Musacchio v. United States

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Musacchio v. United States
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Argued November 30, 2015
Decided January 25, 2016
Full case nameMichael Musacchio, Petitioner v. United States
Docket nos. 14–1095
Citations 577 U.S. ___ ( more )
136 S. Ct. 709; 193 L. Ed. 2d 639
Prior history On Writ of Certiorari to the United States Court of Appeals for the Fifth Circuit
Court membership
Chief Justice
John Roberts
Associate Justices
Antonin Scalia  · Anthony Kennedy
Clarence Thomas  · Ruth Bader Ginsburg
Stephen Breyer  · Samuel Alito
Sonia Sotomayor  · Elena Kagan
Case opinions
Majority Thomas, joined by unanimous

Musacchio v. United States, 577 U.S. ___ (2016), was a case in which the Supreme Court of the United States clarified procedures for appellate review when the government does not object to an erroneous jury instruction that adds elements to a criminal offense as well as whether a defendant may raise a statute of limitations defense for the first time on appeal. [1] In a unanimous opinion written by Justice Clarence Thomas, the Court held that when reviewing a claim that the government failed to demonstrate sufficient evidence to substantiate a criminal offense, an appellate court should assess the elements of the alleged crime, rather than the elements that were described in jury instructions. [2] Justice Thomas explained that "[a] reviewing court’s limited determination on sufficiency review ... does not rest on how the jury was instructed." [3] Additionally, with respect to the statute of limitations issue, Justice Thomas held that a statute of limitations defense cannot be raised for the first time on appeal. [4]

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See also

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Descamps v. United States, 570 U.S. ___ (2013), was a case in which the United States Supreme Court clarified standards for evaluating potential prior offenses under the Armed Career Criminal Act (ACCA). In an 8–1 decision written by Justice Elena Kagan, the Supreme Court held that judges may only look at the statutory elements of a crime, rather than the facts associated with that particular crime, "when the crime of which the defendant was convicted has a single, indivisible set of elements." In his review of the case for SCOTUSblog, Daniel Richman opined that following the Court's decision, "[w]hether or not a prior conviction is going to 'count' will have to be determined as mechanically as possible."

Davis v. Ayala, 576 U.S. ___ (2015), was a case in which the Supreme Court of the United States upheld a death sentence of a Hispanic defendant despite the fact that all Blacks and Hispanics were rejected from the jury during the defendant's trial. The case involved a habeas corpus petition submitted by Hector Ayala, who was arrested and tried in the late 1980s for the alleged murder of three individuals during an attempted robbery of an automobile body shop in San Diego, California in April 1985. At trial, the prosecution used peremptory challenges to strike all Black and Hispanic jurors who were available for jury service. The trial court judge allowed the prosecution to explain the basis for the peremptory challenges outside the presence of Ayala's counsel, "so as not to disclose trial strategy". Ayala was ultimately sentenced to death, but he filed several appeals challenging the constitutionality of the trial court's decision to exclude his counsel from the hearings.

DIRECTV, Inc. v. Imburgia, 577 U.S. ___ (2015), was a case in which the Supreme Court of the United States clarified when arbitration provisions in contracts are governed by the Federal Arbitration Act. In a 6-3 opinion written by Justice Stephen Breyer, the Court reversed a decision by the California Court of Appeal that refused to enforce an arbitration agreement between DIRECTV and its customers. The California Court had ruled that the arbitration agreement was unenforceable because, under applicable California law, a class action arbitration waiver between DIRECTV and its customers was unenforceable. However, the Supreme Court of the United States held that the California Court of Appeal's interpretation was preempted by the Federal Arbitration Act, and the California Court of Appeal was therefore required to enforce the arbitration agreement.

