Youth Miranda rights at issue (Updated to 11:09 a.m.)
UPDATED TO 11:09 a.m. The Supreme Court, taking on a second case this Term on the rights of youths facing police questioning, agreed on Monday to decide whether a minor has a right to “Miranda” warnings before any questions may be asked. The new case focuses on whether a suspect’s age counts as a factor in determining when to warn a suspect about the right to silence and the right to a lawyer. This was one of five cases granted review Monday. The Court denied review in a major sequel to its campaign finance ruling in Citizens United v. Federal Election Commission.
Last month, in the other case involving a youth, the Court agreed to decide whether police must obtain a warrant before interviewing a child while at school during a sexual assault investigation. That issue arises in the consolidated cases of Camreta v. Greene (09-1454) and Alford v. Greene (09-1478), granted on Oct. 12.
In the new case, J.D.B. v. North Carolina (09-11121), the Court will be reviewing a North Carolina Supreme Court decision that courts are barred from considering age as a factor in the Miranda v. Arizona context. The state court ruled that this conclusion was dictated by the Supreme Court’s 2004 decision in Yarborough v. Alvorado.
The Justices also agreed to resolve a conflict in lower courts on when evidence obtained by police is to be barred from a case because the search that turned up the evidence was invalid. That involves the meaning of a 1984 Supreme Court ruling in U.S. v. Leon, creating an exception to the “exclusionary rule” when police conducted in “good faith” a search that was illegal at the time. The new case, Davis v. U.S. (09-11328), tests whether the good-faith exception applies to a search that was legal at the time it was done, but was later found to be unconstitutional. The case is another test of the effect of the Supreme Court’s 2009 decision in Arizona v. Gant, limiting police authority to search after making a roadside arrest. The Davis case, from Alabama, involves a search after a traffic stop that turned up an illegal gun.
The Court took on a potentially significant case on the right of a poor person to have a lawyer when facing a possible jail sentence, but indicated that the case may have jurisdictional problems. In Turner v. Price, et al. (10-10), the main issue is whether a poor person has a constitutional right to a lawyer in a civil contempt case, if the proceeding could lead to being sent to jail or prison. The case involves a South Carolina man who has been put in jail for contempt three times for failure to pay child support. In accepting the case, however, the Court also told the two sides to brief and argue whether the Justices have jurisdiction to review the state Supreme Court decision in the case.
In a case of major importance to universities and other non-profit organizations, the Court said it would clarify the right of such institutions to own patents to inventions that are made during research that is federally funded. At issue is the scope of a 1980 federal law, the Bayh-Dole Act, protecting the right of such institutions to own patents that result from government-financed research. The U.S. Solicitor General, asked by the Court for the government’s views, had urged review of Stanford University Board of Trustees v. Roche Molecular Systems (09-1159).
The fifth case granted review was Fox v. Vice (10-114), testing the scope of the federal law that allows parties that have been sued to have their attorneys’ fees paid by the suing party, if the lawsuit was frivolous or without foundation. At issue in this case is whether such a fee award can be made based on dismissal of one of the claims, when there are other, related claims that arguably were not frivolous.
The Court, returning from a two-week recess, also issued a series of orders denying review of a number of new and significant cases. Among the most important was a plea for the Court to expand the right of independent political groups to raise and spend money in federal elections — a sequel to last January’s Citizens United decision. The issue in Keating, et al., v. FEC (10-145) was whether it is unconstitutional to require groups set up to spend money to influence federal elections — independent of candidates or parties — to operate as PACs (political action committees) and thus face significant obligations to disclose their activities and fund sources. The D.C. Circuit Court upheld that requirement for an organization known as SpeechNow.org. The organizers of that group took the issue on to the Supreme Court, arguing that the requirement will impair the rights of independent groups in the electoral process. The FEC opposed review of the case, arguing that there was no conflict among lower courts on the issue.
In another noteworthy case, the Court refused to review a constitutional challenge to government electronic spying in a case involving an Oregon lawyer, Brandon B. Mayfield, who was falsely identified as a suspect in the terrorist bombing of a computer train in Madrid, Spain, in March 2004. In his new appeal in Mayfield, et al., v. U.S. (09-151), the Aloha, Ore., attorney argued that an individual targeted by such spying has a right to sue when the government keeps some of the records gathered in the spying after having agreed to allow the individual to sue. Mayfield’s lawsuit was authorized as part of an agreement he had made with the government, which included a payment to him and his family of $2 million.
One of the Court’s denials of review, in Wong v. Smith (09-1031), led to a seven-page dissent by three Justices. The issue in the case filed by a California prison warden was whether a federal court in a habeas case was wrong in ruling that a state judge had unconstitutionally coerced jurors into returning a guilty verdict by identifying specific evidence in the case as important and instructing jurors to consider it. Justice Samuel A. Alito, Jr., wrote the dissent, joined by Chief Justice John G. Roberts, Jr., and Justice Antonin Scalia. The dissenters said that lower court ruling conflicted with federal habeas law, and “gives short shrift to a venerable common-law practice.”
In other orders, the Court asked the Solicitor General to submit the federal government’s views on whether the Court should hear two cases: PPL Montana v. Montana (10-218) and John Crane Inc. v. Atwell (10-272). The issue in the first case is whether a state is constitutionally barred from claiming ownership, retroactively, of the beds of rivers that for decades had belonged to private owners or the federal government, and from collecting back rents from the present users. The issue in the Atwell case is whether a federal law, the Boiler Inspection Act, preempts the field of locomotive equipment, and thus bars a state court lawsuit over a railroad worker’s death from lung cancer following prolonged exposure to asbestos while repairing locomotives.
Recommended Citation: Lyle Denniston, Youth Miranda rights at issue (Updated to 11:09 a.m.), SCOTUSblog (Nov. 1, 2010, 10:13 AM), http://www.scotusblog.com/2010/11/youth-miranda-rights-at-issue/