Trial and Error: Habeas Corpus, Double Jeopardy, and Reversals
It seems the Supreme Court is trying to clear its plate this week to make room for its late-term blockbuster cases. Yesterday, the Court issued four opinions, including one of the term's two dog sniff decisions. Today, the justices topped the Tuesday tally with five additional opinions.
While we're still waiting on big decisions from early arguments like Fisher v. University of Texas, the Court shared plenty of thoughts on court errors during trial. Let's take a quick look at the five decisions of the day.
- Chaidez v. U.S. In 2010, the Supreme Court ruled in Padilla v. Kentucky that immigrants have a right to effective counsel and must be told about possible deportation stemming from a guilty plea. This week, the 7-2 Court concluded that Padilla does not apply retroactively to cases already final on direct review because under Teague v. Lane a person whose conviction is already final may not benefit from a new rule of criminal procedure on collateral review.
- Evans v. Michigan In an 8-1 decision, the Court concluded that the Double Jeopardy clause bars retrial when a judge enters a directed verdict based on a legal error.
- Henderson v. U.S. Continuing on the plain error theme, the 6-3 Court held that regardless of whether a legal question was settled or unsettled at the time of trial, an error is "plain" within the meaning of Federal Rule of Criminal Procedure 52(b) so long as the error was plain at the time of appellate review.
- Johnson v. Williams In a unanimous decision, the Court held (for purposes of 28 U.S.C. § 2254(d)) when a state court rules against a defendant in an opinion that rejects some of the defendant's claims but does not expressly address a federal claim, a federal habeas court must presume, subject to rebuttal, that the federal claim was adjudicated on the merits.
- Gunn v. Minton In another unanimous decision, the Court decided that federal courts do not have exclusive jurisdiction over a patent case when the sole substantive issue is the application of a patent law doctrine which is an essential element of a legal malpractice claim. Though 28 U. S. C. §1338(a) may give the federal courts exclusive jurisdiction over patents, it doesn't yank malpractice claims away from the states.