Supreme Court of the United States, 2005

The Supreme Court, in a unanimous opinion by Justice O'Connor, held that the 'substantially advances' formula announced in Agins v. City of Tiburon is not a valid method of identifying regulatory takings under the Fifth Amendment: it asks whether a regulation effectively achieves a legitimate public purpose — a due…

Justice Souter, dissenting, would have stayed the case while Texas courts considered relief based on the International Court of Justice's judgment and the President's directive, or alternatively vacated and remanded for consideration of whether the judgment controlled or deserved weight in federal court.

The Court held that Oklahoma's semiclosed primary system, which permits a party to invite Independents but not voters registered with other parties, imposes only a minor burden on associational rights and is justified by legitimate state interests.

Justice O'Connor concurred in part and concurred in the judgment, joining the Court's opinion except Part II-A. She emphasized that the case implicates important associational interests that should not be minimized and noted concerns that other state laws may unreasonably restrict voters' ability to change party…

Justice Stevens, dissenting, argues the Oklahoma semiclosed primary law burdens First Amendment rights of voters and the Libertarian Party by excluding non-members from participating in primaries. He finds the state interests advanced are protectionist and insufficient to justify the burden.

Justice Thomas, joined by Justice Scalia, dissented from the conclusion that visible restraints at capital sentencing violated due process. He reasoned that neither historical practice nor state law establishes a deeply rooted constitutional prohibition, that sentencing differs from trial because the defendant has…

The Court dismissed the writ of certiorari as improvidently granted after Medellín filed a state habeas application relying on President Bush's memorandum following the ICJ's Avena judgment, which could provide the requested review.

Justice Ginsburg concurred in the dismissal of the writ as improvidently granted, joining the per curiam opinion which found the case freighted with threshold issues and potentially moot by state proceedings following the President's Memorandum.

Consolidated challenges to Michigan and New York laws restricting direct wine shipments from out-of-state wineries. The Court held these laws violate the Commerce Clause due to explicit discrimination against out-of-state economic interests and are not saved by the Twenty-first Amendment.

Justices Stevens and Thomas dissent, arguing that the Michigan and New York laws regulating direct wine shipments are constitutional under the Webb-Kenyon Act and the Twenty-first Amendment, which together grant States broad authority to regulate and discriminate in alcoholic beverage commerce without negative…

The Court held that Michigan and New York statutes discriminating against out-of-state wineries regarding direct shipping violate the Commerce Clause and are not saved by the Twenty-first Amendment.

The Court held that a state postconviction petition rejected as untimely under state law is not a "properly filed" application and therefore does not toll AEDPA's federal habeas limitations period.

Justice Breyer concurs with the Court’s judgment, emphasizing that state‑law requirements must be measured against EPA regulations that give content to FIFRA’s misbranding standards and that the EPA is best positioned to assess pre‑emption.

Justice Thomas concurred in part and dissented in part, agreeing that FIFRA § 136v(b) preempts state-law labeling requirements that differ from federal standards. He argued the majority erred by failing to remand warranty and DTPA claims for preemption analysis and incorrectly applied the presumption against…

Justice Ginsburg dissents, arguing the wire fraud statute should not be read to extraterritorially enforce foreign tax laws. She relies on the presumption against extraterritoriality, the common-law revenue rule, and the rule of lenity, concluding the Court's interpretation expands federal criminal jurisdiction…

The Court held that the federal wire fraud statute criminalizes schemes to defraud a foreign government of tax revenue, and this interpretation does not violate the common-law revenue rule. The opinion affirms the convictions of petitioners who smuggled liquor into Canada to evade taxes.

Justice Thomas, joined by Justices Scalia and Kennedy, dissented from the Court's conclusion that the firearm-possession statute excludes convictions entered by foreign courts. He maintained that the statute's unqualified reference to a person convicted in "any court" plainly includes foreign courts and that neither…

The Court held that the phrase 'convicted in any court' in 18 U.S.C. § 922(g)(1) applies only to domestic, not foreign, convictions. Reversed based on presumption against extraterritoriality and statutory anomalies. Thomas, dissenting, would include foreign convictions based on plain meaning.

The Court held that the wire fraud statute criminalizes schemes to defraud a foreign government of tax revenue and that the common-law revenue rule does not bar such prosecutions.

