U.S. Supreme Court - Justia Case Law Summaries

Trump v. Barbara

2026-06-30T07:15:10-08:00

Several parents, some acting on behalf of their children, challenged a presidential executive order issued in January 2025. The order declared that children born in the United States to parents who were unlawfully or temporarily present would not be considered “subject to the jurisdiction” of the United States, and therefore would not be entitled to citizenship under the Fourteenth Amendment or the Immigration and Nationality Act. The plaintiffs argued that this order violated both the Constitution and the INA, as it denied citizenship to children based solely on the immigration status of their parents at the time of birth. The United States District Court for the District of New Hampshire reviewed the case and agreed with the plaintiffs. It provisionally certified a nationwide class of children affected by the order and issued a preliminary injunction, blocking enforcement of the executive order. The government appealed, and the Supreme Court of the United States granted certiorari before judgment from the United States Court of Appeals for the First Circuit. The Supreme Court held that children born in the United States to parents who are unlawfully or temporarily present are “subject to the jurisdiction” of the United States, and are entitled to citizenship at birth under the Fourteenth Amendment’s Citizenship Clause. The Court based its holding on the historical understanding of citizenship rooted in the English common law, the repudiation of Dred Scott v. Sandford, and the precedent established in United States v. Wong Kim Ark. The Court affirmed the judgment of the District Court, upholding birthright citizenship for these children. View "Trump v. Barbara" on Justia Law

National Republican Senatorial Committee v. Federal Election Commission

2026-06-30T07:15:07-08:00

A group of candidates and political party committees, including then-Senate candidate JD Vance and various Republican campaign committees, challenged federal limits on coordinated campaign expenditures by political parties under the Federal Election Campaign Act (FECA). These limits restrict the amount a party can spend in direct coordination with a candidate’s campaign. Plaintiffs argued that the restrictions violate the First Amendment, especially given modern developments in campaign finance law and enforcement tools such as earmarking and disclosure requirements. JD Vance maintained standing to challenge the law, as he had an active Statement of Candidacy and a campaign committee, despite later becoming Vice President. The case was first reviewed by the en banc United States Court of Appeals for the Sixth Circuit, which upheld FECA’s coordinated-expenditure limits. The Sixth Circuit relied primarily on the Supreme Court’s 2001 precedent, Federal Election Commission v. Colorado Republican Federal Campaign Committee (Colorado II), which had previously sustained these limits against First Amendment challenges. However, several Sixth Circuit judges questioned whether Colorado II remained good law in light of more recent Supreme Court decisions, including McCutcheon v. Federal Election Commission and Federal Election Commission v. Ted Cruz for Senate. The Supreme Court of the United States granted certiorari and ultimately reversed the Sixth Circuit. The Court held that FECA’s limits on political-party coordinated expenditures violate the First Amendment. Applying rigorous scrutiny, the Court determined that the limits are not necessary, narrowly tailored, or proportionate to the government’s interest in preventing circumvention of candidate contribution limits, especially given the effectiveness of existing earmarking rules and disclosure laws. The Court explicitly overruled Colorado II, concluding that subsequent precedents have rendered it obsolete. The judgment of the Sixth Circuit was reversed and the case remanded for further proceedings. View "National Republican Senatorial Committee v. Federal Election Commission" on Justia Law

West Virginia v. B. P. J.

2026-06-30T07:15:06-08:00

A state law in West Virginia prohibited male students, as determined by biological sex, from participating on female sports teams. A student who is a biological male but identifies as female and has taken puberty blockers and hormones sought to participate on the girls’ cross-country and track-and-field teams and brought suit against West Virginia officials, alleging violations of Title IX and the Equal Protection Clause. Similarly, Idaho passed a law barring male students from female sports teams; a transgender woman who is a biological male but identifies as female and had taken hormones challenged Idaho’s law after trying out for collegiate women’s sports. Both states justified their laws by referencing inherent physical differences between the sexes and concerns for safety and competitive fairness in women’s sports. The United States District Court for the Southern District of West Virginia granted summary judgment for the state, finding no violation of Title IX or the Equal Protection Clause. The United States Court of Appeals for the Fourth Circuit reversed the ruling on the Title IX claim and remanded for further factual findings on the Equal Protection claim. Meanwhile, in Idaho, the United States District Court for the District of Idaho issued a preliminary injunction against enforcement of the statute; the United States Court of Appeals for the Ninth Circuit affirmed that decision, finding a likely violation of the Equal Protection Clause. The Supreme Court of the United States reversed both appellate court decisions. It held that Title IX permits schools to maintain separate men’s and women’s sports teams determined by biological sex and does not require exceptions for transgender athletes, regardless of puberty blockers or hormone use. The Court further held that the Equal Protection Clause does not bar states from limiting female sports teams to biological females, finding the sex-based classification substantially related to important government interests in safety and competitive fairness. The cases were remanded for further proceedings consistent with this opinion. View "West Virginia v. B. P. J." on Justia Law

Trump v. Cook

2026-06-29T07:15:11-08:00

In August 2025, the President attempted to remove a sitting member of the Board of Governors of the Federal Reserve System, Lisa Cook, citing allegations of mortgage fraud that predated her tenure. This was the first time in the Federal Reserve’s history that a Governor was purportedly fired. Cook, whose term was scheduled to run until 2038, received a letter from the President stating that her integrity was in question due to potential misconduct, and that her immediate removal was necessary. Cook filed suit, arguing both that the alleged misconduct did not constitute “cause” for removal under the governing statute, and that she had not been given the required process—namely, notice and an opportunity to respond—before her termination. The United States District Court for the District of Columbia issued a preliminary injunction preventing Cook’s removal, finding she was likely to succeed on her claims that the purported “cause” did not satisfy the statutory standard, and that she had not received constitutionally or statutorily required pre-termination process. The United States Court of Appeals for the District of Columbia Circuit declined to stay the injunction, with a concurrence emphasizing the due process issue. The Government then sought a stay from the Supreme Court. The Supreme Court of the United States denied the Government’s application for a stay. The Court held that the President’s power to remove Federal Reserve Governors is subject to judicial review and that “cause” for removal must be substantial and related to the Governor’s official duties, reflecting the Federal Reserve’s need for independence. Most importantly, the Court ruled that Governors are entitled by statute to notice and an opportunity to respond before removal. Because Cook was not afforded these protections, her removal could not stand pending further litigation. The Court declined to address broader constitutional questions, deciding the case on statutory grounds. View "Trump v. Cook" on Justia Law

Trump v. Slaughter

2026-06-29T07:15:09-08:00

After President Trump began his second term in 2025, he dismissed two Democratic commissioners from the Federal Trade Commission (FTC), Rebecca Slaughter and Alvaro Bedoya, citing that their continued service conflicted with his administration’s priorities. He did not allege any statutory cause for their removal, instead asserting authority under Article II of the Constitution. Slaughter sued, arguing her removal was unlawful under the relevant statute, the Administrative Procedure Act, and the Constitution. Bedoya’s claims were dismissed as moot after he resigned, leaving only Slaughter’s case at issue. The United States District Court for the District of Columbia granted summary judgment in Slaughter’s favor, finding that President Trump’s action was ultra vires because the relevant statute allows removal of FTC commissioners only for “inefficiency, neglect of duty, or malfeasance in office.” The court relied on the Supreme Court’s prior decision in Humphrey’s Executor v. United States, which had recognized such statutory protections for FTC commissioners. The court issued a permanent injunction prohibiting interference with Slaughter’s ability to perform her duties. The United States Court of Appeals for the District of Columbia Circuit denied the government’s motion for a stay pending appeal, finding that Humphrey’s Executor controlled the issue. The Supreme Court of the United States reversed. It held that the FTC’s statutory provision limiting removal of commissioners to “for cause” is unconstitutional because it impermissibly restricts the President’s authority to remove executive officers. The Court overruled Humphrey’s Executor to the extent it permitted such statutory insulation for executive officers, reaffirming that officers exercising executive power must be removable by the President at will to preserve the Constitution’s separation of powers. The case was remanded for further proceedings consistent with this holding. View "Trump v. Slaughter" on Justia Law

Chatrie v. United States

2026-06-29T07:15:07-08:00

A man robbed a credit union in Midlothian, Virginia in May 2019. Police learned from witnesses and surveillance that the robber appeared to use a cell phone but could not identify him. To find leads, the officers applied for a geofence warrant, compelling Google to provide anonymized location data for all cell phones within a 150-meter radius of the credit union around the time of the crime. The warrant described a three-step process: first, Google would produce anonymized data for all devices within the geofence for an hour; second, police would narrow the list and receive additional location data for those devices; third, police would further narrow the list and obtain identifying information. Ultimately, Google provided the identities of three users, including the petitioner, whose movements matched those of the robber. The United States District Court for the Eastern District of Virginia found the geofence warrant “plainly violates the rights enshrined in [the Fourth] Amendment” but denied the motion to suppress the evidence, applying the good-faith exception to the exclusionary rule. A divided panel of the United States Court of Appeals for the Fourth Circuit affirmed, but on the ground that no Fourth Amendment search had occurred because the petitioner had no reasonable expectation of privacy in the Location History data given to Google. On rehearing en banc, the Fourth Circuit affirmed in a one-sentence opinion, dividing evenly on the search question. The Supreme Court of the United States held that police conduct a Fourth Amendment search when they acquire an individual’s cell-phone Location History data from Google, because a person has a reasonable expectation of privacy in such information. The Court vacated the Fourth Circuit’s judgment and remanded the case for further proceedings to determine whether the warrant satisfied the Fourth Amendment’s requirements of particularity and probable cause at each stage of the search process. View "Chatrie v. United States" on Justia Law

Watson v. Republican National Committee

2026-06-29T07:15:05-08:00

Mississippi allows certain residents, including college students away from home and senior citizens, to vote in federal elections by absentee ballot. These absentee ballots must be postmarked on or before election day and received by the registrar no more than five business days after the election. In 2024, several Republican-affiliated organizations and individuals, as well as the Libertarian Party of Mississippi, sued the Mississippi Secretary of State and other election officials. They argued that federal election-day statutes require both the casting and receipt of ballots to occur by election day, thereby preempting Mississippi’s law that permits counting absentee ballots received after election day. The United States District Court for the Southern District of Mississippi consolidated the cases and granted summary judgment in favor of Mississippi, finding no conflict between federal statute and state law. The United States Court of Appeals for the Fifth Circuit reversed, holding that the federal election-day statutes preempt Mississippi’s law, and required ballots to be received by election day. The Fifth Circuit denied rehearing and rehearing en banc, prompting the defendants to seek review by the Supreme Court. The Supreme Court of the United States held that the federal election-day statutes do not prevent Mississippi from counting absentee ballots postmarked by election day but received up to five days later. The Court clarified that the federal statutes set the deadline for when votes must be cast, not when they must be received, and that state law governs ballot receipt deadlines. The Court reversed the Fifth Circuit’s decision and remanded the case for further proceedings, emphasizing that the statutes do not preempt Mississippi’s practice of counting properly postmarked but late-arriving absentee ballots. View "Watson v. Republican National Committee" on Justia Law

Mullin v. Al Otro Lado

2026-06-25T06:45:12-08:00

In 2016, U.S. Customs and Border Protection faced a surge of individuals seeking admission at ports along the U.S.-Mexico border, often exceeding the capacity for safe processing. To manage this, the Department of Homeland Security instituted a “metering” policy that limited the number of people allowed to cross each day, with CBP officials stationed on the U.S. side of the border to prevent entry beyond daily capacity. The policy’s enforcement meant that some asylum seekers remained in Mexico, unable to present themselves for inspection or apply for asylum immediately. A group of asylum seekers and the advocacy organization Al Otro Lado filed a class action in the United States District Court for the Southern District of California, challenging the legality of metering. The District Court certified a class and granted summary judgment for the plaintiffs, declaring the government’s denial of inspection and asylum processing to those “in the process of arriving in the United States” to be unlawful. After the government rescinded the metering policy, the United States Court of Appeals for the Ninth Circuit affirmed in part, holding that an individual standing in Mexico who encounters a U.S. official at the border “arrives in the United States” for purposes of inspection and asylum eligibility. The Supreme Court of the United States reversed the Ninth Circuit’s decision. It held that under the Immigration and Nationality Act, an alien “arrives in the United States” only upon physically crossing the border. The statutory language does not entitle someone standing in Mexico to inspection or to apply for asylum, nor does it require U.S. officials to inspect such individuals. The Court concluded that the statutory provisions at issue do not have extraterritorial effect and that the metering policy, as applied, was not unlawful under the INA. The judgment was reversed and remanded. View "Mullin v. Al Otro Lado" on Justia Law

Mullin v. Doe

2026-06-25T06:45:11-08:00

Several Syrian and Haitian nationals challenged the United States Secretary of Homeland Security’s decision to terminate Temporary Protected Status (TPS) designations for Syria and Haiti. TPS provides humanitarian relief for foreign nationals who cannot safely return to their countries. Syria’s TPS status, granted in 2012 due to civil war, was set for termination in 2025 following changes in the country’s government and improved conditions. Haiti’s TPS status, in place since a 2010 earthquake, was also scheduled for termination in 2026, with the government citing improved conditions and foreign policy considerations. In the United States District Court for the Southern District of New York, Syrian plaintiffs sued under the Administrative Procedure Act (APA), and the court granted interim relief, postponing termination. The United States Court of Appeals for the Second Circuit denied the government’s request for a stay. Separately, Haitian plaintiffs in the United States District Court for the District of Columbia brought APA and constitutional equal protection claims, alleging racial motivation behind the termination. That court also granted interim relief, and the United States Court of Appeals for the District of Columbia Circuit declined to issue a stay. The government petitioned for a stay and certiorari before judgment, after which the Supreme Court consolidated the cases for review. The Supreme Court of the United States held that the TPS statute bars judicial review of any non-constitutional claims related to the designation, extension, or termination of TPS for a foreign state. The Court also concluded that the equal protection claim brought by the Haitian plaintiffs was unlikely to succeed, finding insufficient evidence that race was a motivating factor in the termination decision. As a result, the Supreme Court reversed the interim relief granted by both district courts and remanded the cases for further proceedings. View "Mullin v. Doe" on Justia Law

Monsanto v. Durnell

2026-06-25T06:45:09-08:00

Monsanto Company manufactures Roundup, a glyphosate-based herbicide. The Environmental Protection Agency (EPA) has repeatedly evaluated glyphosate and concluded it is not likely to cause cancer, and as a result, EPA has not required a cancer warning on Roundup’s label. John Durnell used Roundup for about 20 years and developed non-Hodgkin’s lymphoma. He sued Monsanto in Missouri state court, asserting a failure-to-warn claim, arguing that Monsanto should have included a cancer warning on Roundup’s label. A jury in the Missouri trial court found in Durnell’s favor on the failure-to-warn claim and awarded him more than $1 million in damages. Monsanto argued that the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) expressly preempted the state-law failure-to-warn claim because it would require labeling different from what the EPA mandates. The Missouri trial court rejected this argument, and the Missouri Court of Appeals affirmed, reasoning that Missouri’s failure-to-warn requirements were consistent with FIFRA’s misbranding provisions. The Supreme Court of the United States reviewed the case. It held that FIFRA expressly preempts Durnell’s state-law failure-to-warn claim. The Court reasoned that EPA’s approval of Roundup’s label—without a cancer warning—constitutes a federal labeling requirement. Because FIFRA’s preemption clause prohibits states from imposing labeling requirements “in addition to or different from” federal requirements, Missouri’s requirement for a cancer warning is preempted. The Court therefore reversed the judgment of the Missouri Court of Appeals and remanded the case for further proceedings consistent with its opinion. View "Monsanto v. Durnell" on Justia Law

Wolford v. Lopez

2026-06-25T06:45:07-08:00

Three residents of Maui County, Hawaii, each possessing a concealed-carry firearm permit, along with an organizational plaintiff, challenged a Hawaii statute that prohibits carrying firearms on private property open to the public unless the owner gives express, affirmative consent. This law, enacted after a Supreme Court decision recognized a constitutional right to carry handguns outside the home for self-defense, significantly limited the places where permit holders could lawfully carry. The statute imposed new burdens: permit holders had to obtain explicit permission before entering everyday establishments like stores and restaurants, reversing the traditional rule where entry was presumed permissible unless expressly forbidden. At the trial level, the United States District Court for the District of Hawaii enjoined enforcement of the law as applied to private property open to the public, finding it unconstitutional. The United States Court of Appeals for the Ninth Circuit reversed this injunction, allowing Hawaii’s law to remain in effect. The full Ninth Circuit denied a request for rehearing en banc, with several judges dissenting. The Supreme Court of the United States reviewed the case and held that Hawaii’s law violates the Second and Fourteenth Amendments. The Court found that the restriction fell within the plain text of the Second Amendment, creating a significant burden on the right to carry firearms for self-defense. The Court determined that Hawaii’s historical analogues—laws from the colonial and early state periods—were not sufficiently similar, as they primarily targeted unauthorized hunting, not self-defense in public establishments. The Supreme Court reversed the Ninth Circuit’s decision and remanded for further proceedings, holding that states cannot adopt default property rules that broadly prohibit carrying firearms on public-facing private property without individualized, express consent. View "Wolford v. Lopez" on Justia Law

Blanche v. Lau

2026-06-23T10:45:06-08:00

A Chinese citizen was admitted to the United States as a lawful permanent resident in 2007. In 2012, New Jersey charged him with trademark counterfeiting. While awaiting trial, he traveled temporarily to China. Upon his return to the U.S., a border officer, aware of his pending criminal charge, declined to treat him as already admitted and instead paroled him into the country pending the outcome of his case. After he pleaded guilty to the state charge in 2013, the government initiated removal proceedings, charging him as an applicant for admission who was inadmissible because of his conviction for a crime involving moral turpitude. An Immigration Judge found him removable on these grounds, and the Board of Immigration Appeals affirmed. The respondent sought review in the United States Court of Appeals for the Second Circuit. That court vacated the removal order, holding that unless border officers had “clear and convincing” evidence at the time of entry that the lawful permanent resident had committed the crime, the individual must be treated as already admitted. The Second Circuit concluded that the pending criminal charge did not constitute clear and convincing evidence, so the individual should not have been paroled but deemed admitted, and thus could not be removed on inadmissibility grounds. The Supreme Court of the United States reviewed the case and vacated the Second Circuit’s judgment. The Court held that the Immigration and Nationality Act does not require border officers to have clear and convincing evidence that a lawful permanent resident has committed a crime involving moral turpitude before treating the resident as an applicant for admission. The Court remanded the case for further proceedings, without deciding whether the underlying crime involved moral turpitude. View "Blanche v. Lau" on Justia Law

