Details on today’s opinions
on Feb 21, 2012 at 1:32 pm
The Court issued two opinions in argued cases, as well as two per curiam opinions in non-argued cases.
The first opinion this morning was in Howes v. Fields, which Justice Alito announced for the Court. The Court reversed the decision of the Sixth Circuit. The Court unanimously held that the Sixth Circuit’s categorical rule – that an interrogation is per se custodial, for purposes of Miranda v. Arizona, when a prisoner is questioned in private about events occurring outside the prison – is not clearly established by Supreme Court precedent. And by a vote of six to three, the Court held that the Sixth Circuit’s rule is also wrong. Justice Ginsburg filed an opinion concurring in part and dissenting in part, which Justices Breyer and Sotomayor joined.
The second opinion was in Kawashima v. Holder, which Justice Thomas announced for the Court. Also by a vote of six to three, the Court affirmed the decision of the Ninth Circuit. It held that violations of 26 U.S.C. §§ 7206(1) and (2), which preclude making (or assisting in the making of) a false tax return, are crimes “involv[ing] fraud or deceit” under 8 U.S.C. § 1101(a)(43)(M)(i) and are therefore aggravated felonies for purposes of the Immigration and Nationality Act, 8 U.S.C. § 1101 et seq., when the loss to the government exceeds $10,000. Justice Ginsburg filed a dissenting opinion in which Justices Breyer and Kagan joined.
The Court also issued two per curiam opinions in non-argued cases. In Wetzel v. Lambert, the U.S. Court of Appeals for the Third Circuit had granted the respondent, who was convicted of capital murder in 1984, habeas relief. That court relied on notations on a police activity sheet that had not been disclosed to Lambert at trial, and which indicated that one of Lambert’s accomplices had identified a third individual as a “co-defendant.” It held that the failure to disclose the activity sheet violated his rights under Brady v. Maryland. The Supreme Court vacated that decision and remanded the case for further proceedings on the ground that the Third Circuit had failed to address the state court’s determination that the notations on the activity sheet were “not exculpatory or impeaching”” but instead “entirely ambiguous.” Justice Breyer filed a dissenting opinion, which Justices Ginsburg and Kagan joined.
The last opinion of the day came in Marmet Health Care Center, Inc. v. Brown and Clarksburg Nursing Home and Rehabilitation Center v. Marchio. The Court vacated the decision of the West Virginia Supreme Court of Appeals, holding that the state’s categorical prohibition of pre-dispute agreements to arbitrate personal-injury or wrongful-death claims against nursing homes is contrary to the terms and coverage of the FAA.