{"id":83,"date":"2026-05-27T16:40:08","date_gmt":"2026-05-27T16:40:08","guid":{"rendered":"https:\/\/americanservicereview.com\/?p=83"},"modified":"2026-05-27T16:40:08","modified_gmt":"2026-05-27T16:40:08","slug":"new-york-times-v-sullivan-service-and-sentence-credits","status":"publish","type":"post","link":"https:\/\/americanservicereview.com\/?p=83","title":{"rendered":"New York Times v. Sullivan, service, and sentence credits"},"content":{"rendered":"
\n

The Relist Watch column examines cert petitions that the Supreme Court has \u201crelisted\u201d for its upcoming conference. A short explanation of relists is available here. <\/em><\/p>\n

Read more Criminal law update: some defense-friendly rulings and a big case that wasn\u2019t<\/a><\/p>\n

The Supreme Court has done a substantial amount of house cleaning this week, disposing of six relists.<\/p>\n

The justices summarily reversed in Margolin v. National Association of Immigration Judges<\/em>, a fight over whether immigration judges\u2019 challenge to a government speech policy had to proceed through the Civil Service Reform Act\u2019s administrative-review scheme rather than in district court. In a , the court said the U.S. Court of Appeals for the 4th Circuit violated the party-presentation principle by deciding a broader question the parties had not raised \u2013 namely, that the CSRA\u2019s administrative-review scheme was not to be employed if current conditions suggested this was not \u201cfunctioning as Congress intended\u201d (because tenure protections for such judges was being challenged by the administration and the Merit Systems Protection Board lacked a quorum). <\/p>\n

Justice Clarence Thomas, joined by Justice Amy Coney Barrett, concurred to say the 4th Circuit was wrong on the merits too, because the court\u2019s precedents already made clear that this dispute belonged in the CSRA process. One of last week\u2019s relists, Walters v. Coleman<\/em>, is a petition also challenging a claimed 4th Circuit departure from the party-presentation principle, so we may be hearing more on the subject soon. The court also denied review on the judges\u2019 companion cross-petition in National Association of Immigration Judges v. Margolin<\/em>, asking whether a pre-enforcement challenge to a broad speech restriction on federal employees can bypass the CSRA altogether.<\/p>\n

The rest of the cleanup was quieter, though not silent. The court denied review in Florida v. California and Washington<\/em> (Florida\u2019s effort to invoke the court\u2019s original jurisdiction to block California and Washington from issuing commercial driver\u2019s licenses to undocumented immigrants with poor English), over by Thomas joined by Justice Samuel Alito, reprising their argument (which seems to be correct!) that the Supreme Court \u201ccannot refuse to hear suits between States.\u201d <\/p>\n

The court also denied review in Reinink v. Hart<\/em> (a qualified-immunity case involving whether an officer\u2019s mistaken use of greater-than-intended force should be analyzed under deadly-force rules, and whether the officer was entitled to qualified immunity), with Thomas and Alito noting they would have granted and summarily reversed; in New York Football Giants v. Flores<\/em> (whether an NFL arbitration agreement is unenforceable under the Federal Arbitration Act because it names the commissioner as the default arbitrator and lets him shape the procedures), with Justice Brett Kavanaugh indicating he would have granted; and in Union Carbide Corp. v. Sommerville<\/em> (a fight over whether challenges to the factual basis of expert testimony go to admissibility or merely weight), which was denied without comment.<\/p>\n

On to new business: There are 85 petitions and applications on the docket for this week\u2019s conference. Three are being considered for a second time.<\/p>\n

Overruling<\/strong>\u00a0New York Times v. Sullivan<\/em>?<\/strong><\/p>\n

Dershowitz v. Cable News Network, Inc.<\/em> asks the court to revisit one of the press\u2019 favorite precedents and one of Thomas\u2019 least favorite: New York Times v. Sullivan<\/em>, holding that the First Amendment prohibits allowing a public figure from recovering for defamation absent \u201cactual malice,\u201d meaning a showing the defendant knew the statement was false or was reckless in publishing it.<\/p>\n