Landor v. Louisiana Dept of Corrections and Public Safety

2026-06-23T10:45:04-08:00

An inmate, whose Rastafarian beliefs require him not to cut his hair, was incarcerated in Louisiana. Near the end of his sentence, he was transferred to a different facility. Concerned that the new facility would enforce its grooming policy against his religious practice, he informed the officers and provided them with a relevant court decision supporting his position. Despite this, the officers forcibly shaved his head, violating his religious beliefs. After this incident, the inmate filed a suit under the Religious Land Use and Institutionalized Persons Act (RLUIPA), seeking money damages. He named both the Louisiana Department of Corrections and certain individual officers in their personal capacities as defendants. The officers moved to dismiss the claims against them, arguing that while their employer may have agreed to answer certain suits as a condition of federal funding, they themselves had not consented to such liability. The United States District Court dismissed the RLUIPA claims against both the Department and the individual officers. On appeal, the inmate challenged only the dismissal of the claims against the officers. The United States Court of Appeals for the Fifth Circuit affirmed, holding that RLUIPA does not allow suits for damages against officers in their individual capacities. The Supreme Court of the United States reviewed the case and affirmed the Fifth Circuit’s decision. The Court held that individuals may not be held liable in their personal capacities under a Spending Clause statute like RLUIPA unless those individuals have voluntarily and knowingly consented to answer lawsuits under the statute. Because the individual officers had not entered any agreement with the federal government consenting to such suits, the inmate’s claims against them could not proceed. The Court reasoned that Congress’s Spending Clause authority cannot be used to impose liability on nonconsenting individuals. View "Landor v. Louisiana Dept of Corrections and Public Safety" on Justia Law

Pung v. Isabella County

2026-06-23T06:45:08-08:00

The Pung family owned a home in Isabella County, Michigan, which was their primary residence for decades. After a disputed reassessment, the local tax assessor imposed an additional property tax on the family, even though a Michigan tax tribunal had previously determined that the family owed only the ordinary tax rate. The assessor sent the additional tax bill separately, and the family was unaware of its existence until after the foreclosure deadline. The County initiated foreclosure proceedings for a debt of $2,241.93 and ultimately sold the home, assessed at $194,400, at public auction for $76,008. The County initially kept all sale proceeds. The family challenged the foreclosure and sale in state court, arguing insufficient notice. Although the trial court agreed and set aside the foreclosure, the Michigan Court of Appeals reversed, finding that the County had sufficiently tried to notify the family. The property was lost, and the family later sued in federal court. The United States District Court for the Eastern District of Michigan granted partial summary judgment to the family on their Fifth Amendment claim, ordering the County to return only the surplus proceeds from the sale. The court rejected their Eighth Amendment Excessive Fines Clause claim. The United States Court of Appeals for the Sixth Circuit affirmed, reasoning that the auction price—not the fair market value—was the proper measure of compensation. The Supreme Court of the United States reviewed the case and held that "just compensation" under the Fifth Amendment, following a tax sale, is measured by the auction sale price, not the property’s hypothetical fair market value, provided the sale is fairly conducted in keeping with historical practice. The Court also rejected the claim under the Eighth Amendment, finding no violation of the Excessive Fines Clause. The judgment was vacated and remanded for further proceedings. View "Pung v. Isabella County" on Justia Law

Cisco Systems, Inc. v. Doe

2026-06-23T06:45:06-08:00

Several individuals who practice Falun Gong, a religious movement originating in China, asserted that they were persecuted by the Chinese Government due to their beliefs. They alleged that Cisco Systems, Inc. and its executives enabled this persecution by providing surveillance technology that assisted Chinese authorities in identifying and apprehending them. The plaintiffs claimed that Cisco and its executives were liable for aiding and abetting multiple violations of international law, including torture and crimes against humanity, under the Alien Tort Statute (ATS). Additionally, one plaintiff sought to hold two Cisco executives liable for aiding and abetting torture under the Torture Victim Protection Act of 1991 (TVPA). The United States District Court for the Northern District of California dismissed the plaintiffs’ complaint. The United States Court of Appeals for the Ninth Circuit reversed in part, addressing whether aiding-and-abetting liability could be imposed under the ATS and TVPA. The Ninth Circuit found that aiding-and-abetting liability was viable under both statutes, concluding that such liability was supported by international norms and that no prudential reasons justified withholding it. The Supreme Court of the United States reviewed the case to determine if courts may recognize aiding-and-abetting liability under the ATS and the TVPA. The Court held that federal courts may not create new causes of action for violations of international norms under the ATS, closing the possibility for such judicially created claims. The Court further held that the TVPA does not provide for aiding-and-abetting liability, as its language does not expressly allow for such claims. Thus, the Supreme Court reversed the Ninth Circuit’s judgment and remanded the case for further proceedings consistent with its opinion. View "Cisco Systems, Inc. v. Doe" on Justia Law

Exxon Mobil Corp. v. Corporación Cimex, S. A.

2026-06-23T06:45:05-08:00

After the Cuban revolution in 1959, the Cuban government seized numerous foreign-owned properties, including Exxon’s oil refinery and related facilities in Cuba. Two Cuban government-controlled companies, CUPET and CIMEX, subsequently operated these assets. Exxon, a U.S. corporation, was unable to pursue legal remedies for decades until Congress enacted the Helms-Burton Act in 1996, which created a private right of action for U.S. nationals whose property was confiscated by the Cuban Government. The Act allows lawsuits against any “person” trafficking in such property, with “person” defined to include agencies or instrumentalities of a foreign state. Exxon sued CUPET, CIMEX, and CIMEX’s Panamanian affiliate in the U.S. District Court for the District of Columbia, seeking damages for the use of its expropriated assets under the Helms-Burton Act. The Cuban companies moved to dismiss, arguing that they were immune under the Foreign Sovereign Immunities Act (FSIA), which provides immunity to foreign states and their agencies unless an exception applies. The District Court agreed and dismissed the case, finding that Exxon had not met any relevant FSIA exception. The U.S. Court of Appeals for the D.C. Circuit affirmed, holding that suits under the Helms-Burton Act must also satisfy an FSIA exception. The Supreme Court of the United States reversed, holding that the Helms-Burton Act itself abrogates the foreign sovereign immunity of Cuban agencies and instrumentalities. The Court determined that plaintiffs suing these entities under the Act need not also meet an FSIA exception. The Court found that the statutory text, structure, and the President’s explicit power to suspend claims under the Act all indicate that Congress created a standalone exception to sovereign immunity for suits authorized by the Helms-Burton Act. The case was remanded for further proceedings. View "Exxon Mobil Corp. v. Corporación Cimex, S. A." on Justia Law

McCarthy v. Hernandez

2026-06-22T14:47:57-08:00

In May 1979, a six-year-old boy disappeared in Manhattan after stopping at a bodega where Pedro Hernandez worked. The case remained unsolved until 2012, when Hernandez, who had a low IQ and a history of mental illness, confessed multiple times to the crime following police questioning—initially without Miranda warnings and later after receiving them. Hernandez was charged with murder and kidnapping in New York. At trial, after a first mistrial, he moved to suppress his confessions, but the trial court found he was not in custody before receiving Miranda warnings and that he had knowingly waived his rights before later confessions. The trial court instructed the jury on voluntariness and Miranda but, consistent with New York law, did not instruct the jury to determine whether subsequent confessions were tainted by an initial, possibly involuntary confession. The Appellate Division, First Department affirmed the conviction, agreeing that the confessions were admissible and the jury instructions proper under state law. The court also found that any failure to instruct on attenuation was harmless. The New York Court of Appeals denied further review. Hernandez sought federal habeas relief, arguing the trial court should have instructed the jury on the attenuation issue, citing Missouri v. Seibert. The U.S. District Court denied relief, finding no clearly established federal law requiring such an instruction. However, the United States Court of Appeals for the Second Circuit reversed, holding that the trial court’s failure to instruct the jury on attenuation violated federal law as articulated in Seibert and was not harmless error. The Supreme Court of the United States reversed the Second Circuit, holding that no clearly established federal law required the trial court to instruct the jury about attenuation under Seibert. The Court concluded that the Second Circuit exceeded its authority under AEDPA, as Seibert did not address jury instructions and only governs judicial suppression determinations. The judgment was reversed and remanded. View "McCarthy v. Hernandez" on Justia Law

T. M. v. University of Md. Medical System Corporation

2026-06-18T06:45:08-08:00

T.M. suffered an episode related to a medical condition that can induce psychosis upon ingesting gluten, leading to her involuntary commitment at a Maryland medical center after an administrative hearing. During her stay, she was forcibly medicated pursuant to an order affirmed by an administrative law judge. These events led T.M. and her parents to initiate multiple legal actions in both state and federal courts, seeking her release and to prevent forced medication. Eventually, the parties negotiated a settlement, which a Maryland state court entered as a consent order. This order allowed T.M.’s release under several conditions, including that she and her parents dismiss all pending actions against the respondents. Shortly after the consent order was entered, T.M. and her parents, with new counsel, filed suit in the U.S. District Court for the District of Maryland. They sought to have the consent order declared unconstitutional and unenforceable, and to enjoin its enforcement. Meanwhile, T.M. also appealed the consent order to the Appellate Court of Maryland, raising similar arguments. She successfully moved to stay the state-court appeal to avoid inconsistent rulings. The District Court dismissed the federal lawsuit for lack of subject matter jurisdiction under the Rooker-Feldman doctrine, which generally bars federal district courts from reviewing state-court judgments. The U.S. Court of Appeals for the Fourth Circuit affirmed, rejecting T.M.’s argument that the doctrine should only apply to final judgments from a state’s highest court. The Supreme Court of the United States held that the Rooker-Feldman doctrine bars federal district court jurisdiction over suits seeking review and rejection of state-court judgments, regardless of whether the judgment is still subject to further review in state appellate proceedings. The Court affirmed the Fourth Circuit’s decision, clarifying that this bar applies even if the state-court judgment is not yet final in the sense required for Supreme Court review under 28 U.S.C. §1257. View "T. M. v. University of Md. Medical System Corporation" on Justia Law

United States v. Hemani

2026-06-18T06:45:07-08:00

Ali Hemani, a dual citizen of the United States and Pakistan, lived in Texas with his parents and maintained steady employment. In 2022, federal agents searched his home based on suspicions of terrorism-related activity. Hemani cooperated fully with law enforcement, surrendering a firearm and marijuana found on the property, and admitted during an interview that he used marijuana about every other day. Several months later, the government charged Hemani under 18 U.S.C. §922(g)(3) for possessing a gun while being an unlawful user of a controlled substance, relying solely on his admitted marijuana use. The United States District Court for the Northern District of Texas granted Hemani’s motion to dismiss the indictment, finding the prosecution violated his Second Amendment rights. The government appealed, but the United States Court of Appeals for the Fifth Circuit affirmed the dismissal, prompting the government to seek review from the Supreme Court. The Supreme Court of the United States reviewed whether the government’s prosecution of Hemani under §922(g)(3) was consistent with the Second Amendment. The Court held that the government’s automatic ban on firearm possession for anyone who regularly uses a controlled substance, without individualized proof of dangerousness or any pre-deprivation process, is inconsistent with the Second Amendment’s protections. The government failed to demonstrate that §922(g)(3), as applied, was sufficiently analogous to historical regulations targeting habitual drunkards, which operated for different reasons, targeted different groups, and provided procedural safeguards. The Court’s decision is narrow, addressing only the automatic application of the statute to regular drug users without further showing. The judgment of the Fifth Circuit was affirmed. View "United States v. Hemani" on Justia Law

Hunter v. United States

2026-06-18T06:45:05-08:00

Hunter was charged with ten counts of bank and wire fraud, involving a scheme that cost financial institutions approximately $500,000. He entered a written plea agreement with the government, pleading guilty to one count of aiding and abetting wire fraud. In exchange, the government dismissed the other nine charges and agreed not to prosecute Hunter for related conduct in the future. The plea agreement contained an appeal waiver, barring him from appealing his conviction and sentence, except for claims of ineffective assistance of counsel. The agreement stipulated that any modification must be in writing and signed by all parties. At sentencing, the District Court imposed 51 months’ imprisonment and three years of supervised release, including a requirement that Hunter participate in a mental-health treatment program and take any prescribed medications. Hunter objected to the medication condition, but the District Court stated he could address any disputes with the probation officer or the court. At the conclusion of sentencing, the court erroneously informed Hunter that he had a right to appeal, without objection from either party. Hunter appealed, challenging the mandatory-medication condition as violating his fundamental due process rights. The government moved to dismiss the appeal based on the plea agreement’s waiver. Hunter conceded he had knowingly and voluntarily signed the waiver, but argued it was unenforceable because the sentence allegedly infringed on a fundamental constitutional right and that the District Court’s statement at sentencing, coupled with the prosecutor’s silence, voided the waiver. The United States Court of Appeals for the Fifth Circuit dismissed the appeal, holding that the District Court’s misstatement did not invalidate the waiver and that Fifth Circuit precedent permitted appeals despite a waiver only in cases of ineffective assistance of counsel or sentences exceeding the statutory maximum. The Supreme Court of the United States held that an appeal waiver is unenforceable when its enforcement would result in a miscarriage of justice—specifically, when it would leave in place an egregious error undermining the judicial system’s integrity. The Court vacated the Fifth Circuit’s judgment and remanded the case for consideration under this miscarriage-of-justice standard. View "Hunter v. United States" on Justia Law

Keathley v. Buddy Ayers Construction, Inc.

2026-06-11T06:45:17-08:00

Thomas Keathley and his wife filed for Chapter 13 bankruptcy in December 2019. During the bankruptcy proceedings, they were required to disclose all assets, including any claims against third parties. In August 2021, while the bankruptcy case was still open, Keathley was involved in a car accident with an employee of Buddy Ayers Construction, Inc. He hired a personal injury attorney and told his bankruptcy counsel that he intended to file a lawsuit, but neither he nor his counsel disclosed this potential claim to the Bankruptcy Court. Later, Keathley filed a negligence lawsuit in federal district court without updating his bankruptcy disclosures. Buddy Ayers Construction moved for summary judgment in the U.S. District Court for the Northern District of Mississippi based on judicial estoppel, arguing Keathley was barred from bringing the lawsuit because he had not disclosed the claim to the Bankruptcy Court. When faced with the motion, Keathley amended his bankruptcy filings to include the claim and submitted affidavits asserting the omission was inadvertent. The District Court, following Fifth Circuit precedent, granted summary judgment for Buddy Ayers Construction, finding the omission was not inadvertent because Keathley knew of the facts and had a potential motive to conceal the claim. The United States Court of Appeals for the Fifth Circuit affirmed, though a concurring judge questioned whether this approach furthered the goals of judicial estoppel. The Supreme Court of the United States reviewed the case and held that courts must examine the totality of the circumstances to determine whether a debtor’s omission in bankruptcy was inadvertent or mistaken for purposes of judicial estoppel. The Court found that the Fifth Circuit’s rule—which considered only whether the debtor knew of the claim and had a motive to conceal—was too rigid and overly broad for an equitable doctrine. The Supreme Court vacated the Fifth Circuit’s judgment and remanded the case for further proceedings. View "Keathley v. Buddy Ayers Construction, Inc." on Justia Law

Abouammo v. United States

2026-06-11T06:45:08-08:00

Ahmad Abouammo, while working at Twitter’s San Francisco office, provided a Saudi official with confidential information about dissident users and was paid $300,000. After leaving Twitter, Abouammo moved to Seattle and started a consulting business. FBI agents from San Francisco, investigating these disclosures, interviewed him at his Seattle home. During the interview, Abouammo denied sharing confidential information and claimed the payments were for consulting work. When asked for documentation, he created and emailed a fake invoice to the agents while they waited downstairs. The agents later determined, based on metadata, that the invoice was fabricated during the interview. Abouammo was indicted in the United States District Court for the Northern District of California for violating 18 U.S.C. §1519, which criminalizes falsifying a document with intent to obstruct a federal investigation. He moved to dismiss the charge for improper venue, arguing trial should only occur where the falsification happened—Seattle, in the Western District of Washington. The District Court denied the motion, holding venue was also proper where the investigation was located. A jury convicted him, and the district court reaffirmed its venue ruling after trial. The United States Court of Appeals for the Ninth Circuit affirmed, reasoning that, because §1519 requires intent to obstruct an investigation, the offense’s “essential conduct” included effects in the district where the investigation was based. The Supreme Court of the United States reversed. The Court held that a charge under §1519 must be tried in the district where the falsification occurred, not where the investigation was located. The only conduct constituting the offense is the act of falsification, which was completed in Seattle. The statute’s intent requirement does not expand venue to other districts. Therefore, the trial in California’s Northern District was improper, and the case was remanded for further proceedings. View "Abouammo v. United States" on Justia Law

FS Credit Opportunities Corp. v. Saba Capital Master Fund, Ltd.

