Nelson v. Colorado | |
---|---|
![]() | |
Argued January 9, 2017 Decided April 19, 2017 | |
Full case name | Shannon Nelson, Petitioner v. Colorado Louis A. Madden, Petitioner v. Colorado |
Docket no. | 15-1256 |
Citations | 581 U.S. ___ ( more ) 137 S. Ct. 1249; 197 L. Ed. 2d 611 |
Argument | Oral argument |
Opinion announcement | Opinion announcement |
Case history | |
Prior | People v. Nelson, 2013 COA 58, 369 P.3d 625; reversed, 2015 CO 68, 362 P.3d 1070; People v. Madden, 2013 COA 56, 399 P.3d 706; reversed, 2015 CO 69, 364 P.3d 866; cert. granted, 137 S. Ct. 30 (2016). |
Holding | |
The Colorado Exoneration Act's scheme does not comport with the Fourteenth Amendment's guarantee of due process | |
Court membership | |
| |
Case opinions | |
Majority | Ginsburg, joined by Roberts, Breyer, Sotomayor, Kagan, Kennedy |
Concurrence | Alito (in judgment) |
Dissent | Thomas |
Gorsuch took no part in the consideration or decision of the case. | |
Laws applied | |
U.S. Const. amend. XIV |
Nelson v. Colorado, 581 U.S. ___ (2017), is a decision by the Supreme Court of the United States. [1] In a 7-1 decision written by Justice Ruth Bader Ginsburg, the Court held that a state had no right to keep fines and other money based on an invalid conviction. [2] Justice Samuel Alito wrote an opinion concurring in the judgment, Justice Clarence Thomas wrote a dissenting opinion, and Justice Neil Gorsuch did not take part in the consideration or decision of the case. [3]
The case combined lawsuits by two petitioners: Shannon Nelson and Louis Madden. Nelson was convicted of child abuse and sentenced to 20 years to life, and assessed $8,192 in various fees and restitution. [4] Madden was convicted of attempting to patronize a prostituted child and attempted sexual assault, and received an indeterminate sentence and had to pay $4,413. [5] Both convictions were overturned on appeal and the petitioners were considered factually innocent.
Colorado's Exoneration Act [6] requires that a person who is exonerated after being convicted must petition a Colorado District Court for an order entitling them to receive compensation.
On January 9, 2017, oral arguments were heard, where Professor Stuart Banner appeared for the accused, and the Colorado Solicitor General appeared for that state. [7]
On April 19, 2017, the Supreme Court delivered judgment in favor of the accused, voting 7–1 to reverse and remand to the state court. [8] Justice Ruth Bader Ginsburg wrote the opinion of the Court, joined by Chief Justice John Roberts, Justice Kennedy Anthony Kennedy and Stephen Breyer, Sonia Sotomayor, and Elena Kagan. [9] This decision held that the part of the law regarding "any fine, penalty, court costs, or restitution imposed upon and paid by the wrongfully convicted person" violated the Fourteenth Amendment's guarantee of due process. [2] The petitioners are entitled to prompt repayment of the money that they paid in regard to the wrongful conviction.
Justice Samuel Alito concurred only in the judgment. [9]
Justice Clarence Thomas dissented. [9]
The Supreme Court of the United States handed down sixteen per curiam opinions during its 2005 term, which lasted from October 3, 2005, until October 1, 2006.
Arlington Central School District Board of Education v. Murphy, 548 U.S. 291 (2006), was a United States Supreme Court case about experts' fees in cases commenced under the Individuals with Disabilities Education Act (IDEA). Justice Samuel Alito, writing for the majority, ruled that IDEA does not authorize the payment of the experts' fees of the prevailing parents. Justice Ruth Bader Ginsburg concurred in part, and in the judgment. Justices David Souter and Stephen Breyer filed dissents.
Baze v. Rees, 553 U.S. 35 (2008), is a decision by the United States Supreme Court, which upheld the constitutionality of a particular method of lethal injection used for capital punishment.
Skinner v. Switzer, 562 U.S. 521 (2011), is a decision by the U.S. Supreme Court regarding the route through which a prisoner may obtain biological DNA material for testing to challenge his conviction; whether through a civil rights suit or a habeas corpus petition. A majority of the Court held that the civil rights path was the appropriate path.
