The Supreme Court on Monday ruled for a man suing police for entering his home to check on his mental health, for energy companies being sued for climate change, and against those seeking new trials because they were convicted by non-unanimous juries.
Justice Clarence Thomas, writing for the court, acknowledged that precedent allowed officers to undertake a warrantless search of a vehicle for a firearm, and mentioned the caretaking tasks police offers perform in modern society.
But that was simply “a recognition that these tasks exist, and not an open-ended license to perform them anywhere,” Thomas wrote. “What is reasonable for vehicles is different from what is reasonable for homes.”
The court was reviewing a decision to the contrary by a panel of the U.S. Court of Appeals for the 1st Circuit in Boston, which happened to be joined by retired Justice David Souter.
It said that Cranston, R.I., did not violate the Constitution’s Fourth Amendment ban on unreasonable searches and seizures when officers entered the home of Edward Caniglia in 2015.
Caniglia’s wife had called police after the couple had an argument, and she said she was worried about his mental state. The officers took Caniglia to a hospital for a mental health evaluation and seized his guns and ammunition.
Caniglia told police he was fine, that he was not suicidal and that his mental health was none of their business. He was released, but his weapons were not returned until he sued the city.
Despite the unanimous ruling, several justices wrote separately to warn lower courts to be aware of the limits of Monday’s ruling.
Chief Justice John G. Roberts Jr. noted that the court in 2006 said a warrant was not required when there is a “need to assist persons who are seriously injured or threatened with such injury.” He added: “Nothing in today’s opinion is to the contrary.”
The case is Caniglia v. Strom.
The court ruled 6 to 3 that prisoners convicted by non-unanimous juries cannot ask federal courts to grant them new trials.
The decision in Edwards v. Vannoy, which cut along the court’s conservative-liberal divide, was a follow-up to last term’s ruling that required unanimous juries before convicting someone of a serious crime. Louisiana, Oregon and the U.S. territory of Puerto Rico allowed such convictions, and prisoners there sought new trials after the court’s decision.
But Justice Brett M. Kavanaugh said there was no recourse in federal courts for those who already had exhausted their appeals. And he expanded the ruling’s reach by saying changes in criminal procedure rules do not qualify as “watershed” decisions that demand retroactive enforcement.
Although the court in the past has held out the possibility that such an important change might present itself, Kavanaugh wrote, decades have passed without one, and it was time for the court to close the loop.
“A theoretical exception that never actually applies in practice offers false hope to defendants, distorts the law, misleads judges, and wastes the resources of defense counsel, prosecutors, and courts,” wrote Kavanaugh.
The decision means no federal recourse for Thedrick Edwards, who was convicted in 2007 of rape and multiple charges of armed robbery and kidnapping. The jury was split 10 to 2 on most of the robbery charges and 11 to 1 on the rest, and Edwards — who police said confessed — was sentenced to life in prison without the possibility of parole. (His lawyer said he will still pursue relief at the state level.)
Justice Elena Kagan wrote a dissent for the court’s liberals saying the unanimous-jury rule qualified as a watershed ruling. Then she and Kavanaugh sparred over the propriety of her dissent.
Kagan was in the minority last term in the case that required unanimous juries, saying she was abiding the court’s general practice of standing by previous rulings. The court had required unanimity for federal juries, but not state juries.
Kavanaugh said it was rich of Kagan to dissent last term and then “impugn today’s majority for supposedly shortchanging criminal defendants.” They are better off because of last term’s decision, he said, even with Monday’s limitation.
Kagan said she found Kavanaugh’s criticism “surprising.”
“It treats judging as scorekeeping — and more, as scorekeeping about how much our decisions, or the aggregate of them, benefit a particular kind of party,” she wrote. “I see the matter differently. Judges should take cases one at a time, and do their best in each to apply the relevant legal rules.”
The court ruled 7 to 1 in favor of fossil-fuel energy companies in a tuneup for a looming battle with local governments about liability for climate-change damage they say their jurisdictions have suffered.
BP v. Mayor and City Council of Baltimore presents the question of where a showdown should occur: in state courts, which plaintiffs such as the city consider a more hospitable setting, or in federal court, where the multinational oil and gas companies feel their chances are better.
But the technical question decided by the court Monday was even narrower. It was not about whether the U.S. Court of Appeals for the 4th Circuit had been right in upholding a district judge’s decision in sending the case to state court. It was whether the appeals court should consider all of the arguments raised by the companies.
Justice Neil M. Gorsuch wrote for the majority that the appeals court was wrong in saying its authority was extremely limited.
“The Fourth Circuit erred in holding that it was powerless to consider all of the defendants’ grounds,” he wrote.
The court sent the case back to the lower court but declined to decide anything more than that — for instance, whether such cases should be heard in federal or state court.
Justice Samuel A. Alito Jr. recused himself from the case, probably because of his personal stock holdings. Justice Sonia Sotomayor was the lone dissenter.
She said expanding appellate review of a district judge’s decision to shift a case from federal court to state court will lead to delay and gamesmanship, such as the companies loading their complaint with extraneous issues.
“Baltimore, which has already waited nearly three years to begin litigation on the merits, is consigned to waiting once more,” Sotomayor wrote.