2014 term per curiam opinions of the Supreme Court of the United States

The Supreme Court of the United States has handed down four per curiam opinions during its 2014 term, which began October 6, 2014 and will conclude October 4, 2015.

Because per curiam decisions are issued from the Court as an institution, these opinions all lack the attribution of authorship or joining votes to specific justices. All justices on the Court at the time the decision was handed down are assumed to have participated and concurred unless otherwise noted.

Court membership

Chief Justice: John Roberts

Associate Justices: Antonin Scalia, Anthony Kennedy, Clarence Thomas, Ruth Bader Ginsburg, Stephen Breyer, Samuel Alito, Sonia Sotomayor, Elena Kagan

Lopez v. Smith

Full case name: Raul Lopez, Warden v. Martin Vernis Smith
Citations: 574 U.S. ___;
Prior history: Petition granted, C.D. Cal.; aff'd, 731 F. 3d 859 (9th Cir. 2013)
Laws applied:

U.S. const. amend. VI, XIV; 8 U.S.C. § 2254(d) (Antiterrorism and Effective Death Penalty Act of 1996)


Full text of the opinion: official slip opinion

574 U.S. ___
Decided October 6, 2014.
Ninth Circuit reversed and remanded. Under the Antiterrorism and Effective Death Penalty Act of 1996, if a state prisoner claims that a state court misapplied federal law, a federal court of appeals may only grant habeas relief if the state court's decision was "contrary to, or involved an unreasonable application of, clearly established Federal law, as determined by the Supreme Court", not as determined by that federal court's own precedent.


Johnson v. City of Shelby

Full case name: Tracey L. Johnson, et al. v. City of Shelby, Mississippi
Citations: 574 U.S. ___;
Prior history: Summary judgment granted, No. 2:10-cv-00036, N.D. Miss., Mar. 28, 2012; aff'd, 743 F. 3d 59 (5th Cir. 2013)
Laws applied:

Fed. R. Civ. P. 8(a)(2); 42 U.S.C. § 1983


Full text of the opinion: official slip opinion

574 U.S. ___
Decided November 10, 2014.
The lower court erred granted summary judgment against the plaintiffs for their failure to invoke 42 U.S.C. §1983 in their complaint. A complaint must only contain "a short and plain statement of the claim showing that the pleader is entitled to relief," and cannot be dismissed for an "imperfect statement of the legal theory supporting the claim asserted." There is also no heightened pleading standard for claims brought under section 1983 that would require that statute to be expressly invoked. Fifth Circuit reversed and remanded

Carroll v. Carman

Full case name: Jeremy Carroll v. Andrew Carman, et ux.
Citations: 574 U.S. ___;
Prior history: Judgment for defendants, No. 3:10-cv-01013, M.D. Penn., Apr. 10, 2013; rev'd in part, 749 F. 3d 192 (3d Cir. 2014)
Laws applied:

U.S. Const. amend. IV; 42 U.S.C. § 1983


Full text of the opinion: official slip opinion

574 U.S. ___
Decided November 10, 2014.
It is not clearly established constitutional law that a police officer must begin at a residence's front door to employ the "knock and talk" exception to the warrant requirement. The lower court therefore erred in ruling that the defendants were not entitled to qualified immunity, in a lawsuit alleging they unlawfully entered the plaintiffs' property in violation of the Fourth Amendment by going into their backyard and onto their deck without a warrant. Third Circuit reversed and remanded.

Glebe v. Frost

Full case name: Patrick Glebe, Superintendent, Stafford Creek Corrections Center v. Joshua James Frost
Citations: 574 U.S. ___;
Prior history: Magistrate report and recommendation that petition be denied, Frost v. Van Boening, No. C09-725-TSZ-BAT, 2010 WL 5775657 (W.D. Wash. Oct. 5, 2010); report and recommendation adopted, No. C09-725-TSZ, 2011 WL 486198 (W.D. Wash. Feb. 4, 2011); aff'd, 692 F. 3d 924 (9th Cir. 2012); rev'd, en banc, 757 F. 3d 910 (9th Cir. 2014)
Laws applied:

U.S. Const. amends. VI, XIV, 8 U.S.C. § 2254(d) (Antiterrorism and Effective Death Penalty Act of 1996)


Full text of the opinion: official slip opinion

574 U.S. ___
Decided November 17, 2014.
Ninth Circuit reversed and remanded. Under the Antiterrorism and Effective Death Penalty Act of 1996, a Court of Appeals may only grant habeas corpus if a state's Supreme Court decision was "contrary to, or involved an unreasonable application of clearly established federal law as determined by the Supreme Court of the United States" or was "based on an unreasonable determination of the facts in light of the evidence presented in the State court proceeding". The Ninth Circuit instead erred in granting relief by misapplying the Herring v. United States ruling, which involved a complete denial of a summation instead of, as in this case, a limitation on it.

References