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Carney v. Adams

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Supreme Court of the United States
Carney v. Adams
Term: 2020-2021
(Originally 2019-2020)
Important Dates
Argument: October 5, 2020
Decided: December 10, 2020
Outcome
Vacated and remanded
Vote
8-0
Majority
Chief Justice John G. Roberts • Clarence Thomas • Stephen Breyer • Samuel Alito • Sonia Sotomayor • Elena Kagan • Neil Gorsuch • Brett Kavanaugh
Concurring
Sonia Sotomayor


Carney v. Adams is a case argued before the Supreme Court of the United States on October 5, 2020, during the court's October 2020-2021 term. It came on a writ of certiorari to the United States Court of Appeals for the 3rd Circuit. The case concerned judicial selection in Delaware.

The court vacated the 3rd Circuit's decision in an 8-0 ruling, holding James Adams, the respondent, did not have the legal right to sue the governor of Delaware. Justice Stephen Breyer wrote the opinion and Justice Sonia Sotomayor filed a concurring opinion. Justice Amy Coney Barrett did not take part in the case. Click here for more information about the ruling.

Oral argument was initially scheduled for March 25, 2020, during the court's October 2019-2020 term. However, the U.S. Supreme Court announced on March 16 that it was postponing the 11 oral arguments originally scheduled during its March sitting. In a press release, the court said the delay was "in keeping with public health precautions recommended in response to COVID-19."[1] COVID-19 was the abbreviation for coronavirus disease 2019, caused by SARS-CoV-2.

  • Click here for more information about the court's response to the coronavirus pandemic.
  • Click here for more information about political responses to the pandemic.
HIGHLIGHTS
  • The case: As of December 2019, when the governor of Delaware filed a petition before the U.S. Supreme Court, Article IV, Section 3 of the Delaware Constitution required that no more than the bare majority of judges on a given Delaware court could be of the same political party. James Adams, a retired lawyer, sued the governor of Delaware in federal district court. Adams argued Article IV, Section 3 violated the First Amendment. The governor, in response, argued Adams did not have the legal right to file a lawsuit. A federal magistrate judge ruled the state constitution's provision was unconstitutional. On appeal, the U.S. Court of Appeals for the 3rd Circuit affirmed in part and reversed in part the federal district court's ruling. Governor John Carney (D), acting in his official capacity, filed a petition with the U.S. Supreme Court, arguing the 3rd Circuit's decision conflicted with decisions in similar cases from the 2nd Circuit, 6th Circuit, and the 7th Circuit.[2][3]
  • The issues: (1) Does the First Amendment invalidate the Delaware Constitution's "bare majority" requirement? (2) Was the 3rd Circuit wrong to hold that part of the Delaware Constitution's "bare majority" requirement is not severable from the rest of the requirement? (3) Does the respondent have standing?[4]
  • The outcome: The court vacated the 3rd Circuit's decision in an 8-0 ruling, holding James Adams, the respondent, did not have standing to sue the governor of Delaware. Justice Stephen Breyer wrote the opinion and Justice Sonia Sotomayor filed a concurring opinion. Justice Amy Coney Barrett did not take part in the case's consideration or decision.


    • Click here to review the lower court's opinion.

    Timeline

    The following timeline details key events in this case:

    • December 10, 2020: The U.S. Supreme Court vacated and remanded the U.S. Court of Appeals for the 3rd Circuit's ruling.
    • October 5, 2020: Oral argument was heard.
    • March 16, 2020: The U.S. Supreme Court postponed its March sitting. Oral arguments were initially scheduled for March 25, 2020.
    • December 6, 2019: The U.S. Supreme Court agreed to hear the case.
    • September 4, 2019: The governor of Delaware, the petitioner, filed a petition with the U.S. Supreme Court.
    • April 10, 2019: The 3rd Circuit affirmed in part and reversed in part the U.S. District Court for the District of Delaware's ruling.

    Background

    See also: Judicial selection in Delaware

    As of December 2019, when the governor of Delaware filed a petition before the U.S. Supreme Court, Article IV, Section 3 of the Delaware Constitution required that no more than the bare majority of judges on a given Delaware court could be of the same political party. A bare majority is one where the majority party has a one-seat advantage on the minority party. On a five-member court, for example, a bare majority would be a 3-2 majority.[2]

    James R. Adams, a retired lawyer, was registered as a Democrat until 2016. In 2009, Adams applied for a position on the Delaware Family Court. He was not selected. Adams changed his party affiliation to independent in 2017.[2]

    In February of that year, Adams filed a lawsuit in U.S. district court against the governor of Delaware, arguing the state's bare majority requirement "violate[d] his First Amendment right to be considered for public office without regard to his political affiliation."[2] The governor argued Adams did not have the legal right to sue the state. Magistrate Judge Mary Pat Thynge ruled the bare majority provision was unconstitutional.[3]

    The governor appealed to the United States Court of Appeals for the 3rd Circuit. In April 2019, a three-judge panel affirmed in part and reversed in part the U.S. district court's ruling. The circuit court ruled that the bare majority provision violated the First Amendment. However, it also ruled Adams did not have the legal right, or standing, to challenge certain sections of Article IV, Section 3.[3]

    Governor John Carney (D), acting in his official capacity, filed a petition with the U.S. Supreme Court. In the petition, the governor argued the 3rd Circuit's ruling conflicted with decisions in similar cases from the 2nd Circuit, 6th Circuit, and the 7th Circuit. The governor also argued SCOTUS should "reaffirm that federal courts are obligated to respect the States’ sovereign authority to structure their own governments, including by setting qualifications for state judges."[2]

    Questions presented

    The petitioner presented the following questions to the court:[4]

    Questions presented:
    “

    1. Does the First Amendment invalidate a longstanding state constitutional provision that limits judges affiliated with any one political party to no more than a "bare majority" on the State's three highest courts, with the other seats reserved for judges affiliated with the "other major political party?

