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SENTENCING

When can a defendant challenge his ACCA sentence on the basis that his prior state convictions were unconstitutional?

Daniels v. United States
Docket No. 99-9136

From: The Ninth Circuit

Case at a Glance

The Armed Career Criminal Act imposes harsh sentences on criminal defendants with three prior violent felony convictions. But what if such a defendant can demonstrate that one or more of his prior convictions were obtained in violation of his constitutional rights? In this case, a lower court refused to entertain such a constitutional challenge. The Supreme Court is asked to determine whether that decision was correct.

• Previewed by Michael O'Hear, an assistant professor at Marquette University Law School in Milwaukee, Wis.

Supreme Court Decision: Click to read decision

Case at a Glance

The federal sentencing guidelines provide that if a federal defendant's prior state-court sentences are “related,” then those cases count as only one prior conviction. But if the prior sentences are deemed “unrelated,” then the defendant may be considered a "career offender," resulting in a much higher sentencing guideline range. In this case, the Supreme Court is asked to resolve a split in the circuits over the standard of review that appellate courts should use when reviewing a trial court's determination that a defendant's prior convictions are "unrelated."

• Previewed by Theresa L. Schulz, an attorney with offices in Lake Elmo, Minn.

Supreme Court Decision: Click to read decision

Case at a Glance

An American father's last hope to keep his foreign-born son in the United States might rest on this equal protection challenge to a federal law that makes it easier for mothers to obtain U.S. citizenship for their children who are born out of wedlock overseas.

• Previewed by Steve Lash, a Maryland lawyer who has written extensively on the U.S. Supreme Court for numerous publications.

Supreme Court Decision: Click to read decision
More information about this case is available in Cases of Interest to the School Community.

Case at a Glance

Wesley Aaron Shafer, Jr., was convicted of murdering a convenience store clerk during a failed robbery attempt. Once his sentencing jury found an aggravating statutory factor in his case, it had only two choices: it could sentence him to death, or it could sentence him to life imprisonment. After the trial judge refused to instruct the jury that, under state law, Shafer would never be released from prison if he received a life sentence, the jury sentenced him to death.

• Previewed by David L. Hudson, Jr., a staff attorney with the First Amendment Center at Vanderbilt University in Nashville, Tenn.

Supreme Court Decision: Click to read decision

Case at a Glance

Under the Federal Rules of Civil Procedure, a federal trial judge’s decision to grant a new trial is widely discretionary. The Seventh Amendment preserves the right to a jury trial in actions at law, and prohibits judicial re-examination of any fact tried by a jury. Some federal courts hold that the Seventh Amendment does not restrict a trial judge’s discretion, but that it does restrict appellate review to an "abuse of discretion" standard; others apply a “more sweeping” appellate inquiry.

• Previewed by Mary Phelan D’Isa, a professor of law at Thomas M. Cooley Law School in Lansing, Mich.

Supreme Court Decision: Click to read order dismissing case

Case at a Glance

The issue in this case is whether Exemption 5 of the Freedom of Information Act protects confidential documents exchanged between the Department of the Interior, Bureau of Indian Affairs, and certain Indian tribes, in furtherance of the Department's trust responsibility to manage tribal water rights. The United States argues that release of the seven documents at issue in this case would impair the special trust relationship between the United States and Indian tribes.

• Previewed by Judith V. Royster, a professor of law and co-director of the Native American Law Center at the University of Tulsa in Tulsa, Okla.

Supreme Court Decision: Click to read decision

Case at a Glance

Title VI of the Civil Rights Act of 1964 prohibits any recipient of federal funds from discriminating on the basis of race, color, or national origin in any federally funded program. In this case, the Supreme Court is asked whether individuals may bring a private action under Title VI against the Director of the Alabama Department of Public Safety under the theory of "disparate impact" because the Department requires driver’s license applicants to take their examinations in English.

• Previewed by Jay E. Grenig, a professor of law at Marquette University Law School in Milwaukee, Wis., and co-author of West’s Federal Jury Practice and Instructions.

Supreme Court Decision: Click to read decision
More information about this case is available in Cases of Interest to the School Community.

Case at a Glance

The Ninth Circuit ruled that Montana State Prison violated an inmate's First Amendment rights when it punished him for sending another inmate a letter containing legal advice. The prison officials say this ruling carved out a dangerous “legal advice” exception to the prison's rules that will make it much harder for state prison officials to carry out their duties. The inmate responds that if this inmate can be punished, other inmates will be chilled from speaking out about prison abuses.

• Previewed by David L. Hudson, Jr., a staff attorney with the First Amendment Center at Vanderbilt University in Nashville, Tenn.

Supreme Court Decision: Click to read decision

Case at a Glance

A defendant charged with burglary of a house later confessed to the murder of two people who had been in the house at the time of the burglary. Although the defendant had obtained counsel on the burglary charge, his attorney was not present when police questioned him about the murders. The trial judge allowed the confession into evidence. In what could be one of this term’s most significant cases, the Court is asked to decide whether the resulting capital murder conviction was properly reversed on Sixth Amendment grounds.

• Previewed by Alan Raphael, an associate professor at Loyola University Chicago School of Law and the author of a recently published casebook, Criminal Procedure (Lupus 1999).

Supreme Court Decision: Click to read decision

Case at a Glance

The Americans with Disabilities Act prohibits discrimination based on disability. This case represents the first attempt by a disabled athlete to use the ADA to require a professional sports association to modify its rules to accommodate him. The Supreme Court must decide whether the Act applies and, if so, whether the requested modification is reasonable or a fundamental alteration of the game.

• Previewed by Phyllis Coleman, a professor of law at Nova Southeastern University in Fort Lauderdale, Fla., and the co-author of Sports Law: Cases and Materials (West 1999).

Supreme Court Decision: Click to read decision

Read the accompanying full-text article from Preview for this case.

Case at a Glance

The D’Oench doctrine is the federal common-law concept that a party is precluded from asserting a claim or defense against the FDIC if that party has lent itself to a secret or side agreement that deceived, or would tend to deceive, creditors of the banking authority. In 1989, Congress enacted the Financial Institutions Reform, Recovery and Enforcement Act, which codified much of the D’Oench doctrine. Now the Supreme Court must decide whether the common-law D’Oench doctrine has been displaced by the congressional enactment.

• Previewed by Ralph C. Anzivino, a professor of law at Marquette University Law School in Milwaukee, Wis.

Supreme Court Decision: Dismissed Jan. 12, 2001