criminal law

Issues

After was Convicted of a murder that occurred on disputed tribal land, Patrick Murphy asks the Supreme Court to determine if the 1866 territorial boundaries of the Creek Nation tribal land are still in effect today. If the boundaries are in effect, Murphy asserts that his murder conviction must be overturned because it was committed within the Creek Nation boundaries, meaning the Oklahoma state court that convicted him did not have jurisdiction to hear the case.  Oklahoma State Penitentiary Interim Warden Mark Carpenter counters that the Creek Nation reservation has been disestablished and is no longer in effect, arguing that Oklahoma state courts indeed had jurisdiction to prosecute Murphy for the murder. Carpenter contends that giving effect to the territorial boundaries would create taxation and regulatory problems, while Murphy counters that acknowledging the tribal land boundaries would lead to mutually profitable tax agreements and other community benefits such as increased job opportunities and more effective law enforcement.

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This case asks the Supreme Court to decide whether the “right to control” theory of fraud creates a cause of action under the federal wire fraud statute. Under the “right to control” theory, the federal wire fraud statute may be used to punish schemes which intend to deprive a victim of valuable information regarding an economic decision. Ciminelli claims that the “right to control” theory improperly expands rights considered in the fraud statutes and improperly eases the government’s burden of proof. United States maintains that the “right to control” is properly limited to specifically target information deprivation schemes with tangible economic harms and that Ciminelli’s conviction holds even without the “right to control” theory. This case has significant implications for the construction industry, concerns of overcriminalization, and the limit of federal jurisdiction.

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On June 21, 2000, 17-year-old Eric Clark shot and killed Flagstaff, Arizona Police Officer Jeffrey Moritz. Brief for Petitioner at 2. At the time, Clark had been suffering from delusions and hallucinations and had been diagnosed as suffering schizophrenia and psychosis. Id. At trial, he attempted to present evidence of his mental illness in order to negate the mens rea knowledge and intent elements of first degree murder. The government, however, argued successfully that under Arizona's definition of insanity (A.R.S. § 13-502(A)) and State v. Mott, evidence of Clark's mental illness was impermissible to negate the mens rea of the crime. Clark was subsequently convicted of first degree murder. He appeals the conviction, arguing that preventing him from using evidence of his mental disease to negate the mens rea of the crime violates his Due Process rights under the Fourteenth Amendment.

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This case will allow the Supreme Court to clarify the appellate rights of criminal defendants who have pled guilty and subsequently want to challenge the constitutionality of their statute of conviction. Circuit courts have been divided on the subject. Petitioner, Class, argues that the Court should apply the precedent set in Blackledge v. Perry and Menna v. New York to his case by holding that constitutional challenge claims do not challenge a defendant’s factual guilt or dispute whether the government met every burden of proving each element of the crime, and therefore are not precluded by pleading guilty. Respondent, the United States, argues that a constitutional challenge to a defendant’s statute of conviction is inherently waived in a guilty plea as an aspect of his factual guilt unless it is expressly preserved in his plea agreement. With this decision, the Supreme Court will determine the constitutional rights of all criminal defendants who plead guilty and likely impact the role guilty pleas play in United States jurisprudence.

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When Johnnie Corley was arrested for assaulting an officer and interrogated about the robbery of a credit union, he did not confess to a role in the robbery until more than six hours after his arrest. Moreover, Corley did not appear before a magistrate judge until the next day. After the District Court found Corley guilty, the Third Circuit affirmed. Corley is now appealing to the Supreme Court of the United States. His case will determine whether, if there was unreasonable delay in bringing a suspect before a magistrate judge, the suspect's confession is still valid. The Supreme Court's decision will affect suspects' rights and the procedure that police must follow during a confession.

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This case asks the Supreme Court to consider whether an Arizona Rule of Criminal Procedure, which only allows postconviction relief if there has been a significant change in law to make it an adequate and independent state-law ground for the judgment, prevents federal review. Petitioner John Montenegro Cruz claims that the rule cannot apply because it conflicts with the Supreme Court’s precedent requiring the application of settled rules of constitutional law on postconviction review. Cruz also asserts that the rule requires consideration of federal law, and thus that the Supreme Court may review determinations made under it for consistency with federal law. Respondent, the state of Arizona, argues that its Rule prevents federal review because it is premised on a matter of state law, rather than federal law. Arizona asserts that its rule only regulates when a claim may be brought, not the rule to be applied when evaluating the claim.

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Petitioner Michael Currier was charged with burglary, grand larceny, and possession of a firearm as a convicted felon. Currier and the prosecution agreed to sever the charges. At the first trial, a jury acquitted Currier of burglary and grand larceny. At the second trial, in which the prosecution introduced many of the same facts, the jury convicted Currier of possession of a firearm as a convicted felon. Michael Currier argues that issue preclusion bars the state from re-litigating an issue upon which the jury acquitted him in the first trial. Virginia contends that the defendant waived his right to issue preclusion when he consented to severing the criminal charges into successive trials. The Court’s determination on the scope of the Double Jeopardy Clause will have significant consequences for defendants charged with counts requiring evidence of prior criminal records and, more broadly, for national criminal procedure.

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