2016-17 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. Please note, some cases have not yet been assigned official citations.
QUALIFIED IMMUNITY
White v. Pauly, 137 S.Ct. 548 (2017), Decided Jan. 9, 2017
ISSUE: Is it clearly established law that a late-arriving officer at an ongoing situation must second guess the actions of officers who arrived before?
HOLDING: In this case, the officer who was sued arrived late to a situation, in which fellow officers already had taken fire. Within moments of his arrival, one of the subjects pointed a handgun in the officer’s direction, and he fatally shot the subject. He did not know what had happened between the officers and the occupants prior to his arrival, with the suggested possibility the subject could have believed he was lawfully defending his home against intruders. There was some question as to whether the initial officers fully identified themselves as such.
Qualified immunity is appropriate when an officer does not violate clearly-established statutory or constitutional rights of which a reasonable officer would be aware. In this case, the Court agreed no reasonable officer in the situation presented would believe deadly force would not be appropriate when a weapon was pointed in his or her direction, nor would the officer be required to second guess or even know about the actions of officers who already were present at the scene.
CAPITAL PUNISHMENT
Moore v. Texas, 137 S.Ct. 1039 (2017), Decided March 28, 2017
ISSUE: Must a ruling on intellectual disability in a death-penalty case use current medical standards?
HOLDING: In a situation in which a court is considering capital punishment, it must use currently accepted medical standards in evaluating a subject’s intellectual status. The Court may not use a standard which differs from that used in juvenile court and the school system, for example.
42 U.S.C. §1983 – FORCE
County of Los Angeles v. Mendez, 137 S.Ct. 1240 (2017), Decided May 30, 2017
ISSUE: Does an action brought under 42 U.S.C. § 1983, in an incident giving rise to a reasonable use of force, allow for a secondary analysis of a provocative action that preceded the use of force and made the use of force unreasonable?
HOLDING: The Court agreed lower courts may not apply a rule that requires consideration of whether an officer’s earlier violation of a constitutional rule in some way affected a later use of lawful force, instead rendering it unlawful.
FIRST AMENDMENT
Packingham v. North Carolina, 137 S.Ct. 1730 (2017), Decided June 19, 2017
ISSUE: May a state enact a statute that prohibits sex-offender registrants from using common social-media sites?
HOLDING: The Court agreed it no longer was appropriate to deny a convicted sex offender the ability to access common social-media sites, such as Facebook, solely because minors have access to the forum. This decision is based upon the First Amendment and does not apply to statutes that specifically prohibit contacting juveniles through such methods. This case directly impacts KRS 17.546, which is similar in relevant content to the North Carolina statute.
FORFEITURE
U.S. v. Honeycutt, 137 S.Ct. 1626 (2017), Decided June 19, 2017
ISSUE: May the government apply joint and several liability (where both are responsible for the total amount of the fine, rather than each being assessed a percentage of the fine) in a drug conviction under 21 U.S.C. §853 when the defendant obtained no direct benefit?
HOLDING: The Court agreed the criminal-forfeiture statutes are intended to authorize confiscation of property from individuals who received it from, or used it to, facilitate criminal activity. An employee, while they may receive a tangential benefit, is not in possession of tainted property and is not subject to forfeiture.
BRADY
Turner v. U.S., 137 S.Ct. 1885 (2017), Decided June 22, 2017
ISSUE: Does all suppressed evidence implicate Brady v. Maryland, 373 U.S. 83 (1963)?
HOLDING: The Court agreed not all evidence improperly withheld during discovery was material to the case, even if favorable to the defense. The standard, however, is whether in the context of the entire record, there was a reasonable probability it truly would have made a difference in the ultimate verdict. In the facts of this case, the Court agreed, it would not have affected the jury’s decision.
This summary may be reproduced, for education purposes only, with attribution to DOCJT. A longer summary of each of these cases may be found on the DOCJT website at http://docjt.ky.gov/legal. There also are additional summaries of cases not included in this update located on the website.
Full text of all U.S. Supreme Court cases may be found at http://www.supremecourt.gov.
