The Supreme Court of the United States announced decisions in four cases today:

Swarthout v. Cooke, No. 10-333: Under California state law, a conclusion that an inmate is unsuitable for parole is to be upheld on state judicial review as long as "some evidence" supports that conclusion. On review of federal habeas decisions following state habeas denials, the Ninth Circuit held that the "some evidence" standard was part of a liberty interest protected by the federal Due Process Clause, allowing it to review whether state determinations regarding the evidence were unreasonable. In a per curiam opinion, the Supreme Court reversed the Ninth Circuit, noting that federal habeas relief is not available for an error of state law, and that "it is no federal concern here whether California’s 'some evidence' rule of judicial review (a procedure beyond what the Constitution demands) was correctly applied."

The Court's decision is available here.

Chase Bank USA v. McCoy, No. 09-329: A credit card agreement provided that the cardholder was eligible for a certain interest rate as long as he met certain conditions, but the issuer reserved the right to raise the rate, up to a pre-set maximum, and to apply the change to both existing and new balances, if those conditions were not met. The cardholder alleged that the issuer had to notify him before an increase in rates could take effect under that provision, and that its failure to do so violated a Federal Reserve Board regulation. The Supreme Court held that the regulation did not require a change-in-terms notice before implementing the agreement term, finding it appropriate for the Court to defer to the interpretation of the regulation offered by the Board in an amicus brief to the Court in this case.

The Court's opinion is available here.

Ortiz v. Jordan, No. 09-737: Two state prison officers sought summary judgment on immunity grounds from an inmate's suit for damages. The trial court denied summary judgment. At trial, the officers moved for judgment as a matter of law under Federal Rule of Civil Procedure 50(a) before the matter was submitted to the jury, but did not renew that motion under Rule 50(b) after the verdict, and did not make a new trial motion. They contended on appeal that the district court had erred in denying summary judgment, and the Sixth Circuit agreed and reversed the judgment for the inmate. The Supreme Court held that a party may not appeal a denial of summary judgment after a district court has conducted a full trial on the merits, and that to the extent the officers' claim was that the inmate had not proved her case, they were obliged to raise that sufficiency-of-the evidence issue by postverdict motion for judgment as a matter of law under Rule 50(b). Because they did not do so, the Sixth Circuit had no authority to upset the jury’s decision on their liability.

The Court's opinion is available here.

Thompson v. North American Stainless, No. 09-291: After petitioner's fiancée filed a sex discrimination charge with the EEOC against their employer, the employer fired petitioner. He filed his own charge and a subsequent lawsuit under Title VII of the Civil Rights Act, claiming he was fired to retaliate against his fiancée for filing her charge. The lower courts granted and affirmed summary judgment against petitioner on the ground that third-party retaliation claims were not permitted by Title VII. The Supreme Court held that Title VII’s antiretaliation provision must be construed to cover a broad range of employer conduct, and that if the facts alleged are true, petitioner's firing constituted unlawful retaliation, for which Title VII grants petitioner himself a cause of action.

The Court's decision is available here.

The Supreme Court also granted review today in two cases:

Howes v. Fields, No. 10-680: Whether a prisoner is "in custody" for purposes of Miranda any time that prisoner is isolated from the general prison population and questioned about conduct occurring outside the prison, regardless of the surrounding circumstances.

Reynolds v. United States, No. 10-6549: Whether a person who was required to register as a sex offender under state law has standing to challenge certain federal regulations regarding registration under the federal Sex Offender Registration and Notification Act.