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Supreme Court backs trial judges on juror dismissal decisions

[JURIST] The US Supreme Court [official website; JURIST news archive] handed down decisions in three argued cases Monday, including Uttecht v. Brown [Duke Law case backgrounder] where the Court held that federal courts reviewing claims that a juror was improperly dismissed due to their views on capital punishment "owe deference to the trial court, which is in a superior position to determine the demeanor and qualifications of a potential juror." The Supreme Court reversed the Ninth Circuit's decision [PDF text] in the case. Read the Court's 5-4 opinion [text] per Justice Kennedy, along with a dissent [text] from Justice Stevens, and a second dissent [text] from Justice Breyer. AP has more.

In Safeco Insurance v. Burr [Duke Law case backgrounder; JURIST report], the Court held that initial rates charged for new insurance policies may be considered adverse actions under the Fair Credit Reporting Act [PDF text] that a company can be found to have violated the FCRA for both knowing violations of the law and for reckless disregard of the FCRA requirement that a consumer subjected to "adverse action" based on information contained in their consumer credit report be notified of the adverse action. Read the Court's opinion [text] per Justice Souter, along with a concurrence [text] from Justice Stevens, and a second concurrence [text] from Justice Thomas. AP has more.

In the final decision in an argued case, the Court held in Sole v. Wyner [Duke Law case backgrounder] that a party cannot be awarded attorneys' fees in an action brought under 42 USC 1983 [text] when the party wins a preliminary injunction in the case but does not ultimately win on the merits. The Supreme Court reversed the Eleventh Circuit's decision [PDF text] in the case, ruling that "a final decision on the merits denying permanent injunctive relief ordinarily determines who prevails in the action for purposes of §1988(b). A plaintiff who achieves a transient victory at the threshold of an action can gain no award under that fee-shifting provision if, at the end of the litigation, her initial success is undone and she leaves the courthouse emptyhanded." Read the Court's unanimous opinion [text] per Justice Ginsburg.

The Court also issued a per curiam decision [text] in Erickson v. Pardus, ruling that the US Court of Appeals for the Eleventh Circuit erred in concluding that William Erikson's allegations that a prison doctor's decision to stop his Hepatitis C treatment caused Erikson substantial harm were too conclusory under pleading standards set forth in Federal Rule of Civil Procedure 8(a)(2) [text]. Justice Scalia would have denied the petition for a writ of certiorari and Justice Thomas issued a dissent [text] in the case.

Lastly, Claiborne v. United States [Duke Law case backgrounder; JURIST report] was dismissed [PDF text] as moot because the petitioner in the case died last week. The case involved the federal sentencing guidelines and questioned whether a sentence substantially lower than the minimum suggested by the guidelines could only be justified by extraordinary situations.

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