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US Supreme Court Roundup June 2017

30 Jun 2017 9:49 PM | Anonymous

Nelson v. Colorado, No. 15-1256 [Arg: 1.9.2017; Decided 4.19.2017]

Holding: The scheme under Colorado's Exoneration Act -- which permits the state to retain conviction-related assessments unless and until the prevailing defendant institutes a discrete civil proceeding and proves her innocence by clear and convincing evidence -- does not comport with the 14th Amendment's guarantee of due process.

County of Los Angeles v. Mendez, No. 16-369 [Arg: 3.22.2017; Decided 5.30.2017]

Holding: The Fourth Amendment provides no basis for the U.S. Court of Appeals for the 9th Circuit's "provocation rule," which makes an officer's otherwise reasonable use of force unreasonable if (1) the officer "intentionally or recklessly provokes a violent confrontation" and (2) "the provocation is an independent Fourth Amendment violation."

Honeycutt v. U.S., No. 16-142 [Arg: 3.29.2017; Decided 6.5.2017]

Holding: Because forfeiture pursuant to Section 853(a)(1) of the Comprehensive Forfeiture Act of 1984 is limited to property the defendant himself actually acquired as the result of the crime, that provision does not permit forfeiture with regard to Terry Honeycutt, who had no ownership interest in his brother's store and did not personally benefit from the illegal sales.

Virginia v. LeBlanc, No. 16-1177 [ Decided 6.12.2017]

Holding: The Virginia trial court's ruling denying Dennis LeBlanc's motion to vacate his sentence in light of the Supreme Court's requirement in Graham v. Florida that a state give juvenile offenders convicted of a nonhomicide crime "some meaningful opportunity to obtain release based on demonstrated maturity and rehabilitation" -- a ruling which rested on the Virginia Supreme Court's earlier ruling in Angel v. Commonwealth that the state's geriatric release program satisfies this requirement -- was not objectively unreasonable in light of the U.S. Supreme Court's current case law.

Packingham v. North Carolina, No. 15-1194 [Arg: 2.27.2017; Decided 6.19.2017]

Holding: The North Carolina statute, which makes it a felony for a registered sex offender "to access a commercial social networking Web site where the sex offender knows that the site permits minor children to become members or to create or maintain personal Web pages," impermissibly restricts lawful speech in violation of the First Amendment.

Weaver v. Massachusetts, No. 16-240 [Arg: 4.19.2017; Decided 6.22.2017]

Holding: (1) In the context of a public-trial violation during jury selection, when the error is neither preserved nor raised on direct review but is raised later via an ineffective-assistance-of-counsel claim, the defendant must demonstrate prejudice to secure a new trial; (2) Because Kentel Weaver has not shown a reasonable probability of a different outcome but for counsel's failure to object or that counsel's shortcomings led to a fundamentally unfair trial, he is not entitled to a new trial.

Turner v. U.S., No. 15-1503 [Arg: 3.29.2017; Decided 6.22.2017]

Holding: The withheld evidence is not material under Brady v. Maryland. Considering the withheld evidence “in the context of the entire record,” Agurs, supra, at 112, that evidence is too little, too weak, or too distant from the main evidentiary points to meet Brady’s standards


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