Brief Summaries of Supreme Court Criminal Cases

Here are brief summaries of the holdings in the criminal and related cases for the U.S. Supreme Court term just ended, October 2023 to June 2024. The summaries are taken from the Supreme Court’s website or the syllabus by the Reporter of Decisions.

McElrath v. Georgia, No. 22-721, decided February 21, 2024. Opinion by Justice Jackson. The jury’s verdict that McElrath was not guilty of malice murder by reason of insanity constituted an acquittal for double jeopardy purposes notwithstanding any inconsistency with the jury’s other verdicts.

Pulsifer v. United States, No. 22-340, decided March 15, 2024. Opinion by Justice Kagan. A defendant facing a mandatory minimum sentence is eligible for safety-valve relief under 18 U. S. C. § 3553(f )(1) only if he satisfies each of the provision’s three conditions—or said more specifically, only if he does not have more than four criminal-history points, does not have a prior three-point offense, and does not have a prior two-point violent offense.

McIntosh v. United States, No. 22-7386, decided April 17, 2024. Opinion by Justice Sotomayor. A district court’s failure to comply with Rule 32.2(b)(2)(B)’s requirement to enter a preliminary order before sentencing does not bar a judge from ordering forfeiture at sentencing subject to harmless-error principles on appellate review.

Culley v. Marshall, No. 22-585, decided May 9, 2024. Opinion by Justice Kavanaugh. In civil forfeiture cases involving personal property, the Due Process Clause requires a timely forfeiture hearing but does not require a separate preliminary hearing.

Brown v. United States, No. 22-6389, decided May 23, 2024. Opinion by Justice Alito. For purposes of the Armed Career Criminal Act’s 15-year mandatory minimum sentence on certain defendants with three or more previous convictions, a state drug conviction counts as an ACCA predicate if it involved a drug on the federal schedules at the time of that offense.

Thornell v. Jones, No. 22-982, decided May 30, 2024. Opinion by Justice Alito. The Ninth Circuit’s grant of habeas relief on Jones’s ineffective assistance of counsel claim was based on an erroneous interpretation and application of Strickland v. Washington, 466 U. S. 668.

Diaz v. United States, No. 23-14, decided June 20, 2024. Opinion by Justice Thomas. Expert testimony that “most people” in a group have a particular mental state is not an opinion about “the defendant” and thus does not violate Federal Rule of Evidence 704(b).

Chiaverini v. City of Napoleon, No. 23-50, decided June 20, 2024. Opinion by Justice Kagan. Pursuant to the Fourth Amendment and traditional common-law practice, the presence of probable cause for one charge in a criminal proceeding does not categorically defeat a Fourth Amendment malicious-prosecution claim relating to another, baseless charge.

Gonzalez v. Trevino, No. 22-1025, decided June 20, 2024. Opinion Per Curiam. In requiring petitioner Sylvia Gonzalez to provide specific comparator evidence to support her retaliatory arrest claim, the Fifth Circuit did not properly apply the principles of Nieves v. Bartlett, 587 U. S. 391 (2019).

United States v. Rahimi, No. 22-915, decided June 21, 2024. Opinion by Chief Justice Roberts. When an individual has been found by a court to pose a credible threat to the physical safety of another, that individual may be temporarily disarmed consistent with the Second Amendment.

Smith v. Arizona, No. 22-899, decided June 21, 2024. Opinion by Justice Kagan. When an expert conveys an absent lab analyst’s statements in support of the expert’s opinion, and the statements provide that support only if true, then the statements come into evidence for their truth, and thus implicate the Sixth Amendment’s Confrontation Clause.

Erlinger v. United States, No. 23-370, decided June 21, 2024. Opinion by Justice Gorsuch. The Fifth and Sixth Amendments require a unanimous jury to make the determination beyond a reasonable doubt that a defendant’s past offenses were committed on separate occasions for purposes of the Armed Career Criminal Act, 18 U. S. C. § §924(e)(1).

Snyder v. United States, No. 23-108, decided June 26, 2024. Opinion by Justice Kavanaugh. Federal law, 18 U. S. C. §666, proscribes bribes to state and local officials but does not make it a crime for those officials to accept gratuities for their past acts.

Fischer v. United States, No. 23-5572, decided June 28, 2024. Opinion by Chief Justice Roberts. To prove a violation of 18 U. S. C. §1512(c)(2)—a provision of the Sarbanes-Oxley Act—the Government must establish that the defendant impaired the availability or integrity for use in an official proceeding of records, documents, objects, or other things used in an official proceeding, or attempted to do so.

City of Grants Pass v. Johnson, No. 23-175, decided June 28, 2024. Opinion by Justice Gorsuch. The enforcement of generally applicable laws regulating camping on public property does not constitute “cruel and unusual punishment” prohibited by the Eighth Amendment.

Trump v. United States, No. 23-939, decided July 1, 2024. Opinion by Chief Justice Roberts. The nature of Presidential power entitles a former President to absolute immunity from criminal prosecution for actions within his conclusive and preclusive constitutional authority; he is also entitled to at least presumptive immunity from prosecution for all his official acts; there is no immunity for unofficial acts.