Blueford v. Arkansas
Blueford v. Arkansas was a 2012 case that sought to determine the bounds of the double jeopardy clause. Under the United States Constitution, criminals are not supposed to be tried more than once for the same offense. However, it may be allowed in certain instances, such as a retrial after a mistrial that fulfills the manifest necessity. In this case, Alex Blueford had been tried for capital murder and other felonies. However, the jury was engaged in a deadlock, making the judge to call for a mistrial. Blueford unsuccessfully filed a motion to drop some of the offenses under the double jeopardy grounds. During an interlocutory appeal, the denial of the motion was affirmed by the Supreme Court of Arkansas since the acquittal of some offenses by the jury was not a formal verdict ( Blueford v. Arkansas , 2012). Therefore, the case was brought to the U.S. Supreme Court to seek further clarification of the legal issue of double jeopardy.
The court confirmed the affirmation previously made by the Supreme Court of Arkansas. The decision was made based on a 6-3 vote. The court's final opinion was written by Chief Justice Roberts, who stated that the court found the foreperson's announcement about the jury's deadlock did not establish a verdict of acquittal considering the jury continued deliberations on the case even after the foreperson's announcement. Justice Sotomayor wrote a dissenting opinion in conjunction with Justice Kagan and Justice Ginsburg. The dissenting opinion noted that the foreperson's affirmation about the jury's decision to acquit some offenses constituted a legal exoneration.
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Missouri v. Galin E. Frye
The Missouri v. Galin E. Frye was a case in 2012 involving plea bargains communication by attorneys. The case revolved around Galin Frye, who had been charged thrice with driving without a license ( Schwinn, 2011). In Missouri, three such charges amount to a felony. The case's prosecutor provided Frye's attorney with two plea offers. However, the attorney did not inform Frye about the plea offers, and they expired without any action from him. Before the preliminary hearing, the accused was arrested for the fourth time in which he pleaded guilty and was given a three-year sentence. The accused filed for post-conviction relief, and the appeal was initially denied by a state court but later overturned by a court of appeal. The state of Missouri took the case to the Supreme Court to seek reversal and overturning of the decision.
The Supreme Court supported the decision in favor of Frye in a vote of 5-4. The court's opinion was authored by Justice Anthony Kennedy where he stressed the counsel's role in plea bargain. The court argued that the accused had the right to be informed of all formal offers made by the prosecution concerning a plea of terms. Scalia offered a dissenting opinion and joined by the Chief Justice, Justice Alito, and Justice Thomas. Justice Scalia argued that the denial to be informed about the plea bargain did not translate into a deprivation of procedural rights and raised concerns concerning the majority's speculative nature.
Lafler v. Cooper
Lafler v. Cooper is a 2012 Supreme Court case seeking to clarify the sixth amendment concerning plea bargaining assistance. Anthony Cooper had been charged with intent to murder and other offenses. He rejected a plea bargain after his lawyer confirmed that the prosecution lacked the capacity to prove the stipulated intent to murder. However, he was convicted, which made him to file an appeal under the grounds that the counsel failed to offer him competitive advice on the plea deal ( Dery & Soo, 2012) . The Michigan courts denied him relief, but the federal court ruled that his sentence should be reduced to the one stipulated in the plea agreement. The state was not contented with the federal court decision and filed an appeal with the Supreme Court.
The verdict was made in a 5 majority and 4 dissenting Justices. The majority comprised of Justices Kennedy, Sotomayor, Ginsburg, Kagan, and Breyer. The court's decision was authored by Justice Kennedy, who affirmed that failure to provide competitive counsel is sufficient grounds for relief if such an inaction led to a harsher conviction. The court decided that when lawyers provide ineffective assistance that culminates in a plea agreement rejection, with a surety that the agreement would have turned differently with better advice, the defendant has an entitlement to relief. Justice Scalia gave a dissenting opinion that was supported by Justice Roberts and Thomas to certain extents. Justice Scalia argued that the majority in the voting seems to have created a plea bargain right that was not existent in the Constitution. Justice Alito also provided a dissenting opinion where he stated that the majority's opinion was unsound and also sided with most of Justice Scalia's dissent.
Renico, Warden v. Lett
Renico, Warden v. Lett was a 2010 case brought to the Supreme Court from a District Court in Michigan ( Renico v. Lett , 2010). Lett was facing first-degree murder and felony firearm possession. The initial trial was conducted in 1997 with the jury reaching a deadlock, thereby making the judge to declare a mistrial. Lett was retried for the felony-firearm and second-degree murder, with a fourteen to forty years' prison term. Lett appealed under the key legal issue that the second trial was a violation of the double jeopardy prohibitions due to a lack of manifest necessity and accused’s consent in the initial case.
