2018-19 Supreme Court Updates
The Kentucky Department of Criminal Justice Training provides the following case summaries for information purposes only. As always, please consult your agency’s legal counsel for the applicability of these cases to specific situations. Please note, the latest cases in this summary have not yet been assigned official citations.
Mitchell v. Wisconsin, (2019) Decided June 27, 2019
ISSUE: Does a statute authorizing a blood draw from an unconscious motorist provide an exception to the Fourth Amendment warrant requirement?
HOLDING: Although the Court elected not to decide the case on the state (Wisconsin) implied consent statute specifically, it agreed that in virtually all circumstances, blood drawn on an unconscious DUI suspect will be justified under exigent circumstances.
Mount Lemmon Fire District v. Guido (2018) Decided Nov. 6, 2018
ISSUE: Does the Age Discrimination in Employer Act (ADEA) apply to government entities with fewer than 20 employees?
HOLDING: The Court ruled that the ADEA applies to all government employers, no matter the size.
FEDERAL LAW – FIREARMS
Rehaif v. U.S., U.S. (2019) Decided June 21, 2019
ISSUE: Must a subject know that it is illegal for them to possess a firearm as a criminal alien and that they are, in fact, a criminal alien?
HOLDING: The Court agreed that scienter (knowledge) is required for criminal prosecution under the statute in question, concerning potentially criminal aliens temporarily possessing a firearm.
U.S. v. Stitt / U.S. v. Sims (2018), Decided Dec. 10, 2018
ISSUE: Is burglary a violent crime under the Armed Career Criminal Act (ACCA)?
HOLDING: The Court agreed that under the law of most states (including Kentucky), generic “burglary” will qualify to enhance a penalty under the ACCA, as it would be considered a violent crime. ACCA cases occur when predicate (earlier) offenses under state law might be used to enhance a penalty for a current conviction under federal law.
Stokeling v. U.S., (2019) Decided Jan. 15, 2019
ISSUE: Is a robbery under the common law elements a predicate offense for the ACCA?
HOLDING: The Court agreed that under the law of most states (including Kentucky), generic “robbery” will qualify to enhance a penalty under the ACCA, as it would be considered a violent crime.
Timbs v. Indiana, (2019) Decided Feb. 20, 2019
ISSUE: Is the Eighth Amendment’s Excessive Fines Clause applicable to states under the 14th Amendment’s Due Process Clause?
HOLDING: The Court ruled that seizing a vehicle that is valued at far more than the highest possible fine in a criminal conviction is a violation of the Eighth Amendment’s prohibition on excessive fines.
42 U.S.C. §1983 - FORCE
City of Escondido (CA) v. Emmons, (2018) Decided Jan. 7, 2019
ISSUE: Is an officer immune from suit if it is debatable whether the force used was excessive under clearly established law?
HOLDING: The Court agreed the specificity regarding the facts is critical in assessing a Fourth Amendment use of force claim. The Court ruled the trial court was far too general in deciding the officer did not qualify for immunity and remanded the case back for further, more specific, analysis of the particular facts in the case.
42 U.S.C. §1983 – ARREST
Nieves v. Bartlett, (2019) Decided May 28, 2019
ISSUE: Does probable cause defeat a First Amendment retaliatory-arrest claim under 42 U.S.C. §1983?
HOLDING: The Court ruled that a probable cause determination will almost always defeat a claim of a retaliatory arrest under the First Amendment. There are, however, minor exceptions to that rule which were not a factor in this case.
42 U.S.C. §1983 – MALICIOUS PROSECUTION
McDonough v. Smith, U.S. (2019) Decided June 20, 2019
ISSUE: When does the statute of limitations for a malicious prosecution claim under 42 U.S.C. §1983 accrue?
HOLDING: The statute of limitations for a case based on malicious prosecution begins to accrue when the underlying criminal case reaches a termination favorable to the defendant. At that point, in Kentucky, the defendant has one year to file the action.
Gamble v. U.S., 2019 Decided June 17, 2019
ISSUE: May an individual be prosecuted for the same essential offense under both state and federal law?
HOLDING: The Court agreed that it is not a violation of the Double Jeopardy clause to prosecute an individual under both state and federal law.