Connick v. Thompson, 563 U.S. 51 (2011), is a United States Supreme Court case in which the Court considered whether a prosecutor's office can be held liable for a single Brady violation by one of its members on the theory that the office provided inadequate training.
United States v. Kebodeaux, 570 U.S. 387 (2013), was a recent case in which the Supreme Court of the United States held that the Sex Offender Notification and Registration Act (SORNA) was constitutional under the Necessary and Proper Clause.
Caetano v. Massachusetts, 577 U.S. 411 (2016), was a case in which the Supreme Court of the United States unanimously vacated a Massachusetts conviction of a woman who carried a stun gun for self-defense.
Foster v. Chatman, 578 U.S. ___ (2016), was a United States Supreme Court case in which the Court held that the state law doctrine of res judicata does not preclude a Batson challenge against peremptory challenges if new evidence has emerged. The Court held the state courts' Batson analysis was subject to federal jurisdiction because "[w]hen application of a state law bar 'depends on a federal constitutional ruling, the state-law prong of the court’s holding is not independent of federal law, and our jurisdiction is not precluded,'" under Ake v. Oklahoma.
The Supreme Court of the United States handed down nine per curiam opinions during its 2016 term, which began October 3, 2016 and concluded October 1, 2017.
Expressions Hair Design v. Schneiderman, 581 U.S. ___ (2017), was a United States Supreme Court decision that held that price controls, when used to prohibit the communication of prices of goods with regards to a surcharge, was a regulation of speech and required an analysis of the First Amendment's protections for freedom of speech.
Cooper v. Harris, 581 U.S. ___ (2017), is a landmark decision by the Supreme Court of the United States in which the Court ruled 5–3 that the North Carolina General Assembly used race too heavily in re-drawing two Congressional districts following the 2010 Census.
Maslenjak v. United States, 582 U.S. ___ (2017), is a United States Supreme Court case in which the Court held that the government cannot revoke the citizenship of a naturalized U.S. citizen based on an immaterial false statement made by the citizen in their naturalization application.
Microsoft Corp. v. Baker, 582 U.S. ___ (2017), is a United States Supreme Court case holding that Federal courts of appeals lack jurisdiction to review a denial of class certification after plaintiffs have voluntarily dismissed their claims with prejudice.
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.
Sessions v. Dimaya, 584 U.S. ___ (2018), was a United States Supreme Court case in which the Court held that 18 U.S.C. § 16(b), a statute defining certain "aggravated felonies" for immigration purposes, is unconstitutionally vague. The Immigration and Nationality Act (INA) classifies some categories of crimes as "aggravated felonies", and immigrants convicted of those crimes, including those legally present in the United States, are almost certain to be deported. Those categories include "crimes of violence", which are defined by the "elements clause" and the "residual clause". The Court struck down the "residual clause", which classified every felony that, "by its nature, involves a substantial risk" of "physical force against the person or property" as an aggravated felony.
The Supreme Court of the United States handed down seven per curiam opinions during its 2018 term, which began October 1, 2018, and concluded October 6, 2019.
Monasky v. Taglieri, 589 U.S. ___ (2020), is a United States Supreme Court case in which the court held that a child's "habitual residence" under the Hague Convention on the Civil Aspects of International Child Abduction should be determined based on the totality of the circumstances specific to the case, and should not be based on categorial requirements.
The Supreme Court of the United States handed down ten per curiam opinions during its 2019 term, which began October 7, 2019 and concluded October 4, 2020.
Department of Homeland Security v. Thuraissigiam, 591 U.S. ___ (2020), was a United States Supreme Court case involving whether the Illegal Immigration Reform and Immigrant Responsibility Act of 1996, which limits habeas corpus judicial review of the decisions of immigration officers, violates the Suspension Clause of Article One of the U.S. Constitution. In the 7–2 opinion, the Court ruled that the law does not violate the Suspension Clause.
Moore v. Texas, 137 S. Ct. 1039 (2017), is a United States Supreme Court decision about the death penalty and intellectual disability. The court held that contemporary clinical standards determine what an intellectual disability is, and held that even milder forms of intellectual disability may bar a person from being sentenced to death due to the Eighth Amendment's prohibition against cruel and unusual punishment. The case clarified two earlier cases, Atkins v. Virginia (2002) and Hall v. Florida (2014).