The Supreme Court holding affirmed that the retrial adhered to the law since the facts of the initial case confirm that there was a manifest necessity ( Renico v. Lett , 2010). The ruling also held that there was no violation of double jeopardy bar, and the ruling given by the trial judge had been sufficiently obvious without any need for further reasoning. The Supreme Court also noted that Lett did not ask for a deadlock jury instruction. The Supreme Court, therefore, reversed the previous overturning judgement by the federal court on a decision based on a 6-3 vote. The court’s opinion based on the majority voting was composed by Justice John Roberts. The court's ruling was dissented by Justice Stevens and then joined by Justice Breyer as well as Justice Sotomayor. The case was dissented by Justice Stevens, Justice Breyer, and Justice Sotomayor.
Donald Bullcoming v. State of New Mexico
Donald Bullcoming v. State of New Mexico is a case argued on March 2, 2011, and ruling held on June 23, 2011. Donald Bullcoming had been apprehended for being suspected of driving while still intoxicated. During the trial, the prosecution used a report showing that he had an elevated blood-alcohol level. Instead of the prosecutors calling whoever prepared the report, they called a work colleague who was not present to observe or analyze the lab results. The key legal issue of the case involved testing if the Confrontation Clause allowed the prosecution to use testimonials from a non-testifying analyst in the forensic department in an in-court supervisor testimony or someone else who was not part of the team performing or observing the forensic analysis.
The U.S. Supreme Court held a ruling in favor of Bullcoming ( Donald Bullcoming v. State of New Mexico , 2011). The ruling was made on a majority of 5-4 vote. The Court majority's opinion was written by Justice Ginsburg stating that testimony from a surrogate is not substantial in ruling. He further quoted the Sixth Amendment stating that it is the right of a criminal defendant to be confronted with a witness. The dissenting opinion was written by Justice Kennedy, together with Justice Roberts, Justice Breyer, and Justice Alito.
Skilling v. the United States
Skilling v. the United States is a case held in 2010 that tried to interpret the honest services fraud statute. In Texas, a federal District Court convicted Jeffrey Skilling, Enron's former C.E.O. for deception, securities fraud, and falsified reports to the auditors. When appealing, Skilling argued that the United States convicted him basing their argument on a void legal theory and an intolerance Jury ( Skilling v. United States , 2010) . The key legal issue was to give an interpretation of the honest services fraud statute.
The court ruling was that Mr. Skilling had obtained a fair trial, and he did not prove that the jury was biased. The decision was made based on a 6-3 vote. Justice Ruth Dader Ginsburg wrote on behalf of the majority, noting that the case had been conducted in Houston as opposed to some lower courts where it is not easy to identify biased jurors. Eventually, the sentence of Skilling was reduced by ten years. No judge dissented fully, but Justice Sonia Sotomayor, together with Justices Breyers and Stevens, dissented partly. Justice Sotomayor disagreed that the Skilling's trial was fair with hostility in Houston arising from the Enron collapse.
Flowers v. Mississippi
Flowers v. Mississippi is a 2019 case with a focus on peremptory challenges. Curtis faced six jury trials in Mississippi concerning his accusation of four murders. The first three trials faced a prosecutorial misconduct and got overturned while the fourth and fifth ones ended in a mistrial ( Butler, 2020) . During the first three trials, the prosecution used peremptory challenges that created a jury comprising of Whites only. During the sixth trial, the accused was sentenced to death by a jury that had only one African-American juror as the other five African-American jurors were dismissed under peremptory challenges. Flowers appealed, but the Mississippi Supreme Court upheld the verdict, making Flowers petition to the U.S. Supreme Court.
The Supreme Court reached a verdict with a vote of 7-2 ( Butler, 2020). The court's opinion was authored by Justice Brett Kavanaugh, who affirmed that the Mississippi Supreme Court was mistaken in upholding the trial court's ruling. The Justice also noted that the prosecution struck some black jurors without removing the white counterparts who gave similar answers. A concurrence was provided by Justice Alito, who termed the case as highly unusual and unique. A dissenting opinion was provided by Clarence Thomas, who was partially joined by Justice Neil. The dissenting opinion was in favor of upholding Flower's conviction since most of the struck African-American jurors had a connection with Flower's family, which would have constituted bias.
McDonough v. Smith
McDonough v. Smith is a 2019 case concerning the statute of limitations on evidence fabrication. In 2009, an affiliate of the W.F.P. political party held elections where more than 50 absentee ballots were fraudulently cast. After investigations by a special prosecutor, eight indictments were made where four of them pled guilty while charges against two were dropped. The first trial for the other two ended in a deadlock, whereas the second trial led to the acquittal of both defendants. In 2015, McDonough, one of the defendants whose case was dropped, filed a lawsuit claiming that Smith had fabricated evidence and framed him ( McDonough v. Smith , 2019) . Both of the violations filed by McDonough were dropped in the District Court. McDonough appealed, but the Court of Appeals upheld the District Court's former verdict, making him to appeal to the U.S. Supreme Court.