2026-06-11T06:45:07-08:00

Several investment companies managing closed-end mutual funds, incorporated in Maryland, adopted resolutions under the Maryland Control Share Acquisition Act (MCSAA) to limit the voting rights of shareholders who accumulate a large percentage of shares, such as activist investors. Saba Capital, an activist investor, sought to acquire significant stakes in these funds to influence their management. Saba challenged the funds’ resolutions, alleging they violated the Investment Company Act’s (ICA) requirement that every share of stock have equal voting rights. Saba based its legal claim on Section 47(b) of the ICA, which addresses rescission of contracts that violate the Act. The United States District Court ruled in Saba’s favor, holding that Section 47(b) of the ICA creates an implied private right of action that allows private parties to sue for rescission of contracts allegedly violating the ICA. The District Court granted summary judgment to Saba on this basis. The United States Court of Appeals for the Second Circuit summarily affirmed the District Court’s decision. The Supreme Court of the United States reviewed the case to resolve a circuit split regarding whether Section 47(b) of the ICA impliedly authorizes private parties to sue for rescission. The Court held that Section 47(b) does not confer an implied private right of action. The Court reasoned that the provision directs courts on how to exercise remedial authority in cases already before them but does not create a right for private parties to initiate such suits. The statutory text and structure, including the explicit enforcement roles given to the Securities and Exchange Commission and the existence of other express private rights of action in the ICA, further supported this conclusion. The Supreme Court reversed the Second Circuit’s judgment and remanded the case for further proceedings. View "FS Credit Opportunities Corp. v. Saba Capital Master Fund, Ltd." on Justia Law

Sripetch v. SEC

2026-06-04T08:45:05-08:00

Ongkaruck Sripetch orchestrated several fraudulent schemes involving over 20 penny-stock companies. These schemes included classic “pump and dump” operations, where Sripetch and his associates would acquire shares, artificially inflate their value through promotion, and then sell at a profit. The Securities and Exchange Commission (SEC) discovered these activities and filed a civil enforcement action, charging Sripetch with six counts of securities fraud and one count of selling unregistered securities. Sripetch consented to judgment and agreed that the court could order disgorgement of ill-gotten gains. The United States District Court for the Southern District of California reviewed the SEC’s request for more than $4.1 million in disgorgement. Sripetch objected, arguing that the SEC had not demonstrated that investors suffered financial losses. The district court rejected this objection, finding that the SEC had made an adequate showing of pecuniary harm suffered by investors, but it did not decide whether such a showing was necessary. Sripetch appealed to the United States Court of Appeals for the Ninth Circuit, which held that a finding of pecuniary harm is not required for a disgorgement order, relying on traditional equitable principles and relevant Restatements. The court’s decision deepened a split among the circuits. The Supreme Court of the United States granted certiorari to resolve whether the SEC must prove that investors suffered financial losses to obtain disgorgement. The Court held that a showing of pecuniary loss is not required before the SEC may secure a disgorgement award. The main holding is that, under traditional equitable principles and the relevant statutes, disgorgement may be ordered based on the defendant’s wrongful gain, regardless of whether the victims suffered financial losses. The Court affirmed the judgment of the Ninth Circuit. View "Sripetch v. SEC" on Justia Law

FCC v. AT&T

2026-06-04T06:45:05-08:00

This case involved two major cellular service providers that were investigated by the Federal Communications Commission (FCC) for allegedly mishandling customer location data, potentially violating laws and regulations concerning confidentiality. Following reports of security breaches, the FCC issued notices of apparent liability to the companies and, after reviewing their responses, assessed monetary penalties—about $57 million against one provider and $47 million against the other. The companies paid these penalties but challenged the process, contending that their Seventh Amendment right to a jury trial was violated because the FCC imposed penalties through an administrative process without the involvement of a jury. One of the companies sought review in the United States Court of Appeals for the Fifth Circuit, which ruled in its favor, holding that the FCC’s process violated the Seventh Amendment since the agency found facts, interpreted the law, and assessed penalties without a jury. The other provider’s case was heard by the United States Court of Appeals for the Second Circuit, which upheld the FCC’s process. The Second Circuit reasoned that the FCC’s forfeiture order did not, by itself, compel payment, and any actual collection would require the Department of Justice to file a civil suit, at which point a jury trial would be available. The Supreme Court of the United States reviewed both cases to resolve the conflict. The Court held that the FCC’s procedures did not violate the Seventh Amendment because the forfeiture orders did not create a binding obligation to pay, nor were the FCC’s factual findings conclusive. Instead, a party could insist on a jury trial in a de novo civil enforcement action brought by the government to collect the penalty. The judgment of the Fifth Circuit was reversed and remanded, while the judgment of the Second Circuit was affirmed. View "FCC v. AT&T" on Justia Law

Hikma Pharmaceuticals USA Inc. v. Amarin Pharma, Inc.

2026-06-04T06:45:04-08:00

Amarin Pharma, Inc. developed and marketed Vascepa, a drug containing icosapent ethyl. Initially, the Food and Drug Administration (FDA) approved Vascepa for treating severe hypertriglyceridemia (the SH indication). Later, the FDA approved a new use: reducing cardiovascular risk in certain patients (the CV indication), for which Amarin held two method-of-use patents. Hikma Pharmaceuticals USA Inc., a generic manufacturer, sought to market a generic icosapent ethyl. After Amarin’s SH-indication patents were invalidated by a district court, Hikma pursued FDA approval for a “skinny label” generic, carving out the patented CV indication. The FDA approved Hikma’s application with the label limited to the SH indication. Amarin sued Hikma in the United States District Court for the District of Delaware, alleging that Hikma actively induced infringement of Amarin’s CV-indication patents. Amarin argued that various statements in Hikma’s skinny label, patient information leaflet, website, and press releases encouraged infringement. The District Court granted Hikma’s motion to dismiss, finding that the statements did not constitute active encouragement of infringement. The United States Court of Appeals for the Federal Circuit reversed, holding it plausible that a physician could read Hikma’s statements as instructions or encouragement to prescribe the drug for the patented use. The Supreme Court of the United States reviewed the case and held that Amarin failed to state a claim for active inducement under 35 U.S.C. §271(b). The Court clarified that liability requires affirmative “active steps” to encourage infringement, not merely statements that could be read as encouragement. The Court found Hikma’s statements either reflected legal compliance or ordinary industry practice, or were too vague or passive to plausibly constitute active inducement. The Supreme Court reversed the Federal Circuit’s judgment and remanded for further proceedings. View "Hikma Pharmaceuticals USA Inc. v. Amarin Pharma, Inc." on Justia Law

Allen v. Milligan

2026-06-03T06:45:05-08:00

In this matter, Alabama enacted a congressional district map in 2023 that included only one district in which Black voters constituted a majority. Plaintiffs challenged the map, arguing that it diluted Black voting strength in violation of Section 2 of the Voting Rights Act and the Fourteenth Amendment. The essential factual dispute centered on whether Alabama’s map failed to provide an additional district offering Black voters an opportunity to elect their preferred candidates, and whether the State had intentionally avoided implementing a remedial map previously ordered by the court. The United States District Court for the Northern District of Alabama first enjoined the use of Alabama’s 2023 congressional map, finding it violated Section 2 because it did not include an additional Black-opportunity district and concluding that the State’s actions also violated the Fourteenth Amendment as a deliberate refusal to comply with prior remedial requirements. After the Supreme Court vacated this injunction in light of its decision in Louisiana v. Callais, the District Court issued a new injunction on similar grounds. State officials then applied to the Supreme Court for a stay of the District Court’s order. The Supreme Court of the United States granted Alabama’s application for a stay, holding that the State is likely to succeed on the merits. The Court concluded that the District Court failed to apply the updated standards for Section 2 liability announced in Callais, particularly the requirement that a plaintiff’s alternative map must perform “just as well” with respect to all constitutionally permissible districting criteria, and erred in its evaluation of alleged discriminatory intent. The Supreme Court stayed the District Court’s order pending further proceedings, emphasizing the importance of not altering election rules close to an election. View "Allen v. Milligan" on Justia Law

Whitton v. Dixon

2026-06-01T12:45:05-08:00

The petitioner was convicted of murder in Florida and sentenced to death after a jury trial. A key witness for the prosecution was a jailhouse informant, Jake Ozio, who testified that he heard the petitioner confess while in jail. Ozio also testified, falsely, that he had no prior criminal history, despite juvenile records showing otherwise—records that were in the State’s possession at the time of trial. The petitioner later argued that the use of this false testimony violated his due process rights under Giglio v. United States because the prosecution knew Ozio’s statement was untrue and there was a reasonable likelihood it affected the jury’s verdict. After unsuccessful direct appeals and postconviction relief in state court, the petitioner sought habeas corpus relief in federal court. The United States District Court denied his application, finding any Giglio violation harmless because juvenile records are generally inadmissible under Florida law. The United States Court of Appeals for the Eleventh Circuit disagreed with the District Court’s harmlessness reasoning, noting that such records could have been used to impeach Ozio since he had opened the door by denying any prior history. However, the Court of Appeals affirmed the denial of habeas relief on the alternative ground that, even without Ozio’s testimony, the evidence against the petitioner was overwhelming—a conclusion it based in part on post-trial DNA testing not presented to the jury. The Supreme Court of the United States held that the Eleventh Circuit erred by considering DNA evidence that did not exist at the time of trial when assessing whether the Giglio error was harmless. The proper inquiry is limited to whether the constitutional error had a substantial and injurious effect or influence on the jury’s verdict, considering only evidence available to the jury. The Supreme Court vacated the judgment and remanded the case for further proceedings. View "Whitton v. Dixon" on Justia Law

Flowers Foods, Inc. v. Brock

2026-05-28T06:45:10-08:00

Angelo Brock operated as a franchisee distributing baked goods for a large national baking company in Colorado. He picked up products from a local warehouse and delivered them to stores within the state, never leaving Colorado or directly interacting with vehicles that crossed state lines. In 2022, Brock and other distributors alleged in federal court that the baking company underpaid them, violating federal and state laws. The company moved to compel arbitration, citing an agreement Brock had signed requiring disputes to be arbitrated, and invoked the Federal Arbitration Act (FAA). The United States District Court denied the company's motion to compel arbitration. On appeal, the United States Court of Appeals for the Tenth Circuit affirmed this denial. The Tenth Circuit focused on Section 1 of the FAA, which exempts “contracts of employment” for workers “engaged in interstate commerce.” The appellate court found that even though Brock’s deliveries were confined to Colorado and he did not interact with interstate vehicles, his role as part of the continuous interstate distribution of goods qualified him for the exemption. The court determined that Brock was part of a class of workers engaged in interstate commerce, placing his contract outside the FAA’s compulsory arbitration requirements. The Supreme Court of the United States reviewed whether the FAA’s exemption for “workers engaged in interstate commerce” applies to workers who do not cross state lines or interact with vehicles that do. The Court held that a worker transporting goods on an intrastate segment of an interstate journey can fall under the FAA’s Section 1 exemption, even without leaving the state or handling vehicles engaged in interstate transit. The judgment of the Tenth Circuit was affirmed. View "Flowers Foods, Inc. v. Brock" on Justia Law

Rutherford v. United States

2026-05-28T06:45:08-08:00

Two individuals were convicted of multiple counts under 18 U.S.C. §924(c) for using and carrying firearms during crimes of violence, resulting in lengthy mandatory minimum sentences due to a “stacking” provision. Years after their convictions, Congress enacted the First Step Act of 2018, which eliminated the stacking requirement for first-time offenders, thereby reducing future sentences for similar offenses. However, the new law did not apply retroactively to individuals already sentenced, including the petitioners. Following the Act’s enactment, both petitioners sought sentence reductions under 18 U.S.C. §3582(c)(1)(A)(i), which allows for “compassionate release” if there are “extraordinary and compelling reasons.” The United States District Court denied their motions, and the United States Court of Appeals for the Third Circuit affirmed those denials, holding that the nonretroactive change in the law could not itself qualify as an “extraordinary and compelling” reason for a sentence reduction. The Third Circuit reasoned that allowing such relief would conflict with Congress’s clear decision not to apply the Act retroactively. The Supreme Court of the United States reviewed the consolidated cases to resolve a circuit split on whether sentencing disparities created by nonretroactive statutory changes can justify compassionate release. The Court held that when Congress chooses not to make a sentencing amendment retroactive, the resulting sentencing disparity does not constitute an “extraordinary and compelling” reason for a reduced sentence under §3582(c)(1)(A)(i). The Court further concluded that the Sentencing Commission’s policy statement to the contrary is invalid to the extent it conflicts with this statutory interpretation. The decision of the Third Circuit was affirmed. View "Rutherford v. United States" on Justia Law

Pitchford v. Cain

2026-05-28T06:45:07-08:00

Two black teenagers carried out a robbery at a grocery store in Mississippi, during which one of them shot and killed the white store owner. The shooter accepted a plea deal for a 20-year sentence. The other participant was charged with capital murder, and the state sought the death penalty. During jury selection, the prosecutor used peremptory strikes on four out of five black prospective jurors. Defense counsel objected under Batson v. Kentucky, alleging that these strikes were racially motivated. The trial court asked the prosecutor for race-neutral explanations and accepted them but did not allow the defense to rebut or argue that the reasons were pretextual, effectively ending the Batson analysis at the second step. Attempts by defense counsel to revisit the issue were cut off by the court. The jury ultimately consisted of eleven white jurors and one black juror, and the defendant was convicted and sentenced to death. On direct appeal, the Mississippi Supreme Court found that the defendant had waived his Batson objection by not specifically arguing pretext at trial. In subsequent federal habeas proceedings, the U.S. District Court for the Northern District of Mississippi determined that the state court’s finding of waiver was unreasonable, noting the trial court had not conducted the required three-step Batson process and had prevented defense counsel from making a pretext argument. The District Court granted relief, but the U.S. Court of Appeals for the Fifth Circuit reversed, holding that the Mississippi Supreme Court’s waiver finding was reasonable. The Supreme Court of the United States held that the Mississippi Supreme Court unreasonably applied Batson and unreasonably determined that the defendant waived his opportunity to rebut the prosecution’s race-neutral reasons for peremptory strikes. The Court reversed the Fifth Circuit’s judgment and remanded the case for further proceedings. View "Pitchford v. Cain" on Justia Law

Fernandez v. United States

2026-05-28T06:45:05-08:00

Joe Fernandez was indicted in 2013 for his alleged role as the backup shooter in a double assassination connected to a drug ring. Prosecutors asserted Fernandez was paid to kill two gang members, firing 14 rounds after the primary shooter’s gun malfunctioned. Fernandez’s cousin, Patrick Darge, testified against him at trial. Fernandez’s defense claimed Darge was framing him to protect another relative. The jury convicted Fernandez of murder for hire and a firearms offense, resulting in two consecutive life sentences. After his conviction, Fernandez challenged the verdict in the United States District Court for the Southern District of New York, alleging Brady violations concerning the Government’s failure to disclose statements by another alleged co-conspirator, Luis Rivera. The District Court reviewed the relevant notes and found no exculpatory information but expressed concern about the Government’s lenient treatment of Rivera. The United States Court of Appeals for the Second Circuit affirmed the conviction and sentence, rejecting both the Brady claim and Fernandez’s argument that evidence was insufficient. Fernandez later filed two motions for postconviction relief under 28 U.S.C. §2255; the first was denied as meritless, while the second vacated the firearms conviction based on United States v. Davis, 588 U.S. 445, but left the murder-for-hire conviction intact. Fernandez then sought compassionate release under 18 U.S.C. §3582(c)(1)(A)(i), arguing that doubts about his guilt constituted extraordinary and compelling reasons for a sentence reduction. The District Court granted release based on concerns about the conviction’s validity. The United States Court of Appeals for the Second Circuit reversed, holding that challenges to the validity of a conviction are not cognizable as “extraordinary and compelling reasons” under §3582. The Supreme Court of the United States affirmed, holding that a prisoner who collaterally attacks the validity of his conviction must proceed under 28 U.S.C. §2255, not §3582, and that the alleged invalidity of a conviction is not a valid basis for compassionate release. View "Fernandez v. United States" on Justia Law

Margolin v. National Association of Immigration Judges

2026-05-26T12:45:04-08:00

An association representing immigration judges challenged a policy issued by the Executive Office for Immigration Review, which required judges to obtain supervisory approval before making public statements relating to their official duties. The association claimed this policy violated its members’ First and Fifth Amendment rights. The dispute centered on whether such claims must proceed through the administrative review process established by the Civil Service Reform Act of 1978 (CSRA), which channels most work-related federal employee grievances to the Merit Systems Protection Board and the Special Counsel rather than federal district courts. The United States District Court for the Eastern District of Virginia concluded that the CSRA did indeed cover the claims, and therefore dismissed the association’s case for lack of district court jurisdiction. The association appealed, maintaining that its constitutional claims fell outside the scope of the CSRA’s jurisdiction-stripping provisions, but did not dispute that the CSRA generally channels review of covered claims out of district court. On appeal, the United States Court of Appeals for the Fourth Circuit agreed that the association’s claims were covered by the CSRA. Nonetheless, the appellate court vacated the District Court’s judgment and remanded the case for additional factfinding, raising on its own initiative concerns about the current operation of the CSRA’s administrative review scheme—specifically, issues arising from challenges to tenure protections and the lack of a quorum at the Merit Systems Protection Board. The Supreme Court of the United States found that the Fourth Circuit erred by addressing issues not raised or argued by the parties, thus violating the principle of party presentation. The Supreme Court reversed the judgment of the Fourth Circuit and remanded for further proceedings consistent with its opinion. The main holding is that appellate courts may not decide cases on grounds not presented or argued by the parties. View "Margolin v. National Association of Immigration Judges" on Justia Law

Havana Docks Corp. v. Royal Caribbean Cruises, Ltd.

