[JURIST] The US Supreme Court [official website; JURIST news archive] handed down decisions in two cases Monday, including Carey v. Musladin [Duke Law case backgrounder; JURIST report], where the Court held that a federal appeals court improperly overturned a state court ruling allowing a murder victim's family to wear buttons depicting the victim's face during a criminal trial. The US Court of Appeals for the Ninth Circuit vacated Mathew Musladin's 32-year prison sentence for first-degree murder, asserting that the buttons deprived Musladin, who pleaded self-defense, of a fair trial by tacitly indicating that he acted as the instigator in the underlying shooting. During trial, Musladin's lawyer requested the judge ban the buttons, which family members wore in plain sight of the jury, and the Ninth Circuit ruled [text, PDF] that the buttons created an outside influence that impermissibly affected the jury and his right to a fair trial. The Supreme Court ruled that the Ninth Circuit exceeded its authority under 28 USC 2254(d)(1) [text] by finding that the state court's decision "was contrary to, or involved an unreasonable application of, clearly established Federal law." The Court reasoned that:
In contrast to state-sponsored courtroom practices, the effect on a defendant's fair-trial rights of the spectator conduct to which Musladin objects is an open question in this Court's jurisprudence. This Court has never addressed a claim that such private-actor courtroom conduct was so inherently prejudicial that it deprived a defendant of a fair trial. And although the Court articulated the test for inherent prejudice that applies to state conduct in Williams and Flynn, we have never applied that test to spectators' conduct. Indeed, part of that test asking whether the practices furthered an essential state interest suggests that those cases apply only to state-sponsored practices.Read the Court's majority opinion [text] per Justice Thomas, along with a concurrence [text] from Justice Stevens, a concurrence [text] from Justice Kennedy, and a third concurrence [text] from Justice Souter. AP has more.
Reflecting the lack of guidance from this Court, lower courts have diverged widely in their treatment of defendants' spectator-conduct claims....
Given the lack of holdings from this Court regarding the potentially prejudicial effect of spectators' courtroom conduct of the kind involved here, it cannot be said that the state court "unreasonabl[y] appli[ed] clearly established Federal law."
In BP America Production Co. v. Watson [Duke Law case backgrounder; JURIST report], the Court held that a six-year statute of limitations [28 USC 2415(a) text] on lawsuits to recover damages does not apply to agency enforcement actions. BP America sued the US Department of the Interior to prevent the Minerals Management Service (MMS), the DOI agency that manages natural gas, oil and other mineral resources, from collecting methane gas royalties that were more than six years old. BP America appealed the US Court of Appeals for the District of Columbia Circuit decision [opinion, PDF] which affirmed a district court ruling that the statute of limitations does not apply to MMS's administrative order. The Supreme Court held that the statute of limitations "applies only to court actions and not to the administrative proceedings involved in this case." Read the Court's 7-0 unanimous opinion [text] per Justice Alito. Chief Justice Roberts and Justice Breyer did not participate in this case. AP has more. SCOTUSblog has additional coverage.