Help us improve in just 2 minutes—share your thoughts in our reader survey.

Dupree v. Younger

From Ballotpedia
Jump to: navigation, search

Supreme Court of the United States
Dupree v. Younger
Term: 2022
Important Dates
Argued: April 24, 2023
Decided: May 25, 2023
Outcome
vacated and remanded
Vote
9-0
Majority
Chief Justice John Roberts • Clarence Thomas • Samuel Alito • Sonia Sotomayor • Elena Kagan • Neil Gorsuch • Brett Kavanaugh • Amy Coney Barrett • Ketanji Brown Jackson

Dupree v. Younger is a case that was decided by the Supreme Court of the United States on May 25, 2023, during the court's October 2022-2023 term. The case was argued before the Supreme Court of the United States on April 24, 2023. In a unanimous opinion, the Court vacated and remanded the judgment of the United States Court of Appeals for the Fourth Circuit, holding that a post-trial motion is not required for a party to request an appellate court to review an argument that they had lost in a lower court summary judgment due to purely legal reasons. Justice Amy Coney Barrett delivered the opinion.[1]

HIGHLIGHTS
  • The questions presented: Whether to preserve the issue for appellate review a party must reassert in a post-trial motion a purely legal issue rejected at summary judgment.[2]
  • The outcome: The Supreme Court vacated and remanded the judgment of the United States Court of Appeals for the Fourth Circuit, holding that a post-trial motion is not required for a party to request an appellate court to review an argument that they had lost in a lower court summary judgment due to purely legal reasons.[1]


    • The case came on a writ of certiorari to the United States Court of Appeals for the Fourth Circuit. To review the lower court's opinion, click here.

    Timeline

    The following timeline details key events in this case:

    Background

    Kevin Younger was being detained and awaiting trial at the Maryland Reception, Diagnostic & Classification Center (MRDCC), where guards have a history of claims of assaulting inmates. Younger claims that in 2013, three MRDCC guards entered his cell and physically assaulted him. Younger sued the guards, the state of Maryland, the current Secretary of the Maryland Department of Public Safety and Correctional Services, and a number of senior prison officials including Neil Dupree. Younger sued the defendants in the U.S. District Court for the District of Maryland. Under 42 U.S.C. § 1983, he argued that they violated his due process rights.[3]

    Dupree moved to dismiss the lawsuit. He argued that Younger had failed to exhaust all internal prison remedies, a step that the Prison Litigation Reform Act of 1995 (PLRA) set as a requirement for suits brought by inmates. The district court ruled against Dupree, concluding that because of an ongoing investigation into the attack allegations, the internal prison remedies were not available to Younger.[4][5]

    Dupree appealed the district court’s decision to the U.S. Court of Appeals for the Fourth Circuit. The circuit court ruled against him, holding that although he had raised the PLRA requirement in a pretrial motion, he had not done so in a post-trial motion. Therefore, the argument was not eligible for review. Dupree has asked the Supreme Court to review the circuit court’s decision and reopen his case.[4][5]

    Questions presented

    The petitioner presented the following questions to the court:[2]

    Questions presented:
    “ Whether to preserve the issue for appellate review a party must reassert in a

    post-trial motion a purely legal issue rejected at summary judgment. [6]

    		”

    Oral argument

    Audio

    Audio of oral argument:[7]



    Transcript

    Transcript of oral argument:[8]

    Outcome

    In a unanimous opinion, the Supreme Court vacated and remanded the judgment of the United States Court of Appeals for the Fourth Circuit, holding that a post-trial motion is not required for a party to request an appellate court to review an argument that they had lost in a lower court summary judgment due to purely legal reasons. Justice Amy Coney Barrett delivered the opinion of the court.[1][9]

    Opinion

    In the court's majority opinion, Justice Amy Coney Barrett wrote:[1]

    “ The Fourth Circuit was wrong to hold that purely legal issues resolved at summary judgment must be renewed in a post-trial motion. We need not decide whether the issue Dupree raised on appeal is purely legal—the Court of Appeals may evaluate that and any other properly preserved arguments in the first instance. We therefore vacate the judgment of the Court of Appeals and remand the case for further proceedings consistent with this opinion.

    [6]

    		”
    —Justice Amy Coney Barrett

    Text of the opinion

    Read the full opinion here.

    October term 2022-2023

    See also: Supreme Court cases, October term 2022-2023

    The Supreme Court began hearing cases for the term on October 3, 2022. 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.[10]


    See also

    External links

    Footnotes

    1. ↑ 1.0 1.1 1.2 1.3 U.S. Supreme Court, "Dupree V. Younger Certiorari to the United States Court of Appeals for the Fourth Circuit," accessed May 26, 2023
    2. ↑ 2.0 2.1 'Supreme Court, "22-210 DUPREE V. YOUNGER," accessed January 20, 2023
    3. ↑ 'Supreme Court, "Dupree v. Younger," accessed April 20, 2023
    4. ↑ 4.0 4.1 'U.S. Supreme Court, "NEIL DUPREE, PETITIONER, v. KEVIN YOUNGER ON PETITION FOR A WRIT OF CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT," accessed January 20, 2023
    5. ↑ 5.0 5.1 'SCOTUSblog, "In Maryland prison-assault case, a request to clarify an important procedural question," accessed January 20, 2023
    6. ↑ 6.0 6.1 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    7. ↑ [Oral argument audio page https://www.supremecourt.gov/oral_arguments/audio/2022/22-210 Supreme Court of the United States, "Oral Argument - Audio," argued April 24, 2023]
    8. ↑ Supreme Court of the United States, "Oral Argument - Transcript," argued April 24, 2023
    9. ↑ 'SCOTUSblog, "Dupree v. Younger," accessed May 26, 2023
    10. ↑ SupremeCourt.gov, "The Supreme Court at Work: The Term and Caseload," accessed January 24, 2022
    Retrieved from "https://ballotpedia.org/wiki/index.php?title=Dupree_v._Younger&oldid=9149148"