2026-05-21T06:45:09-08:00

Havana Docks Corporation, a U.S.-based entity, obtained a usufructuary concession from the Cuban Government in 1928, granting it the right to develop and operate docks at the Port of Havana until 2004. This concession included a government promise of compensation if expropriation occurred before expiration. In 1960, following Fidel Castro’s rise to power, the Cuban Government seized control of the docks without compensating Havana Docks, prematurely terminating its concession. The Foreign Claims Settlement Commission later certified Havana Docks’ loss as approximately $9 million plus interest. Decades later, from 2016 to 2019, four major cruise lines used the Havana docks to transport passengers to Cuba, paying Cuban government-affiliated entities for access. Havana Docks sued the cruise lines under the Cuban Liberty and Democratic Solidarity Act (LIBERTAD Act) in the United States District Court for the Southern District of Florida. The cruise lines argued they could not be liable because Havana Docks’ concession would have expired in 2004 even without confiscation. The District Court disagreed, found for Havana Docks, and ordered each cruise line to pay over $100 million. The United States Court of Appeals for the Eleventh Circuit reversed this judgment, holding that liability under the Act required the defendant’s conduct to interfere with a property interest the plaintiff would have had absent confiscation, and since Havana Docks’ concession would have expired before the cruise lines’ conduct, no liability attached. The Supreme Court of the United States reviewed the case and disagreed with the Eleventh Circuit’s analysis. The Court held that, under the Act, liability attaches to anyone who traffics in physical property confiscated by the Cuban Government, not just property interests. It concluded that the cruise lines’ use of the docks constituted trafficking in confiscated property to which Havana Docks owns a claim, regardless of when Havana Docks’ concession would have expired. The Supreme Court vacated the Eleventh Circuit’s decision and remanded the case for further proceedings. View "Havana Docks Corp. v. Royal Caribbean Cruises, Ltd." on Justia Law

Hamm v. Smith

2026-05-21T06:45:07-08:00

A state official sought review of a lower court decision concerning an inmate, Joseph Clifton Smith, who was involved in litigation against the Alabama Department of Corrections. The case reached the United States Supreme Court on a writ of certiorari, which is a request for the Supreme Court to review the decision of a lower court. Previously, the United States Court of Appeals for the Eleventh Circuit had reviewed the case and issued a decision regarding Smith’s claims. The party dissatisfied with the Eleventh Circuit’s ruling—the Commissioner of the Alabama Department of Corrections—then sought review in the Supreme Court, prompting the granting of certiorari. Upon consideration, the Supreme Court of the United States dismissed the writ of certiorari as improvidently granted. This means that the Court concluded it should not have agreed to hear the case and, as a result, did not issue a decision on the merits. The effect of this order is that the decision of the Court of Appeals for the Eleventh Circuit remains in place, and the Supreme Court will not provide further review or guidance in this matter. View "Hamm v. Smith" on Justia Law

M & K Employee Solutions, Inc. v. Trustees of IAM Nat. Pension

2026-05-21T06:45:05-08:00

Four employers participating in an underfunded multiemployer pension plan withdrew from the plan in 2018. The plan’s trustees, using a newly adopted discount rate of 6.50% (previously 7.50%), calculated each employer’s withdrawal liability based on the plan’s unfunded vested benefits as of December 31, 2017. The change in the discount rate, adopted after the measurement date but before the calculation, significantly increased the amounts the employers owed. The employers challenged these assessments in arbitration, arguing that only actuarial assumptions in effect as of the measurement date could be used. Each arbitrator agreed with the employers, concluding that the plan should have used the discount rate in effect on the measurement date and requiring reassessment with the prior, higher rate. The fund’s trustees then sought review in the United States District Court for the District of Columbia, which disagreed with the arbitrators and held that it was permissible for the plan’s actuary to select assumptions after the measurement date. The United States Court of Appeals for the District of Columbia Circuit affirmed, reasoning that the statutory text did not require actuarial assumptions to be fixed as of the measurement date, and that assumptions could be adopted later as long as they reflected the best estimate as of that date. This decision created a conflict with a prior ruling by the United States Court of Appeals for the Second Circuit. The Supreme Court of the United States held that the relevant provisions of ERISA do not require the actuarial assumptions used to calculate withdrawal liability to be selected on or before the statutory measurement date. The Court affirmed the D.C. Circuit, concluding that, while the measurement date fixes the relevant factual data, the timing of selecting actuarial assumptions is not limited by statute. The Court also noted that the statute requires only that the assumptions be reasonable and reflect the actuary’s best estimate. View "M & K Employee Solutions, Inc. v. Trustees of IAM Nat. Pension" on Justia Law

Jules v. Andre Balazs Properties

2026-05-14T14:55:54-08:00

The case concerns an employee who worked at a Los Angeles hotel and was terminated in March 2020, allegedly due to COVID-19-related staffing issues. The employee sued the hotel and its affiliates in the United States District Court for the Southern District of New York, alleging federal and state law discrimination claims. However, before starting work, the employee had signed an arbitration agreement covering disputes related to employment or termination. The hotel moved to stay the court proceedings and compel arbitration under the Federal Arbitration Act (FAA), and the District Court stayed the case pending arbitration. Arbitration proceeded, resulting in an award against the employee on all claims, as well as sanctions for misconduct. After the arbitrator’s award, the hotel moved to confirm the award in the District Court under §9 of the FAA, while the employee sought to vacate it under §10. The employee argued that the District Court lacked jurisdiction to confirm or vacate the award because the post-arbitration motions did not independently satisfy the requirements for federal-question or diversity jurisdiction. The District Court disagreed, held that it retained jurisdiction, and confirmed the arbitral award. The United States Court of Appeals for the Second Circuit affirmed, distinguishing the case from Supreme Court precedent involving freestanding FAA motions, and holding that the District Court’s original jurisdiction over the employee’s federal claims extended to the post-arbitration proceedings. The Supreme Court of the United States affirmed the Second Circuit’s judgment. It held that when a federal court has original jurisdiction over claims and stays those claims pending arbitration under §3 of the FAA, the court retains jurisdiction to confirm or vacate the resulting arbitral award under §9 and §10. The Court reasoned that nothing in the FAA divests the court of jurisdiction over the original claims while arbitration is pending, and that post-arbitration motions are integral to the resolution of those stayed claims. View "Jules v. Andre Balazs Properties" on Justia Law

Montgomery v. Caribe Transport II, LLC

2026-05-14T14:55:53-08:00

A man suffered severe injuries, including the loss of his leg, when his stopped tractor-trailer was struck by a truck driven by an employee of a motor carrier. The shipment had been coordinated by a broker, and the injured man alleged the broker was liable for negligently hiring the motor carrier and its driver, pointing to the carrier’s poor safety rating and regulatory violations. The claim asserted that the broker knew, or should have known, that hiring this carrier posed a reasonable risk of causing harm. In the United States District Court for the Southern District of Illinois, the broker moved to dismiss the negligent-hiring claim, arguing that it was preempted by the Federal Aviation Administration Authorization Act (FAAAA). That court, following precedent from the United States Court of Appeals for the Seventh Circuit, agreed and dismissed the claim, reasoning that it was expressly preempted by the FAAAA and did not fall within the safety exception. The Seventh Circuit affirmed the district court’s decision, maintaining that the safety exception did not apply to the broker in this context. The Supreme Court of the United States reviewed the case to resolve a division among the circuits. The Court held that the FAAAA’s safety exception does encompass negligent-hiring claims against brokers when those claims concern the use of motor vehicles in transportation. Specifically, the Court determined that state common-law negligent-hiring standards, as applied to brokers who select motor carriers, constitute the exercise of “safety regulatory authority of a State with respect to motor vehicles” and are thus not preempted by the FAAAA. The Supreme Court reversed the judgment of the Seventh Circuit and remanded the case for further proceedings. View "Montgomery v. Caribe Transport II, LLC" on Justia Law

First Choice Women's Resource Centers, Inc. v. Davenport

2026-04-29T22:15:07-08:00

A religious nonprofit organization in New Jersey, active since 1985, provides counseling and resources to pregnant women but does not offer or refer for abortions due to its belief that life begins at conception. In 2022, the state’s Attorney General created a task force that accused groups like this one of spreading misleading information about abortion. Subsequently, the Attorney General issued a subpoena demanding the group turn over documents identifying many of its donors, except those who donated through one specific webpage. The subpoena warned that noncompliance could lead to contempt charges and other penalties. The organization responded by filing a lawsuit in the United States District Court, seeking to block enforcement of the subpoena and arguing that the compelled disclosure of its donor information would chill its First Amendment rights by deterring donors. The district court denied the group’s request for a preliminary injunction and dismissed the complaint, holding there was no justiciable claim because no court had yet ordered the group to comply with the subpoena, so no injury had occurred. The United States Court of Appeals for the Third Circuit affirmed, finding that the group lacked standing since any potential harm was not sufficiently concrete or imminent. The Supreme Court of the United States reversed the Third Circuit’s decision. The Court held that the subpoena itself, even before enforcement, constitutes an ongoing injury to the organization’s First Amendment associational rights by deterring donors and burdening protected association. The Court clarified that the injury arises when the government issues such a demand—not only if and when a court enforces it. The Court further held that the possibility of later confidentiality protections or limited exceptions in the subpoena did not eliminate the injury. The case was remanded for further proceedings. View "First Choice Women's Resource Centers, Inc. v. Davenport" on Justia Law

Louisiana v. Callais

2026-04-29T22:15:05-08:00

After the 2020 census, Louisiana redrew its congressional districts, enacting a map (HB1) with only one majority-black district. Plaintiffs challenged this map in the United States District Court for the Middle District of Louisiana, arguing that it diluted black voting power in violation of Section 2 of the Voting Rights Act. The court agreed, finding a likely Section 2 violation and ordering the state to add a second majority-black district. To avoid a court-imposed map, the legislature enacted a new map (SB8) with a second majority-black district, which connected distant black populations across the state. The new SB8 map was then challenged as an unconstitutional racial gerrymander in the United States District Court for the Western District of Louisiana (a three-judge court). The court found that race predominated in the drawing of SB8’s District 6 and that the state could not justify its actions under the Equal Protection Clause. The court concluded that the state had failed to show that Section 2 of the Voting Rights Act required the creation of an additional majority-black district or that compliance with the Act was a compelling interest. The court therefore held SB8 unconstitutional. On direct appeal, the Supreme Court of the United States addressed whether compliance with Section 2 of the Voting Rights Act can ever justify intentional race-based districting. The Court held that Section 2, properly interpreted, requires liability only when there is a strong inference of intentional discrimination, not merely disparate impact. The Court also clarified that a plaintiff’s illustrative maps must satisfy all the state’s legitimate districting goals without using race as a predominant factor and that evidence of racially polarized voting must be disentangled from partisan affiliation. The Supreme Court affirmed the district court’s ruling, holding that Louisiana’s SB8 map was an unconstitutional racial gerrymander because Section 2 did not require a second majority-black district, and no compelling interest justified the use of race. The case was remanded for further proceedings. View "Louisiana v. Callais" on Justia Law

Hencely v. Fluor Corp.

2026-04-22T22:15:06-08:00

A former Army specialist was seriously injured in a suicide bombing at a U.S. military base in Afghanistan. The attack was carried out by Ahmad Nayeb, a Taliban operative hired by Fluor Corporation, a military contractor, as part of a program encouraging the hiring of Afghan nationals. The Army’s investigation concluded that Fluor was primarily responsible due to negligent supervision and failure to enforce proper security procedures, including allowing Nayeb to check out tools used in the bombing and to move about the base unsupervised. The plaintiff sued Fluor in federal court in South Carolina, seeking damages under state law for negligent supervision, negligent entrustment, and negligent retention of Nayeb. The United States District Court for the District of South Carolina granted summary judgment to Fluor, holding that state-law tort claims were preempted under Fourth Circuit precedent whenever they arose out of combatant activities in a wartime setting. The United States Court of Appeals for the Fourth Circuit affirmed, adopting a broad “battlefield preemption” doctrine. It reasoned that the Federal Tort Claims Act’s (FTCA) combatant-activities exception, which preserves government immunity for claims arising out of military combatant activities, reflected an intent to bar all tort suits against contractors connected with those activities, regardless of whether the contractor followed or violated military instructions. The Supreme Court of the United States vacated the Fourth Circuit’s judgment and remanded the case. The Court held that the Fourth Circuit erred in finding the state-law tort claims preempted where the federal government neither ordered nor authorized the challenged conduct. The Supreme Court clarified that neither the Constitution, federal statutes, nor its precedents support such broad preemption. Preemption applies only if the contractor was following government directives or if there is a significant conflict between federal interests and state law, which was not the case here. View "Hencely v. Fluor Corp." on Justia Law

Enbridge Energy, LP v. Nessel

2026-04-22T22:15:05-08:00

The case concerns a dispute over the operation of Line 5, a petroleum pipeline owned and operated by Enbridge, which traverses the Straits of Mackinac in Michigan under a 1953 easement granted by the State. In June 2019, the Michigan Attorney General filed a lawsuit in state court seeking to stop Enbridge from operating the pipeline, arguing that the easement was void and that continued operation violated state law due to environmental risks. Enbridge was served with the complaint in July 2019 but did not remove the case to federal court within the statutory 30-day deadline. Instead, Enbridge litigated in state court for over a year. Subsequently, in November 2020, the Michigan Governor revoked the easement and initiated a separate state lawsuit with similar claims. Enbridge timely removed the Governor’s case to federal court, where the parties agreed to pause the Attorney General’s case pending resolution. After the District Court in the Governor’s case denied remand, finding federal-question jurisdiction, the Governor dismissed her suit. Thereafter, 887 days after the Attorney General’s complaint was served, Enbridge removed the original state lawsuit to federal court. The Attorney General moved to remand, arguing removal was untimely. The U.S. District Court denied the motion, excusing Enbridge’s late removal on equitable grounds and certified the issue for interlocutory appeal. The United States Court of Appeals for the Sixth Circuit reversed, holding that although the 30-day removal deadline in 28 U.S.C. §1446(b)(1) is nonjurisdictional, it is not subject to equitable tolling due to the statute’s text, structure, and context. The Supreme Court of the United States affirmed the Sixth Circuit’s decision, holding that §1446(b)(1)’s 30-day removal deadline cannot be equitably tolled. As a result, Enbridge’s removal was untimely, and the case must be remanded to Michigan state court. View "Enbridge Energy, LP v. Nessel" on Justia Law

District of Columbia v. R.W.

2026-04-21T22:15:25-08:00

In the early morning hours, a Metropolitan Police officer in Washington, D.C., responded to a radio dispatch about a suspicious vehicle at a specific location. Upon arrival, the officer observed two individuals fleeing from the car without any apparent provocation, leaving at least one car door open. The driver, R.W., then began to back the car out of its parking space with the rear door still open. The officer ordered R.W. to put his hands up and subsequently recovered evidence leading to charges including unauthorized use of a motor vehicle and felony receipt of stolen property. The Superior Court of the District of Columbia conducted a suppression hearing and denied R.W.’s motion to suppress, finding that the officer had reasonable suspicion based on the dispatch, the passengers’ flight, the late hour, and the car’s movement. After a bench trial, the court adjudicated R.W. delinquent on all counts. On appeal, the District of Columbia Court of Appeals reversed the suppression ruling and vacated the adjudication. It held that the officer lacked reasonable suspicion, after discounting the dispatch and the companions’ flight as relevant factors. The Supreme Court of the United States reviewed the case and held that the officer did have reasonable suspicion to stop R.W. The Court emphasized that the totality-of-the-circumstances test must be used, and that the Court of Appeals erred by disregarding key facts, such as the dispatch and the passengers’ flight, from its analysis. The Supreme Court reversed the judgment of the District of Columbia Court of Appeals and remanded the case for further proceedings consistent with its opinion. The holding is that, under the totality of the circumstances, the officer’s stop was supported by reasonable suspicion as required by the Fourth Amendment. View "District of Columbia v. R.W." on Justia Law

Chevron USA Inc. v. Plaquemines Parish

2026-04-19T22:15:05-08:00

During the Second World War, Chevron’s corporate predecessor operated oil fields in Plaquemines Parish, Louisiana, producing crude oil that was refined into aviation gasoline (avgas) for the United States military under federal contracts. Decades later, following the enactment of Louisiana’s State and Local Coastal Resources Management Act of 1978, which imposed permit requirements on certain uses of the coastal zone but exempted uses lawfully commenced before 1980, Plaquemines Parish and other parishes brought suit in state court. They alleged that Chevron and other oil companies had failed to obtain required permits and that some pre-1980 activities, including those during the war, were illegally commenced and not exempt. The parish’s expert report specifically challenged Chevron’s wartime crude-oil production methods, including its use of vertical drilling, canals, and earthen pits, as harmful to the environment and not in compliance with the Act. Chevron sought removal to federal court under the federal officer removal statute, 28 U.S.C. §1442(a)(1), arguing that the suit was “for or relating to” acts under color of its duties as a federal contractor refining avgas. The United States District Court granted the parish’s motion to remand to state court. The United States Court of Appeals for the Fifth Circuit affirmed, reasoning that although Chevron acted under a federal officer as a military contractor, the suit did not “relate to” those acts because the federal refining contract did not govern how Chevron obtained or produced crude oil. The Supreme Court of the United States held that Chevron plausibly alleged a close, not tenuous or remote, relationship between the challenged crude-oil production and its federal avgas refining duties. The Court concluded that the suit satisfied the “relating to” requirement for removal under §1442(a)(1), vacated the Fifth Circuit’s judgment, and remanded the case for further proceedings. View "Chevron USA Inc. v. Plaquemines Parish" on Justia Law

Chiles v. Salazar

2026-03-31T06:45:06-08:00

A licensed mental health counselor in Colorado, who provides talk therapy to clients—including minors—challenged a state law that prohibits licensed counselors from engaging in “conversion therapy” with minors. The law defines conversion therapy broadly to include any practice or treatment that attempts to change an individual’s sexual orientation or gender identity, including efforts to alter behaviors, expressions, or attractions. However, the law permits counselors to support clients exploring their identity or undergoing gender transition. The counselor’s practice involves helping clients pursue their own stated goals, which may include support for changes in sexual orientation or gender identity, but she only utilizes talk therapy and does not engage in any physical interventions. The United States District Court for the District of Colorado first reviewed the case. That court, and later the United States Court of Appeals for the Tenth Circuit, concluded that the counselor had standing to bring a pre-enforcement, as-applied First Amendment challenge to the law. Both courts interpreted the law as prohibiting her from using speech to help clients change their sexual orientation or gender identity. Nevertheless, both courts denied her request for a preliminary injunction, reasoning that the law regulates professional conduct, not speech, and any effect on speech is merely incidental. Applying rational-basis review, they found the law constitutionally permissible. The Supreme Court of the United States granted review to resolve a circuit split. The Supreme Court held that, as applied to the counselor’s talk therapy, the Colorado law regulates speech based on viewpoint, not merely conduct, and that the lower courts erred by applying only rational-basis scrutiny. The Supreme Court ruled that the law is subject to strict scrutiny under the First Amendment and reversed the Tenth Circuit’s decision, remanding the case for further proceedings consistent with its opinion. View "Chiles v. Salazar" on Justia Law

Cox Communications, Inc. v. Sony Music Entertainment

2026-03-25T06:45:08-08:00

Several major music copyright owners, including a leading entertainment company, sought to hold an Internet service provider responsible for copyright infringement committed by its subscribers. The service provider, which serves millions of customers, was notified by a monitoring company of over 160,000 instances where its subscribers’ IP addresses were linked to alleged copyright violations such as illegal music file sharing. Although the provider had policies prohibiting infringement and took steps such as issuing warnings and suspending service, the copyright holders argued these measures were inadequate and brought suit seeking to impose liability on the provider for continuing to serve known infringers. The case was tried in the United States District Court for the Eastern District of Virginia. There, the jury found in favor of the copyright owners on both contributory and vicarious liability, and determined the provider’s infringement was willful, awarding $1 billion in statutory damages. After the District Court denied the provider’s post-trial motion, the United States Court of Appeals for the Fourth Circuit affirmed the finding of contributory liability, reasoning that supplying a service with knowledge it would be used for infringement was sufficient. The Fourth Circuit, however, reversed as to vicarious liability and remanded for a new determination of damages. The Supreme Court of the United States reviewed the case concerning contributory liability. The Court held that a service provider is contributorily liable for a user’s infringement only if it either induced the infringement or provided a service tailored for infringement. Because the provider neither encouraged infringement nor offered a service primarily designed for infringement—since Internet access has substantial lawful uses—the provider was not contributorily liable. The Supreme Court reversed the Fourth Circuit’s judgment on contributory liability and remanded the case for further proceedings. View "Cox Communications, Inc. v. Sony Music Entertainment" on Justia Law

