Montgomery v Louisiana

Montgomery filed a state postconviction petition seeking to set aside his mandatory life without parole sentence imposed for a crime committed while he was juvenile. The Louisiana trail court ruled the Court’s precedent banning such sentences did not apply in state postconviction proceedings and the Louisiana Supreme Court denied review. Resolving a split of appellate authority on the issue, the Court, 6-3, reversed. The majority fist held that new substantive constitutional rules which bar certain punishments are applicable and binding in state postconviction proceedings as those rules apply in federal habeas proceedings, the Supremacy Clause requires states to apply binding federal law and the state has no interest in keeping anyone in prison when the punishment is not allowed. It held that the bar on mandatory life without parole sentences for juvenile offenders is a new substantive rule because it placed a punishment beyond the state’s power to impose based on previously recognized difference between adult and juvenile offenders and the lesser blameworthiness of juvenile offenders. It held that the procedural protections set out tint the opinions adopting the new rule merely set out a mechanism to implement the underlying substantive rule. The majority also explicitly held the bar is a new rule. It also pointed out that allowing those sentenced to life without parole to apply for parole is an appropriate method to implement the new rule. Scalia, joined by Thomas and Alito, dissented arguing that there was no jurisdiction to hear this case because retroactivity precedent was limited to federal prisoner litigating in federal court under habeas statues, federal courts review state decision based on the law at the time of conviction and retroactivity here is inconsistent with the underlying policy of not continually forcing states to reopen convictions. Thea argued the sole reasoning the majority applies is the rule is retroactive because we say so and given the changes in constitutional law every few years the majority’s approach will conscript sates into perpetual revisiting of old convictions. He also argued that even under the majority’s approach, the bar is not retroactive as life without parole remains available for some juvenile offenders after an individualized review and is thus a procedural rule not a substantive one. Thomas added a dissent arguing that no provision of the Constitution provides a basis for the right adopted here by the majority and there is also no support in the history of state and federal postconviction review for the majority’s decision.

Federal Power Regulatory Commission v Electric Power Supply Association

Commission appealed the DC Circuit’s decision that Commission’s rules on offers to pay consumers to not use electricity at certain times were beyond the commission’s stator authority. The Court, 6-2 with Alito recused, reversed. The majority held that the rules were within the Commission’s power under 16 USC 824 because the rules explicitly limit themselves to the wholesale market and thus directly affect the wholesale prices as allowed by 824’s text and limited to direct affects by the majority’s adoption of that test from DC Circuit precedent, did not regulate retail rates which are state responsivity and if Commission is not allowed to regulate the offers then no entity can which would create a regulatory no man’s land which Court precedent states should not be done. The majority also held the rules were not arbitrary or capricious as Commission explained that the rules treated offerees like other wholesale level providers, helps overcome certain barriers in the wholesale market and that trying to deduct the retail price from the offers would be administratively impracticable. Scalia, joined by Tomas, dissented arguing that the offerees did not involve purchase of electricity for resale and thus were beyond Commission’s authority under 824. He also argued that the offer system was intended to be run by states not the Commission as evidenced by the rules’ opt out provision allowing states to bar the offers in their boundaries.

Musaccchio v United States

Musacchio appealed his conviction for unauthorized computer system use argui9ng the government failed to prove an element added in the jury instructions to the statutory elements and that the statute of limitations had run and this was plain error. The 5th circuit affirmed. Resolving a circuit split on the two issues, the Court affirmed. As to the added element, the Court held that review for sufficiency of the evidence is limited to whether or not a rational jury could find each statutory element proved beyond a reasonable doubt and thus added elements in jury instructions play no role in the analysis. The Court noted the 5th circuit erred in applying law of the case doctrine here as there was no district court ruling to review. As to the limitations issue, the Court held that in the federal system, limitations defenses only become an issue if raised by the defense in the district court. Thus, when a defendant fails to raise the issue, like Musacchio, there is nothing to review even for plain error.

Menominee Tribe of Wisconsin v United States

Tribe appealed the DC Circuit’s holding that the statute of limitations had run on its claims for payments under a health care contract arguing that equitable tolling applied. The Court, resolving a circuit split on tolling of tribal claims, affirmed. It held federal equitable tolling requires two elements namely the party asserting toiling acting diligently to protect its rights and an extraordinary circumstance that prevented the party from timely filing. The Court held the extraordinary circumstance must be external to the party and here Tribe’s mistaken belief about the law and the effect of another pending claim were not extraordinary circumstances and tolling thus did not apply.

Amgen, Inc. v Harris

On remand from the Court, the 9th Circuit held Harris’s complaint stated a claim for breach of fiduciary duty. The Court reversed in a per curium opinion holding the 9th Circuit failed to analyze the complaint to see if it plausible pled that no fiduciary would conclude discontinuing purchases of Amgen stock would cause more harm than good and that the complaint as filed did not allege sufficient facts The Court noted amending the complaint may be appropriate and remanded the case for further proceedings.

James v City of Boise

The Idaho Supreme Court awarded attorney fees to City under 28 USC 1988 without finding James’ suit was frivolous as required by Court precedent. The Court summarily reversed reminding the Idaho Supreme Court that United States Supreme Court’s decisions about federal law, including 1988, control and cannot be ignored like was done here.