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February 2010 Archives

Adequacy of Miranda Warnings Addressed in Florida v. Powell

Florida v. Powell, No. 08-1175, involved a state prosecution for possession of a weapon by a convicted felon.  The state supreme court reversed defendant's conviction on Miranda grounds.

As the Court wrote:  "In a pathmarking decision, Miranda v. Arizona, 384 U. S. 436, 471 (1966), the Court held that an individual must be "clearly informed," prior to custodial questioning, that he has, among other rights, "the right to consult with a lawyer and to have the lawyer with him during interrogation." The question presented in this case is whether advice that a suspect has "the right to talk to a lawyer before answering any of [the law enforcement officers'] questions," and that he can invoke this right "at any time. . . during th[e] interview," satisfies Miranda."

The Court in this case reversed, holding that the police had indeed satisfied Miranda's requirements by informing defendant that he had "the right to talk to a lawyer before answering any of their questions," and that he had "the right to use any of his rights at any time he wanted during the interview."

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Corporate Citizenship Addressed in Hertz Corp. v. Friend

Hertz Corp. v. Friend, No. 08-1107, involved a wage and hour action in which a court of appeals affirmed the district court's order remanding the case to state court.

As the Court wrote:  "The federal diversity jurisdiction statute provides that"a corporation shall be deemed to be a citizen of any State by which it has been incorporated and of the State where it has its principal place of business." 28 U.S.C. §1332(c)(1) (emphasis added). We seek here to resolve different interpretations that the Circuits have given this phrase."

The Supreme Court vacated and remanded, on the ground that the Court returned to the "nerve center" approach in determining a corporation's citizenship for diversity jurisdiction purposes, under which "principal place of business" is best read as referring to the place where a corporation's officers direct, control, and coordinate the corporation's activities.

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Court Clarifies "Break-in-custody" Exception

The Court's handed down Maryland v. Shatzer, No. 08-680, which concerned a sexual child abuse prosecution in which a state court of appeals reversed defendant's conviction on Miranda grounds. The Supreme Court granted the state's certiorari petition.

As the Court wrote:  "When, unlike what happened in these three cases, a suspect has been released from his pretrial custody and has returned to his normal life for some time before the later attempted interrogation, there is little reason to think that his change of heart regarding interrogation without counsel has been coerced."

The Supreme Court reversed, holding that defendant experienced a break in Miranda custody lasting more than two weeks between first and second attempts at interrogation, and thus Edwards did not mandate suppression of defendant's statements during the second interrogation.

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Court Rejects "De Minimis" Injury Requirement in Prisoner's Excessive Force Case

The other ruling the Court handed down today, Wilkins v. Gaddy, No. 08-10914, involved a 42 U.S.C. section 1983 claim of excessive force by a prisoner.  The district court had dismissed the complaint and the Fourth Circuit had affirmed such ruling.

But, as the Court wrote:  "In requiring what amounts to a showing of significant injury in order to state an excessive force claim, the Fourth Circuit has strayed from the clear holding of this Court in Hudson. . . . Reversing the Court of Appeals, this Court rejected the notion that 'significant injury' is a threshold requirement for stating an excessive force claim."

The Court reversed, holding that the district court's approach (based on its determination that plaintiff's injuries were "de minimis") was at odds with precedent directing it to decide excessive force claims based on the nature of the force, rather than the extent of the injury.

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Court Addresses Batson Claim in Habeas Case

Today, the Supreme Court decided two cases, one in a capital habeas matter and the other dealing with a prisoner's claim of excessive force (covered here).

In Thaler v. Haynes, No. 09-273, a capital habeas case, a court of appeals had reversed a denial of petitioner's habeas petition.

The Supreme Court outlined the issue presented as follows: "This case presents the question whether any decision of this Court 'clearly establishes' that a judge, in ruling on an objection to a peremptory challenge under Batson v. Kentucky, 476 U.S. 79 (1986), must reject a demeanor-based explanation for the challenge unless the judge personally observed and recalls the aspect of the prospective juror's demeanor on which the explanation is based."

The Court reversed on the ground that clearly established law did not provide that a demeanor-based explanation for a peremptory challenge, in response to a Batson claim, must be rejected unless the judge personally observed and recalled the relevant aspect of the prospective juror's demeanor.

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