- Abdul-Kabir v. Quarterman (No. 05-11284)
Do Texas's "special issue" jury instructions for capital sentencing allow jurors to give full consideration and effect to mitigating evidence about a defendant's destructive family background and mental defects, as required by the Eighth Amendment?
No. The Court ruled 5-4 that the Texas jury instructions conflicted with Supreme Court precedents requiring that jurors be given the opportunity "to give meaningful consideration and effect to all mitigating evidence that might provide a basis for refusing to impose the death penalty." The majority opinion by Justice John Paul Stevens found Texas's scheme of yes-or-no determinations of deliberateness and future dangerousness to be far too constraining. This was particularly true when the defense offers "double edged" evidence, which can be mitigating or aggravating depending on the jury's interpretation. The Court faulted the Fifth Circuit for not recognizing that Abdul-Kabir had presented mitigating evidence of his deprived childhood and his lack of self-control in order to show his relative lack of moral culpability - not to dispute either the deliberateness of his crime or his likely future dangerousness (which indeed might be aggravated by the evidence). Since the instruction did not allow the jury to consider the evidence as mitigating in the sense Abdul-Kabir intended, it was unconstitutional.
- Altadis USA, Inc. v. Sea Star Line, LLC (No. 06-606)
Does the Carmack Amendment apply to the inland portion of a shipment's transport into the United States even if the inland carrier does not issue a separate bill of lading?
Unanswered. Before hearing oral arguments, the parties reached a settlement and the Court granted their motion to dismiss the case.
- Ayers v. Belmontes (No. 05-493)
1) Is an "unadorned" factor (k) instruction sufficient to inform a jury that it must consider any mitigating evidence that a defendant may present concerning his probability of rehabilitation and good behavior as a prisoner?
2) Is the Ninth Circuit's ruling that factor (k) is constitutionally inadequate a "new constitutional rule of criminal procedure," in which case it would not be applied retroactively to other defendants whose cases are already final?
Yes and unanswered. In a 5-4 decision, the Court reversed the Ninth Circuit and upheld the factor (k) instruction, allowing Belmontes's death sentence to go forward. The opinion by Justice Anthony Kennedy held that "The factor (k) instruction is consistent with the constitutional right to present mitigating evidence in capital sentencing proceedings." Following the analysis in Boyde v. California, the Justices ruled that there was no reasonable likelihood that the jury had misunderstood the instruction. The Court held that the jurors had interpreted factor (k) as a broad catch-all under which they could consider forward-looking mitigating factors such as the possibility of rehabilitation. Since the jury had considered all of Belmontes's mitigating evidence before his sentencing, the sentence was constitutional. - BCI Coca-Cola Bottling Company of Los Angeles v. Equal Employment Opportunity Commission (No. 06-341)
If an employer with no discriminatory motive fires a subordinate based in part on the influence of another employee with a discriminatory motive, can the employer be held liable for discrimination under Section 703(a) of Title VII of the Civil Rights Act of 1964?
Unanswered. Prior to oral argument, BCI Coca-Cola moved to have the case dismissed. The government raised no objection, and the Court granted the motion.
- Beck v. PACE International Union (No. 05-1448)
Does the Employee Retirement Income Security Act of 1974 require an employer to consider merging an employee pension plan into a multiemployer pension plan prior to terminating the plan?
No. In a unanimous opinion authored by Justice Antonin Scalia, the Court held that "merger is not a permissible method of terminating a single-employer defined-benefit pension plan." Therefore, PACE's argument that Crown was required by ERISA to consider merger as a method of terminating the pension plan was rejected. Since ERISA does not expressly list merger as a method of termination, the Court relied on the view of the Pension Benefit Guaranty Corporation (PBGC) that merger is not covered under the statute's residual clause. This interpretation was supported by the structure of ERISA, which deals with mergers in a separate section.
- Bell Atlantic Corporation v. Twombly (No. 05-1126)
Can a plaintiff claim a violation of Section 1 of the Sherman Act by alleging parallel conduct by defendants amounting to a conspiracy?
No. The Court ruled 7-2 that a plaintiff claiming a Section 1 violation must also allege facts that, if true, would suggest a conspiratorial agreement. The opinion by Justice David Souter held that "Without more, parallel conduct does not suggest conspiracy [...]" and "A statement of parallel conduct [...] needs some setting suggesting the [conspiratorial] agreement [...]" The Court laid out a "plausibility standard" for the pleading stage of Section 1 suits. Claims are valid only if they allege facts that plausibly suggest a conspiracy. To allege facts that are merely consistent with a conspiracy is not sufficient. The suggestive facts need only be alleged; a suit can go forward even if the facts are unlikely to be proven by the plaintiff. The Court held that Twombly's claim should be dismissed, because he had failed to identify any facts that suggested illegal conspiracy over the alternative: a concurrent appraisal of the economic situation by several telecomm companies. The dissenting Justices accused the majority of acting on the basis of practical concerns over "enormously expensive" antitrust lawsuits with the potential to confuse juries.
- Bowles v. Russell (No. 06-5306)
May a federal Court of Appeals, acting on its own, dismiss an appeal as too late under Federal Rule of Appellate Procedure 4(a)(6) when the appeal is filed after the 14-day extension specified in the Rule but before the deadline established by the District Court?
Yes. The Court ruled that, even though Bowles was relying on the mistaken order of the District Court, the Circuit Court was correct to dismiss his untimely appeal. Justice Clarence Thomas's opinion for the 5-4 majority held that statutory time limits for filing a notice of appeal are jurisdictional, and therefore the Circuit Court had no choice but to dismiss Bowles's appeal once it found that the appeal was filed too late. The Court ruled that it had no authority to create an exception for Bowles under the little-used doctrine of "unique circumstances," and it overruled its precedents "to the extent they purport to authorize an exception to a jurisdictional rule." The majority left it to Congress to change the rule if Congress thought it unfair. In dissent, Justice David Souter wrote: "It is intolerable for the judicial system to treat people this way, and there is not even a technical justification for condoning this bait and switch."
- BP America Production Company v. Burton (No. 05-669)
Does the six-year statute of limitations for government actions for monetary damages in 28 U.S.C. 2415(a) govern the issuance of administrative orders, as opposed to the government's filing of a complaint in court?
No. The Court ruled 7-0 that "the 6-year statute of limitations in 2415(a) applies only to court actions and not to the administrative proceedings involved in this case." The opinion by Justice Samuel Alito relied on the plain meaning of the language in Section 2415(a). The statute used the terms "action" and "complaint" when referring to the statute of limitations. The Court held that these terms, when used by themselves, refer only to judicial proceedings, not administrative ones. Additionally, the Court noted that statutes of limitations on government actions are normally construed in favor of the government.
- Brendlin v. California (No. 06-8120)
When a vehicle is subject to a traffic stop, is a passenger in the vehicle "detained" for purposes of the Fourth Amendment?
Yes. In a unanimous opinion written by Justice David Souter, the Court held that when a vehicle is stopped at a traffic stop, the passenger as well as the driver is seized within the meaning of the Fourth Amendment. The justices said, "We resolve this question by asking whether a reasonable person in Brendlin's position when the car stopped would have believed himself free to 'terminate the encounter' between the police and himself." The Court held that Brendlin would have reasonably believed himself to be intentionally detained and subject to the authority of the police. Thus, he was justified in asserting his Fourth Amendment protection against unreasonable seizure. The Court noted that its ruling would not extend
