[JURIST] The US Supreme Court [official website; JURIST news archive] on Monday handed down decisions in five cases, including Randall v. Sorrell [Duke Law case backgrounder; JURIST report], consolidated with two other cases, where the Court struck down Vermont's Act 64 campaign law [text], which places strict caps on campaign contributions and spending. Opponents of the campaign financing law argued that the restrictions violate the First and Fourteenth Amendments of the US constitution and that the low contribution levels - $200 for state House races, $300 for state Senate campaigns, and $400 for statewide offices - fall below an acceptable constitutional threshold. In its appellate ruling [PDF text] in the litigation, the Second Circuit interpreted the Supreme Court's 1976 decision in Buckley v. Valeo [text] as allowing spending limits that are "narrowly tailored to secure clearly identified and appropriately documented compelling governmental interests" and upheld the Vermont law. Read the court's opinion [text] per Justice Breyer, along with a concurrence in part [text] from Justice Alito, a concurrence in the judgment [text] from Justice Kennedy, a second concurrence in the judgment [text] from Justice Thomas, who was joined by Justice Scalia, a dissent [text] from Justice Stevens, and a second dissent [text] from Justice Souter, who was joined by Justice Ginsburg and in part by Justice Stevens. AP has more.
In Kansas v. Marsh [Duke Law case backgrounder], the Court upheld Kansas' death penalty statute, which requires the death penalty when jurors find mitigating and aggravating factors to be equal. Marsh was convicted of first degree murder and sentenced to death, but on appeal the Kansas Supreme Court ruled the state's death penalty statute unconstitutional [decision text]. The Supreme Court reversed the state court, ruling that the Kansas statute "rationally narrows the class of death-eligible defendants and permits a jury to consider any mitigating evidence relevant to its sentencing determination." The Court first heard arguments [JURIST report] in the case in December, but the case was reargued [JURIST report] in April in order to allow Justice Alito to participate in consideration of the case. Read the Court's majority opinion [text] per Justice Thomas, along with a concurrence [text] from Justice Scalia, a dissent [text] from Justice Stevens and a second dissent [text] from Justice Souter, who was joined by Justices Stevens, Ginsburg and Breyer. AP has more.
In Washington v. Recuenco [Duke Law case backgrounder], the Court held that "failure to submit a sentencing factor to the jury is not 'structural' error" and thus does not require automatic reversal. The Court considered whether error as to the definition of a sentencing enhancement should be subject to a harmless error analysis where it is shown beyond a reasonable doubt that the error did not contribute to the verdict on the enhancement. Recuenco was convicted of second degree assault and the jury found that he was armed with a deadly weapon - a handgun. At sentencing, however, the judge enhanced Recuenco's sentence because he was armed with a firearm rather than because he was armed with a deadly weapon. The Washington Supreme Court reversed [opinion text] this decision, ruling that Recuenco's Sixth Amendment rights had been violated because there was no finding that he was armed with a firearm, but the Supreme Court reversed the state court's ruling. Read the Court's majority opinion [text] per Justice Thomas, along with a concurrence [text] from Justice Kennedy, a dissent [text] from Justice Stevens and a second dissent [text] from Justice Ginsburg, who was joined by Justice Stevens.
In Arlington Central School District v. Murphy [Duke Law case backgrounder], the Court held that the attorneys' fees shifting provision [text] contained in the Individuals with Disabilities Education Act [Dept. of Educ. materials] does not authorize a court to award "expert" fees to the parents of a child with a disability who successfully sued under IDEA. The Murphys successfully sued the school district under IDEA and the district court ordered the school district to pay attorneys' fees and fees for an educational consultant. The school district appealed the order to pay consultant fees and the Second Circuit affirmed [opinion, PDF] the district court's decision, but the Supreme Court reversed the appeals court's ruling. Read the Court's 5-4 majority opinion [text] per Justice Alito, along with a concurrence in part [text] from Justice Ginsburg, a dissent [text] from Justice Souter and a second dissent [text] from Justice Breyer, who was joined by Justices Stevens and Souter.
Finally, in US v. Gonzalez-Lopez [Duke Law case backgrounder; JURIST report], the Court held that a defendant is entitled to a reversal of conviction under the Sixth Amendment right to counsel if a trial court improperly denies a person their choice of counsel. In the case, Gonzalez-Lopez wanted to bring in his own out-of-state attorney to represent him on federal drug trafficking charges, but was denied by the trial court in Missouri. On appeal, the US Court of Appeals for the Eighth Circuit vacated the conviction [ruling, PDF] and remanded the case for a new trial, ruling that the district court should have provided a reason for denying the defendant his choice of counsel. Read the Court's majority opinion [text] per Justice Scalia, along with a dissent [text] from Justice Alito, who was joined by Chief Justice Roberts and Justices Kennedy and Thomas. Reuters has more.