Sonia Sotomayor

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.

civil rightsprocedure

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.

criminal lawcivil rightsprocedure

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.

civil rightsfederal powerprocedure

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.

procedurefederal power

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.

criminal lawcivil rightsprocedure

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.

criminal lawgunsprocedure

The case concerned whether a federal district court that had stayed an employment discrimination lawsuit under §3 of the Federal Arbitration Act retained jurisdiction to confirm or vacate the resulting arbitral award under §§9 and 10, even though the motions themselves presented no independent basis for federal jurisdiction. The Supreme Court held that it did, affirming the Second Circuit. The Court reasoned that because the case was originally filed in federal court under 28 U.S.C. §1331 and stayed rather than dismissed, the court’s existing jurisdiction over the live claims extended to the post-arbitration motions needed to finally resolve them; this differed from freestanding §9/10 actions addressed in Badgerow v. Walters, where no prior federal case existed and the FAA provided no jurisdictional hook. The opinion emphasized that the FAA’s structure, including the mandatory stay requirement, contemplates continued federal-court oversight through confirmation or vacatur.

labor & employmentprocedurecivil rightsfederal power

The Supreme Court addressed consolidated cases challenging Alabama’s 2023 congressional redistricting plan, which followed an earlier ruling that the state’s prior map unlawfully diluted Black voters’ voting power under Section 2 of the Voting Rights Act. In a brief order, the Court granted certiorari before judgment in one case, vacated the District Court’s injunction against the 2023 plan along with related judgments in the other cases, and remanded all matters to the lower courts for further consideration in light of its recent decision in Louisiana v. Callais. The Court’s action rested on the view that the new interpretation of Section 2 set forth in Callais warranted reexamination of the District Court’s findings and remedial orders regarding the plan’s legality. A dissent argued that at least one independent constitutional holding of intentional discrimination was unaffected by Callais and that vacatur risked disrupting imminent elections.

electionscivil rights

The case concerned whether Enbridge Energy could remove a 2019 Michigan state-court lawsuit—filed by the state Attorney General to void a 1953 easement and halt operation of the Line 5 pipeline—to federal court long after the statutory deadline. Enbridge removed the case 887 days after being served, arguing that equitable tolling should excuse its untimeliness because of later events, including a related lawsuit by the Governor. The Supreme Court held that the 30-day removal deadline in 28 U.S.C. §1446(b)(1) is not subject to equitable tolling, so the case must be remanded to state court. The Court reasoned that even assuming the deadline is nonjurisdictional, the statute’s mandatory language, its detailed list of specific exceptions (such as extensions when removability is later discovered or a plaintiff acts in bad faith), and the overall removal scheme demonstrate that Congress did not intend courts to add further equitable exceptions.

procedureenvironmentbusiness & regulatory

This case arose under the Hague Convention on international child abduction after petitioner took her three-year-old daughter from Venezuela to the United States without the father’s consent in 2021. The father filed suit more than a year later seeking the child’s return; the district court found the child well settled in the United States and denied return, but the Fifth Circuit reversed, ordering return to Venezuela. Petitioner sought Supreme Court review on the narrow question of whether appellate courts should review a “well-settled” finding de novo or for clear error, noting a circuit split and arguing that Monasky v. Taglieri supported clear-error review. The Supreme Court denied certiorari. Justice Sotomayor concurred in the denial because the child had already returned to Venezuela, rendering further review unlikely to serve the Convention’s emphasis on the child’s current circumstances and best interests.

family lawprocedure

In Skinner v. Louisiana, the Supreme Court addressed a petition for certiorari filed by James Skinner, who was convicted of a 1998 murder and sentenced to life in prison based on the same two eyewitness accounts that led to his codefendant Michael Wearry’s death sentence. The Court denied the petition. The dissent explained that Wearry’s conviction had been vacated in 2016 due to the prosecution’s failure to disclose favorable evidence in violation of Brady v. Maryland, that Skinner was subject to the same nondisclosure (plus additional issues), and that Louisiana courts had rejected his claims by deeming the cases distinguishable; it argued that the Court should have granted review to ensure consistent application of its precedents to similarly situated defendants.