Harvard Law professor emeritus Alan Dershowitz sued CNN over commentary criticizing his argument, made while representing President Donald Trump at his first impeachment trial, that a president who acts partly to help his reelection does not commit an impeachable offense if he believes his reelection serves the public interest. CNN commentators characterized the argument as a claim that presidents can do essentially anything to get reelected; Dershowitz says that ignored his explicit carveout for \u201cpurely corrupt\u201d conduct involving personal pecuniary gain, such as demanding kickbacks. The U.S. Court of Appeals for the 11th Circuit affirmed the district court\u2019s summary judgment for CNN, concluding that even if the commentary was wrong, overheated, or uncharitable \u2013 imagine that, on cable news! \u2013 Dershowitz had not shown actual malice because the record showed the commentators believed their interpretations were accurate. Judge Barbara Lagoa concurred but wrote a lengthy originalist critique of Sullivan<\/em>, saying the opinion was inconsistent with Founding-era practice; Judge Charles Wilson also concurred, defending Sullivan<\/em> as a cornerstone of First Amendment law.<\/p>\n

asks whether deliberate omission of qualifying language suffices to show actual malice; whether Sullivan<\/em> should be overruled or not applied to private citizens; and whether its clear-and-convincing-evidence rule should be relaxed. that this case is less a clean vehicle than a cable-news pileup: Florida law independently requires actual malice, the court of appeals found no evidence that CNN\u2019s speakers actually doubted their characterizations, and CNN aired the full remarks and later gave Dershowitz time to explain himself. And plus, CNN says, Sullivan<\/em> was correctly decided. While Thomas \u00a0\u00a0 cert-stage opinions that , as has Justice Neil Gorsuch, the other justices have not shown much interest in revisiting that case. So this petition seems more likely to produce separate writing than a grant.<\/p>\n

Service in immigration cases<\/strong><\/p>\n

United States v. Rivera-Valdes<\/em> is the solicitor general\u2019s effort to persuade the court that the U.S. Court of Appeals for the 9th Circuit has converted a modest due-process rule into an immigration-administering headache. Leopoldo Rivera-Valdes, a Mexican citizen, was served in 1994 with an order to show cause advising him that a deportation hearing would be scheduled at a future date and that notice would be mailed to his last-provided address. As then specified by statute, the government later mailed the hearing notice by certified mail to that address containing the time, place, and location of his hearing. But the letter was \u201cReturned to Sender\u201d \u201cunclaimed,\u201d and the immigration court proceeded without him and ordered Rivera-Valdes deported in absentia. After he was removed in 2006 and later reentered the country, Rivera-Valdes was charged with illegal reentry and collaterally attacked the old deportation order. <\/p>\n

Sitting en banc, the 9th Circuit held by a six-to-five vote that Jones v. Flowers<\/em> \u2013 a 2006 tax-sale case holding that the due process clause requires the government to take additional reasonable steps when certified-mail notice of a tax sale is returned unclaimed \u2013 applies in immigration removal proceedings too, and remanded for the district court to decide whether further practicable steps were available and whether Rivera-Valdes can satisfy the other requirements for a collateral attack under 8 U.S.C. \u00a7 1326(d) (the \u201cReentry of removed aliens\u201d statute).<\/p>\n

that Jones v. Flowers<\/em> does not justify requiring the government do more than Congress specified in attempting to serve immigrants with the hearing notice. It argues that Congress\u2019 certified-mail scheme for in absentia deportation orders was constitutionally adequate and that demanding immigration officials go beyond the statute whenever mail comes back will encourage evasion and unsettle old removal orders. responds that there is less here than meets the eye: there is no circuit split, as all 11 en banc judges agreed that Jones<\/em> supplies the governing due-process framework, the case is interlocutory (non-final), the district court has not yet resolved what additional steps were practicable or other \u00a7 1326(d) issues, and the particular certified-mail statute at issue was superseded three decades ago (now the statute provides for service by regular mail). That of a government petition on an immigration matter and a closely divided 9th Circuit en banc decision is usually enough to get attention. But the absence of a clean split, the changed statutory setting, and the remand posture may leave the court wondering whether this is the case to decide how far Jones<\/em> travels once it leaves the tax collector\u2019s office.<\/p>\n

