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The U.S. Supreme Court on Dec. 11 rendered the following decisions: The justices held unanimously that the 9th U.S. Circuit Court of Appeals had improperly overturned a state court ruling that allowed a murder victim’s family to wear buttons depicting the victim’s face during a criminal trial. Carey v. Musladin, No. 05-785. Matthew Musladin was convicted of the first-degree murder of Tom Studer, his former wife’s fiance, and sentenced to 32 years in prison. At the trial, Studer’s mother, father and brother wore buttons bearing his photograph while seated in the front row of the courtroom. Defense counsel objected, but the trial judge rejected the challenge, finding that a photograph alone could not be prejudicial. The higher state courts affirmed, but the 9th Circuit reversed, holding that the buttons had deprived Musladin, who pleaded self-defense, of a fair trial by tacitly indicating that “Studer was the innocent party and that the defendant was necessarily guilty.” The case turned on a 1996 law, the Anti-terrorism and Effective Death Penalty Act, limiting the circumstances under which federal judges may grant habeas corpus petitions in state court cases. According to the law, a federal judge can step in only if a state court decision is “contrary to” or an “unreasonable application” of clearly established federal law as determined by the Supreme Court. The justices reversed. Writing on behalf of the court, Justice Clarence Thomas said that certain actions by the state at trial-such as forcing a defendant to wear prison garb or surrounding the defendant with uniformed state troopers-are prejudicial enough to cause the reversal of convictions. But the court “has never addressed a claim that . . . private-actor courtroom conduct was so inherently prejudicial that it deprived a defendant of a fair trial . . . .Given the lack of applicable holdings from this Court, it cannot be said that the state court ‘unreasonably appli[ed] . . . clearly established Federal law.’ “ The justices held unanimously that a six-year statute of limitations on lawsuits to recover damages does not apply to agency enforcement actions. BP America v. Burton, No. 05-669. In 1996, the U.S. Department of the Interior’s Minerals Management Service (MMS) ordered BP America Production Co. and Atlantic Richfield Co. (Arco), which pump natural gas from wells in the San Juan Basin, to pay $4.1 million and $780,000, respectively, to cover royalty deficiencies. Amoco Production Co., BP’s predecessor, calculated the royalty as a percentage of the value of the gas as of the moment it was produced at the well. The MMS insisted that royalties should be calculated based on the value of the gas after it was treated to meet the quality requirements for introduction into the nation’s pipelines. Amoco appealed, arguing that MMS’ order was barred by 28 U.S.C. 2415(a), which says, “[E]very action for money damages brought by the United States or an . . . agency thereof which is founded upon any contract . . . shall be barred unless the complaint is filed within six years after the right of action accrues.” A Washington federal court ruled that the statute of limitations doesn’t apply to an agency’s administrative order. The U.S. Circuit Court of Appeals for the District of Columbia affirmed. The justices affirmed. Writing on behalf of the court, Justice Samuel A. Alito Jr. said, “Unless otherwise defined, statutory terms are generally interpreted in accordance with their ordinary meaning. Read in this way, § 2415(a)’s text is quite clear: Its key terms-”action” and “complaint”-are ordinarily used in connection with judicial, not administrative, proceedings . . . .The phrase ‘action for money damages’ reinforces this reading because the term ‘damages’ is generally used to mean pecuniary compensation or indemnity recovered in court.”

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