February 21, 2012 United States Supreme Court opinions

Marmet Health Care Center, Inc. v Brown

The West Virginia Supreme Court of Appeals ruled arbitration clauses involving wrongful death and personal injury claims in nursing home admissions contracts unenforceable. The United States Supreme Court reversed holding the Federal Arbitration Act applied and preempted the policy based West Virginia rule. The cases were remanded for evaluation under generally applicable contract principals.

Wetzel v Lambert

Pennsylvania state courts found certain statements contained in a police activity sheet were merely cumulative impeachment materials and denied relief on defendant’s Brady claim. The district court denied habeas, but, Third Circuit granted habeas rejecting the cumulative impeachment rationale. The United States Supreme Court, 6-3, reversed finding that the Pennsylvania state courts also found the statements ambiguous and remanded the case for evaluation of that conclusion. The dissent would have found the state courts did not hold the statements were ambiguous and affirmed.

Howes v Fields

A Michigan inmate was taken from his cell to a conference room and questioned by deputies about alleged sexual abuse of a minor. No Miranda warnings were given and the inmate was told he could leave at any time. The inmate confessed to the sexual abuse. Michigan state courts rejected the inmate’s Miranda claim holding he was not in custody during the interrogation. The federal district court and Sixth Circuit held the removal of the inmate from the general populations and questioning about events outside the prison per se violated Miranda. The United States Supreme Court, 6-3, held this categorical rule was not well established for habeas review purposes and, in any event, was wrong as the elements identified did not identify a setting of coercion which Miranda protects against. Further, the Court also found that on the specific facts of this interrogation, the inmate was not in custody and reversed the grant of habeas. The dissent would have found the interrogation violated Miranda and affirmed.

Kawashima v Holder

A resident alien married couple were convicted of making false tax returns. An immigration judge found that these convictions were for fraud or deceit, were aggravated felonies for immigration purposes and held the couple could be deported. The Ninth Circuit affirmed. The United States Supreme Court held, 6-3, the tax return crimes were crimes involving fraud or deceit and affirmed.  The dissent noted the relevant statute explicitly identified tax evasion as an aggravated felony and would have reversed on the grounds that lesser tax offenses were not covered by the fraud or deceit provisions.

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