed the judgment of the Ninth Circuit.

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.

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.

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 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.

Respondent sought damages from employees at a privately run federal prison in California, claiming that they had deprived him of adequate medical care in violation of the Eighth Amendment's prohibition against cruel and unusual punishment. At issue was whether the Court could imply the existence of an Eighth Amendment-based damages action against employees of a privately operated federal prison. Because the Court believed that in the circumstances of this case, state tort law authorized adequate alternative damage actions - actions that provide both significant deterrence and compensation - no Bivens v. Six Unknown Fed. Narcotics Agents remedy could be implied here.

Defendant was convicted of theft by unauthorized taking. On appeal, defendant argued that the trial court erred in requiring an initial showing that police arranged a suggestive identification procedure. Suggestive circumstances alone, defendant contended, sufficed to require court evaluation of the reliability of an eyewitness identification before allowing it to be presented to the jury. The New Hampshire Supreme Court rejected defendant's argument and affirmed his conviction. The Court held that the Due Process Clause did not require a preliminary judicial inquiry into the reliability of an eyewitness identification when the identification was not procured under unnecessarily suggestive circumstances arranged by law enforcement. Accordingly, the Court affirmed the judgment of the New Hampshire Supreme Court.

This case interpreted two provisions of the Antiterrorism and Effective Death Penalty Act of 1996, (AEDPA). The first, 28 U.S.C. 2253(c), provided that a habeas petitioner must obtain a certificate of appealability (COA) to appeal a federal district court's final order in a habeas proceeding (section 2253(c)(1)). The COA could issue only if the petitioner had made a "substantial showing of the denial of a constitutional right" (section 2253(c)(2)), and "shall indicate which specific issue" satisfied that showing (section 2253(c)(3)). The Court held that section 2253(c)(3) was not a jurisdictional requirement. Accordingly, a judge's failure to "indicate" the requisite constitutional issue in a COA did not deprive a court of appeals of subject-matter jurisdiction to adjudicate the habeas petitioner's appeal. The second provision, 28 U.S.C. 2244(d)(1)(A), established a 1-year limitations period for state prisoners to file federal habeas petitions, running from "the date on which the judgment became final by the conclusion of direct review or the expiration of the time for seeking such review." The Court held that, for a state prisoner who did not seek review in a State's highest court, the judgment became "final" on the date that the time for seeking such review expired.