The case involved Cecil Johnson, who was convicted of three murders in 1981 and spent nearly 29 years on death row before challenging his execution as unconstitutionally cruel under the Eighth Amendment due to state-caused delay, including withheld evidence; he brought the claim via 42 U.S.C. § 1983 rather than habeas corpus. The Supreme Court denied both the application for a stay of execution and the petition for a writ of certiorari. The core reasoning for denial centered on the absence of grounds for further review of the procedural questions—whether a Lackey-type delay claim is cognizable under § 1983 or barred as successive in habeas—and the lack of precedent supporting an Eighth Amendment violation from extended incarceration alone.
The case concerned whether police officers violated the Fourth Amendment by searching the passenger compartment of a car after arresting its recent occupant. Respondent Gant was arrested for driving with a suspended license, handcuffed, and secured in a patrol car; officers then searched his vehicle and found cocaine. The Supreme Court held that a vehicle search incident to a recent occupant's arrest is permissible only if it is reasonable to believe the arrestee could access the vehicle at the time of the search or that the vehicle contains evidence of the offense of arrest. The Court reasoned that the justifications from Chimel v. California—officer safety and preservation of evidence—did not apply here because Gant was already secured and his offense would not reasonably yield evidence in the car, distinguishing the facts from New York v. Belton. The Court affirmed the Arizona Supreme Court's ruling that the search was unreasonable.
The case involved a patient who suffered severe injury after receiving the drug Phenergan via IV push, leading to a state-law failure-to-warn lawsuit against manufacturer Wyeth for inadequate labeling. The Vermont courts awarded damages, rejecting Wyeth's defense that FDA approval of the label preempted the state claims. The Supreme Court affirmed, holding that federal law does not preempt the claim because the manufacturer could have unilaterally strengthened the warning under the FDA's changes-being-effected regulation without prior approval, and nothing showed the FDA would have rejected it. The Court reasoned that the FDCA places primary responsibility for labeling on the manufacturer, Congress did not intend to preempt state tort actions, and an FDA preamble asserting preemption lacked the force of law or deference given its inconsistency with prior positions and lack of process.
The case concerned whether Federal Rule of Criminal Procedure 32(h) requires a sentencing court to give advance notice before imposing a sentence outside the Federal Sentencing Guidelines range that is treated as a variance rather than a departure. Petitioner Irizarry had pleaded guilty to making a threatening interstate communication and received a 60-month sentence exceeding the recommended 41-to-51-month Guidelines range without prior notice of the court's intent. The Supreme Court held that Rule 32(h) applies only to Guidelines departures and does not extend to variances under 18 U.S.C. §3553(a). The core reasoning was that United States v. Booker rendered the Guidelines advisory, eliminating the mandatory regime and associated due-process expectations that had prompted the notice requirement in Burns v. United States when the Guidelines were binding. The Court concluded that existing Rule 32 procedures suffice to ensure fairness without mandating additional notice for variances.
The case involved Ahmed Ressam, who attempted to enter the United States with explosives hidden in his car while providing false information on a customs declaration form, leading to convictions under 18 U.S.C. §1001 for the false statement and under §844(h)(2) for carrying an explosive during the commission of that felony. The Ninth Circuit vacated the explosives conviction, interpreting "during" to require that the explosives be carried "in relation to" the underlying offense. The Supreme Court reversed, holding that the statute requires only a temporal connection. The Court reasoned that the plain meaning of "during" denotes a contemporaneous link between the carrying of explosives and the felony, supported by the statutory text and history showing no additional relational element was intended by Congress.
The case concerned whether state courts must follow the federal retroactivity limits from Teague v. Lane when applying new constitutional rules of criminal procedure, such as the rule from Crawford v. Washington on testimonial statements, in state postconviction proceedings. Petitioner Danforth sought a new trial in Minnesota state court after his conviction became final, arguing that admitting certain evidence violated Crawford. The Minnesota Supreme Court held that states could not give broader retroactive effect to such new rules than the U.S. Supreme Court required. The Court reversed, deciding that Teague constrains only federal habeas review and does not limit state courts' authority to provide broader remedies for violations of new federal constitutional rules in their own postconviction cases. The reasoning was that Teague derives from interpretation of the federal habeas statute and reflects federalism principles allowing states independent authority over their criminal procedures as long as they respect federal constitutional guarantees.
The case involved a participant in a defined contribution pension plan who sued the plan administrator under ERISA §502(a)(2) for allegedly failing to follow his investment instructions, resulting in a $150,000 loss to his individual account. The lower courts had dismissed the claim, relying on precedent that limited remedies under that section to harms affecting the entire plan rather than individual participants. The Supreme Court vacated and remanded, holding that while the provision does not remedy individual injuries separate from the plan, it does authorize suits for fiduciary breaches that diminish the value of assets in a participant's account within a defined contribution plan, distinguishing such plans from traditional defined benefit plans where the entire plan's solvency is at issue.
In Gall v. United States, the petitioner pleaded guilty to participating in a conspiracy to distribute ecstasy while in college, though he had withdrawn from the scheme after seven months, ceased all drug use, and maintained steady employment for years afterward. The district court imposed 36 months of probation instead of the 30-37 month prison term recommended by the Federal Sentencing Guidelines, finding that the defendant's post-offense conduct showed he posed no danger to society and that imprisonment was unnecessary. The Eighth Circuit reversed, holding that a sentence outside the Guidelines range required extraordinary circumstances. The Supreme Court held that appellate courts must review all sentences—inside or outside the Guidelines—under a deferential abuse-of-discretion standard for reasonableness, without presuming unreasonableness for variances or demanding extraordinary justifications, and that the district court's individualized assessment under 18 U.S.C. §3553(a) supported the probation sentence here.
