United States
Supreme Court
News
Willamette Law Online - Willamette
University
College of
Law
The
United States Supreme Court has
issued the
following
opinions:
DECISIONS
(1) CRIMINAL PROCEDURE:
When an
officer runs a
license plate
and learns
that the owner
has a revoked
license—absent
knowledge of
any
contradictory
facts—it is
reasonable for
the officer to
infer that the
driver is also
the owner of
the vehicle,
and the
traffic stop
is justified.
[Read
Summary Online]
(2) ELECTION LAW: The
application
for stay
presented to
Justice
Kavanaugh and
by him
referred to
the Court is
granted. The
District
Court’s order
granting a
preliminary
injunction is
stayed to the
extent it
requires the
State to count
absentee
ballots
postmarked
after April 7,
2020. [Read
Summary Online]
(3) EMPLOYMENT LAW: The
plain language
of the Age
Discrimination
in Employment
Act of 1967
shows that age
need not be
the but-for
cause of a
personnel
action for
there to be a
violation of
29 U.S.C. §
633a(a). [Read
Summary Online]
DECISIONS
Date Filed: April 6,
2020
Case #: 18–556
THOMAS, J.,
delivered the
opinion of the
Court, in
which ROBERTS,
C. J., and
GINSBURG,
BREYER, ALITO,
KAGAN,
GORSUCH, and
KAVANAUGH,
JJ., joined.
KAGAN, J.,
filed a
concurring
opinion, in
which
GINSBURG, J.,
joined.
SOTOMAYOR, J.,
filed a
dissenting
opinion.
Full Text
Opinion: https://www.supremecourt.gov/opinions/19pdf/18-556_e1pf.pdf
CRIMINAL PROCEDURE:
When an
officer runs a
license plate
and learns
that the owner
has a revoked
license—absent
knowledge of
any
contradictory
facts—it is
reasonable for
the officer to
infer that the
driver is also
the owner of
the vehicle,
and the
traffic stop
is justified.
Respondent was charged as a
“habitual
violator” for
driving with a
revoked
license.
Respondent
claimed that
the officer
failed to meet
the reasonable
suspicion
standard
required to
make a traffic
stop and filed
a motion to
suppress all
of the
resultant
evidence. The
district court
granted
Respondent’s
motion. The
court of
appeals
reversed,
holding that
the officer’s
common-sense
inference that
the driver was
the owner of
the vehicle
was reasonable
and “gave rise
to a
reasonable
suspicion.”
The state
supreme court
reversed,
stating that
the officer’s
inference was
merely a
“hunch.” On
appeal, the
United States
Supreme Court
reversed,
holding that
when an
officer lacks
any facts
contradicting
the inference
that the owner
of the vehicle
is the one
driving, a
traffic stop
for driving
with a revoked
license is
reasonable.
The Supreme
Court reasoned
that Fourth
Amendment
precedent
recognizes
that an
officer’s
common-sense
inference can
be drawn from
everyday
experiences,
rather than
solely from
law
enforcement
training.
Furthermore,
the Supreme
Court reasoned
that, under a
“totality of
the
circumstances”
analysis, the
officer had
“individualized
suspicion”
that
Respondent was
engaged in a
criminal act
based on
database
information
regarding the
vehicle’s
description
and the
owner’s
revoked
license,
empirical
knowledge that
drivers with
revoked
licenses often
continue to
drive, and the
officer's own
common-sense
inference that
the driver was
the registered
owner of the
vehicle.
Therefore, the
traffic stop
was justified.
REVERSED and
REMANDED.
[Summarized
by: Teresa Schulte]
ELECTION LAW: The
application
for stay
presented to
Justice
Kavanaugh and
by him
referred to
the Court is
granted. The
District
Court’s order
granting a
preliminary
injunction is
stayed to the
extent it
requires the
State to count
absentee
ballots
postmarked
after April 7,
2020.