A pro se prisoner petition with legs<\/strong><\/p>\n

Maxwell v. Thomas<\/em> presents the sort of humble-looking prisoner case that occasionally hides a real cert-worthy issue under a mountain of administrative-remedy paperwork. William Maxwell, a federal prisoner, filed a pro se petition \u2013 and, it must be said, a remarkably good one, complete with a circuit-split argument and an eye for vehicle problems (issues that might prevent a clean legal resolution) \u2013 arguing that the Bureau of Prisons wrongly refused to credit him under the First Step Act in a way that would have allowed earlier transfer to a halfway house or home confinement. As relevant here, the district court dismissed his claims for failure to exhaust administrative remedies\/adhere to the correct legal procedure. The U.S. Court of Appeals for the 5th Circuit did not reach the exhaustion issue; instead, relying on its \u201cbright-line rule\u201d from the 2020 case of Melot v. Bergami<\/em>, it held sua sponte that Maxwells\u2019 habeas petition is unavailable unless success would automatically shorten the prisoner\u2019s sentence, rather than merely reduce the level of custody.<\/p>\n

that the 5th Circuit\u2019s decision cannot be squared with language in 2022\u2019s Jones v. Hendrix<\/em> stating that habeas relief is available for a prisoner to argue that he is \u201cbeing detained in a place or manner not authorized by the sentence\u201d or that he \u201chas unlawfully been denied parole or good-time credits,\u201d as well as with other decisions allowing habeas challenges to the execution, place, or manner of confinement. He also alleged his case implicated a circuit split. The government waived its right to file a response, but the court ordered it to do so anyway. The government needed four extensions before filing.<\/p>\n

The government concedes that the 5th Circuit\u2019s determination that petitioner could not challenge BOP\u2019s execution of time credits under the First Step Act through a habeas petition was \u201cinconsistent with language in \u2026 Jones v. Hendrix<\/em>.\u201d It nevertheless states that review is unwarranted for two reasons: Maxwell failed to exhaust his administrative remedies, and the decision below reflects intracircuit tension between Melot v. Bergami<\/em> and an unpublished decision in Cheek v. Warden<\/em>, holding that a Section 2241 habeas petition (like this one) is an appropriate vehicle to raise a home-confinement request under another act (the CARES Act).<\/p>\n

After the court called for a response, Masha G. Hansford of Davis Polk (joined by lawyers from her former firm Paul Weiss) swooped in to file the , which gives the case a more conventional Supreme Court polish while preserving the basic point Maxwell had already spotted. The reply argues that the government essentially concedes both a conflict and the merits: the U.S. Courts of Appeals for the 1st, 2nd, and 3rd Circuits allow prisoners to use Section 2241 to seek a less restrictive form of custody, while the U.S. Courts of Appeals for the 5th and 8th Circuits require such claims to proceed, if at all, through civil-rights litigation \u2013 an especially unpromising route for federal prisoners.<\/p>\n

That\u2019s all for this week. Check back on Monday to see whether the court serves up some grants or just another helping of relist purgatory.<\/p>\n

New Relists<\/strong><\/p>\n

Dershowitz v. Cable News Network, Inc.<\/em>, 25-770<\/p>\n

Issues:<\/strong> (1) Whether a defendant\u2019s systematic omission of qualifying and limiting language from a plaintiff\u2019s recorded statement constitutes proof of actual malice under\u00a0New York Times Co. v. Sullivan<\/em>, sufficient to survive summary judgment; (2) whether the actual malice standard established in\u00a0Sullivan<\/em>, or as extended by its progeny, should be discarded altogether or at least as to private citizens who are public figures; and (3) whether this court should modify\u00a0Sullivan\u2019s<\/em>\u00a0clear-and-convincing and burden-of-proof evidentiary standards.<\/p>\n

(Relisted after the May 21 conference.)<\/p>\n

United States v. Rivera-Valdes<\/em>, 25-972<\/p>\n

Issue:<\/strong> Whether service of a notice of the time and place for deportation proceedings, sent by certified mail to an alien\u2019s self-reported address consistent with statutory notice procedures under the\u00a0Immigration and Nationality Act, is constitutionally adequate to support the entry of an in absentia deportation order as contemplated under\u00a08 U.S.C. 1252b(c).<\/p>\n

(Relisted after the May 21 conference.)<\/p>\n

Maxwell v. Thomas<\/em>, 25-5930<\/p>\n

Issues:<\/strong> (1) Whether disputes regarding the calculation of an inmate\u2019s earned First Step Act time credits, enabling the inmate to transfer into a halfway house or home confinement earlier, are actionable under\u00a028 U.S.C. \u00a7 2241; and (2) whether, given all the obstruction of the administrative remedy process that took place in this case, under\u00a0Perttu v. Richards<\/em>, exhaustion of administrative remedies is interwoven into the underlying claims, creating a fact issue for a jury.<\/p>\n

(Relisted after the May 21 conference.)<\/p>\n

Returning Relists<\/strong><\/p>\n

Gator\u2019s Custom Guns, Inc. v. Washington<\/em>, 25-153<\/p>\n

Issue:<\/strong> Whether ammunition feeding devices with the capacity to hold more than ten rounds are \u201cArms\u201d presumptively entitled to constitutional protection under the plain text of the Second Amendment.<\/p>\n

