Recent SCOTUS Cases

The Federal Docket

Lange v. California (U.S. Supreme Court, June 2021)

In a 6-3 opinion with several justices concurring in the judgment, the Supreme Court reversed the denial of a defendant’s suppression motion after an officer entered his garage without a warrant after chasing him for a misdemeanor traffic offense. The Court held that the flight of a person suspected of a misdemeanor does not categorically create exigency sufficient to allow the warrantless entry into a home. Instead, a case-by-case analysis must be performed to see if, under the totality of the circumstances, there is a true emergent need to act before a warrant could be obtained.

Terry v. United States (U.S. Supreme Court, June 2021)

In a 9-0 decision (with J. Sotomayor concurring in the judgment), the Supreme Court held that a defendant who had been convicted for a crack-cocaine offense that did not carry a mandatory minimum did not have a conviction for a “covered offense” under the First Step Act and was thus ineligible to move for a sentence reduction. The First Step Act had the Fair Sentencing Act of 2010 retroactive.

Greer v. United States (U.S. Supreme Court, June 2021)

In an almost unanimous opinion, the Supreme Court held that defendants in post-conviction proceedings alleging plain error under Rehaif must make a sufficient showing that they could have presented evidence at trial that they did not know they were a felon at the time they possessed the firearm. The Court affirmed the conviction of two defendants, one who pleaded guilty and one who was convicted by a jury, after finding that neither of them had presented any evidence or argument that they were unaware that they were felons and that both had multiple prior convictions.

Borden v. United States (U.S. Supreme Court, June 2021)

In a 5-4 opinion, the Supreme Court held that prior convictions for offenses that only require a mens rea of “recklessness” cannot serve as predicate convictions under the “elements clause” of the Armed Career Criminal Act. The Court reasoned that the language requiring that an offense involved the use of force “against the person of another,” reflected that the perpetrator must act purposefully and intentionally.

Van Buren v. United States (U.S. Supreme Court, June 2021)

In a 6-3 decision, the Supreme Court held that a defendant “exceeds authorized access” to a computer under the CFAA if they access information from an area in the computer that they are not authorized to access, and the Court clarified that a defendant does not violate the CFAA simply by using their authorized access for an improper purpose or motive. In doing so, the Court rejected the Government’s broad reading of the law and cautioned it could apply to innocuous conduct such as employees using work computers to send personal emails.

Edwards v. Vannoy (U.S. Supreme Court. May 2021)

In a 6-3 decision, the Supreme Court held that the unanimous verdict rule announced in Ramos v. Louisiana was not retroactive for inmates convicted on split verdicts. The Court also effectively overruled the “watershed exception” from Teague v. Lane that held that a new rule of criminal procedure can be applied retroactively if it is a “watershed” rule pertaining to “basic due process.”

Torres v. Madrid (U.S. Supreme Court, March 2021)

In a 5-3 decision, the Supreme Court held that officers who shot at a woman who was driving away had committed a “seizure” under the Fourth Amendment. The Court held that an officer’s conduct can constitute a seizure even if their use of force is from a distance, as long as the conduct involves a use of force and “objectively manifests an intent to restrain.”

Ramos v. Louisiana (U.S. Supreme Court, April 2020)

In a patchwork opinion involving a lengthy discussion of stare decisis, a majority of the Court held that the Sixth Amendment right to a unanimous verdict in a criminal prosecution applies to the states through the Fourteenth amendment.

Kelly v. United States (U.S. Supreme Court, May 2020)

In a unanimous opinion, the Supreme Court reversed the convictions of the Port Authority officials involved in the infamous “Bridgegate scandal,” holding that their convictions for wire fraud on a federally funded program, predicated on their blocking off certain lanes as political retribution against an opposition mayor, were not supported by sufficient evidence because they did not involve a scheme “to obtain money or property.”

United States v. Davis (U.S. Supreme Court, June 2019)

The Supreme Court struck down the residual clause of 18 U.S.C. § 924(c), which criminalizes carrying a firearm in connection with a “crime of violence” or drug trafficking crime, as unconstitutionally vague. The decision was based on prior Supreme Court decisions striking down similar provisions defining “crimes of violence” under 18 U.S.C. § 16 and the ACCA.

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