The Court held that the phrase 'convicted in any court' in 18 U.S.C. § 922(g)(1) applies only to domestic convictions, not foreign ones. This conclusion rests on the presumption that Congress legislates with domestic concerns in mind and the inconsistencies that would arise from including foreign convictions.

The Supreme Court held that a private securities-fraud plaintiff must prove that the defendant's misrepresentation proximately caused the economic loss for which recovery is sought; an inflated purchase price alone neither constitutes nor proximately causes such a loss.

The Supreme Court denied an application for a stay of Florida Circuit Court orders that applicant sought to restrict its publication of grand jury transcripts. Justice Kennedy, writing as Circuit Justice, found the record insufficient to show the applicant was enjoined or faced a real threat of prosecution, especially…

The Court held that Individual Retirement Accounts (IRAs) can be exempted from the bankruptcy estate under 11 U.S.C. § 522(d)(10)(E). It concluded that IRAs qualify as similar plans to those listed in the statute because they substitute for wages, and rights to payment are on account of age due to tax penalties on…

The Court held that a state‑court order vacating a prior conviction is a "fact" for purposes of the one‑year limitation period in 28 U.S.C. §2255¶6(4), but that the period begins only when the petitioner receives notice of the vacatur and has shown due diligence in seeking that order after the federal judgment…

The Court held that the Rooker-Feldman doctrine is limited to cases brought by state-court losers who seek federal district court review and rejection of an injury caused by a state-court judgment entered before the federal proceedings began.

The Supreme Court reversed the Second Circuit, holding that the Oneida Indian Nation cannot unilaterally revive its ancient sovereignty over parcels of historic reservation land purchased on the open market.

Justice Thomas dissents from the Court's holding that Title IX's private right of action for sex discrimination encompasses claims of retaliation. He concludes that retaliation is not discrimination on the basis of sex under the statute's plain terms and that the spending clause requires clear notice of liability.

The Supreme Court held that the private right of action implied by Title IX encompasses claims of retaliation: when a funding recipient retaliates against a person because he has complained about sex discrimination, that retaliation is intentional 'discrimination' 'on the basis of sex' under 20 U.S.C.

Justice Stevens dissents, arguing that only Congress has the power to diminish a reservation or revoke tribal tax immunity. He contends the majority's ruling effectively disestablishes tribal status without congressional authorization and violates established Indian law principles.

The Supreme Court reversed the Second Circuit, holding that the Oneida Indian Nation cannot unilaterally revive its ancient sovereignty over discrete parcels of historic reservation land purchased in the open market after a long lapse of time.

Justice Stevens concurs with the Court’s judgment that the Telecommunications Act of 1996 provides an exclusive remedial scheme that precludes §1983 actions, but he notes two flaws: the Court’s handling of the presumption favoring §1983 and its dismissal of legislative history.

Justice Breyer concurs with the Court's decision that the Telecommunications Act of 1996 provides an exclusive judicial remedy and forecloses § 1983 relief. He emphasizes that context is often more significant than literal text in determining congressional intent.

Justice Stevens, joined by Justices Souter, Ginsburg, and Breyer, concurred in the judgment in part because the Court of Appeals erred in ruling the officers should have released the respondent from handcuffs sooner as a matter of law rather than reviewing evidence sufficiency.

The Supreme Court held that officers executing a search warrant acted consistently with the Fourth Amendment in detaining occupant Iris Mena in handcuffs for the duration of the search, because the authority to detain occupants incident to a warranted search is categorical and the safety interests were at their…

Justice Kennedy concurs in the judgment, emphasizing that while handcuffing may be justified at the outset of a search, it must not become routine or excessively prolonged; he adds that the reasonableness of handcuffing must be reassessed if the detention extends for hours.

The Supreme Court held that two Ohio prisoners could pursue constitutional challenges to the State's parole-eligibility and parole-suitability procedures under 42 U.S.C. § 1983 rather than being confined to federal habeas corpus, because success would at most yield a new eligibility review or a new discretionary…

Justice Kennedy dissents, arguing that challenges to parole determinations must be brought in habeas corpus under Preiser v. Rodriguez rather than under 42 U.S.C. § 1983. He contends the majority's reasoning is inconsistent with how sentencing challenges are treated and ignores that parole challenges relate to the…

Justice Scalia joins the majority opinion holding that state prisoners' claims challenging discretionary parole procedures may be brought under 42 U.S.C. § 1983 rather than habeas corpus, as they do not necessarily imply speedy release.