Read more The Roberts court\u2019s record on the First Amendment<\/a><\/p>\n

(Relisted after the Dec. 5, Dec. 12, Jan. 9, Jan. 16, Jan. 23, Feb. 20, Feb. 27, Mar. 6, Mar. 20, Mar. 27, Apr. 2, Apr. 17, Apr. 24, May 1, May 14, and May 21 conferences.)<\/p>\n

Duncan v. Bonta<\/em>, 25-198<\/p>\n

Issue:<\/strong> (1) Whether a ban on the possession of exceedingly common ammunition feeding devices violates the Second Amendment; and (2) whether a law dispossessing citizens, without compensation, of property that they lawfully acquired and long possessed without incident violates the takings clause.<\/p>\n

(Relisted after the Dec. 5, Dec. 12, Jan. 9, Jan. 16, Jan. 23, Feb. 20, Feb. 27, Mar. 6, Mar. 20, Mar. 27, Apr. 2, Apr. 17, Apr. 24, May 1, May 14, and May 21 conferences.)<\/p>\n

Viramontes v. Cook County<\/em>, 25-238<\/p>\n

Issue<\/strong>: Whether the Second and Fourteenth Amendments guarantee the right to possess AR-15 platform and similar semiautomatic rifles.<\/p>\n

(Relisted after the Dec. 5, Dec. 12, Jan. 9, Jan. 16, Jan. 23, Feb. 20, Feb. 27, Mar. 6, Mar. 20, Mar. 27, Apr. 2, Apr. 17, Apr. 24, May 1, May 14, and May 21 conferences.)<\/p>\n

National Association for Gun Rights v. Lamont<\/em>, 25-421<\/p>\n

Issue<\/strong>: Whether a ban on the possession of AR-15-style rifles and firearm magazines with a capacity in excess of 10 rounds violates the Second Amendment.<\/p>\n

(Relisted after the Feb. 20, Feb. 27, Mar. 6, Mar. 20, Mar. 27, Apr. 2, Apr. 17, Apr. 24, May 1, May 14, and May 21 conferences.)<\/p>\n

Grant v. Higgins<\/em>, 25-566<\/p>\n

Issue<\/strong>: Whether the Second and Fourteenth Amendments guarantee the right to possess semiautomatic rifles that are in common use for lawful purposes, including the AR-15.<\/p>\n

(Relisted after the Feb. 20, Feb. 27, Mar. 6, Mar. 20, Mar. 27, Apr. 2, Apr. 17, Apr. 24, May 1, May 14, and May 21 conferences.)<\/p>\n

Whitton v. Dixon<\/em>, 25-580<\/p>\n

Issues<\/strong>: (1) Whether in determining if a constitutional error had a prejudicial effect on the outcome of a trial a court must consider only that evidence that was presented to the jury at the trial; and (2) whether the prejudice from the\u00a0\u00a0violation in this case met the standards for relief under Giglio and\u00a0.<\/p>\n

(Relisted after the Mar. 6, Mar. 20, Mar. 27, Apr. 2, Apr. 17, Apr. 24, May 1, May 14, and May 21 conferences.)<\/p>\n

City of Los Angeles v. Estate of Hernandez<\/em>, 25-538<\/p>\n

Issue<\/strong>: (1) Whether the U.S. Court of Appeals for the 9th Circuit disregarded this court\u2019s precedents, including\u00a0Graham v. Connor<\/em>\u00a0and\u00a0Plumhoff v. Rickard<\/em>, by artificially parsing a six-second event into discrete segments, finding the first four shots reasonable, but the final two unconstitutional based on a split-second gap and slow-motion video review; (2) whether the 9th Circuit effectively adopted a new and more extreme \u201cmoment-of-threat\u201d rule that this court unanimously rejected in\u00a0Barnes v. Felix<\/em>; (3) whether, in denying qualified immunity, the en banc 9th Circuit evaluated whether the right at issue was \u201cclearly established\u201d at an impermissibly high level of generality, contrary to this court\u2019s repeated warnings in\u00a0Kisela v. Hughes<\/em>,\u00a0City & County of San Francisco v. Sheehan<\/em>, and\u00a0Ashcroft v. al-Kidd<\/em>; and (4) whether this case presents a novel opportunity to clarify Fourth Amendment guidance that while officers should be encouraged to continue to reassess a situation, they must also be judged in light of the rapidly evolving and life-threatening circumstances they confront.<\/p>\n

