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Supreme Court to rule on juvenile Miranda rights

By Ann Riley

[JURIST] The US Supreme Court [official website; JURIST news archive] on Monday granted certiorari [order list, PDF] in five cases and called for views by the Acting Solicitor General [official website] on two pending petitions. In JDB v. North Carolina [docket], the court will determine whether a juvenile student who incriminated himself while being questioned by law enforcement officers was in custody and therefore entitled to the safeguards set forth in Miranda v. Arizona [opinion text] and the additional protections afforded to juveniles by NCGS § 7B-2101(a) [text]. The Supreme Court of North Carolina held [opinion, PDF] that the student was not in custody when he made incriminating statements and therefore not entitled to the protections of Miranda or the North Carolina statute.

The court will also hear the case of Board of Trustees of the Leland Stanford Junior University v. Roche Molecular Systems, Inc. [docket; cert. petition, PDF], to determine whether the rights of universities under the Bayh-Dole Act [35 USC §§ 200-212] to inventions arising from federally funded research can be terminated by the individual inventors through separate agreements assigning the inventor's rights to a third party. The US Court of Appeals for the Federal Circuit held [opinion, PDF] that Roche possesses an ownership interest in the patents at issue, depriving Stanford's standing to sue. The appeals court also remanded the case to the US District Court for the Northern District of California, finding that the trial court incorrectly failed to consider Roche's affirmative defense based on ownership of the patents in issue.

In Davis v. United States [docket; cert. petition, PDF], the court will determine whether the Fourth Amendment [text] exclusionary rule requires the suppression of evidence obtained from a search permitted by the US Court of Appeals for the Eleventh Circuit decision in United States v. Gonzalez [opinion text], after the court overturned Gonzalez in Arizona v. Gant [opinion, PDF; JURIST report]. The Eleventh Circuit refused to apply the exclusionary rule, holding [opinion, PDF] that the search was objectively reasonable when relying on the then-binding precedent and that the good faith exception allows the use of evidence obtained under reasonable reliance on well-settled precedent.

In Turner v. Price [docket; cert. petition, PDF], the court will determine whether an indigent defendant has a constitutional right to appoint counsel at a civil contempt proceeding resulting in his imprisonment. The Supreme Court of South Carolina held [opinion text] that, because the incarceration of the defendant was not a permanent or unconditional loss of liberty as he can avoid it by complying with the court's orders, he does not maintain the constitutional right to appointed counsel. The court will also consider whether it has jurisdiction to review the decision of the South Carolina Supreme Court, ordering the parties to submit briefs on the issue.

The court will also hear the case of Fox v. Vice [docket, cert. petition, PDF] to determine whether 42 USC § 1988 [text] permits the court to award defendants attorney's fees based on an action dismissing a claim when the plaintiff also asserts non-frivolous claims. The court will also consider if it is improper to award defendants the full amount of attorney's fees incurred while defending non-frivolous claims along with a frivolous claim. The US Court of Appeals for the Fifth Circuit affirmed [opinion, PDF] the granting of attorney's fees.

Additionally, the court requested the Acting Solicitor General to submit views on PPL Montana, LLC v. Montana [docket, cert. petition, PDF] and Crane v. Atwell. Montana presents the question of if the constitutional test for determining whether a section of the river is navigable for title purposes requires a trial court to determine if the relevant stretch of the river was navigable at the time the state joined the Union. The Supreme Court of Montana held [opinion, PDF] that the title to the riverbeds passed to Montana when it became a state in 1889 and that the riverbeds are public trust lands under Article X, Section 11. Addressing the question of whether a State's attempt to claim title and impose rent obligations for use of the riverbeds is preempted when a hydropower project is licensed under the Federal Power Act [text], the court additionally affirmed the lower court's finding of damages.

Crane v. Atwell [docket; cert. petition, PDF] presents the question of whether federal law preempts the litigation of state court claims based on work related asbestos exposure where the employment and exposure occurs in a railroad maintenance facility. The Superior Court of Pennsylvania held [opinion, PDF] that no federal preemption occurs because Occupational Health and Safety Administration (OSHA) [official website] regulations apply.

Also on Monday, the court denied certiorari in Wong v. Smith [docket].

Full post as published by JURIST - The Paper Chase on November 01, 2010 (boomark / email).