2015-16 Supreme Court Updates
The Kentucky Department of Criminal Justice Training provides the following
case summaries for information purposes only. As always, please consult your agency’s
legal counsel for the applicability of these cases to specific situations.
This summary may be reproduced, for educational purposes only, with attribution to DOCJT. A longer summary of each of these cases may be found on the DOCJT website.
There also are additional summaries of cases not included in this update located on the website.
Find full text of all cases on the U.S. Supreme Court website.
Please note, the latest cases in this summary have not yet been assigned official citations.
DEFICIENT COUNSEL
Maryland v. Kulbicki, 136 S.Ct. 2 (2015), Decided Oct. 5, 2015
ISSUE: Is it proper to expect defense counsel to be prescient and anticipate challenges to scientific evidence in the future?
HOLDING: The Court agreed that it could not fault defense counsel for being unaware of possible challenges in the future to the validity of scientific evidence.
42 U.S.C. §1983 – QUALIFIED IMMUNITY
Mullenix v. Luna, 136 S.Ct. 305 (2015), Decided Nov. 9, 2015
ISSUE: Is the question of whether a law enforcement officer is entitled to qualified immunity in a deadly-force incident dependent upon the specific facts of the case?
HOLDING: Qualified immunity provides protection when an officer’s actions are not clearly unconstitutional, but which instead, fall into the “hazy legal background” at issue in this case (shooting into a moving vehicle to halt a dangerous pursuit).
FEDERAL SENTENCING
Lockhart v. U.S., 136 S.Ct. 958 (2016), Decided March 1, 2016
ISSUE: Does the phrase “aggravated sexual abuse, sexual abuse, or abusive sexual conduct involving a minor or ward” in 18 U.S.C. §2252(b)(2), require a minor to be the victim in all three of the listed offenses?
HOLDING: The Court agreed that only the last clause, “abusive sexual conduct involving a minor or ward,” required that the victim be, in fact, a minor. In the other two, the victim may be an adult.
BRADY
Wearry v. Cain, 136 S.Ct. 1002 (2016), Decided March 7, 2016
ISSUE: Will the failure to reveal material, exculpatory evidence during a trial likely lead to a reversal of the conviction?
HOLDING: The Court agreed that if exculpatory evidence is not revealed that could have had a material impact on the underlying conviction, the conviction would be subject to reversal.
WEAPONS
Caetano v. Massachusetts, 136 S.Ct. 1027 (2016), Decided March 21, 2016
ISSUE: Are stun guns/electrical weapons protected under the Second Amendment?
HOLDING: The Court agreed that a stun gun (or similar electrical weapon) is considered a weapon under the Second Amendment.
FORFEITURE
Luis v. U.S., 136 S.Ct. 1083 (2016), Decided March 30, 2016
ISSUE: Are a defendant’s untainted funds subject to seizure prior to conviction?
HOLDING: The Court agreed that depriving suspects of untainted funds effectually denied them the right to be represented by counsel of their choice. As such, seizing funds that are not specifically part of the charged crime is improper.
DEFICIENT COUNSEL
Woods (Warden) v. Etherton, 136 S.Ct. 1149 (2016), Decided April 4, 2016
ISSUE: Does the Antiterrorism and Effective Death Penalty Act of 1996 defer to a trial court’s decision regarding ineffective assistance of counsel?
HOLDING: The Court agreed that if the trial court concluded the defense attorney performed an adequate representation on behalf of their client, the higher court would not change that decision unless there was clear evidence to the contrary.
SEX OFFENDER REGISTRY AND NOTIFICATION ACT
Nichols v. U.S., 136 S.Ct.1113 (2016), Decided April 4, 2016
ISSUE: Are sex offender registrants required, under 18 U.S.C. §2250, to update their registration at their previous address?
HOLDING: The Court agreed that, at the time, sex offenders are generally not required to notify a jurisdiction that they had left the country. However, subsequent federal law now requires notification of foreign travel, and as such, the issue is now essentially moot.