Rico v. United States

2026-03-25T06:45:06-08:00

The case concerns a federal defendant who, after serving a prison sentence for drug trafficking, began a term of supervised release. Following her initial release, she violated the conditions of supervised release, resulting in revocation and a new term of supervised release. During her second supervised release period, she again violated the conditions by changing her address without notifying her probation officer. A warrant was issued, but authorities did not apprehend her until over a year after her supervised release term was scheduled to expire. While absconding, she committed a separate state drug offense and was convicted in state court. The United States District Court concluded that her state drug offense, committed after her supervised release term had expired by the original schedule, constituted a violation of supervised release because her period was tolled (paused) while she was absconding. The court treated the drug offense as a Grade A violation and imposed another prison sentence followed by a new term of supervised release. The United States Court of Appeals for the Ninth Circuit affirmed, adopting the view that abscondment automatically tolled the supervised release period, allowing post-expiration violations to be treated as if they occurred during the term. The Supreme Court of the United States reversed the Ninth Circuit’s decision. The Court held that the Sentencing Reform Act does not authorize an automatic extension of a supervised release term when a defendant absconds. The Act specifies when supervised release begins and ends, provides mechanisms for revocation and extension under defined circumstances, and allows delayed adjudication of violations only for conduct occurring before expiration if a warrant or summons issues before the term ends. The Court concluded that abscondment does not automatically extend or toll the supervised release term beyond its judicially prescribed limit. The case was remanded for further proceedings. View "Rico v. United States" on Justia Law

Zorn v. Linton

2026-03-24T05:15:06-08:00

During the inauguration of Vermont’s governor, a group of protesters, including Shela Linton, staged a sit-in at the state capitol to advocate for universal healthcare. When the building closed, police instructed the protesters to leave or face arrest for trespassing. Some complied, while others, including Linton, refused. Sergeant Jacob Zorn approached Linton, who remained seated and passively resisted. After multiple warnings, Zorn used a rear wristlock to lift Linton to her feet, causing her to exclaim in pain. Linton alleged that this action resulted in physical and psychological injuries. Linton filed a lawsuit under 42 U.S.C. §1983, claiming Zorn’s use of force violated her Fourth Amendment rights. The United States District Court for the District of Vermont granted summary judgment to Zorn, holding he was entitled to qualified immunity because it was not clearly established that his actions constituted excessive force in these circumstances. The United States Court of Appeals for the Second Circuit reversed, relying on its earlier decision in Amnesty America v. West Hartford, reasoning that the use of a rear wristlock on a passively resisting protester was clearly established as excessive force. The Second Circuit remanded the case for a jury trial. The Supreme Court of the United States reviewed the case and held that Zorn was entitled to qualified immunity. The Court determined that Amnesty America did not clearly establish, with the requisite specificity, that Zorn’s conduct—using a wristlock after repeated warnings—violated the Fourth Amendment. The Court emphasized that qualified immunity protects officials unless prior precedent places the constitutional question beyond debate and found that no case had clearly held such conduct unlawful in similar circumstances. Accordingly, the Supreme Court granted certiorari and reversed the judgment of the Second Circuit. View "Zorn v. Linton" on Justia Law

Olivier v. City of Brandon

2026-03-20T06:45:37-08:00

Gabriel Olivier, a street preacher in Mississippi, was convicted in 2021 for violating a city ordinance that restricted expressive activities near a public amphitheater. The ordinance required individuals engaging in protests or demonstrations during event times to remain within a designated protest area. Olivier found the area too remote to reach his audience and, after returning to a more visible location, was arrested. He later pleaded no contest in municipal court, received a fine, probation, and a suspended jail sentence, and did not appeal his conviction. Following his conviction, Olivier filed a lawsuit in the United States District Court for the Southern District of Mississippi under 42 U.S.C. §1983 against the City and its police chief, claiming the ordinance violated the First Amendment. He sought declaratory and injunctive relief to prevent future enforcement of the ordinance, but not to overturn his prior conviction or seek damages. The City argued, based on Heck v. Humphrey, that his suit was barred because success would imply the invalidity of his conviction. The District Court agreed, and the United States Court of Appeals for the Fifth Circuit affirmed, holding that a §1983 suit implying a prior conviction’s invalidity is not allowed, regardless of the relief sought. The Supreme Court of the United States reviewed the case and unanimously held that Heck v. Humphrey does not bar a §1983 suit seeking only prospective relief, such as an injunction against future enforcement of a law, even if the plaintiff was previously convicted under that law. The Court reasoned that Olivier’s suit did not challenge his prior conviction or seek damages for it, but merely sought to avoid future prosecutions. The Supreme Court reversed the judgment of the Fifth Circuit and remanded the case for further proceedings. View "Olivier v. City of Brandon" on Justia Law

Urias-Orellana v. Bondi

2026-03-04T07:45:07-08:00

The petitioners, a family from El Salvador, entered the United States without authorization in 2021 and were placed in removal proceedings. Seeking asylum, they claimed that they had been targeted by a hitman in their home country. The testimony of Douglas Humberto Urias-Orellana, the principal applicant, was found credible by the Immigration Judge (IJ). However, the IJ determined that the evidence presented did not establish past persecution or a well-founded fear of future persecution as defined under the Immigration and Nationality Act (INA). The IJ denied their asylum applications and ordered their removal, with the claims of the wife and minor child treated as derivative of Urias-Orellana’s. Upon appeal to the Board of Immigration Appeals (BIA), the Board affirmed the IJ’s findings, concluding that the harm described did not rise to the statutory level of persecution and that Urias-Orellana did not demonstrate a well-founded fear of future persecution. The petitioners then sought review from the United States Court of Appeals for the First Circuit. The First Circuit applied the substantial-evidence standard, holding that the agency's conclusion was supported by the record and that a reasonable adjudicator would not be compelled to reach a contrary conclusion. The Supreme Court of the United States reviewed whether the First Circuit applied the correct standard of review. The Court held that the INA requires courts of appeals to apply the substantial-evidence standard to the entire agency determination of persecution, including both factual findings and the application of the statutory standard to those facts. Substantial-evidence review is required unless any reasonable adjudicator would be compelled to conclude otherwise. The Court affirmed the judgment of the First Circuit. View "Urias-Orellana v. Bondi" on Justia Law

Galette v. New Jersey Transit Corp.

2026-03-04T07:45:05-08:00

The case concerns injuries suffered by two individuals, one in New York and one in Pennsylvania, each struck by buses operated by New Jersey Transit Corporation (NJ Transit), a public transportation entity created by the New Jersey Legislature. NJ Transit operates as a “body corporate and politic” with significant powers such as suing and being sued, entering contracts, and raising funds. Its founding statute specifies that debts or liabilities of NJ Transit are not debts of the State of New Jersey, and all expenses must be paid from NJ Transit’s own funds. The State retains substantial control over NJ Transit through board appointments and removal powers, veto authority, and some legislative oversight, but the statute also stresses NJ Transit’s operational independence. After the incidents, the injured parties filed negligence lawsuits against NJ Transit in their home state courts. NJ Transit moved to dismiss both suits, arguing it was an arm of New Jersey and thus entitled to sovereign immunity. The Court of Appeals of New York concluded that NJ Transit is not an arm of New Jersey, allowing the New York suit to proceed. Conversely, the Supreme Court of Pennsylvania found that NJ Transit is an arm of New Jersey and dismissed the Pennsylvania suit. The Supreme Court of the United States reviewed both cases to resolve the conflict. It held that NJ Transit is not an arm of the State of New Jersey and therefore does not share in New Jersey’s interstate sovereign immunity. The Court emphasized that NJ Transit’s status as a legally separate corporation, responsible for its own debts and judgments, and the absence of formal state liability for its obligations, are decisive. The Court affirmed the New York decision, reversed the Pennsylvania decision, and remanded both cases for further proceedings. View "Galette v. New Jersey Transit Corp." on Justia Law

Mirabelli v. Bonta

2026-03-03T06:15:06-08:00

Parents and teachers in California challenged state policies that require schools to keep information about students’ gender transitioning confidential from parents unless the students consent. The parents objected to being excluded from knowledge and decisions regarding their children’s gender presentation at school, especially when those actions conflicted with their religious beliefs or their desire to participate in their children’s mental health care. Several parents described situations in which they were not informed about their children’s gender identity at school until after significant mental health crises occurred. Teachers objected to being compelled to use students’ preferred names and pronouns contrary to the wishes of parents and their own beliefs. The case was initiated in the United States District Court for the Southern District of California, where two teachers first challenged district policies. As litigation unfolded, the case expanded to include state officials as defendants and parents as additional plaintiffs. The District Court certified parent and teacher classes, granted summary judgment for the plaintiffs, and entered a permanent injunction that prohibited schools from withholding information from parents and required adherence to parental directions on names and pronouns. The District Court also ordered state-created instructional materials to include notice of the rights protected by the injunction. The United States Court of Appeals for the Ninth Circuit granted a stay of the injunction pending appeal, expressing procedural concerns about class certification under Federal Rule of Civil Procedure 23 and skepticism regarding the merits of the constitutional claims. The Supreme Court of the United States vacated the Ninth Circuit’s stay as to the parent plaintiffs, concluding that the parents seeking religious exemptions are likely to succeed on their Free Exercise and Due Process claims. The Court found the parents face irreparable harm and that equities favor them. The procedural objections raised by the Ninth Circuit were deemed unlikely to prevail. The application to vacate was otherwise denied. View "Mirabelli v. Bonta" on Justia Law

Geo Group, Inc. v. Menocal

2026-02-25T07:45:09-08:00

A company operating a private detention facility in Colorado under contract with U.S. Immigration and Customs Enforcement was sued in a class action by a former detainee. The lawsuit challenged two of the company’s work policies for detainees: a sanitation policy that required unpaid cleaning under threat of punishment, and a voluntary work program offering minimal pay. Plaintiffs alleged that the sanitation policy violated federal anti-forced-labor laws and that the voluntary work program constituted unjust enrichment under Colorado law. After discovery, the United States District Court for the District of Colorado considered the company’s argument that, under the Supreme Court’s decision in Yearsley v. W. A. Ross Construction Co., it could not be held liable for conduct that the government had lawfully “authorized and directed.” The District Court concluded that the government contract did not instruct the company to adopt the specific work policies at issue and that the company had developed those policies on its own. Therefore, the court held that the Yearsley doctrine did not shield the company from liability and allowed the case to proceed to trial. The company appealed immediately, but the United States Court of Appeals for the Tenth Circuit dismissed the appeal for lack of jurisdiction, holding that a denial of Yearsley protection is not subject to interlocutory appeal under Cohen v. Beneficial Industrial Loan Corp. The Supreme Court of the United States affirmed the Tenth Circuit’s decision, holding that Yearsley provides a merits defense, not an immunity from suit. Therefore, a pretrial order denying Yearsley protection cannot be immediately appealed; any review must wait until after final judgment. The Court remanded the case for further proceedings. View "Geo Group, Inc. v. Menocal" on Justia Law

Villarreal v. Texas

2026-02-25T07:45:07-08:00

During his murder trial, the defendant chose to testify in his own defense, claiming self-defense in the fatal stabbing. Partway through his testimony, the trial was interrupted by a 24-hour overnight recess. Before the break, the trial judge instructed the defendant’s attorneys not to “manage” or shape his ongoing testimony during the recess but clarified that the defendant was not barred from speaking with his lawyers about other matters, such as sentencing or trial strategy. After the recess, the defendant resumed testifying and was later convicted of murder. Upon appeal, the Texas Court of Criminal Appeals reviewed the trial judge’s conferral order. The appellate court found that the order was constitutionally permissible because it only restricted discussions specifically about managing the defendant’s ongoing testimony, not all attorney-client consultations. The appellate court emphasized that the order did not prevent the defendant from consulting his attorneys on other protected matters, such as plea negotiations or trial strategy, and was therefore a proper exercise of the trial court’s discretion. The Supreme Court of the United States addressed whether a qualified order limiting discussion of a defendant’s ongoing testimony during a midtestimony overnight recess violates the Sixth Amendment right to counsel. The Supreme Court held that such a qualified order is constitutional, so long as it prohibits only discussion of testimony for its own sake and does not prevent consultation on other protected topics, including trial strategy, plea discussions, or evidentiary issues. The Court distinguished this qualified order from a total ban on attorney-client discussions and affirmed that the order properly balanced the defendant’s right to counsel against the integrity of unaltered trial testimony. The judgment of the Texas Court of Criminal Appeals was affirmed. View "Villarreal v. Texas" on Justia Law

Hain Celestial Group, Inc. v. Palmquist

2026-02-24T07:45:09-08:00

The parents of a young child in Texas purchased and fed him baby food manufactured by one company and sold by another. After the child began exhibiting serious developmental and physical disorders, doctors attributed his condition to heavy-metal poisoning. Years later, a congressional subcommittee released a report identifying elevated levels of toxic heavy metals in certain baby foods, including that manufactured by the company in question. The parents then sued both the manufacturer and the retailer in Texas state court, alleging various state-law product liability, negligence, and breach-of-warranty claims. The manufacturer, a Delaware corporation with its principal place of business in New York, removed the case to federal court, arguing that the retailer—a Texas citizen like the plaintiffs—had been improperly joined and should be dismissed, thereby creating complete diversity. The United States District Court agreed, dismissed the retailer, denied the plaintiffs’ motion to remand, and proceeded to trial against the manufacturer alone. After trial, the District Court granted judgment as a matter of law to the manufacturer. On appeal, the United States Court of Appeals for the Fifth Circuit disagreed with the District Court’s finding of improper joinder, reversed the dismissal of the retailer, and concluded that because the retailer was a proper party, complete diversity was lacking. The Fifth Circuit vacated the judgment and remanded the case to state court. The Supreme Court of the United States held that the District Court’s erroneous dismissal of the nondiverse defendant did not cure the jurisdictional defect present at the time of removal. Because the jurisdictional defect was not cured and persisted through final judgment, the federal court’s judgment had to be vacated. The Supreme Court affirmed the Fifth Circuit’s decision and remanded the case for further proceedings. View "Hain Celestial Group, Inc. v. Palmquist" on Justia Law

Postal Service v. Konan

2026-02-24T07:45:07-08:00

The case involved a property owner in Euless, Texas, who had an ongoing dispute with the local post office regarding mail delivery to her two rental properties. She alleged that United States Postal Service employees intentionally withheld her mail and interfered with its delivery, resulting in personal and financial harm, including lost rental income and difficulty attracting tenants. Despite her attempts to resolve the issue through administrative complaints and by requesting alternative mail-handling services, the problems persisted. After these efforts failed, the property owner filed suit against the United States in the United States District Court for the Northern District of Texas, asserting various state-law tort claims such as nuisance, conversion, tortious interference with prospective business relations, and intentional infliction of emotional distress. The District Court dismissed her complaint, holding that the Federal Tort Claims Act’s (FTCA) postal exception preserved the government’s sovereign immunity for claims relating to the loss, miscarriage, or negligent transmission of mail, regardless of whether the conduct was negligent or intentional. On appeal, the United States Court of Appeals for the Fifth Circuit reversed, holding that the statutory terms did not encompass intentional acts of non-delivery. The Supreme Court of the United States reviewed the case to resolve a split among federal appellate courts. The Supreme Court held that the FTCA’s postal exception bars claims against the United States for the intentional nondelivery of mail. The Court found that, at the time the statute was enacted, the terms “miscarriage” and “loss” of mail included failures to deliver mail regardless of intent, and thus sovereign immunity applies even to claims alleging intentional misconduct by postal workers. The Supreme Court vacated the Fifth Circuit’s judgment and remanded the case for further proceedings. View "Postal Service v. Konan" on Justia Law

Learning Resources, Inc. v. Trump

2026-02-20T07:45:06-08:00

President Trump, after taking office, declared national emergencies over two foreign threats: the influx of illegal drugs from Canada, Mexico, and China, and persistent trade deficits affecting U.S. manufacturing and supply chains. Invoking authority under the International Emergency Economic Powers Act (IEEPA), he imposed tariffs—25% on most Canadian and Mexican imports, 10% on most Chinese imports for drug trafficking, and at least 10% on all imports for trade deficit concerns, with higher rates for dozens of nations and frequent modifications. Two sets of plaintiffs challenged these tariffs. In the United States District Court for the District of Columbia, Learning Resources plaintiffs won a preliminary injunction, as the court found IEEPA did not authorize the President to impose tariffs. The Government's motion to transfer to the United States Court of International Trade (CIT) was denied. In V.O.S. Selections, plaintiffs prevailed in the CIT, which granted summary judgment. The United States Court of Appeals for the Federal Circuit, sitting en banc, affirmed, holding that IEEPA’s authority to “regulate… importation” did not authorize such tariffs, as their scope, amount, and duration were unbounded. The Supreme Court of the United States reviewed the consolidated appeals. It held that IEEPA does not grant the President authority to impose tariffs, reasoning that the statute’s language—particularly “regulate… importation”—does not include the distinct power to tax or raise revenue through tariffs, a core congressional function. The Court emphasized the absence of explicit authorization and the constitutional structure reserving tariff powers to Congress. The Court affirmed the Federal Circuit’s judgment in the V.O.S. Selections case and vacated the District Court’s judgment in Learning Resources, remanding with instructions to dismiss for lack of jurisdiction. View "Learning Resources, Inc. v. Trump" on Justia Law

