| Ayestas v. Davis | |
|---|---|
 | |
| Decided March 21, 2018 | |
| Full case name | Ayestas v. Davis |
| Citations | 584 U.S. ___ ( more ) |
| Holding | |
| An ex parte decision by a judge can still be judicial in nature. | |
| Court membership | |
| |
| Case opinions | |
| Majority | Alito, joined by unanimous |
| Concurrence | Sotomayor |
Ayestas v. Davis, 584 U.S. ___ (2018), was a United States Supreme Court case in which the Court held that an ex parte decision by a judge can still be judicial in nature. [1] [2]
The case concerned an imprisoned person's funding request for a habeas corpus petition under a law that gave a judge discretion to approve funds that were "reasonably necessary." A judge denied the request because the imprisoned person, Ayesta, did not show a "substantial need" for the funds. The Supreme Court reversed because this "substantial need" standard was more demanding than the "reasonably necessary" language of the statute. Indeed, in the Court's estimation, the lower court was effectively requiring Ayesta to prove his case before being allowed to fund the investigation. [3]
Habeas corpus is a recourse in law by which a report can be made to a court in the events of unlawful detention or imprisonment, requesting that the court order the person's custodian to bring the prisoner to court, to determine whether their detention is lawful.
Ex parte Merryman, 17 F. Cas. 144 (No. 9487), was a controversial U.S. federal court case that arose out of the American Civil War. It was a test of the authority of the President to suspend "the privilege of the writ of habeas corpus" under the Constitution's Suspension Clause, when Congress was in recess and therefore unavailable to do so itself. More generally, the case raised questions about the ability of the executive branch to decline to enforce judicial decisions when the executive believes them to be erroneous and harmful to its own legal powers.
Ex parte Milligan, 71 U.S. 2 (1866), is a landmark decision of the U.S. Supreme Court that ruled that the use of military tribunals to try civilians when civil courts are operating is unconstitutional. In this particular case, the Court was unwilling to give former President Abraham Lincoln's administration the power of military commission jurisdiction, part of the administration's controversial plan to deal with Union dissenters during the American Civil War. Justice David Davis, who delivered the majority opinion, stated that "martial rule can never exist when the courts are open" and confined martial law to areas of "military operations, where war really prevails", and when it was a necessity to provide a substitute for a civil authority that had been overthrown. Chief Justice Salmon P. Chase and three associate justices filed a separate opinion concurring with the majority in the judgment, but asserting that Congress had the power to authorize a military commission, although it had not done so in Milligan's case.
Ex parte McCardle, 74 U.S. 506 (1869), is a United States Supreme Court decision that considered its jurisdiction to review decisions of lower courts under federal law.
A writ of coram nobis is a legal order allowing a court to correct its original judgment upon discovery of a fundamental error that did not appear in the records of the original judgment's proceedings and that would have prevented the judgment from being pronounced. The term coram nobis is Latin for "before us" and the meaning of its full form, quae coram nobis resident, is "which [things] remain in our presence". The writ of coram nobis originated in the courts of common law in the English legal system during the sixteenth century.
In United States law, habeas corpus is a recourse challenging the reasons or conditions of a person's confinement under color of law. A petition for habeas corpus is filed with a court that has jurisdiction over the custodian, and if granted, a writ is issued directing the custodian to bring the confined person before the court for examination into those reasons or conditions. The Suspension Clause of the United States Constitution specifically included the English common law procedure in Article One, Section 9, clause 2, which demands that "The privilege of the writ of habeas corpus shall not be suspended, unless when in cases of rebellion or invasion the public safety may require it."
Boumediene v. Bush, 553 U.S. 723 (2008), was a writ of habeas corpus petition made in a civilian court of the United States on behalf of Lakhdar Boumediene, a naturalized citizen of Bosnia and Herzegovina, held in military detention by the United States at the Guantanamo Bay detention camps in Cuba. The case underscored the essential role of habeas corpus as a safeguard against government overreach, ensuring that individuals cannot be detained indefinitely without the opportunity to challenge the legality of their detention. Guantánamo Bay is not formally part of the United States, and under the terms of the 1903 lease between the United States and Cuba, Cuba retained ultimate sovereignty over the territory, while the United States exercises complete jurisdiction and control. The case was consolidated with habeas petition Al Odah v. United States. It challenged the legality of Boumediene's detention at the United States Naval Station military base in Guantanamo Bay, Cuba as well as the constitutionality of the Military Commissions Act of 2006. Oral arguments on the combined cases were heard by the Supreme Court on December 5, 2007.
