2010 TERM UNITED STATES SUPREME COURT OPINIONS OF SONIA SOTOMAYOR

Williamson v. Mazda Motor of America, Inc.

562 U.S. 323 (2011)

National Traffic and Motor Vehicle Safety Act of 1966 • Federal Motor Vehicle Safety Standards on seat belt design • state law torts against auto manufacturers • federal preemption

Michigan v. Bryant

562 U.S. 344 (2011)

Sixth Amendment • Confrontation Clause • hearsay exception for statements to help police address ongoing emergency

Roberts, Kennedy, Breyer, Alito

Pepper v. United States

562 U.S. 476 (2011)

Federal Sentencing Guidelines • consideration of postsentencing rehabilitation

Roberts, Scalia, Kennedy, Ginsburg; Breyer, Alito (in part)

Pitre v. Cain • [ full text

562 U.S. 992 (2010)

Eighth Amendment • prison conditions • right to refuse medical treatment

Sotomayor dissented from the Court's denial of certiorari. She believed that the lower courts erred in dismissing a prison inmate's complaint, which alleged that, as punishment for his refusal to take his HIV medication as a protest against his transfer to a prison facility, prison officials subjected him to hard labor in extreme heat that posed a serious risk to his health. Sotomayor argued that the inmate stated an Eighth Amendment claim for deliberate indifference, and that it was incorrect for the lower court to dismiss his complaint for his failure to submit evidence in support prior to a responsive pleading being submitted.

Gamache v. California • [ full text

562 U.S. 1083 (2010)

harmless error • burden of proof

Ginsburg, Breyer, Kagan

Sotomayor filed a statement respecting the Court's denial of certiorari. Prior to rendering a guilty verdict and death sentence, a jury had been given access to a damaging video tape depicting the defendant that had not been admitted into evidence. The California Supreme Court, stating that the defendant had the burden of proving prejudice, determined that the introduction of the tape was harmless error. Sotomayor wrote to correct the court's error of law, noting that under Supreme Court precedent the burden is instead upon the prosecution to prove beyond a reasonable doubt that a constitutional trial error was harmless. She believed, however, that based on the evidence and the court's analysis, the outcome would have been the same in this case regardless of how the burden was allocated, and so did not disagree with the denial of certiorari.

Williams v. Hobbs • [ full text

562 U.S. 1097 (2010)

habeas corpus • evidentiary hearings • preservation of issues on appeal

Ginsburg

Sotomayor dissented from the Court's denial of certiorari of a judgment reversing the granting of a habeas petition after an evidentiary hearing. The petitioner had been convicted of murder in state court and sentenced to death after his attorneys conceded his guilt at trial and failed to present any substantive mitigating evidence at sentencing. In District Court, he established that his counsel was ineffective and at the evidentiary hearing to establish prejudice, presented evidence of his childhood of abuse and neglect. In reversing the District Court's granting of the petition, the Eighth Circuit claimed that the State had preserved its objection to the evidentiary hearing, when in Sotomayor's view it not only made no clear objection but in fact, "voluntarily participate[d]...without objection, with an apparent intent of supplementing the record for its own purposes, and at a significant cost and expenditure of judicial resources." "Today", she wrote, "the Court refuses to review the Eighth Circuit's conclusion that a State may withhold an objection to a federal habeas evidentiary hearing until after the hearing is complete, the constitutional violation established, and habeas relief granted. Because I believe such a rule enables, and even invites, States to manipulate federal habeas proceedings to their own strategic advantage at an unacceptable cost to justice, I respectfully dissent."

Matrixx Initiatives, Inc. v. Siracusano

563 U.S. 27 (2011)

Securities Exchange Act of 1934 • Rule 10b-5 • failure of pharmaceutical company to disclose evidence of drug side effect • materiality

Unanimous

Cullen v. Pinholster

563 U.S. 170 (2011)

Antiterrorism and Effective Death Penalty Act of 1996 • introduction of new evidence in habeas corpus proceedings • Sixth Amendment • ineffective assistance of counsel

Ginsburg, Kagan (in part)

Sossamon v. Texas

563 U.S. 277 (2011)

prisoners' rights • Religious Land Use and Institutionalized Persons Act • Spending Clause • sovereign immunity

Breyer

United States v. Tohono O'odham Nation

563 U.S. 307 (2011)

Court of Federal Claims jurisdiction • separate suits based on same operative facts

Breyer

Chamber of Commerce of United States of America v. Whiting

563 U.S. 582 (2011)

Immigration Reform and Control Act • Legal Arizona Workers Act • state requirement that businesses use E-Verify • suspension or revocation of business licenses for hiring unauthorized aliens • federal preemption

Roberts

Camreta v. Greene

563 U.S. 692 (2011)

Article III • Case or Controversy Clause • standing • review of constitutional issue on appeal from defendant with qualified immunity • mootness

Breyer

Kagan

Ashcroft v. al-Kidd

563 U.S. 731 (2011)

material witness arrest of terrorism suspects • pretextual motivation • Fourth Amendment • qualified immunity

Ginsburg, Breyer

Board of Trustees of Leland Stanford Junior Univ. v. Roche Molecular Systems, Inc.

563 U.S. 776 (2011)

patent law • University and Small Business Patent Procedures Act of 1980 • vesting of federally funded patents in inventors or contractors

Roberts

DePierre v. United States

564 U.S. 70 (2011)

Anti-Drug Abuse Act of 1986 • sentence enhancement for "cocaine base"

Roberts, Kennedy, Thomas, Ginsburg, Breyer, Alito, Kagan; Scalia (in part)

Microsoft Corp. v. i4i Ltd. Partnership

564 U.S. 91 (2011)

Patent Act of 1952 • presumption of patent validity • on-sale bar • clear and convincing evidence

Scalia, Kennedy, Ginsburg, Breyer, Alito, Kagan

United States v. Jicarilla Apache Nation

564 U.S. 162 (2011)

fiduciary exception to attorney–client privilege • general trust relationship between the United States and Indian tribes

Davis v. United States

564 U.S. 229 (2011)

Fourth Amendment • exclusionary rule • good faith reliance on binding appellate precedent

J. D. B. v. North Carolina

564 U.S. 261 (2011)

Fifth Amendment • Miranda warning • effect of minor's age on determining custodial status

Kennedy, Ginsburg, Breyer, Kagan

Tapia v. United States

564 U.S. 319 (2011)

extension of prison sentence to foster rehabilitation

Alito

Kagan

Freeman v. United States

564 U.S. 522 (2011)

Sentencing Reform Act of 1984 • sentence reduction due to retroactive amendment of Sentencing Guidelines • plea bargain under Federal Rule of Criminal Procedure 11

Roberts

PLIVA, Inc. v. Mensing

564 U.S. 604 (2011)

federal generic drug labeling requirements • federal preemption

Ginsburg, Breyer, Kagan

Bullcoming v. New Mexico

564 U.S. 647 (2011)

Sixth Amendment • Confrontation Clause • forensic laboratory report as testimony