Klein v. Martin

2026-01-26T11:42:47-08:00

A man was convicted in Maryland state court for the attempted murder of his girlfriend, who was shot in her apartment. The prosecution presented evidence including a homemade device that appeared to be a silencer and DNA evidence tying the defendant to that device. Witnesses testified about the defendant’s involvement in preparing the device and his motive, which stemmed from the girlfriend’s pregnancy and her threat to seek child support. Additional evidence linked the defendant to the type of firearm used in the shooting. The jury found the defendant guilty as an accessory before the fact, and he was sentenced to life in prison. After his conviction was affirmed on appeal, the defendant sought postconviction relief in Maryland state court, arguing that the prosecution failed to disclose a forensic report about a laptop, which could have impeached a key witness’s testimony regarding the defendant’s online activity. The state postconviction court granted a new trial, but the Maryland Court of Special Appeals reversed, holding that the undisclosed evidence was not material because the other evidence linking the defendant to the crime was strong enough that there was no reasonable probability of a different outcome. The Maryland Court of Appeals denied review. The defendant then sought federal habeas relief. The United States District Court granted his petition, and a divided panel of the United States Court of Appeals for the Fourth Circuit affirmed, concluding that the state court had not properly applied the correct standard for materiality under Brady v. Maryland. The Supreme Court of the United States reversed, holding that the state appellate court correctly applied the materiality standard and that, under the Antiterrorism and Effective Death Penalty Act (AEDPA), federal courts must defer to reasonable state court decisions. The Supreme Court found that a fairminded jurist could conclude the withheld evidence was not material, and therefore federal habeas relief was not warranted. View "Klein v. Martin" on Justia Law

Coney Island Auto Parts Unlimited, Inc. v. Burton

2026-01-20T07:45:08-08:00

Vista-Pro Automotive, LLC initiated bankruptcy proceedings in 2014 and brought an adversary action against Coney Island Auto Parts Unlimited, Inc. to recover $50,000 in unpaid invoices. Vista-Pro attempted to serve Coney Island by mail but allegedly did not comply with the required service rules. Coney Island did not respond, leading the Bankruptcy Court to enter a default judgment in 2015. Over the next six years, the bankruptcy trustee sought to enforce the judgment, including notifying Coney Island’s CEO of the judgment in 2016. In 2021, a marshal seized funds from Coney Island’s bank account to satisfy the judgment, prompting Coney Island to seek relief from the judgment, alleging it was void due to improper service. The United States Bankruptcy Court denied Coney Island’s motion to vacate the judgment, finding that Coney Island failed to meet the requirement under Federal Rule of Civil Procedure 60(c)(1) that such motions be brought within a “reasonable time.” The United States District Court and the United States Court of Appeals for the Sixth Circuit both affirmed this decision, agreeing that the reasonable-time limit applied to motions alleging a void judgment. The Supreme Court of the United States reviewed the case to resolve a split among lower courts over whether the reasonable-time requirement of Rule 60(c)(1) applies to motions under Rule 60(b)(4) claiming a judgment is void. The Court held that the plain language and structure of Rule 60 make the reasonable-time requirement applicable to all Rule 60(b) motions, including those asserting voidness. The Supreme Court affirmed the judgment of the Sixth Circuit, concluding that motions for relief from allegedly void judgments must be made within a reasonable time. View "Coney Island Auto Parts Unlimited, Inc. v. Burton" on Justia Law

Ellingburg v. United States

2026-01-20T07:45:07-08:00

The petitioner was convicted of a federal crime and, after the enactment of the Mandatory Victims Restitution Act of 1996 (MVRA), was sentenced to pay $7,567.25 in restitution to his victim, even though his criminal conduct occurred before the MVRA became law. Years later, the petitioner challenged the continued obligation to pay restitution, arguing that applying the MVRA retroactively to his conduct violated the Ex Post Facto Clause of the Constitution. The United States District Court initially sentenced the petitioner under the MVRA. When the petitioner challenged the restitution order, the United States Court of Appeals for the Eighth Circuit found against him, ruling that restitution under the MVRA is not criminal punishment and thus not subject to the Ex Post Facto Clause. The Eighth Circuit’s decision rested on its interpretation that MVRA restitution was a civil remedy rather than a criminal penalty. The Supreme Court of the United States reviewed the case and reversed the Eighth Circuit’s judgment. The Supreme Court held that restitution imposed under the MVRA constitutes criminal punishment for purposes of the Ex Post Facto Clause. The Court explained that the statutory text and structure, as well as its placement in the criminal code and its role as a penalty imposed at sentencing, demonstrate that restitution under the MVRA is penal in nature. The Court further noted that only criminal defendants can be ordered to pay restitution, it is imposed in criminal proceedings, and the government, not the victim, is the adverse party. The Supreme Court remanded the case for further proceedings consistent with its ruling, allowing the Eighth Circuit to consider other arguments raised by the government. View "Ellingburg v. United States" on Justia Law

Berk v. Choy

2026-01-20T07:45:05-08:00

Harold Berk, while traveling in Delaware, suffered a fractured ankle and sought treatment at Beebe Medical Center, where Dr. Wilson Choy recommended a protective boot. Berk alleged that hospital staff improperly fitted the boot, worsening his injury, and that Dr. Choy failed to order an immediate follow-up X-ray, resulting in delayed treatment and the need for surgery. Berk, a citizen of another state, filed a medical malpractice suit in federal court against both the hospital and Dr. Choy under Delaware law. Delaware law requires that a medical malpractice complaint be accompanied by an affidavit of merit from a medical professional. Berk requested an extension to file this affidavit, which was granted, but ultimately failed to secure the required affidavit and instead filed his medical records under seal. The United States District Court for the District of Delaware dismissed Berk’s suit for failing to comply with Delaware’s affidavit of merit statute. The United States Court of Appeals for the Third Circuit affirmed the dismissal, finding the state law substantive and applicable in federal court because, in its view, the Federal Rules of Civil Procedure do not address the affidavit requirement. The Supreme Court of the United States reviewed the case and held that Delaware’s affidavit of merit requirement does not apply in federal court. The Court reasoned that Federal Rule of Civil Procedure 8, which governs the information a plaintiff must provide at the outset of a lawsuit, sets the standard for pleadings and does not require supporting evidence such as an affidavit. Because Rule 8 is a valid procedural rule under the Rules Enabling Act and regulates the manner and means by which claims are presented, it displaces the contrary Delaware law. The Supreme Court reversed the Third Circuit’s decision and remanded the case for further proceedings. View "Berk v. Choy" on Justia Law

Case v. Montana

2026-01-14T09:15:10-08:00

After receiving a report from his ex-girlfriend that he was threatening suicide and may have shot himself, law enforcement officers in Montana responded to William Case’s home. The officers were aware of Case’s mental health and substance abuse history, as well as prior threats of suicide and confrontations with police. Upon arrival, they received further details about the phone call from Case’s ex-girlfriend, observed an empty handgun holster, a notepad resembling a suicide note, and noted Case’s lack of response to their attempts at contact. Believing Case might be injured or at risk of imminent harm, the officers entered the home without a warrant to render emergency aid. During their search, Case emerged from a closet holding an object that appeared to be a gun, prompting an officer to shoot and injure him. A handgun was found near where Case had been standing. Case was charged with assaulting a police officer and moved to suppress the evidence obtained from the warrantless entry, arguing a Fourth Amendment violation. The trial court denied the motion, finding the entry justified by emergency circumstances. A Montana jury convicted Case. On appeal, the Montana Supreme Court upheld the conviction, applying its “community caretaker doctrine” and concluding that police may enter a home for a welfare check if “objective, specific and articulable facts” lead an experienced officer to suspect peril. The court rejected the argument that probable cause was required for such an entry, distinguishing emergency aid situations from criminal investigations. The Supreme Court of the United States reviewed the case to clarify the legal standard for warrantless home entry to render emergency aid. The Court held that officers may enter a home without a warrant if they have an “objectively reasonable basis for believing” that an occupant is seriously injured or imminently threatened with such injury. It declined to require probable cause in this context and affirmed the judgment of the Montana Supreme Court, finding the officers’ entry reasonable under the Fourth Amendment. View "Case v. Montana" on Justia Law

Barrett v. United States

2026-01-14T09:15:08-08:00

The defendant committed a series of robberies, one of which involved the fatal shooting of a victim by an accomplice. He was charged with Hobbs Act robbery, using a firearm during a crime of violence under 18 U.S.C. §924(c)(1)(A)(i), and causing death during that firearm use under 18 U.S.C. §924(j). A jury found him guilty on all counts, and the District Court sentenced him to a lengthy prison term, merging the sentences for the firearm offenses. After subsequent appellate proceedings, including reconsideration in light of Supreme Court decisions, the District Court resentenced the defendant, ultimately merging the convictions related to the firearm offenses. On appeal, the United States Court of Appeals for the Second Circuit addressed whether the defendant could be convicted under both §924(c)(1)(A)(i) and §924(j) for the same act. The Second Circuit held that, notwithstanding the overlap between the two provisions and the Blockburger v. United States test indicating they are the same offense, Congress had authorized cumulative punishments for both. The appellate court relied in part on its reading of Supreme Court precedent and statutory language concerning consecutive sentences, instructing the District Court to impose separate convictions and sentences for each provision. The Supreme Court of the United States reviewed the case and held that Congress did not clearly authorize convictions under both §§924(c)(1)(A)(i) and (j) for a single act that violates both provisions. The Court found that the Blockburger presumption—that Congress does not intend to punish the same offense under two statutes—applies, and no statutory text, structure, or legislative history overcame that presumption. As a result, a single act violating both provisions may yield only one conviction. The Supreme Court reversed the relevant part of the Second Circuit’s judgment and remanded the case for further proceedings consistent with its opinion. View "Barrett v. United States" on Justia Law

Bost v. Illinois Bd. of Elections

2026-01-14T09:15:05-08:00

Illinois law provides that election officials must count mail-in ballots postmarked or certified no later than election day, as long as those ballots are received within two weeks after election day. Congressman Michael Bost and two other political candidates filed suit against the Illinois State Board of Elections and its executive director, asserting that counting ballots received after election day violates federal statutes that set a single election day for federal offices. The plaintiffs alleged that the challenged law would require them to expend additional campaign resources, potentially harm their reputations, and deprive them of a fair electoral process. Congressman Bost, in particular, claimed he would need to extend campaign activities and monitoring efforts for two additional weeks, incurring costs and risking a reduction in his margin of victory. The United States District Court for the Northern District of Illinois dismissed the case, concluding that the plaintiffs lacked standing. The United States Court of Appeals for the Seventh Circuit affirmed, reasoning that the injuries alleged—such as increased campaign costs and potential reputational harm—were speculative or voluntarily incurred. The Seventh Circuit emphasized that Congressman Bost had won his prior election with a significant margin and found the plaintiffs’ injuries to be neither concrete nor particularized enough to support standing. The Supreme Court of the United States reviewed the case and held that Congressman Bost, as a candidate for office, does have standing to challenge the rules governing vote counting in his election. The Court reasoned that candidates possess a concrete and particularized interest in the integrity and legality of the electoral process, which is distinct from the generalized interest of voters. The judgment of the Seventh Circuit was reversed and the case remanded for further proceedings. View "Bost v. Illinois Bd. of Elections" on Justia Law

Bowe v. United States

2026-01-09T13:45:08-08:00

In this case, a federal prisoner pleaded guilty in 2008 to charges including conspiracy and attempted Hobbs Act robbery, as well as using a firearm during a “crime of violence” under 18 U.S.C. §924(c). The firearm conviction carried a mandatory 10-year consecutive sentence. After later Supreme Court decisions—United States v. Davis (which invalidated the residual clause of §924(c) as unconstitutionally vague) and United States v. Taylor (which held that attempted Hobbs Act robbery does not qualify as a “crime of violence” under the elements clause)—the validity of the petitioner’s §924(c) conviction was called into doubt. The petitioner first sought relief in federal district court in 2016, but was denied because at that time, Eleventh Circuit precedent still considered attempted Hobbs Act robbery a crime of violence under the elements clause. After Davis, the petitioner sought authorization from the United States Court of Appeals for the Eleventh Circuit to file a second or successive motion under 28 U.S.C. §2255(h), but the court denied authorization, finding he could not make a prima facie case for relief based on then-current precedent. After Taylor, he again sought authorization, but the Eleventh Circuit denied or dismissed his requests, relying on 28 U.S.C. §2244(b)(1) to bar claims previously presented and holding that Taylor did not announce a new constitutional rule. The petitioner’s efforts for rehearing and for certification of the controlling question to the Supreme Court were also denied. The Supreme Court of the United States held that the certiorari bar in §2244(b)(3)(E) does not apply to federal prisoners seeking leave to file a second or successive motion under §2255(h), so the Court had jurisdiction. The Court further held that §2244(b)(1)’s bar on previously presented claims applies only to state prisoners’ habeas applications under §2254, not to federal prisoners’ §2255 motions. The Court vacated the Eleventh Circuit’s decision and remanded for further proceedings. View "Bowe v. United States" on Justia Law

Clark v. Sweeney

2025-11-25T13:53:34-08:00

Jeremiah Sweeney was involved in a late-night argument with neighbors over stolen marijuana, during which he fired a gun, missing his intended targets but fatally striking a bystander some distance away. At trial, a key issue was whether Sweeney could have been the shooter given his location and the trajectory of the bullet. After the prosecution rested, a juror independently visited the crime scene and reported his findings to the rest of the jury, leading to his dismissal and the continuation of deliberations with the remaining eleven jurors. Sweeney was convicted of second-degree murder and other charges. His convictions were upheld by a Maryland appellate court on direct appeal. Sweeney then pursued postconviction relief in Maryland state court, arguing his trial counsel was ineffective for not seeking to question the rest of the jury about possible prejudice following the dismissed juror’s unauthorized crime-scene visit. The state court denied relief. Sweeney repeated this claim in a federal habeas petition before the United States District Court, which also denied relief, finding that the state court's application of Strickland v. Washington was not objectively unreasonable. The United States Court of Appeals for the Fourth Circuit reversed, not on the ineffective assistance claim Sweeney asserted, but on the grounds that a series of failures deprived him of his constitutional rights, and ordered a new trial. The Supreme Court of the United States held that the Fourth Circuit erred by granting relief on a claim that Sweeney had never raised, thus violating the principle of party presentation. The Supreme Court reversed the Fourth Circuit’s judgment and remanded the case, instructing the lower court to address only the ineffective-assistance claim Sweeney actually raised. View "Clark v. Sweeney" on Justia Law

Pitts v. Mississippi

2025-11-25T13:53:33-08:00

A child reported sexual abuse by her father following a weekend visit, which led to criminal charges against him. At trial, the prosecution requested that a screen be placed between the child witness and the defendant during her testimony, citing a Mississippi statute that mandated such a screen in child-abuse cases. The defendant objected, contending that the statute’s mandatory requirement could not override his Sixth Amendment right to confront his accuser face to face unless the court made a case-specific finding that such a procedure was necessary to protect the witness. The trial court granted the State’s motion, reasoning that the statutory mandate left no discretion, and the defendant was subsequently convicted by a jury. On appeal, the Mississippi Supreme Court acknowledged that the trial court did not make a case-specific finding of necessity but upheld the procedure, distinguishing Supreme Court precedents and holding that the statutory requirement was sufficient authority for the use of the screen. The Supreme Court of the United States reversed the decision of the Mississippi Supreme Court. The Court held that under the Sixth Amendment, a defendant’s right to confront witnesses may not be denied based solely on a statute or generalized findings of necessity. Instead, a trial court must hear evidence and make a case-specific finding of necessity before permitting screening of a child witness. The Court remanded the case, allowing the Mississippi Supreme Court to consider whether the constitutional error was harmless beyond a reasonable doubt, consistent with the harmless-error standard. View "Pitts v. Mississippi" on Justia Law

Goldey v. Fields

2025-07-01T12:12:10-08:00

Andrew Fields, an inmate at the U.S. Penitentiary in Lee County, Virginia, was placed in solitary confinement by prison officials, who monitored his condition during his isolation. Fields claimed that during periodic checks, certain officials physically abused him. He filed suit in federal court against the Bureau of Prisons, the warden, and several prison officials, seeking damages for alleged excessive force in violation of the Eighth Amendment. The U.S. District Court for the Western District of Virginia dismissed Fields’s complaint, determining that there is no implied cause of action under Bivens v. Six Unknown Fed. Narcotics Agents, 403 U.S. 388 (1971), for excessive force claims by federal prison officers against inmates. The court reasoned that the Supreme Court had never recognized a damages remedy for such claims, so Fields's case arose in a new context, and a Bivens remedy was unavailable. Fields appealed, and the U.S. Court of Appeals for the Fourth Circuit reversed in relevant part. The Fourth Circuit allowed Fields’s Eighth Amendment excessive-force claim for damages to proceed, finding that no special factors counseled against extending Bivens to this context. A dissenting judge argued that precedent barred creating a new Bivens action. The Supreme Court of the United States granted certiorari and reversed the Fourth Circuit’s judgment. The Court held that recognizing a Bivens cause of action for Eighth Amendment excessive-force claims by federal prison officials is inappropriate. The Court found that this case presents a new Bivens context and that special factors, including congressional action in prisoner litigation, alternative remedial structures, and concerns about the operation of prisons, counsel against extending Bivens. The case was remanded for further proceedings consistent with this opinion. View "Goldey v. Fields" on Justia Law

Trump v. CASA, Inc.

2025-06-27T08:35:35-08:00

The case involves three separate lawsuits filed by individuals, organizations, and states to prevent the enforcement of President Trump's Executive Order No. 14160. This order specifies conditions under which a person born in the United States is not considered a citizen. The plaintiffs argue that the order violates the Fourteenth Amendment's Citizenship Clause and the Nationality Act of 1940. District Courts in each case issued universal injunctions, preventing the order's enforcement against anyone, not just the plaintiffs. The Government sought to limit these injunctions to the plaintiffs, arguing that the courts lacked the authority to issue such broad relief. The District Courts concluded that the Executive Order was likely unlawful and issued universal preliminary injunctions. The Courts of Appeals denied the Government's requests to stay these injunctions. The Government then filed emergency applications with the Supreme Court, seeking partial stays to limit the injunctions to the plaintiffs. The Supreme Court of the United States reviewed the case and held that universal injunctions likely exceed the equitable authority granted to federal courts by Congress. The Court granted the Government's applications for partial stays, limiting the injunctions to the extent necessary to provide complete relief to each plaintiff with standing to sue. The Court emphasized that federal courts' equitable authority is confined to traditional remedies available at the time of the Judiciary Act of 1789, and universal injunctions do not have a historical precedent. The Court directed the lower courts to determine whether narrower injunctions would be appropriate. View "Trump v. CASA, Inc." on Justia Law

FCC v. Consumers' Research

2025-06-27T08:35:29-08:00

The case involves the Federal Communications Commission (FCC) and its universal-service contribution scheme, which requires telecommunications carriers to contribute to a fund that subsidizes communications services for underserved communities. The FCC uses a formula to determine the contribution amount, and the Universal Service Administrative Company, a private entity, assists in managing the fund and projecting financial needs. The Fifth Circuit Court of Appeals reviewed the case and found the contribution scheme unconstitutional due to a "double-layered delegation" of authority. The court expressed skepticism about Congress's delegation of power to the FCC and the FCC's delegation to the Administrator, suggesting that the combination of these delegations violated the Constitution's nondelegation doctrine. The Supreme Court of the United States reviewed the case and reversed the Fifth Circuit's decision. The Court held that the universal-service contribution scheme does not violate the nondelegation doctrine. It found that Congress provided sufficient guidance to the FCC through the Communications Act of 1934 and its amendments, which set clear policies and boundaries for the FCC's actions. The Court also determined that the FCC retained decision-making authority and that the Administrator's role was advisory, not a delegation of governmental power. The Court rejected the Fifth Circuit's combination theory, stating that the separate delegations did not compound to create a constitutional violation. View "FCC v. Consumers' Research" on Justia Law

Kennedy v. Braidwood Management, Inc.

