Holt v Hobbs

Holt challenged Arkansas’ ban on beards in its prison system. The challenge was rejected by the district court and the 8th Circuit affirmed. The Court, with two added concurrences, unanimously reversed. It held the ban on beard violated the Religious Land Use and Institutionalized Persons Act because the policy coerced Holt to act in contradiction to a religious belief and the policy of preventing contraband is not served by the ban on ½ inch beards as contraband could already be hidden in hair on the head or in clothes and searching the beard is less restrictive than banning beards and the fear of changed appearance could be remedied by taking pictures of inmates without beards instead of banning them altogether. The court noted that Arkansas allows short beards for medical reasons which have the same security risks as beards for religious reasons and most prison systems in the United States allow ½ inch beards and Arkansas provided no evidence its prisons are so different that the ban is justified. Justice Ginsberg, joined by Sotomayor added a concurrence noting granting Holts request here will infringe on anyone else’s rights. Justice Sotomayor added a concurrence arguing that deference is due to prison officials, but, they must present evidence not just decree their policy advances a compelling interest and must demonstrate reasoned consideration of alternatives which did not happen here.

Teva Pharmaceuticals USA Inc. v Sandoz, Inc.

Sandoz sued Teva arguing its patent for a certain drug manufacturing process was invalid as the term “molecular weight” was indefinite. The district found as a matter of fact the term had a generally understood meaning in the field and rejected the challenge tot eh patent. The Federal Circuit reviewed de novo and reversed. The Court, 7-2, reversed and remanded. The majority held that while the final determination of a patent’s validity is a questions of law, when a district court makes subsidiary factual determinations, such as the meaning of “molecular weight’ here, after taking evidence, those findings must be reviewed for clear error under the rules of Civil procedure not de novo as there is no exception for patents in the rule. The majority noted this is consistent with how district court determinations in “obviousness” cases is reviewed and there is no reason for a different result here. As there were unresolved issues, the case was remanded. Justice Thomas, joined by Alito, dissented arguing patents are more like statutes than contracts or deed because they are granted by the government and control the actions of persons not party to the patent. Thus, de novo review is appropriate.

Christeson v Roper

Christeson sought substitute counsel to argue his attorneys in his first habeas petition failed to meet him until after the deadline past. The district court denied his motion and the 8th circuit affirmed.  The Court, 7-2, reversed. The per curium majority held the district court erred by failing to consider the first attorneys conflict given their inability to argue their own incompetence. The majority held the concerns about possible future abusive filings were insufficient to overcome this error and remanded the case for further proceedings. Justice Thomas, joined by Alito, dissented arguing the case should have been fully briefed and argued given the importance of the equitable tolling issue Christeson wants to raise to allow his case to proceed.