United States v. Johnson: The Limits of Protective Sweeps

Blanche v. Lau: Burdens of Proof for Reentering Residents

This Supreme Court case, Blanche v. Lau, addresses whether border officers must possess clear and convincing evidence of a crime before treating a lawful permanent resident as an applicant for admission. Under the Immigration and Nationality Act, residents returning from abroad are typically considered already admitted, but an exception exists for those who have committed certain offenses. The Court ruled that the government is not required to prove the commission of a crime at the moment of reentry. Instead, the legal burden may be satisfied during subsequent removal proceedings using evidence like a guilty plea. Consequently, the majority held that a pending criminal charge is sufficient for officials to pause a resident's formal admission status at the border. The dissenting justices argued that this sequence undermines the legal security of green card holders by allowing the government to justify status demotions with post-entry evidence.

McCarthy v. Hernandez: Limiting AEDPA Habeas Relief over Seibert Instructions

This Supreme Court opinion reverses a lower court's decision to grant habeas corpus relief to Pedro Hernandez, who was convicted for the 1979 murder of Etan Patz. The Second Circuit had previously ruled that the trial judge erred by failing to instruct the jury on legal attenuation regarding the defendant's multiple confessions. However, the Supreme Court determined that the Antiterrorism and Effective Death Penalty Act (AEDPA) restricts federal courts from overturning state convictions unless a "clearly established" federal law was violated. The justices clarified that the precedent in Missouri v. Seibert governs judicial decisions on evidence admissibility rather than jury instructions. Since the New York state courts followed their own procedural laws regarding what juries must consider, the federal appellate court exceeded its authority by imposing a new constitutional requirement. Ultimately, the Court maintains that there is no federal mandate requiring a jury to evaluate the voluntariness or legality of confessions once a judge has admitted them into evidence.

Rey v. LCMC Health Care Partners

This episode details a ruling from the United States Court of Appeals for the Fifth Circuit regarding a lawsuit over helicopter noise and vibrations at a New Orleans hospital. A group of local residents sought a mandatory injunction to force the hospital to relocate its helipad, but the district court found that federal regulations preempted such a request. The plaintiffs attempted to appeal this decision immediately, claiming the ruling was an interlocutory order that effectively refused an injunction. However, the appellate court dismissed the appeal, concluding it lacked jurisdiction because the plaintiffs failed to prove the decision would cause irreparable harm before a final judgment. The court emphasized that immediate appeals are generally reserved for preliminary injunctions rather than the permanent relief sought in this nuisance case.

The Juneau Group v. Vendera: LLC Capacity and Sealing Orders

This case from the Fifth Circuit Court of Appeals details a dispute involving The Juneau Group, LLC, which sued several entities for misappropriation of trade secrets after a failed asset acquisition. The court primarily addressed whether the LLC had the legal capacity to sue, ultimately affirming that the case must be dismissed because the entity was voluntarily dissolved before the lawsuit began. Furthermore, the court refused to certify a question to the Louisiana Supreme Court, concluding that state law does not allow for retroactive reinstatement to save claims known prior to dissolution. The judges also upheld the denial of attorneys' fees, noting that the defendants could have avoided significant costs through a simple public-records search. Finally, the appellate court vacated a sealing order regarding the member's mental health records, remanding the issue because the lower court failed to balance the presumption of transparency against privacy interests.

Preemption of Texas Resident Tuition Rates for Illegal Aliens

This federal court opinion focuses on a legal battle over Texas laws that allow undocumented students to qualify for in-state tuition rates. The United States government sued Texas, arguing that federal law preempts these state rules because they grant benefits to noncitizens that are not equally available to all U.S. citizens. Although Texas quickly settled the case, several groups attempted to intervene to defend the state laws, but the court denied their request, labeling their defense legally futile. The majority opinion concludes that because residency is the but-for cause of the tuition discount, the practice violates federal prohibitions against preferential treatment for those not lawfully present. Conversely, a dissenting judge argues the federal statute might be unconstitutional under the Tenth Amendment for improperly commanding state governments.