2025-06-27T08:35:26-08:00

In 1984, the Department of Health and Human Services (HHS) created the U.S. Preventive Services Task Force to make evidence-based recommendations on preventive healthcare services. The Affordable Care Act of 2010 required most health insurers to cover services rated "A" or "B" by the Task Force without cost sharing. Plaintiffs, including Braidwood Management, objected to these requirements and argued that Task Force members are principal officers who must be appointed by the President with Senate consent, not by the Secretary of HHS. The U.S. District Court for the Northern District of Texas agreed with the plaintiffs, ruling that Task Force members are principal officers because they have no superior who supervises and directs them. The court enjoined the government from enforcing the insurance coverage mandates based on Task Force recommendations issued after 2010. The U.S. Court of Appeals for the Fifth Circuit affirmed, holding that Task Force members are principal officers because they cannot be independent and free from political pressure while being supervised by a political appointee. The Supreme Court of the United States reversed the Fifth Circuit's decision, holding that Task Force members are inferior officers. The Court reasoned that the Secretary of HHS has the authority to remove Task Force members at will and to review and block their recommendations before they take effect. This supervision and direction by the Secretary, a principal officer, means that Task Force members are inferior officers. Therefore, their appointment by the Secretary of HHS is consistent with the Appointments Clause of the Constitution. The case was remanded for further proceedings consistent with this opinion. View "Kennedy v. Braidwood Management, Inc." on Justia Law

Mahmoud v. Taylor

2025-06-27T08:35:09-08:00

During the 2022-2023 school year, the Montgomery County Board of Education introduced LGBTQ+-inclusive storybooks into the public school curriculum for kindergarten through fifth grade. Initially, the Board allowed parents to opt their children out of this instruction, consistent with its guidelines for respecting religious diversity. However, the Board later rescinded this opt-out policy, citing disruptions and potential social stigma for students who opted out. A group of parents from diverse religious backgrounds, who believe the curriculum undermines their religious teachings on sexuality and gender, filed a lawsuit seeking to reinstate the opt-out option. The United States District Court for the District of Maryland denied the parents' request for a preliminary injunction, dismissing their reliance on Wisconsin v. Yoder and characterizing their claim as an objection to school indoctrination. The court held that the curriculum did not violate the Free Exercise Clause. A divided panel of the Fourth Circuit affirmed, finding insufficient evidence that the storybooks coerced students to change their views or act contrary to their faith. The Supreme Court of the United States reversed the Fourth Circuit's decision, holding that the parents are entitled to a preliminary injunction. The Court found that the Board's policies substantially interfere with the religious development of the children and impose a burden on religious exercise similar to that in Yoder. The Court concluded that the parents are likely to succeed on the merits of their claim, suffer irreparable harm without relief, and that an injunction is in the public interest. The Board must notify parents in advance when the books will be used and allow their children to be excused from that instruction. View "Mahmoud v. Taylor" on Justia Law

Free Speech Coalition, Inc. v. Paxton

2025-06-27T08:35:06-08:00

In 2023, Texas enacted H.B. 1181, which requires commercial websites publishing sexually explicit content to verify that visitors are 18 or older. The law aims to prevent minors from accessing such content, with violations resulting in injunctions and civil penalties. Representatives of the pornography industry challenged the law, claiming it was unconstitutional under the First Amendment as it hindered adults' access to protected speech. The District Court granted a preliminary injunction, finding that the law was subject to strict scrutiny and that Texas had not shown it was narrowly tailored or the least restrictive means to achieve its goal. The court suggested that encouraging parents to use content-filtering software would be a less restrictive alternative. The U.S. Court of Appeals for the Fifth Circuit vacated the injunction, holding that the law was a regulation of the distribution of materials obscene to minors and only incidentally affected adults' privacy. The court applied rational-basis review, concluding that the age-verification requirement was rationally related to the government's interest in preventing minors' access to pornography. The Supreme Court of the United States reviewed the case and held that H.B. 1181 triggers intermediate scrutiny because it only incidentally burdens adults' protected speech. The Court found that the law advances important governmental interests in shielding children from sexual content and is adequately tailored to that interest. The Court affirmed the Fifth Circuit's judgment, concluding that H.B. 1181 is a constitutionally permissible exercise of Texas's authority to prevent minors from accessing sexually explicit content. View "Free Speech Coalition, Inc. v. Paxton" on Justia Law

Gutierrez v. Saenz

2025-06-26T08:35:12-08:00

In 1998, Ruben Gutierrez was charged with capital murder in Texas for his involvement in the killing of Escolastica Harrison. The prosecution argued that Gutierrez used one of two screwdrivers to stab Harrison. The jury convicted him, and he was sentenced to death after the jury found that he either caused Harrison's death, intended to kill her, or anticipated that a human life would be taken. Gutierrez has sought DNA testing of evidence for nearly 15 years, claiming it would prove he was not present at the crime scene. Texas courts denied his requests, stating that even if his DNA was not found, it would not prove his innocence of the underlying crime. Gutierrez filed a federal lawsuit under 42 U.S.C. §1983 against the district attorney, arguing that Texas's DNA testing procedures violated his due process rights. The District Court agreed and granted declaratory relief. However, the Fifth Circuit vacated this judgment, holding that Gutierrez lacked standing because a declaratory judgment would not likely result in the prosecutor allowing DNA testing. The Supreme Court of the United States reviewed the case and held that Gutierrez has standing to bring his §1983 claim. The Court reasoned that a state-created right to postconviction procedures can create rights to other procedures essential to realizing that right. The Court found that a declaratory judgment in Gutierrez's favor would redress his injury by removing the prosecutor's reliance on Article 64 as a reason for denying DNA testing. The judgment of the Fifth Circuit was reversed, and the case was remanded for further proceedings. View "Gutierrez v. Saenz" on Justia Law

Medina v. Planned Parenthood South Atlantic

2025-06-26T08:35:09-08:00

In 2018, South Carolina excluded Planned Parenthood from its Medicaid program, citing state law prohibiting public funds for abortion. Planned Parenthood and patient Julie Edwards sued, claiming the exclusion violated the Medicaid any-qualified-provider provision, which allows Medicaid beneficiaries to obtain services from any qualified provider. Edwards preferred Planned Parenthood for gynecological care but needed Medicaid coverage. They filed a class action under 42 U.S.C. §1983 to enforce rights under the federal Medicaid statutes. The district court granted summary judgment for the plaintiffs and enjoined the exclusion. The Fourth Circuit affirmed. The Supreme Court granted certiorari, vacated, and remanded the case in light of Health and Hospital Corporation of Marion Cty. v. Talevski, which addressed whether another spending-power statute created §1983-enforceable rights. On remand, the Fourth Circuit reaffirmed its decision. The Supreme Court of the United States held that Section 1396a(a)(23)(A) does not clearly and unambiguously confer individual rights enforceable under §1983. The Court emphasized that spending-power statutes rarely create enforceable rights and that the any-qualified-provider provision lacks the clear rights-creating language necessary to support a §1983 action. The Court reversed the Fourth Circuit's decision and remanded the case for further proceedings consistent with this opinion. View "Medina v. Planned Parenthood South Atlantic" on Justia Law

Riley v. Bondi

2025-06-26T08:35:07-08:00

Pierre Riley, a Jamaican citizen, was ordered removed from the United States by the Department of Homeland Security (DHS) under expedited procedures for aliens convicted of aggravated felonies. Riley sought relief under the Convention Against Torture (CAT), claiming he would be killed by a drug kingpin if returned to Jamaica. An Immigration Judge (IJ) found Riley credible and granted deferral of removal under the CAT. However, the Board of Immigration Appeals (BIA) vacated the IJ’s order, allowing the removal order to be enforced. Riley filed a petition for review in the U.S. Court of Appeals for the Fourth Circuit within 30 days of the BIA’s decision but long after the DHS issued the final administrative review order (FARO). The Fourth Circuit dismissed Riley’s petition for lack of jurisdiction, holding that the 30-day filing deadline for judicial review of a final order of removal is jurisdictional and that the final order of removal was the FARO, not the BIA’s decision. The Supreme Court of the United States reviewed the case and held that BIA orders denying deferral of removal in withholding-only proceedings are not final orders of removal under 8 U.S.C. §1252(b)(1). The Court also held that the 30-day filing deadline under §1252(b)(1) is a claims-processing rule, not a jurisdictional requirement. Consequently, the Court vacated the Fourth Circuit’s judgment and remanded the case for further proceedings consistent with its opinion. View "Riley v. Bondi" on Justia Law

Hewitt v. United States

2025-06-26T08:35:05-08:00

In 2009, Tony Hewitt, Corey Duffey, and Jarvis Ross were convicted of multiple counts of bank robbery and conspiracy, along with corresponding §924(c) offenses for using a firearm during a crime of violence. Each received a mandatory 5-year sentence for the first §924(c) count and 25-year mandatory sentences for each additional count, resulting in sentences exceeding 325 years. After successfully challenging some convictions, the Fifth Circuit vacated their sentences, and they were resentenced to between 285 and 305 years. Following the First Step Act of 2018, which reduced mandatory minimum penalties for first-time §924(c) offenders, the District Court vacated more convictions and resentenced them under the pre-Act scheme, resulting in sentences of 130 years or more. The Fifth Circuit denied the joint request by petitioners and the Government to apply the First Step Act’s more lenient penalties, holding that §403(b) applies only to defendants who had not been sentenced as of the Act’s enactment. Since the petitioners had been sentenced twice before the Act, the court concluded they were ineligible for the Act’s benefits. The Supreme Court of the United States reversed the Fifth Circuit’s decision, holding that under §403(b) of the First Step Act, a sentence “has been imposed” only if it remains valid and has not been vacated. Therefore, the Act’s more lenient penalties apply to defendants whose previous §924(c) sentences have been vacated and who need to be resentenced following the Act’s enactment. The case was remanded for further proceedings consistent with this interpretation. View "Hewitt v. United States" on Justia Law

Diamond Alternative Energy, LLC v. Environmental Protection Agency

2025-06-20T13:24:34-08:00

The Environmental Protection Agency (EPA) approved California regulations under the Clean Air Act that require automakers to produce more electric vehicles and fewer gasoline-powered vehicles to reduce emissions. Several fuel producers, including those of gasoline and ethanol, sued the EPA, arguing that the EPA lacked the authority to approve these regulations as they target global climate change rather than local air quality issues. The fuel producers claimed that the regulations would significantly reduce the demand for liquid fuels, causing them monetary injury. The United States Court of Appeals for the District of Columbia Circuit reviewed the case and held that the fuel producers lacked Article III standing. The court found that the fuel producers failed to demonstrate that automakers would likely respond to the invalidation of the regulations by producing fewer electric vehicles and more gasoline-powered vehicles, thus failing to establish redressability. The Supreme Court of the United States reviewed the case and held that the fuel producers have Article III standing to challenge the EPA’s approval of the California regulations. The Court found that the fuel producers demonstrated injury in fact, causation, and redressability. The Court reasoned that the regulations likely cause monetary injury to the fuel producers by reducing the demand for gasoline and other liquid fuels. The Court also found that invalidating the regulations would likely redress the injury by increasing the sales of gasoline-powered vehicles and, consequently, the demand for liquid fuels. The judgment of the Court of Appeals was reversed and the case was remanded for further proceedings. View "Diamond Alternative Energy, LLC v. Environmental Protection Agency" on Justia Law

Fuld v. Palestine Liberation Organization

2025-06-20T13:24:31-08:00

The case involves two separate lawsuits filed in the United States District Court for the Southern District of New York under the Antiterrorism Act of 1990 (ATA). The plaintiffs, American citizens injured or killed in terror attacks, sued the Palestine Liberation Organization (PLO) and Palestinian Authority (PA). The plaintiffs alleged that the PLO and PA engaged in conduct that triggered jurisdiction under the Promoting Security and Justice for Victims of Terrorism Act (PSJVTA), which deems these entities to have consented to personal jurisdiction in ATA cases under certain conditions. The United States District Court for the Southern District of New York found evidence that the PLO and PA engaged in conduct sufficient to satisfy the PSJVTA's jurisdictional predicates. However, the court ruled that exercising jurisdiction under the PSJVTA was unconstitutional. The Second Circuit Court of Appeals affirmed this decision, holding that the PSJVTA could not establish personal jurisdiction over the PLO or PA consistent with constitutional due process requirements. The Supreme Court of the United States reviewed the case and held that the PSJVTA's personal jurisdiction provision does not violate the Fifth Amendment's Due Process Clause. The Court reasoned that the statute reasonably ties the assertion of jurisdiction over the PLO and PA to conduct involving the United States and implicating sensitive foreign policy matters within the prerogative of the political branches. The Court reversed the Second Circuit's judgment and remanded the case for further proceedings consistent with its opinion. View "Fuld v. Palestine Liberation Organization" on Justia Law

Stanley v. City of Sanford

2025-06-20T13:24:27-08:00

Karyn Stanley, a firefighter for the City of Sanford, Florida, since 1999, was forced to retire in 2018 due to a disability. When she was hired, the City provided health insurance until age 65 for retirees with 25 years of service or those who retired due to disability. In 2003, the City revised its policy, limiting health insurance to 24 months for those retiring due to disability. Stanley, who retired under the revised policy, received only 24 months of health insurance. Stanley sued the City, alleging that the revised policy violated the Americans with Disabilities Act (ADA) by discriminating against those who retire due to disability. The district court dismissed her ADA claim, stating that the alleged discrimination occurred after her retirement, making her not a "qualified individual" under Title I of the ADA, as she no longer held or sought a job with the City. The Eleventh Circuit affirmed the district court's decision. The Supreme Court of the United States reviewed the case and affirmed the lower courts' decisions. The Court held that to prevail under §12112(a) of the ADA, a plaintiff must prove that they held or desired a job and could perform its essential functions with or without reasonable accommodation at the time of the alleged discrimination. The Court concluded that the ADA's protections do not extend to retirees who neither hold nor seek a job. The judgment of the Eleventh Circuit was affirmed, upholding the dismissal of Stanley's ADA claim. View "Stanley v. City of Sanford" on Justia Law

Esteras v. United States

2025-06-20T13:24:23-08:00

Edgardo Esteras pleaded guilty to conspiring to distribute heroin and was sentenced to 12 months in prison followed by a 6-year term of supervised release. After completing his prison term, Esteras was arrested for allegedly threatening to kill the mother of his children and firing shots into her vehicle. Although the charges were dismissed, the District Court held a revocation hearing and found that Esteras had violated the conditions of his supervised release. The court revoked his supervised release, ordered 24 months of reimprisonment, and imposed an additional three years of supervised release. Esteras's counsel objected, arguing that the District Court had impermissibly considered the factor in Section 3553(a)(2)(A). The District Court acknowledged that part of its decision was based on the need to promote respect for the law. The Sixth Circuit affirmed the District Court's decision, reasoning that Section 3583(e) does not explicitly prohibit considering Section 3553(a)(2)(A) and that excluding it would be unworkable. The Supreme Court of the United States reviewed the case and disagreed with the Sixth Circuit. The Court held that Congress's decision to exclude Section 3553(a)(2)(A) from the list of factors in Section 3583(e) implies that courts may not consider it when deciding whether to revoke a term of supervised release. The Court emphasized that supervised release is intended to fulfill rehabilitative ends and provide postconfinement assistance, not to serve as additional punishment for the original offense. Consequently, the Supreme Court vacated the judgments of the Sixth Circuit and remanded the cases for further proceedings consistent with this opinion. View "Esteras v. United States" on Justia Law

McLaughlin Chiropractic Associates, Inc. v. McKesson Corp.

2025-06-20T13:24:20-08:00

McKesson Corporation sent unsolicited fax advertisements to medical practices, including McLaughlin Chiropractic Associates, in 2009 and 2010. McLaughlin sued McKesson in 2014 in the U.S. District Court for the Northern District of California, alleging violations of the Telephone Consumer Protection Act (TCPA) for sending unsolicited faxes without the required opt-out notices. McLaughlin sought damages and an injunction and aimed to represent a class of fax recipients who received the advertisements on traditional fax machines or through online fax services. The District Court certified the class without distinguishing between the two methods of receipt. During the lawsuit, the Federal Communications Commission (FCC) issued the Amerifactors order, which interpreted "telephone facsimile machine" in the TCPA to exclude online fax services. The District Court, following Ninth Circuit precedent, deemed the Amerifactors order binding and granted summary judgment to McKesson for claims involving online fax services. The court then decertified the class, leaving McLaughlin with claims for only 12 faxes received on a traditional machine and damages of $6,000. The Ninth Circuit affirmed the District Court's decision. The Supreme Court of the United States reviewed the case and held that the Hobbs Act does not bind district courts in civil enforcement proceedings to an agency’s interpretation of a statute. District courts must independently determine the law’s meaning under ordinary principles of statutory interpretation while affording appropriate respect to the agency’s interpretation. The Court reversed the Ninth Circuit's decision and remanded the case for further proceedings consistent with this opinion. View "McLaughlin Chiropractic Associates, Inc. v. McKesson Corp." on Justia Law

Food and Drug Administration v. R.J. Reynolds Vapor Co.

