Opinion · Supreme Court of the United States

Florida v. Thomas

Fla. v. Thomas, 532 U.S. 774 (2001)

Type
Opinion
Court
Supreme Court of the United States
Jurisdiction
Federal
Date
2001-06-04
Topic
litigation

How later courts describe this case

  • finding no final judgment—and thus no jurisdiction to review state supreme court's 26 decision on constitutionality of search—where case remanded to trial court for further proceedings
  • "Although the parties did not raise the issue in their briefs on the merits, we must first consider whether we have jurisdiction to decide this case"
  • “[i]n a criminal prosecution, finality is generally defined by a judgment of conviction and the imposition of a sentence”
  • "We find the recent analysis of the Sixth Circuit Court of Appeals in [Hudgins] persuasive."
  • “Here the State can make no claim of serious erosion of federal policy that is not common to all run-of-the-mine decisions suppressing evidence in criminal trials.”
  • court “must first consider whether [it has] jurisdiction to decide this case”
  • emphasizing the "bright-line" nature of the Belton rule
  • dismissing for lack of jurisdiction

Citator

UpLaw has not yet analyzed Florida v. Thomas. The absence of a flag is not a finding that it is good law.

Cited by
32 opinions

Headnotes

  1. Federal Courts & Jurisdiction — Supreme Court Jurisdiction The Supreme Court must, as a threshold matter, consider whether it has jurisdiction to decide a case, even where the parties have not raised the issue in their briefs on the merits. 532 U.S. 774, 777–778 (citing Duquesne Light Co. v. Barasch, 488 U.S. 299, 306)
  2. Federal Courts & Jurisdiction — Supreme Court Jurisdiction Under 28 U.S.C. § 1257(a), the Supreme Court may review only final judgments or decrees rendered by the highest court of a State; in a criminal prosecution, finality is generally defined by a judgment of conviction and the imposition of a sentence. 532 U.S. at 778 (citing Fort Wayne Books, Inc. v. Indiana, 489 U.S. 46, 54)
  3. Federal Courts & Jurisdiction — Supreme Court Jurisdiction The Supreme Court has departed from a strict finality rule in certain circumstances, treating state-court judgments as final for jurisdictional purposes even though further proceedings were to take place in the state court; such cases fall into four categories enumerated in Cox Broadcasting Corp. v. Cohn. 532 U.S. at 778–781 (citing Flynt v. Ohio, 451 U.S. 619, 620–621; Cox Broadcasting Corp. v. Cohn, 420 U.S. 469, 479–483)
  4. Federal Courts & Jurisdiction — Supreme Court Jurisdiction A state-court judgment is final for purposes of Supreme Court review where further proceedings, even entire trials, remain in the state courts but the federal issue is conclusive or the outcome of the further proceedings is preordained, as when the defendant concedes that his only defense to the state charge is his constitutional claim. 532 U.S. at 778–779 (citing Cox Broadcasting Corp. v. Cohn, 420 U.S. 469, 479; Mills v. Alabama, 384 U.S. 214, 216–218)
  5. Federal Courts & Jurisdiction — Supreme Court Jurisdiction A state-court judgment is final for purposes of Supreme Court review where the federal issue finally decided by the State's highest court will survive and require decision regardless of the outcome of future state-court proceedings, as where the state proceedings on remand could not remotely give rise to a federal question that might later come before the Court. 532 U.S. at 779–780 (citing Cox Broadcasting Corp. v. Cohn, 420 U.S. 469, 480; Radio Station WOW, Inc. v. Johnson, 326 U.S. 120)
  6. Federal Courts & Jurisdiction — Supreme Court Jurisdiction A state-court judgment is final for purposes of Supreme Court review where the federal claim has been finally decided, with further proceedings on the merits to come, but later review of the federal issue cannot be had whatever the ultimate outcome—as where a suppression ruling would be moot if the State obtained a conviction and the State would be precluded from pressing its claim if the defendant were acquitted. 532 U.S. at 780–781 (citing Cox Broadcasting Corp. v. Cohn, 420 U.S. 469, 481; New York v. Quarles, 467 U.S. 649, 651 & n.1)
  7. Federal Courts & Jurisdiction — Supreme Court Jurisdiction Where a state judgment is not final, the Court will dismiss the writ of certiorari for want of jurisdiction; a State that may appeal an adverse pretrial suppression ruling under state law can obtain review of both the suppression and related federal issues after the state courts finally decide the matter. 532 U.S. at 781 (citing Fla. Stat. § 924.071(1) (1996); Fla. Rule App. Proc. 9.140(c)(1)(B) (2001); Jefferson v. City of Tarrant, 522 U.S. 75, 83)
  8. Federal Courts & Jurisdiction — Supreme Court Jurisdiction The fourth Cox category—where the federal issue has been finally decided, further proceedings are pending in which the party seeking review might prevail on nonfederal grounds, and reversal on the federal issue would be preclusive of further litigation rather than merely controlling the admissibility of evidence—permits review only where refusal to review immediately might seriously erode federal policy; no such claim lies where the asserted erosion is common to all run-of-the-mine decisions suppressing evidence in criminal trials. 532 U.S. at 781 (citing Cox Broadcasting Corp. v. Cohn, 420 U.S. 469, 482–483)