The Supreme Court of the United States issued decisions in three cases today:

Dietz v. Bouldin, No. 15-458:  An automobile accident case went to a jury trial in federal district court.  Respondent Hillary Bouldin admitted liability and stipulated to damages of $10,186 for respondent Rocky Dietz’s medical expenses, making the only issue before the jury whether Dietz was entitled to more in damages.  The jury returned a verdict in Dietz’s favor, but awarded zero in damages.  This was an error that would require a mistrial, but the judge only realized this error moments after discharging the jury.  The judge ordered the clerk to bring back the jurors, who were all still in the building, and over Dietz’s objection, recalled the jury.  The jury then returned a verdict of $15,000 in damages, which the Ninth Circuit affirmed.  The Court today affirmed, holding that a federal district court has the inherent power to rescind a jury discharge order and recall a jury for further deliberations after identifying an error in the jury’s instructions.  The Court further observed, however,  that because the potential of tainting jurors and the jury process after discharge is extraordinarily high, this power is limited in duration and scope, and must be exercised carefully to avoid any potential prejudice.

The Court's decision is available here

Puerto Rico v. Sánchez Valle, No. 15-108:  Respondents Luis Sánchez Valle and Jaime Gómez Vázquez both sold guns to an undercover police officer.  This led to indictments by Puerto Rican prosecutors for violating the Puerto Rico Arms Act of 2000.  They were also separately indicted by federal grand juries for violating similar U.S. gun trafficking laws.  The defendants both pleaded guilty to the federal charges and then moved to dismiss the Puerto Rico charges on the basis of double jeopardy.  The trial court agreed and dismissed on double jeopardy grounds, but the court of appeals reversed.   The Supreme Court of Puerto Rico, in turn, agreed with the trial court that the Double Jeopardy Clause applied.  The Court today affirmed, determining that the key issue is whether the prosecutorial powers of the two jurisdictions have independent origins, i.e., whether those powers derive from the same “ultimate source,” and held that under that test, Puerto Rico and the United States may not successively prosecute a single defendant for the same criminal conduct because the oldest roots of Puerto Rico’s power to prosecute lie in federal soil.

The Court's decision is available here.

Williams v. Pennsylvania, No. 15-5040: Petitioner Terrance Williams was convicted of a 1984 murder and sentenced to death in Pennsylvania state court. During the trial, the prosecutor received permission to seek the death penalty from her supervisor, then-district attorney Ronald Castille. The conviction and sentence were upheld for decades, until in 2012, Williams filed a successive petition pursuant to Pennsylvania’s Post Conviction Relief Act (PCRA), and the PCRA court stayed Williams’s execution after finding that the trial prosecutor had committed a Brady violation. The Commonwealth filed an emergency application seeking to vacate the stay of execution with the Pennsylvania Supreme Court, whose Chief Justice at that time was former-district attorney Castille. Castille denied without explanation Williams’s motion seeking that he recuse himself or, in the alternative, refer the recusal motion to the full court. The Pennsylvania Supreme Court ultimately vacated the PCRA court’s order and reinstated Williams’s death sentence, with Castille joining in the majority opinion and issuing a separate concurrence. Today, the Court held that due process compelled the Chief Justice’s recusal, because the likelihood of bias on the part of that judge was too high to be constitutionally tolerable.

The Court's decision is available here.