(Relisted after the Mar. 20, Mar. 27, Apr. 2, Apr. 17, Apr. 24, May 1, May 14, and May 21 conferences.)<\/p>\n

Florida v. California and Franchise Tax Board of California<\/em>, 22O163<\/p>\n

Issue<\/strong>: Whether Title 18,\u00a0Section 25137(c)(1)(A)\u00a0of the\u00a0California Code of Regulations\u00a0violates the Constitution\u2019s commerce clause, import-export clause, and due process clause.<\/p>\n

(Relisted after the Apr. 17, Apr. 24, May 1, May 14, and May 21 conferences.)<\/p>\n

Alabama v. Sykes<\/em>, 25-847<\/p>\n

Issue: (1) Whether courts must reverse for\u00a0Griffin v. California<\/em>\u00a0error without examining a prosecutor\u2019s comment in context and without finding prejudice; or (2) whether\u00a0Griffin<\/em>\u00a0should be overruled.<\/p>\n

(Relisted after the Apr. 17, Apr. 24, May 1, May 14, and May 21 conferences.)<\/p>\n

Alabama v. Powell<\/em>, 25-848<\/p>\n

Issue: (1) Whether courts must reverse for\u00a0Griffin v. California<\/em>\u00a0error without examining a prosecutor\u2019s comment in context and without finding prejudice; or (2) whether\u00a0Griffin<\/em>\u00a0should be overruled.<\/p>\n

(Relisted after the Apr. 17, Apr. 24, May 1, May 14, and May 21 conferences.)<\/p>\n

E.D. ex rel. Duell v. Noblesville School District<\/em>, 25-906<\/p>\n

Issue: Whether\u00a0Hazelwood School District v. Kuhlmeier<\/em>\u00a0applies (1) whenever student speech might be erroneously attributed to the school; (2) when student speech occurs in the context of an \u201corganized and structured educational activity\u201d; or (3) only when student speech is part of the \u201ccurriculum.\u201d<\/p>\n

(Relisted after the Apr. 17, Apr. 24, May 1, May 14, and May 21 conferences.)<\/p>\n

Smith v. Kind<\/em>, 25-943<\/p>\n

Issue: Whether, when a government official acts in an obviously unconstitutional manner, that is sufficient for the violation to be clearly established, or it is a violation clearly established only if there is binding precedent in a factually indistinguishable case.<\/p>\n

(Relisted after the Apr. 17, April 24, May 1, May 14, and May 21 conferences.)<\/p>\n

McCarthy v. Hernandez<\/em>, 25-748<\/p>\n

Issues:<\/strong> (1) Whether the U.S. Court of Appeals for the 2nd Circuit violated the\u00a0\u00a0by finding a state jury instruction invalid under\u00a0Missouri v. Seibert<\/em>; and (2) whether the 2nd Circuit violated AEDPA by finding that a single response by a state trial judge to a jury note necessarily infected the jury verdict, when the state courts found that there was more than sufficient evidence of the defendant\u2019s guilt that was unaffected by the response.<\/p>\n

(Relisted after the Apr. 24, May 1, May 14, and May 21 conferences.)<\/p>\n

Walters v. Coleman<\/em>, 25-867<\/p>\n

Issues:<\/strong> (1) Whether the U.S. Court of Appeals for the 4th Circuit violated the \u00a0and the party-presentation principle by granting habeas relief based on its de novo review of the state court\u2019s decision; and (2) whether the 4th Circuit violated AEDPA and the party-presentation principle by granting habeas relief on a state-court judgment that was not before it.<\/p>\n

Read more More redistricting drama<\/a><\/p>\n

(Relisted after the May 14 and May 21 conferences.)<\/p>\n<\/div>\n","protected":false},"excerpt":{"rendered":"

The Relist Watch column examines cert petitions that the Supreme Court has \u201crelisted\u201d for its upcoming conference. A short explanation of relists is available here. Read more Criminal law update: some defense-friendly rulings and a big case that wasn\u2019t The Supreme Court has done a substantial amount of house cleaning this week, disposing of six […]<\/p>\n","protected":false},"author":1,"featured_media":82,"comment_status":"open","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[1],"tags":[],"class_list":["post-83","post","type-post","status-publish","format-standard","has-post-thumbnail","hentry","category-interesting"],"yoast_head":"\nNew York Times v. 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