criminal law

Priscilla Villarreal, a citizen journalist known as “Lagordiloca,” was arrested and charged under Texas Penal Code §39.06(c) after texting a police officer on two occasions in 2017 to confirm non-public details about a border agent’s suicide and a fatal traffic accident, information she then published on her Facebook page. She alleged the arrests, which occurred six months later following a months-long investigation, were retaliatory due to her critical coverage of local police and prosecutors. The Fifth Circuit granted the officials qualified immunity, concluding that the arrests were supported by probable cause. The Supreme Court denied Villarreal’s petition for certiorari. Justice Sotomayor dissented, reasoning that the statute had never previously been used to arrest anyone for routine newsgathering, that any probable cause was tainted by alleged misrepresentations to the magistrate, and that the conduct at issue was core protected speech under the First Amendment.

free speechcriminal lawcivil rights

Rodney Reed, convicted and sentenced to death in Texas for the 1996 murder of Stacey Stites, sought postconviction DNA testing of the murder weapon (a belt) under Texas Code of Criminal Procedure Article 64 to support his claim that another individual committed the crime. State courts denied testing, finding that contamination of the evidence violated the statute’s chain-of-custody requirement. Reed then sued in federal court under 42 U.S.C. §1983, arguing that the noncontamination rule, as applied, arbitrarily deprived him of a liberty interest in proving innocence and thus violated due process. The Fifth Circuit rejected the claim, and the Supreme Court denied certiorari; Justice Sotomayor dissented on the ground that the Fifth Circuit had not addressed Reed’s independent argument that modern DNA protocols can yield reliable results even from contaminated evidence.

criminal lawcivil rightsprocedure

In Galette v. New Jersey Transit Corp., the Supreme Court considered consolidated negligence suits against NJ Transit by individuals injured in bus accidents in New York and Pennsylvania; NJ Transit sought dismissal on grounds that it was an arm of New Jersey entitled to sovereign immunity, but lower courts had reached conflicting results. The Court held that NJ Transit is not an arm of the State and thus may not invoke New Jersey’s interstate sovereign immunity. The reasoning centered on NJ Transit’s statutory structure as a “body corporate and politic” that is legally separate from the State, with powers to sue and be sued, enter contracts, acquire property, and satisfy its own judgments and debts from its own funds, even though the governor may remove board members or veto certain actions. This formal separation, the Court explained, has long been the key marker under federal law for determining whether a state-created entity qualifies as an arm of the State.

federal powertorts & liability

The case concerned whether indigent prisoners filing a joint federal lawsuit may split the $350 filing fee under 28 U.S.C. §1914(a) or whether the Prison Litigation Reform Act requires each prisoner to pay the full fee separately when proceeding in forma pauperis. The Supreme Court denied the petition for a writ of certiorari. In dissent, Justice Sotomayor (joined by Justice Jackson) argued that the PLRA’s text requires prisoners to pay the full statutory fee but does not eliminate the ordinary per-case assessment rule of §1914(a) that permits multiple plaintiffs to divide it; she noted that the Ninth Circuit’s contrary holding deepened a circuit split, that fee-splitting denials recur frequently, and that the $350 amount imposes a substantial burden on prisoners earning minimal wages.

procedurecriminal law

The U.S. Supreme Court granted applications to stay a January 2026 order from a New York trial court that directed the state’s Independent Redistricting Commission to create a new congressional district expressly to enable “minority voters” to elect their preferred candidate. The stay remains in effect while the applicants pursue appeals in the New York courts and, if timely, a petition for certiorari in the Supreme Court. Justice Alito’s concurrence explained that the trial court’s directive constitutes race-based government action subject to strict scrutiny under the Fourteenth Amendment’s Equal Protection Clause, that no recognized compelling interest justified it, and that state law cannot override federal constitutional protections. The Court further held it had jurisdiction under 28 U.S.C. §1257(a) because the New York Court of Appeals’ refusal to grant a stay or hear an expedited appeal effectively constituted a final ruling on the federal claim, consistent with precedent in National Socialist Party of America v. Skokie.

