Supreme Court Year in Review: Four Overlooked Cases
The Supreme Court in 2021 has tackled cases on a range of subjects. The media has prominently featured some of the cases which cover hot-button topics, such as gun rights and abortion. However, there are still many cases on the docket before the year ends.
This article will focus on some Supreme Court decisions that have not appeared as frequently in the news but are still significant.
The First Amendment v. COVID-19
The case Tandon v. Newsom was decided in April 2021. It dealt with First Amendment issues in relation to COVID-19 restrictions.
Facts: During the pandemic, a California regulation prohibited private gatherings of more than three households at a time for at-home bible study. When the plaintiffs challenged the prohibition on private religious gatherings in court, the U.S. Court of Appeals for the Ninth Circuit refused to grant an injunction. The petitioners argued the regulation on private gatherings was a violation of the Free Exercise Clause of the First Amendment. This clause allows private citizens to practice their religion as they please, provided that it does not conflict with a “compelling government interest” or otherwise infringe on public morals.
Holding: The Supreme Court provided injunctive relief to the petitioners. In the majority opinion, the court decided California had treated secular and religious activities differently. It cited examples of non-religious activities that permitted more than three households to gather at a time, such as movie theaters, hair salons, and retail stores.
The Supreme Court on the Takings Clause
The case Cedar Point Nursery v. Hassid was decided in June 2021. The case raised questions about the Fourth and Fifth Amendments to the U.S. Constitution.
Facts: Cedar Point Nursery has a location in California that grows strawberry plants for producers. It employs 100 full-time workers and 400 seasonal workers. In 2015, the United Farm Workers union (UFW) organized a protest on nursery grounds without providing notice of entry. The protest disrupted nursery operations and some workers stopped working to join the protest.
Under a California regulation, labor unions have a “right to take access” to an agricultural employer’s property to rally support for unionization. Cedar Point Nursery argued that the UFW’s illegal access and seizure of their property to solicit union support violated the Fourth and Fifth Amendments.
Holding: The Supreme Court ruled the California regulation constitutes a physical taking and therefore violates the constitution. Under the Takings Clause of the Fifth Amendment, the government may not take private property for public use without providing just compensation.
Life Sentence Without Parole for Juveniles
Jones v. Mississippi was decided in April 2021. At stake was the scope of the Eighth Amendment, which prevents cruel and unusual punishment.
Facts: At the age of 15, Brett Jones stabbed his grandfather to death after an argument over Brett’s girlfriend. The jury convicted him of murder. He received a sentence of life in prison. Under Mississippi law, he was not eligible to receive parole. The case sought to challenge mandatory life sentences without possibility of parole in the Supreme Court.
Holding: In a 6-3 decision, the Supreme Court affirmed the decision of the Mississippi Court of Appeals and said the Eighth Amendment does not prohibit a juvenile from receiving a life sentence without parole. In other words, a juvenile does not need to be found “permanently incorrigible” before a life sentence is imposed.
Instead, the Court ruled that it is constitutionally sufficient for states to have discretionary power to impose sentences. A given court can take age into account in their overall analysis.
All the conservative justices ruled in favor of upholding the life sentence of Brett Jones without parole. Justice Brett Kavanaugh wrote the majority opinion of the court. Justice Sonia Sotomayor wrote the dissenting opinion.
Supreme Court Says No Retroactive Sentencing
Edwards v. Vannoy was decided in May 2021. This case centered around the retroactive application of constitutional rules.
Facts: In 2006, Thedrick Edwards received a sentence of life in prison for committing several robberies and rape. The court in Louisiana permitted a conviction by a 10-2 vote and Edwards’ conviction became final in 2010. At least one juror voted to acquit Edwards.
The case challenged the constitutionality of a nonunamous verdict under the Sixth Amendment. Just a year earlier, the Supreme Court ruled in Ramos v. Louisiana that under this amendment, jury verdicts in criminal trials must be unanimous. The petitioner argued this decision should apply to Edwards v. Vannoy, even though the situation occurred earlier. Edwards also asserted that if he had been prosecuted in one of 48 other U.S. states or by the federal government, he would not have been convicted without a unanimous vote.
Holding: In a 6-3 decision, the Supreme Court ruled that Ramos did not apply retroactively. Since the crimes in Edwards v. Vannoy occurred before the verdict in Ramos, the final ruling by the Louisiana court remained in place.