The U.S. Supreme case gave a verdict favoring McDonough and allowed his lawsuit to continue by overturning the Court of Appeals' decision. The decision was reached on a 6-3 vote. The court's opinion was authored by Justice Sonia Sotomayor, who explained how the limitations statute for evidence fabrication could be delayed beyond the three-year limitation. A dissent was prepared by Justice Thomas, who was joined by Justice Gorsuch and Justice Kagan. The jury argued that the court erred in granting McDonough a writ of certiorari since he had failed to provide clearly defined elements in his claim.
Padilla v. Kentucky
Padilla v. Kentucky is a case involving criminal defense attorneys' role in advising clients who are not United States citizens about the impact of a guilty plea concerning deportation risks. The case involved Padilla, who immigrated to America, served in the military, and remained a lawful resident for more than four decades. He was arrested transporting marijuana, and his attorney advised him that the conviction would not affect his immigration status, thereby making him to accept the plea bargain. Padilla filed for relief based on ineffective advice and won the case in Kentucky Appellate Court. However, the Kentucky Supreme Court ruled that lack of advice or misadvise did not hold grounds for relief. The case proceeded to the Supreme Court, with the main legal issue being on the collateral consequence and gross misadvise repercussions.
The Supreme Court ruled in favor of Padilla, and the decision by the Kentucky Supreme Court was thereby reversed. The court established that criminal defense attorneys were obliged to advise their clients accordingly in matters involving immigration ( Lang, 2011) . Justice Paul Stevens authored this opinion and affirmed that failing to advise the client about deportation was a violation of their Sixth Amendment. A concurrence was authored by Justice Alito, who agreed with most of the court's opinion and ruling. A dissenting opinion was authored by Justice Scalia, who gave concerns about limitations of obligated advice, collateral consequences, and how the issue might have been better handled through legislation.
Southern Union Co. v. the United States
Southern Union Co . v. the United States is a case whose ruling was made in June 2012. The Southern Union Co. had been found guilty of having unpermitted liquid mercury, which was termed as hazardous. Southern Union was tried by a Jury, which never determined the number of days the company had held the hazardous chemical. The company objected with an argument that the jury should have determined the total days the company had held the chemical since the criminal penalty was being increased. The company was of the argument that the fine imposed violated its rights of a full criminal process according to the Fifth Amendment and on Jury trial in line with the Sixth Amendment. The Southern Company appealed, but the Court of Appeal affirmed the ruling made by lower courts. The legal issue revolved on the Criminal due process according to the Fifth Amendment and on Jury trial in accordance with the Sixth Amendment. Concerning the second issue, it is a requirement for anything that increases a criminal penalty above the stated statutory maximum to be tried by a jury and be determined reasonably if the fine is the prescribed in criminal penalties.
The Supreme Court, in its ruling, reversed the verdict made by the Court of Appeal. The decision was made by six against three votes ( Southern Union Co. v. United States , 2012). The majority comprised of Justices Sotomayor, Kagan, Roberts, Ginsburg, Scalia and Thomas. Justice Sonia Sotomayor, who wrote for the majority's decision, disagreed with the government's argument that penalties are not like criminal conviction and therefore did not need to be determined by a jury. Justice Stephen G. Breyer joined by Justices Anthony M. Kennedy and Samuel A. Alito, dissented. In the dissenting opinion, Justice Breyer argued that it was lawful for the judges to give their verdict without a jury.
References
Blueford v. Arkansas, 132 S. Ct. 2044 (2012)
Butler, P. (2020). Mississippi Goddamn: Flowers v Mississippi’s Cheap Racial Justice. The Supreme Court Review , 2019 (1), 73-109.
Dery, G., & Soo, A. (2012). Turning the Sixth Amendment upon Itself: The Supreme Court in Lafler v. Cooper Diminished the Right to Jury Trial with the Right to Counsel. Conn. Pub. Int. LJ , 12 , 101.
Donald Bullcoming v. State of New Mexico, 564 U. S. (2011)
Lang, D. M. (2011). Padilla v. Kentucky: The effect of plea colloquy warnings on defendants' ability to bring successful Padilla claims. Yale LJ , 121 , 944.
McDonough v. Smith, 588 U.S. (2019)
Renico v. Lett, 559 U.S. 766 (2010)
Schwinn, S. D. (2011). Was a Criminal Defendant Denied Effective Assistance of Counsel When His Attorney Failed to Tell him about a Plea Offer, and He Later Pleaded Guilty on a Related Charge and Received a Greater Prison Sentence-If So, What is the Proper Remedy (10-444). Preview US Sup. Ct. Cas. , 39 , 58.
Skilling v. United States, 561 U.S. 358 (2010)
Southern Union Co. v. United States, 567 U.S. 343 (2012) .
