Tapia v. United States, 131 S.Ct. 2382 (2011)
Section 3582(a) of the Sentencing Reform Act prohibits sentencing courts from imposing or lengthening a prison term to foster a defendant’s rehabilitation. Section 3582(a) makes clear imprisonment does not achieve the goal of rehabilitation. Provided a court’s imposition or length of a prison term is not based upon completion of treatment, a court may recommend treatment options or a particular facility based upon the availability of treatment.
J.D.B. v. North Carolina, 131 S.Ct. 2394 (2011)
A child’s age is relevant to the Miranda custody analysis, provided the child’s age was known to the officer during questioning, or would have been objectively apparent to a reasonable officer. Consideration of a child’s age does not require a determination of how youth subjectively affects an individual child. While courts may not ignore a suspect’s youth in Miranda custody analysis, youth is not determinative or significant in all cases.
Davis v. United States, 131 S.Ct. 2419 (2011)
The “good-faith” exception to the exclusionary rule includes searches conducted in objectively reasonable reliance on judicial precedent binding at the time of search. A defendant’s conviction not yet finalized on direct review is subject to retroactive application of new judicial precedent not in existence at the time of search. However, retroactive application of new Fourth Amendment law concerns only whether there is a new basis for relief; remedy remains a separate issue. Exclusion is warranted for culpable police conduct requiring deterrence and where the benefits of exclusion outweigh the social costs. Police action in reliance upon judicial precedent, binding at the time of search, does not warrant exclusion.
Bond v. United States, 131 S.Ct. 2355 (2011)
The liberties protected by federalism do not belong solely to the States. Unconstitutional interference with state sovereignty by the Federal Government can cause individual injury to citizens of the states. Thus, an individual, in an appropriate case, has standing to seek redress where the Federal Government infringes upon authority granted to the States.
DePierre v. United States, 131 S.Ct. 2225 (2011)
The plain meaning of “cocaine base,” as used in Section 841(b)(1) of the Anti-Drug Abuse Act of 1986, means cocaine in its base molecular form–as found in “crack cocaine,” freebase, and coca paste. Given the sound Congressional rationale for using “cocaine base” to refer to cocaine in its base form in Section 841(b)(1), the slight variances in nomenclature in the remainder of the statue for cocaine in its base form are immaterial.
Sykes v. United States, 131 S.Ct. 2267 (2011)
Felony vehicular flight is a violent felony for purposes of punishment enhancement under the Armed Career Criminal Act (ACCA). Indiana’s prohibition on vehicular flight falls within §924(e)(2)(B)(ii)’s residual clause because it presents a serious potential risk of physical injury to another. This holding limits the “purposeful, violent, and aggressive” test proposed in Begay v. United States, 553 U.S. 137 (2008) (holding that driving under the influence is not an ACCA predicate), by suggesting it only applies to strict liability, negligence, and recklessness crimes. In a scathing dissent, Justice Scalia proposes that the ACCA be declared unconstitutionally vague, given each attempt to create a test for the residual clause “is less predictable and more arbitrary than the last,” Sykes, 131 S. Ct. at 2287-88 (2011), and does not “give a person of ordinarily intelligence fair notice” of its reach, id. at 2287 (quoting U. S. v. Batchelder, 442 U.S. 114, 123 (1979)).
McNeill v. United States, 131 S.Ct. 2218 (2011)
A sentencing court must look to the maximum sentence at the time of conviction to determine if a drug offense is “serious” within the meaning of the ACCA. Under the ACCA, 18 U.S.C.A. § 924(e), a drug-trafficking conviction is “serious” if the maximum sentence is ten years or more. McNeil’s drug offense required a maximum sentence of ten years when he was convicted, but the maximum sentence for the violation was later reduced to less than ten years. The Court reasoned that using the version of law that the defendant was actually convicted of when determining if a past drug offense was “serious” prevents absurd results following from consulting current state law to define a previous offense.
Bullcoming v. New Mexico, 09-10876, 2011 WL 2472799 (U.S. June 23, 2011)
Forensic laboratory reports certifying blood-alcohol concentration (BAC) are testimonial for Confrontation Clause purposes, and therefore the prosecution may not introduce this evidence without a live witness competent to testify about the truth of the report’s statements. The prosecution had sought to introduce a BAC report using a witness who qualified as an expert with respect to the testing machine and laboratory procedures, but who had not administered the actual test. The Court found the report violated the Confrontation Clause because the defendant was not able to ask questions concerning the original lab technician’s incompetence, evasiveness, or dishonesty accounting for his removal from work, and therefore the decision of the New Mexico Supreme Court was reversed.
Freeman v. United States, 09-10245, 2011 WL 2472797 (U.S. June 23, 2011)
Defendants who enter into plea agreements recommending a particular sentence as a condition of the guilty plea may be eligible for relief under 18 U.S.C.A. § 3582(c)(2), which permits a defendant who was sentenced to a term of imprisonment “based on” a guidelines sentencing range that has been subsequently reduced by a retroactive amendment to seek a reduced sentence. If the plea agreement is “based on” the Sentencing Guidelines, the defendant is eligible for a sentencing reduction. Furthermore, from a policy standpoint § 3582(c)(2) is designed to cure unwarranted disparities in sentencing, and here the disparity involved sentencing for cocaine base vs. powder cocaine offenses.