The US Supreme Court [official website; JURIST news archive] on Monday granted certiorari [order list, PDF] in five cases. In Williamson v. Mazda Motor of America [docket; cert. petition, PDF], the court granted a limited petition to decide whether a federal minimum safety standard [text], which authorizes automobile manufacturers to install a lap-only seat belt at the inboard seating positions of a vehicle, preempts a state tort action alleging that the manufacturer should have installed a lap and shoulder belt in one of those seating positions. A California state appeals court [official website] held [opinion, PDF] that a state action was preempted by Federal Motor Vehicle Safety Standard No. 208 [text], which requires lap and shoulder seat belt assemblies only for outboard seating. Petitioners claim that Mazda [corporate website] had a duty to warn of safety risks associated with lap only seat belts under Wyeth v. Levine [opinion, PDF; JURIST report], in which the Supreme Court ruled that federal approval of labels giving warnings about effects of drugs does not bar lawsuits under state law claiming inadequate warnings of a health risk.
The court also granted a limited petition in Sossamon v. Texas [docket; cert. petition, PDF] to decide whether an individual may sue a state or state official in his official capacity for damages for violations of the Religious Land Use and Institutionalized Persons Act [42 USC s. 2000cc text], which grants prisoners permission to obtain injunctive and declaratory relief against the government when it imposes a substantial burden on the religious exercise of a inmate. The US Court of Appeals for the Fifth Circuit reversed [opinion, PDF] a grant of summary judgment in favor of Texas and ordered further proceedings to determine if Texas had been exceeded its bounds under the act by prohibiting Sossamon to use the prison chapel for Christian worship, even though it was available for other uses.
The court granted certiorari to another federal preemption case on Monday in AT&T Mobility v. Concepcion [docket; cert. petition, PDF]. The court will decide whether the Federal Arbitration Act (FAA) [text], which provides for judicial facilitation of private dispute resolution through arbitration when the transaction involves interstate commerce, preempts states from enforcing alternate solutions when arbitration clauses are considered unconscionable. The US Court of Appeals for the Ninth Circuit held [opinion, PDF] that the FAA does not preempt a California unconscionability law, which allowed a class action against AT&T mobile despite a contractual clause prohibiting such proceedings.
In Arizona Christian School Tuition Organization v. Winn [docket; cert. petition, PDF] and Garriott v. Winn [docket; cert. petition, PDF], the court granted a consolidated petition, allowing one hour for oral argument. The court will determine the constitutionality of an Arizona tax credit for donations to organizations that provide scholarships at private schools, which allows scholarships funded by religious organizations to be granted only to students attending parochial schools. The US Court of Appeals for the Ninth Circuit held [opinion, PDF] that the taxpayers had standing to challenge the constitutionality of the law and allowed the claim to proceed. The outcome will determine if tax credit program unconstitutionally endorses or advances religion simply because taxpayers choose to direct more contributions to religious organization than nonreligious ones.
In Skinner v. Switzer [docket; cert. petition, PDF], the court will decide whether a convicted prisoner seeking access to biological evidence for DNA testing may assert a civil rights claim under Section 1983 [text] or if such a claim is cognizable only under a writ of habeas corpus. The US Court of Appeals for the Fifth Circuit affirmed [opinion, PDF] a district court decision to dismiss Skinner's s. 1983 claim seeking access to DNA evidence that may prove his innocence in the murders for which he is now sentenced to death, stating that relief could only be sought through habeas corpus. The Supreme Court court also granted a stay of execution until the case is decided.
The court dismissed [opinion, PDF] a writ of certiorari as improvidently granted in Robertson v. US ex rel. Watson [docket; JURIST report], which challenged the constitutionality of a District of Columbia law under which a private party can bring an action for criminal contempt. The decision included a lengthy dissent from Chief Justice Roberts joined by Justices Antonin Scalia, Anthony Kennedy, and Sonia Sotomayor, maintaining that a criminal action can only be brought against a defendant by society as a whole, and therefore the lower court erred in its judgment upholding the law.
Also Monday, the Supreme Court delivered a per curiam opinion for a summary reversal in the capital case of Jefferson v. Upton [docket]. The court reversed and remanded the judgment of the US Court of Appeals for the Eleventh Circuit, which held that ineffective council defenses under habeas claims are subject to a higher standard than the normative "strong presumption of correctness" standard. The court's opinion is its twelfth summary reversal this session.