US Supreme Court: February 2010 Archives

The US Supreme Court issued one opinion today.  In Maryland v. Shatzer, the Court issued an opinion, authored by Justice Scalia, in which it found an exception to the 1981 decision in Edwards v. Arizona.  In Edwards, the Court held that once a suspect invokes the Miranda right to the presence of counsel, there is a presumption that any waiver of that right in response to police interrogation, while the suspect is in custody, is involuntary.  The defendant here invoked his right to counsel in 2003.  Investigation of the case closed and the defendant was returned to general population in prison pursuant to his conviction on another charge.  In 2006, another detective reopened the investigation.  The defendant waived his Miranda rights and gave an inculpatory statement.  The US Supreme Court creates a new rule in Shatzer by finding that if there is a break in Miranda custody of more than two weeks between the first and second attempts at interrogation, Edwards does not apply.  The defendant here was released back into the general prison population and the Court finds this to be a break in Miranda custody.  The continued detention, pursuant to a judgment of conviction, is disconnected from a custodial interrogation.  Justices Stevens and Thomas concur in the judgment but not the opinion.

Supreme Court grants cert in 2 cases

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The Supreme Court granted certiorari in two cases this week.  Scotusblog provides a summary and links to relevant documents:

Title: Los Angeles County v. Humphries
Docket: 09-350
Issues: (1) For a claim for declaratory relief against a local public entity, must the plaintiff demonstrate that the constitutional violation was the result of a policy, custom or practice attributable to the local public entity; and (2) if the plaintiff has not made such a showing, may he or she be a "prevailing party" under 42 U.S.C. ยง 1988 for purposes of a fee award?

Title: Harrington v. Richter
Docket: 09-587
Issue: Does a defense lawyer violate the Sixth Amendment right to the effective assistance of counsel when he does not investigate or present available forensic evidence supporting the theory of defense he uses during trial and instead relies on cross-examination and other methods designed to create reasonable doubt about the defendant's guilt?

In Florida v. Powell, a 7-2 decision authored by Justice Ginsburg, the Court finds that Miranda warnings were sufficient and did not mislead the accused into believing that he could not have an attorney present during questioning.  The Court notes that it has not required specific language for the warnings, so long as the warnings reasonably convey to a suspect his rights as required by Miranda. The Court also finds that a federal question is presented despite the Florida Supreme Court's citation to its state constitution as a basis for its holding.

The Court also issued an opinion in Hertz Corp. v. Friend.  The opinion concerns diversity-of-citizenship jurisdiction and finds that a corporation's principal place of business is the place where the corporation's high level officer's direct, control and coordinate the corporation's activities - it's nerve center.

Yesterday, the Court issued a per curiam, summary decision in Thaler v. Haynes.  The Court found that, under AEDPA, a trial judge need not personally observe a potential juror's behavior in later deciding whether the prosecutor used a peremptory challenge based upon the juror's race.  The prosecutor here claimed that the peremptory was used because of the juror's demeanor.  No prior ruling of the Court has required that the judge be present during jury selection in order to evaluate a Batson claim under these conditions.

The Court also issued a summary decision in Wilkins v. Gaddy.  The Court found that claims of excessive force on a suspect must be evaluated on the basis of the nature of the foce used, not on whether the plaintiff suffered an injury during the incident.

About this Archive

This page is a archive of entries in the US Supreme Court category from February 2010.

US Supreme Court: January 2010 is the previous archive.

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