Respondents sought relief in
district court
to alleviate
burdens
imposed upon
Wisconsin
primary voters
as a result of
the COVID-19
pandemic.
Finding that
existing
deadlines for
absentee
voters would
unconstitutionally
interfere with
the voting
rights of
Wisconsin
citizens, the
district court
ordered an
extension for
absentee
ballot
requests and
extended the
deadline to
receive
completed
absentee
ballots—including
those ballots
postmarked
after the
election date
of April 7,
2020. The
district court
also enjoined
any release of
polling
results prior
to the new
deadline of
April 13,
2020.
Petitioner-intervenors
submitted an
application
for stay to
the U.S.
Supreme Court
after the
Seventh
Circuit denied
their
challenge to
the extended
ballot receipt
deadline and
upheld the
district
court’s
injunction.
The Supreme
Court granted
the stay and
reinstated the
April 7
postmark
deadline for
absentee
ballots. The
Court held
that lower
federal courts
should refrain
from altering
election rules
near the
election date,
citing its
decision Purcell
v. Gonzalez, 549 U. S. 1
(2006) (per
curiam) and
the need to
avoid
“judicially
created
confusion.”
The Court
found no
probative
evidence that
rights of
Wisconsin
voters would
be
substantially
infringed by
retaining the
April 7
postmark
deadline for
absentee
ballots.
GRANTED.
[Summarized
by: Jessy Morris]
Date Filed: April 6,
2020
Case #: 18-882
ALITO, J.,
delivered the
opinion of the
Court, in
which ROBERTS,
C. J., and
BREYER,
SOTOMAYOR,
KAGAN,
GORSUCH, and
KAVANAUGH,
JJ., joined,
and in which
GINSBURG, J.,
joined as to
all but
footnote 3.
SOTOMAYOR, J.,
filed a
concurring
opinion, in
which
GINSBURG, J.,
joined.
THOMAS, J.,
filed a
dissenting
opinion.
Full Text
Opinion: https://www.supremecourt.gov/opinions/19pdf/18-882_3ebh.pdf
EMPLOYMENT LAW: The
plain language
of the Age
Discrimination
in Employment
Act of 1967
shows that age
need not be
the but-for
cause of a
personnel
action for
there to be a
violation of
29 U.S.C. §
633a(a).
Petitioner was a pharmacist at a
U.S.
Department of
Veterans
Affairs
Medical
Center.
Petitioner
alleged
various forms
of
discrimination,
including age
discrimination, after being denied training opportunities and losing
eligibility
for promotion.
Respondent
moved for
summary
judgment. The
district court
granted the
motion on the
basis that
Respondent
offered
legitimate
non-discriminatory
reasons for
the challenged
actions and
that no
reasonable
jury could
find that the
reasons were
pretextual.
Petitioner
appealed and
the Eleventh
Circuit Court
of Appeals
found that the
argument was
foreclosed by
circuit
precedent. The
United States
Supreme Court
held that
while 29
U.S.C. §
633a(a)
requires
plaintiffs to
show that age
consideration
was the
but-for cause
of a personnel
action, if it
played a
lesser part in
the decision
some remedies
may still be
appropriate.
The Court
looked to the
plain language
of 29 U.S.C. §
633a(a) to
resolve the
circuit split
in
interpretation.
The Court
rejected
Respondent’s
argument that
liability is
only imposed
when age
discrimination
is the but-for
cause of a
personnel
action. The
phrases “free
from” and
“shall be
made” in the
language of
the statute
relate to each
other to mean
that personnel
decisions must
be untainted
by any
consideration
of age.
REVERSED and
REMANDED.
[Summarized
by: Ayla O'Scannell]
UNITED STATES SUPREME
COURT NEWS
Willamette Law
Online –
Willamette
University
College of Law
US Supreme Court
Writers:
Margaret Dick,
Connor
McDonald,
Jessy Morris,
Ayla
O'Scannell,
Laura
Schifano,
Teresa
Schulte,
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