Supreme Court Decision Syllabus (SCOTUS Podcast)

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In a per curiam decision, the Supreme Court summarily reversed the Second Circuit’s grant of federal habeas relief to Pedro Hernandez, who was convicted of kidnapping and felony murder in the 1979 disappearance and death of Etan Patz. The Second Circuit had concluded that the state trial judge should have told the jury about the rule from Missouri v. Seibert governing when a confession obtained after a delayed Miranda warning may be tainted by an earlier unwarned confession. Because the judge instead answered the jury’s question with a simple “no,” the Second Circuit found that the state courts had unreasonably applied clearly established federal law. The Supreme Court disagreed, explaining that Seibert concerns a judge’s decision whether to suppress a confession and says nothing about what juries must be instructed to consider. Because no Supreme Court precedent required the jury instruction the Second Circuit demanded, and because federal habeas courts may not overturn state convictions by extending existing precedents into new contexts, the Court held that AEDPA barred relief and reinstated Hernandez’s conviction.
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We speak today to say...nothing has changed...
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Because a criminal law appeal waiver must be both knowingly and voluntary a waiver of ineffective assistance of counsel is not really possible.
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The Supreme Court held that the government's prosecution of Ali Hemani under 18 U.S.C. §922(g)(3)'s prohibition on firearm possession by unlawful users of controlled substances violated the Second Amendment as applied to him. Justice Gorsuch, writing for seven Justices, concluded that the government failed to identify a historical tradition of firearm regulation analogous to its interpretation of §922(g)(3), which automatically disarms anyone who regularly uses a controlled substance regardless of whether the person is dangerous, intoxicated, or incapable of managing his affairs. The Court rejected the government's reliance on historical laws regulating "habitual drunkards," finding that those laws targeted individuals whose intoxication rendered them incapacitated, served different purposes, and generally required individualized proceedings before liberty could be restricted. Because Hemani was prosecuted solely for possessing a firearm while being an admitted marijuana user, and because the government failed to show that such a broad prohibition is consistent with the Nation's historical tradition of firearm regulation, the Court held the prosecution unconstitutional. The Court emphasized the narrowness of its ruling, leaving open the validity of laws targeting addicts, intoxicated persons, or individuals shown through individualized evidence to be dangerous because of their drug use. 
Justice Alito, joined by Justice Kagan, concurred in the judgment.
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In a 6–3 decision, the Supreme Court held that Section 47(b) of the Investment Company Act does not create an implied private right of action allowing investors or other private parties to sue for rescission of contracts that allegedly violate the Act. The case arose when activist investor Saba Capital challenged voting-right restrictions adopted by several closed-end mutual funds and sought rescission under Section 47(b). Writing for the Court, Justice Barrett explained that Congress, not the courts, determines who may enforce federal statutes, and Section 47(b)’s language is directed at courts’ remedial authority once parties are already before them rather than at creating enforceable rights for a particular class of individuals. The Court emphasized that the ICA establishes a comprehensive enforcement scheme centered on the Securities and Exchange Commission and expressly authorizes private suits in only limited circumstances, making it unlikely that Congress intended an additional implied cause of action. The Court also rejected reliance on Transamerica Mortgage Advisors v. Lewis, noting that Congress amended Section 47(b) in 1980 to remove the “shall be void” language that supported an implied remedy in that case. Accordingly, the Court reversed the Second Circuit and held that Saba could not use Section 47(b) as a standalone basis to seek rescission of contracts allegedly violating the ICA.
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