In United States law, habeas corpus is a recourse challenging the reasons or conditions of a person's detention under color of law. The Guantanamo Bay detention camp is a United States military prison located within Guantanamo Bay Naval Base. A persistent standard of indefinite detention without trial and incidents of torture led the operations of the Guantanamo Bay detention camp to be challenged internationally as an affront to international human rights, and challenged domestically as a violation of the Due Process Clause of the Fifth and Fourteenth amendments of the United States Constitution, including the right of petition for habeas corpus. On 19 February 2002, Guantanamo detainees petitioned in federal court for a writ of habeas corpus to review the legality of their detention.
The Excessive Bail Clause of the Eighth Amendment to the United States Constitution prohibits excessive bail set in pre-trial detention. If a judge posts excessive bail, the defendant's lawyer may make a motion in court to lower the bail or appeal directly to a higher court.
Ahrens v. Clark, 335 U.S. 188 (1948), was a United States Supreme Court case that denied a federal district court jurisdiction to issue a writ of habeas corpus if the person detained is not within the territorial jurisdiction of the court when the petition is filed. The 6–3 ruling was handed down on June 21, 1948, with the majority opinion written by Justice William O. Douglas and the dissent written by Justice Wiley Blount Rutledge.
Penry v. Johnson, 532 U.S. 782 (2001), is a United States Supreme Court case which concerned whether instructions given to a Texas jury were constitutionally adequate to emphasize the mitigating factors in sentencing of defendants who are intellectually disabled The Texas courts had determined the sentencing instructions were consistent with prior Supreme Court jurisprudence, but the Court in a divided decision reversed, finding the sentencing instructions insufficient. This was the second time Penry's case made it to the Supreme Court.
The remedies available in a Singapore constitutional claim are the prerogative orders – quashing, prohibiting and mandatory orders, and the order for review of detention – and the declaration. As the Constitution of the Republic of Singapore is the supreme law of Singapore, the High Court can hold any law enacted by Parliament, subsidiary legislation issued by a minister, or rules derived from the common law, as well as acts and decisions of public authorities, that are inconsistent with the Constitution to be void. Mandatory orders have the effect of directing authorities to take certain actions, prohibiting orders forbid them from acting, and quashing orders invalidate their acts or decisions. An order for review of detention is sought to direct a party responsible for detaining a person to produce the detainee before the High Court so that the legality of the detention can be established.
Tarble's Case, 80 U.S. 397 (1872), was a United States Supreme Court case in which the Court held that a State judge has no jurisdiction to issue a writ of habeas corpus, or to continue proceedings under the writ when issued, for the discharge of a person held by the authority, or claim and color of the authority, of the United States by an officer of that government.
Wong Wing v. United States, 163 U.S. 228 (1896), was a United States Supreme Court case in which the Court found that the Fifth and Sixth Amendments to the U.S. Constitution forbid the imprisonment at hard labor without a jury trial for noncitizens convicted of illegal entry to or presence in the United States.
Wilson v. Sellers, 584 U.S. ___ (2018), is a United States Supreme Court case concerning whether a federal court sitting in a habeas corpus proceeding should "look through" a summary ruling to review the last reasoned decision by a state court.
Aetna Life Insurance Co. v. Lavoie, 475 U.S. 813 (1986), was a United States Supreme Court case in which the Court held the Due Process Clause requires state supreme court justices to recuse themselves from cases in which they have a direct, personal, substantial, and pecuniary interest in the outcome.
Alabama v. Smith, 490 U.S. 794 (1989), was a United States Supreme Court case in which the Court held that, if a criminal defendant received a sentence after a guilty plea but withdrew that plea and was convicted at trial, the judge may hand down a more severe sentence.
Zwickler v. Koota, 389 U.S. 241 (1967), was a United States Supreme Court case in which the Court held that a federal court cannot use the abstention doctrine to avoid a constitutional issue merely because it determines that the plaintiff is unlikely to receive the relief they requested. The underlying case was about an anonymous handbill law that the Court believed was overbroad.
Amadeo v. Zant, 486 U.S. 214 (1988), was a United States Supreme Court case in which the Court held that a convicted person may use habeas corpus to challenge their conviction if they later learn that the prosecution racially discriminated in jury selection.
United States v. Sanchez-Gomez, 584 U.S. ___ (2018), was a United States Supreme Court case in which the Court held that there is no analog to class actions under the Federal Rules of Criminal Procedure, and there is no "capable of repetition yet evading review" exception for mootness where repetition would require the defendant to be charged with a crime in the future.
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