The U.S. Supreme Court issued two criminal law decisions today.  In Ayestas v. Davis, the Court held that the Fifth Circuit had applied the wrong standard to review a district court decision to deny a funding request in a capital habeas case under 18 U.S.C. § 3599.  I will have more to say on this decision later. 

In Marinello v. United States, the Court held, "To convict a defendant under [a law against obstructing tax collection], the Government must prove the defendant was aware of a pending tax-related proceeding, such as a particular investigation or audit, or could reasonably foresee that such a proceeding would commence."