    2. Did the Third Circuit err in holding that a provision of the Delaware Constitution requiring that no more than a "bare majority" of three of the state courts may be made up of judges affiliated with any one political party is not severable from a provision that judges who are not members of the majority party on those courts must be members of the other "major political party," when the former requirement existed for more than fifty years without the latter, and the former requirement, without the latter, continues to govern appointments to two other courts?[5]

    		”


    The court additionally directed the parties to answer the following:[4]

    Questions presented:
    “ Whether respondent has demonstrated Article III standing.[5] ”

    Oral argument

    Audio

    Audio of oral argument:[6]



    Transcript

    Outcome

    In an 8-0 opinion, the court vacated the judgment of the United States Court of Appeals for the 3rd Circuit. The court held that James Adams, the respondent, did not having standing. Justice Stephen Breyer delivered the opinion of the court. Justice Sonia Sotomayor filed a concurring opinion. Justice Amy Coney Barrett did not take part in the consideration or decision of the case.[7]

    Opinion

    In his opinion, Justice Breyer wrote:

    “ The plaintiff, a Delaware lawyer, brought this lawsuit in federal court. He claimed that Delaware’s party-membership requirements for its judiciary violate the Federal Constitution. We agreed to consider the constitutional question, but only if the plaintiff has standing to raise that question. We now hold that he does not. ...


    A plaintiff cannot establish standing by asserting an abstract “general interest common to all members of the public,” id., at 440, “no matter how sincere” or “deeply committed” a plaintiff is to vindicating that general interest on behalf of the public. ...

    Our holding follows from a straightforward application of precedent to the particular summary judgment record before us. And, as we have explained, in the context set forth by the evidence, Adams has not shown that he was “able and ready” to apply in the imminent future. Consequently, he has failed to show that “personal,” “concrete,” and “imminent” injury upon which our standing precedents insist.

    For these reasons, we reverse the Third Circuit’s decision in respect to standing, vacate the judgment, and remand with instructions to dismiss the case.[5]

    		”
    —Justice Breyer

    Concurring opinion

    In her concurring opinion, Justice Sotomayor wrote separately to emphasize two aspects she believed would likely appear again in court.

    Sotomayor wrote that Delaware's "bare majority" provision was a "major party" requirement which "preclude[s] anyone who is not a member of the two major political parties from serving in a public body." She compared this to another type of provision, which she referred to as a "bare majority" requirement, which "preclude[s] any single political party from having more than a bare majority of the seats in a public body." According to Sotomayor, "These differences may require distinct constitutional analyses."[7]

    Sotomayor also addressed questions of severability, i.e., if part of the Delaware Constitution's provision falls, can the rest of the law still be enforced? Sotomayor wrote, "It is worth noting that federal courts are not ideally positioned to address such a sensitive issue of state constitutional law. They may therefore be well advised to consider certifying such a question to the State’s highest court."[7]

    Text of the opinion

    Click here to read the full opinion.

    October term 2020-2021

    See also: Supreme Court cases, October term 2020-2021

    The Supreme Court began hearing cases for the term on October 5, 2020. The court's yearly term begins on the first Monday in October and lasts until the first Monday in October the following year. The court generally releases the majority of its decisions in mid-June.[8]

    The court issued 67 opinions during its 2020-2021 term. Two cases were decided in one consolidated opinion. Ten cases were decided without argument. Click here for more information on the court's opinions.

    The court agreed to hear 62 cases during its 2020-2021 term. Of those, 12 were originally scheduled for the 2019-2020 term but were delayed due to the coronavirus pandemic. Five cases were removed from the argument calendar.


    See also

    External links

    Footnotes

    1. ↑ U.S. Supreme Court, "Press release from March 16, 2020," accessed March 16, 2020
    2. ↑ 2.0 2.1 2.2 2.3 2.4 Supreme Court of the United States, "Petition for a writ of certiorari," accessed December 9, 2019
    3. ↑ 3.0 3.1 3.2 United States Court of Appeals for the 3rd Circuit, Adams v. Governor of Delaware, decided April 10, 2019
    4. ↑ 4.0 4.1 4.2 Supreme Court of the United States, "Questions presented, Carney v. Adams," accessed December 9, 2019
    5. ↑ 5.0 5.1 5.2 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    6. ↑ Supreme Court of the United States, "Oral Argument - Audio," accessed October 12, 2020
    7. ↑ 7.0 7.1 7.2 Supreme Court of the United States, Carney v. Adams, decided December 10, 2020
    8. ↑ SupremeCourt.gov, "A Brief Overview of the Supreme Court," accessed April 20, 2015
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