Supreme Court Decision Syllabus (SCOTUS Podcast)

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If anyone thinks I am pronouncing Giglio incorrectly, please see: https://documents.law.yale.edu/pronouncing-dictionary
In a brief per curiam opinion, the Supreme Court vacated an Eleventh Circuit decision denying federal habeas relief to Florida death-row inmate Gary Whitton. Whitton argued that prosecutors violated Giglio v. United States by allowing jailhouse informant Jake Ozio to falsely testify that he had no prior criminal history, despite the State possessing juvenile records showing prior assault, threats, and burglary charges. The Eleventh Circuit agreed that Ozio’s testimony was false and that prosecutors knew it was false, but nevertheless found no prejudice because the evidence against Whitton was overwhelming. In reaching that conclusion, however, the court relied in part on DNA test results obtained years after Whitton’s trial showing that blood on Whitton’s boots matched the victim. The Supreme Court held that this was error: because the post-trial DNA evidence was never presented to the jury, it could not be considered when assessing whether the alleged constitutional violation had a substantial and injurious effect on the jury’s verdict. The Court did not decide whether Whitton is entitled to relief, whether the Florida Supreme Court’s harmless-error determination was reasonable based on the trial record alone, or whether Whitton properly exhausted his claim in state court. Instead, it sent the case back to the Eleventh Circuit to reconsider those issues without relying on evidence the jury never saw.
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In a brief per curiam order, the Supreme Court stayed a federal district court injunction that would have prevented Alabama from using its 2023 congressional map in the 2026 elections. The Court held that Alabama was likely to succeed on appeal because the district court failed to apply the standards the Supreme Court recently announced in Louisiana v. Callais. Under Callais, plaintiffs challenging a map under Section 2 of the Voting Rights Act must show that their proposed alternative map satisfies all of the State’s legitimate districting objectives just as well as the State’s map and must demonstrate racial bloc voting independent of partisan affiliation. The Court found that the district court nevertheless concluded Alabama’s map violated both Section 2 and the Fourteenth Amendment even though the plaintiffs’ alternative map did not perform as well on some of Alabama’s stated districting goals, including preserving the Gulf Coast community of interest and avoiding pairing incumbents. The Court also criticized the district court for treating Alabama’s disagreement with an earlier remedial order as evidence of discriminatory intent and for failing to account for the distinction between racial and partisan voting patterns required by Callais. Finally, the Court emphasized the principle that federal courts should avoid changing election rules close to an election and concluded that the balance of harms and public interest favored allowing Alabama to conduct its imminent 2026 congressional elections under the map enacted by its legislature while the litigation continues.
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Held: When Congress declines to make a sentencing amendment retroactive—as with the change to §924(c)—the resulting sentencing disparity cannot serve as an “extraordinary and compelling” reason that warrants a sentence reduction under 18 U. S. C. §3582(c)(1)(A)(i).  Pp. 8–17.
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Held: A prisoner who collaterally attacks the validity of his conviction must proceed through 28 U. S. C. §2255, not 18 U. S. C. §3582; the supposed invalidity of a conviction is not among the “extraordinary and compelling reasons” that justify compassionate release.  Pp. 5–17. (a) Section 2255 governs collateral attacks on federal convictions and imposes tight procedural constraints, including: a 1-year statute of limitations, §2255(f); a general rule that prisoners get only one shot at collateral relief with narrow exceptions, §§2255(h)(1)–(2); a bar on relitigating claims already raised and rejected on direct review, see Kaufman v. United States, 394 U. S. 217, 227, n. 8; and procedural default rules requiring demonstration of “‘cause’” and “‘prejudice’” or actual innocence for claims not raised on direct review, Bousley v. United States, 523 U. S. 614, 622.
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In a 5–4 decision, the Supreme Court held that the Mississippi Supreme Court unreasonably rejected death-row inmate Terry Pitchford’s claim under Batson v. Kentucky that prosecutors improperly excluded Black jurors during his capital murder trial. The Court concluded that the trial judge failed to complete Batson’s required third step by denying Pitchford’s counsel a meaningful opportunity to argue that the prosecutor’s race-neutral explanations were pretextual and by never determining whether the strikes were motivated by racial discrimination. Because defense counsel repeatedly attempted to pursue the objection and was assured by the trial court that it had been preserved, the Court found it unreasonable for the Mississippi Supreme Court to rule that Pitchford had waived the issue. Applying the deferential federal habeas standard under the Antiterrorism and Effective Death Penalty Act, the Court held that the state court had both unreasonably applied clearly established Batson precedent and unreasonably determined the facts, reversing the Fifth Circuit and remanding for further proceedings.
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