The Supreme Court denied certiorari in this case, in which inmate Antonio Smith sued two Wisconsin prison officials under 42 U.S.C. §1983, claiming that his placement—naked and without bedding or other means of warmth—in a control cell with temperatures ranging from 25 to 57 degrees for 23 hours violated the Eighth Amendment. The Seventh Circuit had held that a jury could find an Eighth Amendment violation based on deliberate indifference to a basic human need but granted the officers qualified immunity, concluding that no prior case involved identical facts regarding temperature and duration. In dissent, Justice Sotomayor (joined by Justices Kagan and Jackson) argued that the grant of qualified immunity was erroneous because existing Supreme Court and Seventh Circuit precedent clearly established that intentionally depriving a prisoner of warmth or other minimal civilized necessities without penological justification violates the Eighth Amendment, even absent a case with precisely matching facts, and would have summarily reversed.
Victor Saldaño, convicted of capital murder in Texas and sentenced to death, filed a subsequent state habeas application claiming that he is intellectually disabled and thus ineligible for execution under the Eighth Amendment per Atkins v. Virginia. Multiple experts for both Saldaño and the State, after reviewing IQ scores in the low 70s and extensive evidence of lifelong adaptive deficits, all concluded he meets the diagnostic criteria for intellectual disability; the State supported remanding the case for an evidentiary hearing on the merits. The Texas Court of Criminal Appeals denied the application in a one-paragraph order, finding that Saldaño had not pleaded sufficient facts. The U.S. Supreme Court denied certiorari without explanation. Three justices dissented, contending that the uncontradicted evidence satisfied Texas’s threshold for proceeding to a merits determination and that the federal constitutional question warranted review.
In T.M. v. University of Maryland Medical System Corporation, the petitioner, after being involuntarily committed and medicated following an episode of psychosis triggered by gluten ingestion, negotiated and entered a state-court consent order for her release that imposed conditions such as continued medication and dismissal of claims; she then sued in federal district court to declare the order unconstitutional, obtained under duress, and unenforceable. The Supreme Court held that the Rooker-Feldman doctrine barred federal jurisdiction and affirmed the dismissal. The Court reasoned that federal district courts possess only original jurisdiction and lack authority to review or reject state-court judgments, a power reserved exclusively to the Supreme Court under 28 U.S.C. §1257(a), and this limitation applies regardless of whether the state judgment is final or remains subject to further state appellate review. Allowing such suits, the Court explained, would undermine comity and federalism by encouraging parallel litigation and inconsistent rulings.
The case concerned whether the Rooker-Feldman doctrine prevents a federal district court from hearing a lawsuit by T.M. that sought to declare a state-court consent order (arising from her involuntary psychiatric commitment and medication dispute) unconstitutional, obtained under duress, and unenforceable, even though the order was not final and remained subject to state appellate review. The Supreme Court affirmed the Fourth Circuit’s dismissal for lack of subject-matter jurisdiction. It held that Rooker-Feldman bars federal district courts from reviewing and rejecting state-court judgments that caused the plaintiff’s alleged injuries, whenever those judgments were rendered before the federal suit began, because only the U.S. Supreme Court possesses appellate jurisdiction over state judgments under 28 U.S.C. §1257. The Court rejected the argument that the doctrine applies solely to final judgments from a state’s highest court, reasoning that such a limit would contradict precedents like Rooker and Feldman, create inconsistent outcomes, and undermine federalism by encouraging parallel litigation.
The Supreme Court denied Tony Terrell Clark’s petition for a writ of certiorari in his capital case. Clark had argued that his trial counsel was constitutionally ineffective under Strickland v. Washington for failing to properly present a Batson claim alleging that prosecutors struck Black jurors at a much higher rate than white jurors and offered inconsistent reasons for those strikes. The Mississippi Supreme Court rejected the claim on both the deficient-performance and prejudice prongs of Strickland, applying a prejudice standard that required Clark to show not only that a properly raised Batson challenge would have succeeded, but also that it would have changed the outcome of his trial. Justice Sotomayor agreed with the denial of certiorari because Clark did not challenge the state court’s separate finding of no deficient performance, leaving an independent ground supporting the lower court’s ruling intact.
In Michael Dewayne Lairy v. United States, the petitioner challenged his federal prison sentence for unlawful handgun possession, which exceeded the applicable statutory maximum by five years, by filing a motion under 28 U.S.C. §2255. Lower courts rejected the motion as untimely under the statute of limitations after the government raised that defense. The Supreme Court denied Lairy’s petition for a writ of certiorari. Justice Sotomayor explained that the government later acknowledged its invocation of the time bar was an inadvertent error that contradicted its own policy of waiving such defenses in cases of undisputed sentences above the statutory maximum. The government then waived the defense in district court, resulting in the motion being granted and Lairy’s release, so no further Supreme Court review was needed.
