Supreme Court strikes down California sentencing rules

[JURIST] The US Supreme Court [official website; JURIST news archive] handed down decisions in three cases Monday, including Cunningham v. California [Duke Law case backgrounder; JURIST report] where the Court struck down as unconstitutional California sentencing rules that allow judges to exercise discretion to tack on additional years to prison sentences beyond that determined by a jury. The Court overturned a California Court of Appeal decision [PDF text; modification, PDF], holding that California's Determinate Sentencing Law [backgrounder, PDF] allows judges to impose enhanced sentences based on a judge's, not the jury's, finding of facts and therefore violates the Sixth and Fourteenth Amendments of the US Constitution. Read the Court's opinion [text] per Justice Ginsburg, along with a dissent [text] from Justice Kennedy and a second dissent [text] from Justice Alito. AP has more.

In the consolidated cases of Jones v. Bock and Williams v. Overton [Duke Law case backgrounder; JURIST report], the Court rejected rules established by the US Court of Appeals for the Sixth Circuit as to when a prisoner can file a lawsuit contesting prison conditions under the Prison Litigation Reform Act of 1995 (PLRA) [text, see Title VIII]. According to the Court, the PLRA "requires prisoners to exhaust prison grievance procedures before filing suit," but Sixth Circuit rules concerning when a prisoner has exhausted other administrative procedures go too far:

The Sixth Circuit, along with some other lower courts, adopted several procedural rules designed to implement this exhaustion requirement and facilitate early judicial screening. These rules require a prisoner to allege and demonstrate exhaustion in his complaint, permit suit only against defendants who were identified by the prisoner in his grievance, and require courts to dismiss the entire action if the prisoner fails to satisfy the exhaustion requirement as to any single claim in his complaint. Other lower courts declined to adopt such rules. We granted certiorari to resolve the conflict and now conclude that these rules are not required by the PLRA, and that crafting and imposing them exceeds the proper limits on the judicial role.
Read the Court's unanimous opinion [text] per Chief Justice Roberts. AP has more.

Finally, in Osborn v. Haley [Duke Law case backgrounder], the Court held that a lawsuit filed in state court by Pat Osborn, an employee of a private contractor, against a Forest Service employee who Osborn alleged influenced the contractor's decision to fire Osborn should be heard in federal court. After the lawsuit had been filed in state court, the US attorney general certified that the government employee, Barry Haley, had acted within the scope of his employment, removed the case to federal court, and sought to have the lawsuit dismissed under the Westfall Act [text], which provides tort immunity to government employees for acts committed within the scope of their employment. The federal district court hearing the case remanded it back to state court after concluding that it must accept Osborn's allegations - that Haley acted outside the scope of employment - as true. The district court ruling was overturned by a federal appeals court. The Supreme Court upheld the Sixth Circuit's decision [PDF text] in the case and ruled that the case should not have been remanded to state court, holding that for purposes of removal, the attorney general's certification gave the federal court "exclusive competence to adjudicate the case." The Court also held that certification under the Westfall Act was proper "when a federal officer charged with misconduct asserts, and the Attorney General concludes, that the incident or episode in suit never occurred." Read the Court's opinion [text] per Justice Ginsburg, along with a concurrence in part and dissent in part [text] from Justice Souter, a second concurrence in part and dissent in part [text] from Justice Breyer, and a dissent [text] from Justice Scalia.

 

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