electionscivil rights

Melvin Trotter, scheduled for execution by lethal injection in Florida, sought a stay of execution and Supreme Court review, arguing that the state was likely to violate its lethal-injection protocol by using expired drugs or committing other errors that would create an unnecessary risk of severe pain in violation of the Eighth Amendment. The Supreme Court denied both the application for a stay and the petition for certiorari. Justice Sotomayor, in a statement respecting the denials, explained that Trotter’s evidence—primarily redacted logs from prior executions and an expert affidavit—was insufficient to meet the high standard under Glossip v. Gross of showing that the execution method was “sure or very likely to cause serious and needless suffering.” She noted that the Florida Supreme Court had rejected the claim as speculative, and that further records had been denied, leaving the allegations without adequate support for judicial intervention.

criminal lawcivil rights

The case arose when Texas parents sued Hain Celestial Group and Whole Foods in state court, alleging that heavy metals in Hain’s baby food caused their child’s developmental disorders and related conditions; Hain, a Delaware-New York company, removed the case to federal court on diversity grounds and argued that Whole Foods had been improperly joined. The district court dismissed Whole Foods, found complete diversity, tried the case against Hain alone, and entered judgment for Hain after concluding the plaintiffs failed to prove causation. The Fifth Circuit reversed the joinder ruling, held that diversity jurisdiction never existed, vacated the judgment, and ordered remand to state court. The Supreme Court affirmed, ruling that an erroneous, interlocutory dismissal of the non-diverse defendant did not cure the jurisdictional defect that existed at removal, so the court of appeals was required to vacate any judgment entered without jurisdiction. The Court explained that jurisdiction is assessed based on the facts at the time of removal and that only a proper cure before final judgment, as in Caterpillar Inc. v. Lewis, would have allowed the verdict to stand.

proceduretorts & liability

The case concerned federal prisoner Michael Bowe’s repeated efforts to obtain postconviction relief under 28 U.S.C. §2255 from a mandatory consecutive sentence imposed under 18 U.S.C. §924(c) for using a firearm during attempted Hobbs Act robbery. After the Supreme Court’s decisions in United States v. Davis (2019) and United States v. Taylor (2022) undermined the validity of his conviction, Bowe sought authorization from the Eleventh Circuit to file a successive §2255 motion; the court denied relief, applying §2244(b)(1)’s bar on claims that had been presented in a prior application. The Supreme Court held that it had jurisdiction to review the denial and that §2244(b)(1)’s prohibition on “old claims” does not apply to federal prisoners’ successive §2255 motions. The Court reasoned that §2244’s provisions, including the old-claim bar and the certiorari prohibition in §2244(b)(3)(E), are located in a section addressed to state prisoners, that §2255(h) incorporates only selected procedures from §2244, and that Congress did not clearly extend the bar to federal prisoners.

criminal lawprocedure

The Supreme Court denied Antonio Nathaniel Davenport Jr.’s petition for a writ of certiorari in his federal murder-in-aid-of-racketeering case. Justice Sotomayor concurred in the denial solely because the petition was filed late and counsel offered no explanation for the delay. She separately addressed the trial court’s refusal to give the defense’s requested instruction defining “reasonable doubt” for the underlying North Carolina murder elements. The district court had stated that federal courts are “specifically prohibited” from defining the term, but Sotomayor explained that Victor v. Nebraska and circuit precedent establish that trial courts have discretion to provide such a definition when appropriate. She noted that judges should weigh case-specific factors, such as potential jury confusion, before deciding whether to define the standard.

criminal lawprocedure