[JURIST] The US Supreme Court [official website; JURIST news archive] on Tuesday dismissed as improvidently granted the writ of certiorari in Philip Morris USA v. Williams [Cornell LII backgrounder; JURIST report]. The Court had originally granted certiorari to consider for a third time a $79.5 million punitive damages verdict against tobacco company Philip Morris USA [corporate website]. The Court previously ruled [JURIST report] that the punitive damages award based "in part on [a jury's] desire to punish the defendant for harming persons who are not before the court" amounts to an unconstitutional taking of property without due process. On remand, the Supreme Court of Oregon [official website] again upheld [opinion text] the verdict, finding that it did not need to reach the federal constitutional issue if there was "an independent and adequate" basis in state law for upholding the verdict.
The Court released two other opinions Tuesday. In Hawaii v. Office of Hawaiian Affairs [Cornell LII backgrounder; JURIST report], the Court ruled [opinion, PDF] unanimously that the state of Hawaii is not precluded from transferring 1.2 million acres of land ceded by the former Hawaiian monarchy, pending a political settlement with Native Hawaiians [advocacy website]. The Office of Hawaiian Affairs (OHA) [official website] had won an injunction [opinion, PDF] from the Hawaii Supreme Court barring the state from selling any ceded lands until claims to the land are settled. The state of Hawaii argued that the 1993 Apology Resolution [text] passed by Congress was not intended to limit the state's ability to manage its land. Reversing the lower court ruling, Justice Samuel Alito wrote:
Here, the State Supreme Court incorrectly held that Congress, by adopting the Apology Resolution, took away from the citizens of Hawaii the authority to resolve an issue that is of great importance to the people of the State. Respondents defend that decision by arguing that they have both state-law property rights in the land in question and "broader moral and political claims for compensation for the wrongs of the past." But we have no authority to decide questions of Hawaiian law or to provide redress for past wrongs except as provided for by federal law. [citations omitted]The Hawaiian monarchy was overthrown [historical timeline] in 1893, and the US annexed its territory five years later. Hawaii was admitted as a state in 1959.
In a second unanimous decision, the Court ruled [opinion, PDF] in Rivera v. Illinois [Cornell LII backgrounder; JURIST report] that an Illinois trial court did not err in refusing to grant a defense counsel's peremptory challenge to dismiss from a murder trial a juror who worked at a hospital that treated a larger number of gunshot wounds. After raising the challenge during jury selection, the trial court overruled the challenge and seated the juror. At the start of the trial, defense counsel again challenged the juror in juror's presence. That challenge was again denied, and the juror was appointed foreperson of the jury, with knowledge that the defendant's counsel had attempted to remove her from the jury. Rivera was found guilty of murder, and sentenced to 85 years in prison. Delivering the opinion of the Court, Justice Ruth Bader Ginsburg wrote:
Nothing in these decisions suggests that federal law renders state-court judgments void whenever there is a state-law defect in a tribunal's composition. Absent a federal constitutional violation, States retain the prerogative to decide whether such errors deprive a tribunal of its lawful authority and thus require automatic reversal. States are free to decide, as a matter of state law, that a trial court's mistaken denial of a peremptory challenge is reversible error per se. Or they may conclude, as the Supreme Court of Illinois implicitly did here, that the improper seating of a competent and unbiased juror does not convert the jury into an ultra vires tribunal; therefore the error could rank as harmless under state law.The ruling affirmed the decision [opinion, PDF] of the Illinois Supreme Court, upholding Rivera's conviction.
In sum, Rivera received precisely what due process required: a fair trial before an impartial and properly instructed jury, which found him guilty of every element of the charged offense.