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Supreme Court rules on deportation, employment retaliation cases

[JURIST] The US Supreme Court [official website; JURIST news archive] handed down four decisions Thursday, including Fernandez-Vargas v. Gonzales [Duke Law case backgrounder; JURIST report], where the Court held that a federal immigration law authorizing deportation can be applied to illegal immigrants who entered the country before its enactment. Mexican immigrant Humberto Fernandez-Vargas, who entered the US in the 1970s and after several deportations lived in the US continuously since 1982, was arrested by US immigration officials on a 1981 deportation warrant while he was applying for lawful permanent resident status in 2003. A provision [text] of the Illegal Immigration Reform and Immigrant Responsibility Act of 1996 amended the Immigration and Nationality Act to authorize prior warrants to be reinstated. The Court affirmed the Tenth Circuit's decision [text] and held that the provision "applies to those who reentered the United States before IIRIRA's effective date and does not retroactively affect any right of, or impose any burden on, the continuing violator of the INA now before this Court." Read the Court's 8-1 majority opinion [text] per Justice Souter, along with a dissent [text] from Justice Stevens. AP has more.

In Burlington Northern & Santa Fe Railroad v. White [Duke Law case backgrounder; JURIST report], the Court held that in order to bring an employment retaliation claim under Title VII of the 1964 Civil Rights Act [text; EEOC backgrounder], an employee does not need to have suffered an ultimate employment decision - denial of promotion or termination, for example. Instead, an employee claiming to have suffered retaliation for complaining about discrimination under Title VII can show retaliation by reassignment to a less attractive job or temporary suspension without pay. The Court affirmed the Sixth Circuit's decision [text] in the case and held that a retaliation plaintiff must "show that the challenged action 'well might have "dissuaded a reasonable worker from making or supporting a charge of discrimination."'" Read the Court's opinion [text] per Justice Breyer, along with a concurrence [text] from Justice Alito. AP has more.

In Dixon v. US [Duke Law case backgrounder; JURIST report], the Court held that jury instructions requiring a criminal defendant to prove a duress defense by a preponderance of the evidence do not violate due process. Dixon was charged with firearms offenses and at trial raised battered woman's syndrome [Wikipedia backgrounder] as a defense. The trial court instructed the jury that Dixon bore the burden of persuasion and the US Court of Appeals for the Fifth Circuit affirmed her conviction [opinion, PDF], ruling that duress is an affirmative defense, and the Court upheld that decision. Read the Court's 7-2 majority opinion [text] per Justice Stevens, along with a concurrence [text] from Justice Kennedy, a second concurrence [text] from Justice Alito, who was joined by Justice Scalia, and a dissent [text] from Justice Breyer, who was joined by Justice Souter. AP has more.

In Woodford v. Ngo [Duke Law case backgrounder], the Court held that the Prison Litigation Reform Act [text; ACLU backgrounder], which requires prisoners to properly exhaust all administrative remedies before filing a complaint in court, bars an inmate who filed an untimely administrative appeal from suing in federal court. A California inmate, Viet Mike Ngo, tried to file a complaint alleging a First Amendment violation with a federal district court after the penal system originally rejected his grievance due to lateness. The Court reversed the Ninth Circuit's decision [PDF text] and ruled that all procedural rules, including filing deadlines, must be satisfied in order for an inmate to exhaust all administrative remedies. Read the Court's 6-3 majority opinion [text] per Justice Alito, along with a concurrence [text] from Justice Breyer and a dissent [text] from Justice Stevens, who was joined by Justices Souter and Ginsburg. AP has more.

Finally, in a one-sentence certiorari ruling, the Court dismissed 5-3 the application for a writ in Laboratory Corp. of America v. Metabolite Laboratories [Duke Law case backgrounder; JURIST report] as "improvidently granted." When the Court heard arguments in the case in March it considered whether a patent on a two-step technique used to measure Vitamin B deficiencies allows its owners to monopolize an unpatentable scientific principle or natural phenomenon. Justice Breyer filed a dissent [PDF text] and was joined by Justices Stevens and Souter. Chief Justice Roberts took no part in the consideration or decision of the case. AP has more.

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