Gonzalez v. Trevino

Docket: 22-1025

Opinion Date: June 20, 2024

Areas of Law: Civil Procedure, Civil Rights

Sylvia Gonzalez, a city council member in Castle Hills, Texas, was involved in a campaign to remove the city manager, Ryan Rapelye. She gathered signatures for a petition, which was introduced at a city council meeting. After the meeting, the mayor, Edward Trevino, II, asked Gonzalez for the petition. Gonzalez found the petition in her binder, which she claimed was unintentional. Trevino reported this to the city police, leading to an investigation. A private attorney concluded that Gonzalez likely violated a Texas anti-tampering statute, leading to her arrest. The charges were later dismissed, but Gonzalez claimed this incident led her to step away from politics.

Gonzalez filed a lawsuit under 42 U.S.C. §1983 in Federal District Court against Trevino, the police chief, and the private attorney, alleging that her arrest was in retaliation for her role in the petition and violated her First Amendment rights. The District Court denied the defendants' motion to dismiss the complaint, finding that it fell within an exception to the no-probable-cause rule recognized in Nieves. However, the Fifth Circuit reversed this decision, stating that Gonzalez's claim could only fall within the Nieves exception if she provided "comparative evidence" of similarly situated individuals who engaged in the same criminal conduct but were not arrested.

The Supreme Court of the United States disagreed with the Fifth Circuit's interpretation of the Nieves exception. The Court found that the Fifth Circuit's requirement for specific comparator evidence was overly restrictive. The Court clarified that to fall within the Nieves exception, a plaintiff must produce objective evidence to prove that his arrest occurred in circumstances where officers typically exercise their discretion not to make arrests. The Court held that Gonzalez's evidence, showing that no one had ever been arrested for similar conduct, was a permissible type of evidence. The Court vacated the Fifth Circuit's judgment and remanded the case for further proceedings.

Chiaverini v. City of Napoleon

Docket: 23-50

Opinion Date: June 20, 2024

Judge: Elena Kagan

Areas of Law: Civil Rights, Criminal Law

This case involves a dispute between Jascha Chiaverini, a jewelry store owner, and police officers from Napoleon, Ohio. The officers charged Chiaverini with three crimes: receiving stolen property, dealing in precious metals without a license, both misdemeanors, and money laundering, a felony. After obtaining a warrant, the police arrested Chiaverini and detained him for three days. However, county prosecutors later dropped the case. Chiaverini, believing that his arrest and detention were unjustified, sued the officers, alleging a Fourth Amendment malicious-prosecution claim under 42 U.S.C. §1983. To win this claim, he had to show that the officers brought criminal charges against him without probable cause, leading to an unreasonable seizure of his person.

The District Court granted summary judgment to the officers, and the Court of Appeals for the Sixth Circuit affirmed. The Court of Appeals held that Chiaverini’s prosecution was supported by probable cause. In its decision, the court did not address whether the officers had probable cause to bring the money-laundering charge. The court believed that there was clearly probable cause to charge Chiaverini with the two misdemeanors. As long as one charge was supported by probable cause, it thought, a malicious-prosecution claim based on any other charge must fail.

The Supreme Court of the United States held that the presence of probable cause for one charge in a criminal proceeding does not categorically defeat a Fourth Amendment malicious-prosecution claim relating to another, baseless charge. The parties, and the United States as amicus curiae, all agreed with this conclusion, which follows from both the Fourth Amendment and traditional common-law practice. The Supreme Court vacated the judgment of the Court of Appeals and remanded the case for further proceedings consistent with its opinion.

Moore v. United States

Docket: 22-800

Opinion Date: June 20, 2024

Judge: Brett M. Kavanaugh

Areas of Law: Constitutional Law, Tax Law

The case involves Charles and Kathleen Moore, who invested in an American-controlled foreign corporation, KisanKraft. From 2006 to 2017, KisanKraft generated substantial income but did not distribute it to its American shareholders. At the end of the 2017 tax year, the application of the new Mandatory Repatriation Tax (MRT) resulted in a tax bill of $14,729 on the Moores’ pro rata share of KisanKraft’s accumulated income from 2006 to 2017. The Moores paid the tax and then sued for a refund, claiming that the MRT violated the Direct Tax Clause of the Constitution because it was an unapportioned direct tax on their shares of KisanKraft stock. The District Court dismissed the suit, and the Ninth Circuit affirmed.

The Supreme Court of the United States affirmed the Ninth Circuit's decision. The Court held that the MRT, which attributes the realized and undistributed income of an American-controlled foreign corporation to the entity’s American shareholders, and then taxes the American shareholders on their portions of that income, does not exceed Congress’s constitutional authority. The Court's decision was based on the broad power of Congress to lay and collect taxes, which includes direct taxes—those imposed on persons or property—and indirect taxes—those imposed on activities or transactions. The Court also noted that taxes on income are indirect taxes, and the Sixteenth Amendment confirms that taxes on income need not be apportioned. The Court's holding is narrow and limited to entities treated as pass-throughs.

Diaz v. United States

Docket: 23-14

Opinion Date: June 20, 2024

Judge: Clarence Thomas

Areas of Law: Criminal Law

Delilah Diaz was stopped at a U.S.-Mexico border port of entry, where border patrol officers discovered over 54 pounds of methamphetamine hidden in the car she was driving. Diaz was charged with importing methamphetamine, a charge that required the government to prove that Diaz knowingly transported the drugs. Diaz claimed she was unaware of the drugs in the car. To counter this claim, the government planned to call an expert witness, Homeland Security Investigations Special Agent Andrew Flood, to testify that drug traffickers generally do not entrust large quantities of drugs to people who are unaware they are transporting them. Diaz objected to this testimony under Federal Rule of Evidence 704(b), which prohibits an expert witness from stating an opinion about whether the defendant did or did not have a mental state or condition that constitutes an element of the crime charged or of a defense. The court ruled that Agent Flood could testify that most couriers know they are transporting drugs. Diaz was found guilty and appealed, challenging Agent Flood’s testimony under Rule 704(b).

The Court of Appeals held that because Agent Flood did not explicitly opine that Diaz knowingly transported methamphetamine, his testimony did not violate Rule 704(b). Diaz appealed this decision to the Supreme Court of the United States.

The Supreme Court affirmed the decision of the Court of Appeals. The Court held that expert testimony that "most people" in a group have a particular mental state is not an opinion about "the defendant" and thus does not violate Rule 704(b). The Court reasoned that Agent Flood did not express an opinion about whether Diaz herself knowingly transported methamphetamine. Instead, he testified about the knowledge of most drug couriers, which does not necessarily describe Diaz’s mental state. The Court concluded that because Agent Flood did not express an opinion about whether Diaz herself knowingly transported methamphetamine, his testimony did not violate Rule 704(b).