meaningful opportunity

In August 1981 a street fight occurred on the south side of Chicago during which Jack Bridges was stabbed in the back. Kevin Taylor was charged with attempted murder and aggravated battery arising from that incident. The State’s evidence at trial included testimony from Bridges, his brother, and three other witnesses who described a twenty-minute argument earlier in the evening and a later violent encounter in which Taylor allegedly stabbed Bridges and fired a gun at him. Well in advance of trial the prosecutor filed a discovery motion requesting a list of all defense witnesses. Taylor’s original response identified two sisters who later testified and two men who did not testify. On the first day of trial the defense was permitted to amend its answer by adding the names of Derrick Travis and a Chicago police officer, neither of whom ultimately testified. On the second day of trial, after the prosecution’s two principal witnesses had completed their testimony, defense counsel made an oral motion to amend the answer to discovery by adding Alfred Wormley and Pam Berkhalter. Counsel represented that he had just been informed about the witnesses and that they had probably seen the entire incident. The trial judge expressed concern that witnesses were being found that really were not there and directed counsel to produce them the next day. The following morning Wormley appeared and testified outside the presence of the jury. He stated that before the incident he saw Bridges and his brother with two guns wrapped in a blanket, heard them say they were after Taylor, and later warned Taylor to watch out. On cross-examination Wormley acknowledged that he had first met Taylor about four months earlier, more than two years after the incident, and that defense counsel had visited him at his home the week before trial. The judge found a blatant and willful discovery violation, expressed doubt about Wormley’s veracity, and excluded the testimony. Taylor was convicted of attempted murder and aggravated battery and sentenced to ten years’ imprisonment. The Illinois Appellate Court affirmed, finding that counsel had acted in bad faith and that exclusion was a proper sanction. The Illinois Supreme Court denied leave to appeal. The United States Supreme Court granted certiorari to consider whether the Compulsory Process Clause had been violated.

George Eldridge was first awarded Social Security disability benefits in June 1968. In March 1972 he received a questionnaire from the state agency charged with monitoring his medical condition. He completed and returned the questionnaire, indicating that his condition had not improved and identifying recent medical sources. The state agency obtained reports from his physician and a psychiatric consultant. After reviewing those reports and other information in his file, the agency sent Eldridge a letter stating that it had made a tentative determination that his disability had ceased in May 1972. The letter included a statement of reasons for the proposed termination and advised Eldridge that he could request time to submit additional information. Eldridge responded in writing, disputing one characterization of his medical condition and asserting that the agency already possessed sufficient evidence of his disability. The state agency then made a final determination that Eldridge had ceased to be disabled in May 1972; the Social Security Administration accepted that determination. In July 1972 Eldridge received written notice that his benefits would terminate after that month and that he could seek reconsideration by the state agency within six months. Instead of requesting reconsideration, Eldridge filed suit in the United States District Court for the Western District of Virginia. He challenged the constitutionality of the Secretary's termination procedures and sought an injunction barring termination of benefits until a pretermination evidentiary hearing was provided, together with immediate reinstatement of benefits. The District Court held that the existing procedures violated the Fifth Amendment's Due Process Clause, ordered the Secretary to provide Eldridge a pretermination hearing, and directed reinstatement of benefits pending that hearing. The Court of Appeals for the Fourth Circuit affirmed. The Supreme Court noted probable jurisdiction and heard the case.

Terrance Graham was sixteen years old when he committed armed burglary and attempted armed robbery in Florida. In return for his guilty plea to these charges, the Florida trial court withheld adjudication of guilt and sentenced him to probation rather than entering a formal conviction. Graham subsequently violated the terms of his probation by committing additional crimes. The trial court then adjudicated him guilty of the original charges, revoked his probation, and sentenced him to life in prison without the possibility of parole for the armed burglary. Because Florida has abolished its parole system, the sentence ensures that Graham will die in prison without any meaningful opportunity to obtain release, no matter what he might do to demonstrate that he has matured or been rehabilitated. The Florida Supreme Court affirmed the sentence on appeal. The case reached the United States Supreme Court on a petition for certiorari to determine whether the sentence violated the Eighth Amendment.

In 2001 Boston police officers received a tip that a Kmart employee was engaging in suspicious activity involving repeated short trips in a blue sedan. Officers set up surveillance in the parking lot, observed the described sequence of events, detained the employee upon his return, and discovered four clear plastic bags containing a substance resembling cocaine. The officers then arrested the two men in the car, one of whom was petitioner Luis Melendez-Diaz. The officers placed all three suspects in a police cruiser. During the short drive to the police station the officers observed their passengers fidgeting and making furtive movements in the back of the car. After depositing the men at the station they searched the police cruiser and found a plastic bag containing nineteen smaller bags hidden in the partition between the front and back seats. The officers submitted the seized substances to the State Laboratory Institute of the Massachusetts Department of Public Health, which was required by law to conduct chemical analysis upon police request. Analysts at the laboratory performed the tests on November 28, 2001, and prepared three certificates of analysis that reported the weight of the bags and stated that the substance was found to contain cocaine. Each certificate was sworn before a notary public by the analysts, as required under Massachusetts law, and reprinted the statutory provision making the certificates prima facie evidence of the composition, quality, and net weight of the narcotic analyzed. Melendez-Diaz was charged with distributing cocaine and trafficking in cocaine in an amount between 14 and 28 grams. At trial the prosecution introduced the bags seized from the codefendant and from the cruiser along with the three certificates. Petitioner objected to admission of the certificates, asserting that Crawford v. Washington required the analysts to testify in person. The trial court overruled the objection and admitted the certificates pursuant to the state statute. The jury found Melendez-Diaz guilty. He appealed, contending that admission of the certificates violated his Sixth Amendment right to be confronted with the witnesses against him. The Appeals Court of Massachusetts affirmed the convictions, relying on a prior decision of the Supreme Judicial Court that had held forensic analysts are not subject to confrontation. The Supreme Judicial Court denied review, and the United States Supreme Court granted certiorari.

Roy Daniels was an inmate at the city jail in Richmond, Virginia. While there, he slipped on a pillow that respondent, a correctional deputy stationed at the jail, had left on the prison stairway. The fall caused Daniels to sustain back and ankle injuries. Daniels filed a suit under 42 U.S.C. § 1983 against the deputy. He alleged that the deputy's conduct had caused him injury and that the deputy would rely on sovereign immunity as a defense if Daniels pursued a state tort action instead. The District Court granted the deputy's motion for summary judgment. A panel of the Court of Appeals for the Fourth Circuit affirmed that judgment. On rehearing, the en banc Court of Appeals again affirmed the District Court's judgment, although it employed different reasoning from the panel. Because lower courts had taken inconsistent approaches to determining when tortious conduct by state officials rises to the level of a constitutional violation, the Supreme Court granted certiorari.