Brief Summaries of Supreme Court Criminal and Related Decisions

Here are brief summaries of the holdings in the criminal and related cases for the U.S. Supreme Court term just ended, October 2024 to June 2025. The summaries are taken from the Supreme Court’s website.

Hamm v. Smith, No. 23-167, decided November 4, 2024. Opinion Per Curiam
The judgment is vacated and the case is remanded to the Eleventh Circuit to clarify the basis for its decision affirming the District Court’s judgment that Smith is ineligible for the death penalty due to intellectual disability.

Andrew v. White, No. 23-6573, decided January 21, 2025. Opinion Per Curiam
At the time of the decision of the Oklahoma Court of Criminal Appeals, clearly established federal law provided that the erroneous admission of unduly prejudicial evidence could render a criminal trial fundamentally unfair in violation of due process, see Payne v. Tennessee, 501 U. S. 808, 825 (1991); the judgment below is vacated and the case is remanded for further proceedings.

Williams v. Reed, No. 23-191, decided February 21, 2025. Opinion by Justice Kavanaugh
Where a state court’s application of a state exhaustion requirement in effect immunizes state officials from 42 U. S. C. §1983 claims challenging delays in the administrative process, state courts may not deny those claims on failure-to-exhaust grounds.

Glossip v. Oklahoma, No. 22-7466, decided February 25, 2025. Opinion by Justice Sotomayor
The Court has jurisdiction to review the judgment of the Oklahoma Court of Criminal Appeals; the prosecution violated its constitutional obligation to correct false testimony under Napue v. Illinois, 360 U. S. 264.

Thompson v. United States, No. 23-1095, decided March 21, 2025. Opinion by Chief Justice Roberts
Title 18 U. S. C. §1014, which prohibits “knowingly mak[ing] any false statement,” does not criminalize statements that are misleading but not false.

Delligatti v. United States, No. 23-825, decided March 21, 2025. Opinion by Justice Thomas
The knowing or intentional causation of injury or death, whether by act or omission, necessarily involves the “use” of “physical force” against another person within the meaning of 18 U. S. C. §924(c)(3)(A).

Barnes v. Felix, No. 23-1239, decided May 15, 2025. Opinion by Justice Kagan
The Fifth Circuit’s moment-of-threat rule—a framework for evaluating police shootings which requires a court to look only to the circumstances existing at the precise time an officer perceived the threat inducing him to shoot—improperly narrows the Fourth Amendment analysis of police use of force.

Kousisis v. United States, No. 23-909, decided May 22, 2025. Opinion by Justice Barrett
A defendant who induces a victim to enter into a transaction under materially false pretenses may be convicted of federal fraud even if the defendant did not seek to cause the victim economic loss.

Martin v. United States, No. 24-362, decided June 12, 2025. Opinion by Justice Gorsuch
The Supremacy Clause does not afford the United States a defense in a suit against it under the Federal Tort Claims Act, 28 U. S. C. §2671 et seq., and the law enforcement proviso in §2680(h) of the FTCA overrides only the intentional-tort exception in that subsection, not the discretionary-function exception or other exceptions throughout §2680.

Rivers v. Guerrero, No. 23-1345, decided June 12, 2025. Opinion by Justice Jackson
Once a district court enters its judgment with respect to a first-filed habeas petition, see 28 U. S. C. §2254, a second-in-time filing qualifies as a “second or successive application” under the Antiterrorism and Effective Death Penalty Act of 1996 properly subject to the requirements of §2244(b).

Perttu v. Richards, No. 23-1324, decided June 18, 2025. Opinion by Chief Justice Roberts
Parties are entitled to a jury trial on the issue of exhaustion of remedies under The Prison Litigation Reform Act when that issue is intertwined with the merits of a claim that requires a jury trial under the Seventh Amendment.

Esteras v. United States, No. 23-7483, decided June 20, 2025. Opinion by Justice Barrett
A district court considering whether to revoke a defendant’s term of supervised release may not consider 18 U. S. C. §3553(a)(2)(A), which covers retribution vis-à-vis the defendant’s underlying criminal offense.

Gutierrez v. Saenz, No. 23-7809, decided June 26, 2025. Opinion by Justice Sotomayor
Petitioner Ruben Gutierrez has standing to bring his 42 U. S. C. §1983 claim challenging Texas’s postconviction DNA testing procedures under the Due Process Clause.

Hewitt v. United States, No. 23-1002, decided June 26, 2025. Opinion by Justice Jackson
Because a sentence “has . . . been imposed” for purposes of §403(b) of the First Step Act only if the sentence is extant (i.e., has not been vacated), the Act’s more lenient penalties apply to defendants whose previous 18 U. S. C. §924(c) sentences have been vacated and who need to be resentenced following the Act’s enactment; the judgment of the Fifth Circuit is reversed and the case is remanded.

Goldey v. Fields, No. 24-809, decided June 30, 2025. Opinion Per Curiam
The Fourth Circuit’s determination that inmate Andrew Fields could proceed with his Eighth Amendment excessive-force claim for damages under Bivens v. Six Unknown Fed. Narcotics Agents, 403 U. S. 388 (1971), is reversed, and the case is remanded.