Kansas v. Carr, 577 U.S. ___ (2016), was a case in which the Supreme Court of the United States clarified several procedures for sentencing defendants in capital cases. Specifically, the Court held that judges are not required to affirmatively instruct juries about the burden of proof for establishing mitigating evidence, and that joint trials of capital defendants "are often preferable when the joined defendants’ criminal conduct arises out of a single chain of events". This case included the last majority opinion written by Justice Antonin Scalia before his death in February 2016.

Montanile v. Board of Trustees of the National Elevator Industry Health Benefit Plan, 577 U.S. ___ (2016) was a case in which the Supreme Court of the United States clarified subrogation procedures under the Employee Retirement Income Security Act ("ERISA"). The Court held that healthcare plan fiduciaries cannot demand reimbursement for medical benefits from a plan member's general assets if the beneficiary's general assets cannot be traced back to the original payment from the fiduciary. Although some scholars suggested that the court's ruling would have little impact, others suggested the case places "significant restrictions" on the rights of ERISA benefit plan providers.

Ocasio v. United States, 578 U.S. ___ (2016), was a United States Supreme Court case in which the Court clarified whether the Hobbs Act's definition of conspiracy to commit extortion only includes attempts to acquire property from someone who is not a member of the conspiracy. The case arose when Samuel Ocasio, a former Baltimore, Maryland police officer, was indicted for participating in a kickback scheme with an automobile repair shop where officers would refer drivers of damaged vehicles to the shop in exchange for cash payments. Ocasio argued that he should not be found guilty of conspiring to commit extortion because the only property that was exchanged in the scheme was transferred from one member of the conspiracy to another, and an individual cannot be found guilty of conspiring to extort a co-conspirator.

Menominee Tribe of Wis. v. United States, 577 U.S. ___ (2016), was a case in which the Supreme Court of the United States clarified when litigants are entitled to equitable tolling of a statute of limitations. In a unanimous opinion written by Justice Samuel Alito, the Court held that the plaintiff in this case was not entitled to equitable tolling of the statute of limitations because they did not demonstrate that "extraordinary circumstances" prevented the timely filing of the lawsuit.

Shaw v. United States, 580 U.S. ___ (2016), was a United States Supreme Court case that clarified the application of the federal bank fraud statute to cases where a defendant intends to only defraud a customer of the bank, rather than the bank itself.

Manuel v. Joliet, 580 U.S. ___ (2017), was a case in which the United States Supreme Court held that a criminal defendant may bring a claim under the Fourth Amendment of the United States Constitution to challenge pretrial confinement. In a 6-2 majority opinion written by Justice Elena Kagan, the Court stated that "the Fourth Amendment governs a claim for unlawful pretrial detention even beyond the start of legal process". This decision reversed and remanded the judgment of the Seventh Circuit Court of Appeals. Justice Clarence Thomas wrote a dissenting opinion. Justice Thomas also joined a dissenting opinion by Justice Samuel Alito.

Esquivel-Quintana v. Sessions, 581 U.S. ___ (2017), is a case in which the Supreme Court of the United States ruled 8–0 that in the context of statutory rape offenses that criminalize sexual intercourse based solely on the ages of the participants, the generic federal definition of “sexual abuse of a minor” requires the age of the victim to be less than 16. Justice Clarence Thomas delivered the majority opinion.

Kellogg Brown & Root Services, Inc. v. United States ex rel. Carter, 575 U.S. ___ (2015), was a United States Supreme Court involving KBR and a former KRB contractor, Benjamin Carter. In a unanimous opinion written by Associate Justice Samuel Alito, the Court held that Wartime Suspension of Limitations Act only applies to criminal offenses. The Court also held that qui tam lawsuits filed under the False Claims Act are no longer considered "pending" after they have been dismissed.

References

  1. Musacchio v. United States, No. 14–1095, 577 U.S. ___, slip op. at 1, 6, 11 (2016).
  2. Musacchio, slip op. at 1, 6.
  3. Musacchio, slip op. at 6.
  4. Musacchio, slip op. at 1, 11.
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