Supreme Court Opinions

The Supreme Court held that allowing a state appellate court to reweigh the aggravating and mitigating factors in a capital case under Clemons v. Mississippi is a permissible remedy after a finding on collateral review that the sentence court failed to consider mitigating factors in violation of Eddings v. Oklahoma.

In a unanimous opinion, the Supreme Court held that a defendant has preserved his ability to appeal a sentence as substantively unreasonable as long as the sentence ultimately imposed was longer than the sentence he requested.

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.

The Supreme Court held that 18 U.S.C. § 922, which criminalizes possession of a firearm by certain groups of individuals (such as felons), has an intent element requiring that the defendant had knowledge of both his possession of a firearm and of his status in a class of individuals prohibited from possessing firearms.

The Supreme Court unanimously held that the defendant’s 2002 Michigan conviction for third-degree home invasion was a “violent felony” under the Armed Career Criminal Act’s enumerated-offenses clause, as the Michigan offense “substantially corresponded to” or was narrower than generic burglary under the categorical approach from Taylor v. United States.

Curtis Flowers was tried six separate times for the same murder by the same prosecutor. Several of his convictions were vacated by the Mississippi Supreme Court based on findings that the State engaged in prosecutorial misconduct and used it peremptory strikes on the basis of race in violation of Batson v. Kentucky. After his sixth trial, in which the State struck five black jurors and allowed one black juror to be seated, Flowers was convicted.

The Court struck down 18 U.S.C. § 3583(k) which required district courts to impose a mandatory minimum sentence upon revoking a term of supervised release for certain offenses, as the Court cannot impose a sentence exceeding a term of supervised release without a jury finding guilt beyond a reasonable doubt.

The Court affirmed the defendant’s conviction for a DUI after police took his blood while he was passed out, with a plurality of the  Court holding that conducting a blood test on a defendant while he is passed out is permissible under the “exigent circumstance” exception to the Fourth Amendment’s warrant requirement.