ARMED CAREER CRIMINAL ACT
Welch v. U.S., 136 S.Ct. 1257 (2016), Decided April 18, 2016
ISSUE: Does Johnson v. U.S., 135 S.Ct. 939 (2015), create a new substantive rule that applies retroactively to cases on collateral review?
HOLDING: In this case, which involved the application of the Armed Career Criminal Act, the Court agreed that Johnson involved substantive law, which allowed for it to be applied to cases that were still on post-conviction review.
FIRST AMENDMENT
Heffernan v. City of Paterson, New Jersey, 136 S.Ct. 1412 (2016), Decided April 26, 2016
ISSUE: Does the First Amendment bar the government from demoting a public employee based on a supervisor’s perception that the employee supports a political candidate?
HOLDING: The Court agreed that to win, the employee must prove that there was an improper employer motive that was tied to the employee’s support. Specifically, the Court noted, in this case, there was at least some evidence that the demotion was simply based on a neutral policy prohibiting officers from overt involvement in any political campaign.
HOBBS ACT
Ocasio v. U.S., 136 S.Ct. 1423 (2016), Decided May 2, 2016
ISSUE: Does a federal conspiracy to commit extortion require that the conspirators agree to obtain property from someone outside the conspiracy?
HOLDING: The Court agreed that it was part of a conspiracy when the subject obtained proceeds by fraud through another member of the conspiracy (who had ultimately received the money through fraud). As such, the crime of conspiracy to commit extortion (albeit from another person involved) was valid.
Taylor v. U.S., 136 S.Ct. (2016), Decided June 20, 2016
ISSUE: Is the government relieved of proving the interstate commerce element by relying exclusively on evidence that the robbery or attempted robbery of a drug dealer is an inherent economic enterprise that satisfies, as a matter of law, the interstate commerce element of the offense?
HOLDING: The Court agreed that although the underlying robbery in this case was purely local (involving marijuana apparently grown within the state in question), it still had enough interstate economic impact to allow prosecution under the federal Hobbs Act.
SEARCH & SEIZURE
Utah v. Strieff, 136 S.Ct. (2016), Decided June 20, 2016
ISSUE: Should evidence seized incident to a lawful arrest on an outstanding warrant be suppressed because the warrant was discovered during an investigatory stop later found to be unlawful?
HOLDING: The Court agreed that when a warrant is found following an unlawful stop, that any evidence found incident to the arrest still will be admissible in most instances.
Armed Career Criminal Act (ACCA)
Mathis v. U.S., 136 S.Ct. (2016), Decided June 23, 2016
ISSUE: Does the application of the Armed Career Criminal Act involve only comparing elements, rather than facts?
HOLDING: The Court emphasized that, pursuant to earlier rulings, a state crime cannot qualify as a predicate under the ACCA if its elements are broader than those of a listed generic offense.
DUI / IMPLIED CONSENT
Birchfield v. North Dakota, Bernard v. Minnesota, and Beylund v. Levi, 136 S.Ct. (2016) (Three cases consolidated upon appeal)
Decided June 23, 2016
ISSUE: May a state make it a separate crime for a person to refuse to take a chemical test to detect the presence of alcohol in the person’s blood?
HOLDING: The Court agreed that breath testing of a person under arrest was permissible without a warrant, but that a forced blood test is not, without consent, a true exigent circumstance or a warrant. As such, it is not appropriate to make it a separate crime to refuse a blood test.
DOMESTIC VIOLENCE
Voisine v. U.S., 136 S.Ct. (2016), Decided June 27, 2016
ISSUE: Does a reckless assault conviction under domestic circumstances invoke the federal gun ban?
HOLDING: The Court agreed that reckless conduct that results in an assault that qualifies under the federal definition of a domestic situation, does trigger the federal gun ban. (However, in Kentucky, the mental state that fits the definition of reckless in Maine, the state where the case originated, would be classified as wanton and not reckless.)
