Brownback v. King | |
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Decided February 25, 2021 | |
Full case name | Brownback v. King |
Citations | 593 U.S. ___ ( more ) |
Holding | |
A dismissal for failure to state a claim under the Federal Tort Claims Act is a judgement on the merits that triggers the FTCA's judgement bar on future actions. | |
Court membership | |
| |
Case opinions | |
Majority | Thomas, joined by unanimous |
Concurrence | Sotomayor |
Laws applied | |
Federal Tort Claims Act, Fed. R. Civ. P. 12(b)(6) |
Brownback v. King, 593 U.S. ___ (2021), was a United States Supreme Court case in which the Court held that a dismissal for failure to state a claim under the Federal Tort Claims Act is a judgment on the merits that triggers the FTCA's judgment bar on future actions. [1] [2]
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Jones v. Mississippi, 593 U.S. ___ (2021), was a United States Supreme Court case regarding the imposition of life sentences for juveniles. The Supreme Court had previously ruled in Miller v. Alabama in 2012 that mandatory life sentences without parole for juvenile offenders was considered cruel and unusual punishment outside of extreme cases of permanent incorrigibility, and made this decision retroactive in Montgomery v. Louisiana in 2016. In Jones, a juvenile offender who was 15 at the time of his offense, challenged his life sentence following Montgomery but was denied by the state. In a 6–3 decision with all six conservative justices upholding the life sentence without parole for Jones, the Court ruled that the states have discretionary ability to hold juvenile offenders to life sentences without parole without having to make a separate assessment of their incorrigibility.
Edwards v. Vannoy, 593 U.S. ___ (2021), was a United States Supreme Court case involving the Court's prior decision in Ramos v. Louisiana, 590 U.S. ___ (2020), which had ruled that jury verdicts in criminal trials must be unanimous under the Sixth Amendment to the U.S. Constitution. The Supreme Court ruled 6–3 that Ramos did not apply retroactively to earlier cases prior to their verdict in Ramos.
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Greer v. United States, 593 U.S. ___ (2021), was a United States Supreme Court case in which the Court held that an unobjected-to failure to instruct the jury that the defendant must have known they were a felon is not structural error requiring reversal. Moreover, it would be difficult to show plain error because "convicted felons ordinarily know that they are convicted felons." The case was consolidated with United States v. Gary; Sotomayor dissented to the court's assessment of Gary.
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