Willamette Law Online - Willamette University College of Law
On May 19, 2016, the United States Supreme Court issued three opinions summarized below.
DECISIONS
(1) ATTORNEY FEES: A judgment on the merits is not necessary to find that a defendant has prevailed for the purposes of determining whether a defendant can recover attorney’s fees. [Read Summary Online]
(2) CRIMINAL PROCEDURE: The Sixth Amendment right to a speedy trial does not apply once a defendant has been found guilty at trial or pleaded guilty, including the time between conviction and sentencing, although other Due Process challenges may still be raised. [Read Summary Online]
(3) IMMIGRATION: State crimes constitute "aggravated felonies" for purposes of the Immigration and Nationality Act if the state crime has all of the elements of a corresponding federal statute except the federal jurisdictional element. [Read Summary Online]
DECISIONS
Date Filed: May 19, 2016
Case #: 14-1375
Kennedy, J., delivered the Court's opinion, which Thomas, J., filed a concurring opinion.
Full Text Opinion: http://www.
Case #: 14-1375
Kennedy, J., delivered the Court's opinion, which Thomas, J., filed a concurring opinion.
Full Text Opinion: http://www.
ATTORNEY FEES: A judgment on the merits is not necessary to find that a defendant has prevailed for the purposes of determining whether a defendant can recover attorney’s fees.
Title VII of the Civil Rights Act of 1964 provides that a court may allow the prevailing party to recover an attorney’s fee. Following an allegation of sexual harassment by a CRST employee, the Equal Employment Opportunity Commission ("EEOC") filed suit against CRST, alleging that CRST subjected numerous employees to a sexually hostile work environment. The district court dismissed the EEOC’s claims for a variety of procedural reasons and found CRST to be the prevailing party. The Court then granted CRST’s motion for attorney’s fees. The Eighth Circuit affirmed the District Court’s dismissal, reversing only two claims, and vacated the attorney’s fees award because, in light of the two reversals, CRST could no longer be considered a prevailing party. On remand, the district court again awarded attorney’s fees to CRST because it had prevailed on the merits on other claims. The Eighth Circuit reversed, disagreeing that CRST prevailed on the merits of those claims. The Eighth Circuit's decision conflicted with the decisions of other circuits, and on appeal, the Supreme Court held that a judgment on the merits is not necessary for a defendant to be considered a prevailing party. The Court reasoned that Congress did not intend for defendants to receive attorney’s fees only in the presence of a judgment on the merits. Rather, the Court acknowledged that it had previously nterpreted that prevailing defendants may recover when the plaintiff’s claim are frivolous, unreasonable, or groundless. VACATED and REMANDED.
[Summarized by: Megan Oshiro]
Date Filed: May 19, 2016
Case #: 14–1457
GINSBURG, J., delivered the opinion for a unanimous Court. THOMAS, J., filed a concurring opinion, in which ALITO, J., joined. SOTOMAYOR, J., filed a concurring opinion.
Full Text Opinion: http://www.
Case #: 14–1457
GINSBURG, J., delivered the opinion for a unanimous Court. THOMAS, J., filed a concurring opinion, in which ALITO, J., joined. SOTOMAYOR, J., filed a concurring opinion.
Full Text Opinion: http://www.
CRIMINAL PROCEDURE: The Sixth Amendment right to a speedy trial does not apply once a defendant has been found guilty at trial or pleaded guilty, including the time between conviction and sentencing, although other Due Process challenges may still be raised.
Petitioner pleaded guilty to bail jumping. Due to delays in the disposition of his presentence motions and the completion of the presentence report, Petitioner was imprisoned for fourteen months before receiving his sentence. On direct appeal to the Montana Supreme Court, Petitioner's sentence was upheld. Petitioner appealed to the Supreme Court, raising a Sixth Amendment violation of his right to a speedy trial. The Supreme Court held that Sixth Amendment's Constitutional guarantee to a speedy trial attaches when the accused is arrested or indicted, and it ends upon conviction and does not extend through sentencing. The Court reasoned that historically the presumption of innocence of the accused was the cornerstone principle supporting the right to a speedy trial and that this justification is negated by a valid conviction. The Court further reasoned that there is no reference to the period after conviction in the text of the Speedy Trial Clause or the legislation giving it effect, the Speedy Trial Act of 1974, 18 U. S. C. §3161 et seq. The Court advised that Due Process, penal statutes, and rules of criminal procedure provide adequate channels of protection for defendants’ liberties between conviction and sentencing. Petitioner did not preserve any of these alternative challenges. AFFIRMED.
[Summarized by: Corey Riley]
Date Filed: May 19, 2016
Case #: 14–1096
KAGAN, J., delivered the opinion of the Court, in which ROBERTS, C. J., and KENNEDY, GINSBURG, and ALITO, JJ., joined. SOTOMAYOR, J., filed a dissenting opinion, in which THOMAS and BREYER, JJ., joined.
Full Text Opinion: http://www.
Case #: 14–1096
KAGAN, J., delivered the opinion of the Court, in which ROBERTS, C. J., and KENNEDY, GINSBURG, and ALITO, JJ., joined. SOTOMAYOR, J., filed a dissenting opinion, in which THOMAS and BREYER, JJ., joined.
Full Text Opinion: http://www.
IMMIGRATION: State crimes constitute "aggravated felonies" for purposes of the Immigration and Nationality Act if the state crime has all of the elements of a corresponding federal statute except the federal jurisdictional element.
Petitioner, a lawful permanent resident, pled guilty to attempted arson in New York state court. Subsequently, immigration officials sought to remove Petitioner after learning of his conviction. Petitioner then applied for and was denied cancellation of removal by the Immigration Judge on the grounds that his prior felony conviction, as an "aggravated felony," made him ineligible for cancellation of removal and other forms of discretionary relief. Petitioner appealed and the Board of Immigration Appeals affirmed. Petitioner then appealed for review to the Second Circuit and was denied. The Supreme Court affirmed the decision of the Second Circuit to deny review, holding that when a state crime has all of the elements of a corresponding federal statute except the federal jurisdictional element, it is immaterial that the state crime lacks that element. The Court reasoned that state and federal crimes would never match up precisely, because federal statutes must apply a jurisdictional element, whereas state crimes do not. The Court acknowledged that the harm of the crime is the same regardless of whether a state or the federal government prosecutes the crime. The Court further noted that when Congress has said nothing about the jurisdictional element, the default rule is that federal courts assume that Congress intended for that element to be excluded from the mens rea requirement of the crime. AFFIRMED.
[Summarized by: Grant Elder]
UNITED STATES SUPREME COURT NEWS
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Willamette Law Online – Willamette University College of Law
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