2025-06-20T13:24:17-08:00

The Family Smoking Prevention and Tobacco Control Act (TCA) mandates that manufacturers must obtain approval from the Food and Drug Administration (FDA) before marketing any new tobacco product. In 2016, the FDA classified e-cigarettes as new tobacco products under the TCA. R. J. Reynolds Vapor Co. (RJR Vapor) applied for FDA approval to market its Vuse Alto e-cigarettes, but the FDA denied the application, stating that RJR Vapor failed to prove that marketing the products would protect public health. RJR Vapor, along with a Texas-based retailer and a Mississippi-based trade association, challenged the FDA's denial in the Fifth Circuit. The FDA requested the Fifth Circuit to dismiss or transfer the petition, arguing that only the applicant (RJR Vapor) was "adversely affected" by the denial and thus eligible to seek judicial review. The Fifth Circuit, however, ruled that the venue was proper and denied the FDA's motion. The Supreme Court of the United States reviewed the case and held that retailers who would sell a new tobacco product if not for the FDA’s denial order are "adversely affected" and may seek judicial review under the TCA. The Court interpreted "adversely affected" broadly, consistent with its use in other statutes, and concluded that the retailers' interests were within the zone of interests protected by the TCA. The Court affirmed the Fifth Circuit's decision and remanded the case for further proceedings. View "Food and Drug Administration v. R.J. Reynolds Vapor Co." on Justia Law

United States v. Skrmetti

2025-06-18T08:35:19-08:00

In 2023, Tennessee enacted Senate Bill 1 (SB1), which prohibits healthcare providers from prescribing, administering, or dispensing puberty blockers or hormones to minors for the purpose of enabling them to identify with a gender different from their biological sex or to treat discomfort from such discordance. However, SB1 allows these treatments for minors with congenital defects, precocious puberty, disease, or physical injury. Three transgender minors, their parents, and a doctor challenged SB1 under the Equal Protection Clause of the Fourteenth Amendment. The District Court partially enjoined SB1, finding that transgender individuals constitute a quasi-suspect class, that SB1 discriminates based on sex and transgender status, and that it was unlikely to survive intermediate scrutiny. The Sixth Circuit reversed, holding that SB1 did not trigger heightened scrutiny and satisfied rational basis review. The court found that SB1 did not classify based on sex or transgender status and that Tennessee had provided considerable evidence regarding the risks associated with the banned treatments. The Supreme Court of the United States reviewed the case and held that SB1 is not subject to heightened scrutiny under the Equal Protection Clause and satisfies rational basis review. The Court determined that SB1 does not classify on any bases that warrant heightened review, such as sex or transgender status. Instead, it classifies based on age and medical use, which are subject to rational basis review. The Court found that Tennessee had a rational basis for enacting SB1, citing concerns about the risks and unknown long-term effects of the treatments, the maturity of minors, and the availability of less invasive approaches. The judgment of the Sixth Circuit was affirmed. View "United States v. Skrmetti" on Justia Law

Perttu v. Richards

2025-06-18T08:35:15-08:00

In this case, inmate Kyle Richards alleged that Thomas Perttu, a prison employee, sexually harassed him and other inmates. Richards also claimed that Perttu destroyed his grievance documents and retaliated against him for attempting to file them. Richards sued Perttu under 42 U.S.C. §1983 for violating his constitutional rights, including his First Amendment right to file grievances. Perttu moved for summary judgment, arguing that Richards had failed to exhaust available grievance procedures as required by the Prison Litigation Reform Act (PLRA). The Magistrate Judge found a genuine issue of fact regarding whether Richards was excused from exhausting his claims due to Perttu's interference and held an evidentiary hearing. The Magistrate Judge concluded that Richards's witnesses lacked credibility and recommended dismissal without prejudice for failure to exhaust. The District Court adopted this recommendation. The Sixth Circuit reversed, holding that the Seventh Amendment requires a jury trial when the resolution of the exhaustion issue under the PLRA would also resolve a genuine dispute of material fact regarding the merits of the plaintiff's substantive case. The Supreme Court of the United States held that parties are entitled to a jury trial on PLRA exhaustion when that issue is intertwined with the merits of a claim that requires a jury trial under the Seventh Amendment. The Court reasoned that the usual practice under the Federal Rules of Civil Procedure is that factual disputes regarding legal claims go to the jury. The PLRA is silent on whether judges or juries should resolve exhaustion disputes, and this silence indicates that the usual practice should be followed. The Court affirmed the judgment of the Sixth Circuit. View "Perttu v. Richards" on Justia Law

Nuclear Regulatory Commission v. Texas

2025-06-18T08:35:12-08:00

Interim Storage Partners (ISP) applied for a license to build a facility in West Texas to store spent nuclear fuel. During the licensing process, a Texas government agency and Fasken Land and Minerals, a private business, submitted comments on the draft environmental impact statement prepared by the Nuclear Regulatory Commission (NRC). Fasken also sought to intervene in the licensing proceeding but was denied by the NRC. Fasken challenged this denial before the full Commission and the D.C. Circuit but was unsuccessful. In September 2021, the NRC granted ISP a license to build and operate the storage facility. Texas and Fasken sought review of the NRC's licensing decision in the Fifth Circuit. The Fifth Circuit vacated ISP's license, allowing Texas and Fasken to challenge the NRC's decision despite not being parties to the licensing proceeding. The Supreme Court of the United States reviewed the case and held that Texas and Fasken were not entitled to judicial review of the NRC's licensing decision because they were not parties to the Commission's licensing proceeding. The Court emphasized that under the Hobbs Act, only a "party aggrieved" by a licensing order of the Commission may seek judicial review. To qualify as a party, one must be the license applicant or have successfully intervened in the proceeding. Since Texas and Fasken did not meet these criteria, they could not obtain judicial review. The Supreme Court reversed the Fifth Circuit's decision and remanded the case with instructions to deny or dismiss the petitions for review. View "Nuclear Regulatory Commission v. Texas" on Justia Law

Environmental Protection Agency v. Calumet Shreveport Refining, L.L.C.

2025-06-18T08:35:10-08:00

The case involves the Environmental Protection Agency (EPA) and its denial of small refinery exemption petitions under the Clean Air Act's (CAA) renewable fuel program. The CAA requires most domestic refineries to blend renewable fuels into transportation fuels, with a phased exemption scheme for small refineries. Following a Supreme Court decision in HollyFrontier Cheyenne Refining, LLC v. Renewable Fuels Assn., the EPA reconsidered and ultimately denied 105 exemption petitions in 2022, based on its interpretation of "disproportionate economic hardship" and an economic theory that Renewable Identification Number (RIN) costs are passed through to consumers. The small refineries challenged these denials in multiple regional Circuits. Most Circuits either dismissed the challenges for improper venue or transferred them to the D.C. Circuit. However, the Fifth Circuit retained jurisdiction, ruling that the EPA's actions were locally applicable and not based on determinations of nationwide scope or effect, as the EPA still examined refinery-specific facts before issuing denials. The Supreme Court of the United States reviewed the case and held that the EPA's denials of small refinery exemption petitions are locally or regionally applicable actions that fall within the "nationwide scope or effect" exception, requiring venue in the D.C. Circuit. The Court concluded that the EPA's interpretation of "disproportionate economic hardship" and its RIN passthrough theory were determinations of nationwide scope or effect that formed the core basis for the denials. Therefore, the Fifth Circuit erred in retaining jurisdiction, and the case was vacated and remanded for further proceedings consistent with this opinion. View "Environmental Protection Agency v. Calumet Shreveport Refining, L.L.C." on Justia Law

Oklahoma v. Environmental Protection Agency

2025-06-18T08:35:07-08:00

The case involves the Environmental Protection Agency's (EPA) disapproval of state emissions-control plans submitted by Oklahoma and Utah. The EPA disapproved these plans, asserting that they did not comply with the Clean Air Act's (CAA) "Good Neighbor" provision, which requires states to prevent their emissions from significantly contributing to air quality problems in other states. The EPA aggregated its disapprovals into a single rule and claimed that the rule was nationally applicable, or alternatively, that it was based on a determination of nationwide scope or effect. The states and energy-industry petitioners challenged the EPA's disapprovals in regional Circuits. The EPA moved to dismiss these challenges or transfer them to the D.C. Circuit. Four out of five Circuits found that regional Circuit review was proper. However, the Tenth Circuit disagreed and transferred the challenges to the D.C. Circuit, reasoning that the EPA's omnibus rule constituted a single, nationally applicable action. The Supreme Court of the United States reviewed the Tenth Circuit's decision. The Court held that the EPA's disapprovals of the Oklahoma and Utah SIPs are locally or regionally applicable actions, not nationally applicable. The Court further held that the "nationwide scope or effect" exception did not apply because the EPA's disapprovals were based on state-specific, fact-intensive analyses rather than on determinations of nationwide scope or effect. Consequently, the Supreme Court reversed the Tenth Circuit's decision and remanded the cases for further proceedings consistent with its opinion. View "Oklahoma v. Environmental Protection Agency" on Justia Law

Commissioner v. Zuch

2025-06-12T08:35:24-08:00

In 2012, Jennifer Zuch and her then-husband Patrick Gennardo filed late 2010 federal tax returns. Gennardo's return showed a significant balance due, which he addressed by submitting an offer in compromise, involving $50,000 in estimated tax payments. The IRS applied these payments to Gennardo's account. Zuch later amended her return, reporting additional income and resulting in $28,000 in taxes due. She argued that the $50,000 should be credited to her account, entitling her to a refund, but the IRS disagreed and placed a levy on her property. Zuch requested a collection due process hearing, which upheld the levy. She appealed to the Tax Court. The Tax Court initially reviewed the case but dismissed it as moot after Zuch's tax liability was reduced to zero through overpayments applied by the IRS. The court ruled it lacked jurisdiction since there was no longer a basis for a levy. Zuch appealed to the Third Circuit, which vacated the dismissal, holding that the IRS's abandonment of the levy did not moot the proceedings, as the Tax Court could still address the underlying tax dispute. The Supreme Court of the United States reviewed the case and held that the Tax Court lacks jurisdiction under 26 U.S.C. §6330 to resolve disputes when the IRS is no longer pursuing a levy. The Court reasoned that the Tax Court's jurisdiction is limited to reviewing the determination of whether a levy may proceed. Once the levy is no longer in question, the Tax Court cannot address the underlying tax liability. The Supreme Court reversed the Third Circuit's decision and remanded the case for further proceedings consistent with this opinion. View "Commissioner v. Zuch" on Justia Law

Martin v. United States

2025-06-12T08:35:22-08:00

In October 2017, the FBI mistakenly raided the home of Hilliard Toi Cliatt, Curtrina Martin, and her 7-year-old son in suburban Atlanta, instead of the intended gang hideout. The error occurred due to Special Agent Guerra's reliance on a personal GPS device and the team's failure to notice the correct street sign and house number. The raid resulted in personal injuries and property damage. The plaintiffs sued the United States under the Federal Tort Claims Act (FTCA) for the officers' negligent and intentional actions. The district court granted summary judgment to the government, and the Eleventh Circuit affirmed. The Eleventh Circuit applied a unique approach to FTCA claims, holding that the law enforcement proviso in §2680(h) overrides all exceptions, including the discretionary-function exception, allowing intentional-tort claims to proceed without further analysis. The court also allowed the government to assert a Supremacy Clause defense, which it found valid, leading to summary judgment for the United States. The Supreme Court of the United States reviewed the case and held that the law enforcement proviso in §2680(h) overrides only the intentional-tort exception, not the discretionary-function exception or other exceptions in §2680. The Court also held that the Supremacy Clause does not afford the United States a defense in FTCA suits. The case was vacated and remanded to the Eleventh Circuit to reconsider whether the discretionary-function exception bars the plaintiffs' claims and to assess liability under Georgia state law without reference to a Supremacy Clause defense. View "Martin v. United States" on Justia Law

Soto v. United States

2025-06-12T08:35:19-08:00

Simon Soto, a Marine Corps veteran, served from 2000 to 2006 and was medically retired due to post-traumatic stress disorder (PTSD). In 2016, Soto applied for combat-related special compensation (CRSC) and was approved, but his retroactive compensation was limited to six years due to the Barring Act's limitations period. Soto filed a class-action lawsuit arguing that the CRSC statute should displace the Barring Act's limitations period. The United States District Court for the Southern District of Texas granted summary judgment in favor of Soto and the class, holding that the CRSC statute provides its own settlement mechanism, thus displacing the Barring Act. However, the United States Court of Appeals for the Federal Circuit reversed this decision, stating that the CRSC statute does not explicitly grant settlement authority and therefore cannot displace the Barring Act. The Supreme Court of the United States reviewed the case and held that the CRSC statute does confer authority to settle CRSC claims, thereby displacing the Barring Act’s settlement procedures and limitations period. The Court reasoned that the CRSC statute authorizes the Secretary concerned to determine both the validity of CRSC claims and the amount due, creating a comprehensive compensation scheme. Consequently, the Supreme Court reversed the Federal Circuit's decision and remanded the case for further proceedings consistent with this opinion. View "Soto v. United States" on Justia Law

Parrish v. United States

2025-06-12T08:35:14-08:00

Donte Parrish, a federal inmate, was placed in restrictive segregated confinement for 23 months due to his suspected involvement in another inmate's death. After being cleared of wrongdoing by a hearing officer, Parrish filed a lawsuit in Federal District Court seeking damages for his confinement. The District Court dismissed his case on March 23, 2020, citing some claims as untimely and others as unexhausted. Parrish, who had been transferred to a different facility, received the dismissal order three months later and promptly filed a notice of appeal, explaining the delay. The Fourth Circuit recognized that Parrish's notice of appeal was filed after the 60-day appeal period for suits against the United States. The court construed his filing as a motion to reopen the time to appeal under 28 U.S.C. §2107(c). On remand, the District Court granted a 14-day reopening period, but Parrish did not file a second notice of appeal. Both Parrish and the United States argued that the original notice was sufficient, but the Fourth Circuit held that Parrish's failure to file a new notice within the reopened period deprived the court of jurisdiction. The Supreme Court of the United States reviewed the case and held that a litigant who files a notice of appeal after the original appeal deadline but before the court grants reopening does not need to file a second notice after reopening. The original notice relates forward to the date reopening is granted. The Court reversed the Fourth Circuit's decision, allowing Parrish's appeal to proceed. View "Parrish v. United States" on Justia Law

A. J. T. v. Osseo Area Schools, Independent School Dist. No. 279

2025-06-12T08:35:11-08:00

A.J.T., a teenage girl with a rare form of epilepsy, moved to Minnesota in 2015. Her new school district, Osseo Area Public Schools, denied her parents' requests to include evening instruction in her Individualized Educational Program (IEP), despite her inability to attend school before noon due to frequent morning seizures. Consequently, A.J.T. received only 4.25 hours of instruction daily, compared to the typical 6.5-hour school day for nondisabled students. After further cuts to her school day were proposed, her parents filed an IDEA complaint, alleging that the refusal to provide afterhours instruction denied A.J.T. a free appropriate public education. An Administrative Law Judge ruled in favor of A.J.T., finding that the school district violated the IDEA and ordered compensatory education and evening instruction. The Federal District Court and the Eighth Circuit Court of Appeals affirmed this decision. However, when A.J.T. and her parents sued under the ADA and the Rehabilitation Act, the District Court granted summary judgment for the school, and the Eighth Circuit affirmed, stating that a plaintiff must prove bad faith or gross misjudgment by school officials to establish a prima facie case of discrimination. The Supreme Court of the United States reviewed the case and held that schoolchildren bringing ADA and Rehabilitation Act claims related to their education are not required to make a heightened showing of bad faith or gross misjudgment. Instead, they are subject to the same standards that apply in other disability discrimination contexts. The Court vacated the Eighth Circuit's judgment and remanded the case for further proceedings consistent with this opinion. View "A. J. T. v. Osseo Area Schools, Independent School Dist. No. 279" on Justia Law

Rivers v. Guerrero

2025-06-12T08:35:07-08:00

Danny Rivers was convicted in Texas state court of continuous sexual abuse of a child and related charges. After failing to obtain relief through direct appeal and state habeas proceedings, Rivers filed his first federal habeas petition in August 2017, which was denied by the District Court in September 2018. The Fifth Circuit granted a certificate of appealability on his ineffective assistance of counsel claim in July 2020. While his appeal was pending, Rivers discovered new evidence in his trial counsel’s client file and filed a second federal habeas petition based on this evidence. The District Court classified Rivers's second petition as a "second or successive" habeas application under 28 U.S.C. §2244(b) and transferred it to the Fifth Circuit for authorization. Rivers appealed the transfer order, arguing that his second petition should not be considered "second or successive" because his first petition was still on appeal. The Fifth Circuit affirmed the District Court's decision, holding that the pending appeal did not exempt Rivers from the requirements for successive petitions under §2244. The Supreme Court of the United States reviewed the case and held that once a district court enters its judgment on a first-filed habeas petition, any subsequent filing qualifies as a "second or successive" application subject to the requirements of §2244(b). The Court emphasized that the existence of a final judgment, not the status of an appeal, determines whether a filing is considered second or successive. The Court affirmed the Fifth Circuit's decision, rejecting Rivers's argument that his second filing should be treated as an amendment to his initial petition. View "Rivers v. Guerrero" on Justia Law

Catholic Charities Bureau, Inc. v. Wisconsin Labor and Industry Review Commission

2025-06-05T10:35:17-08:00

Catholic Charities Bureau, Inc., and its subentities sought an exemption from Wisconsin's unemployment compensation taxes, claiming they were controlled by the Roman Catholic Diocese of Superior and operated primarily for religious purposes. The Wisconsin Supreme Court denied the exemption, ruling that the organizations did not engage in proselytization or limit their services to Catholics, and thus were not operated primarily for religious purposes. The Wisconsin Department of Workforce Development initially denied the exemption request, but an Administrative Law Judge reversed this decision. The Wisconsin Labor and Industry Review Commission then reinstated the denial. The state trial court overruled the commission, granting the exemption, but the Wisconsin Court of Appeals reversed this decision. The Wisconsin Supreme Court affirmed the Court of Appeals, holding that the organizations' activities were secular and not primarily religious, and that the statute did not violate the First Amendment. The United States Supreme Court reviewed the case and held that the Wisconsin Supreme Court's application of the statute violated the First Amendment. The Court found that the statute imposed a denominational preference by differentiating between religions based on theological lines, subjecting it to strict scrutiny. The Court concluded that the statute, as applied, could not survive strict scrutiny because the State failed to show that the law was narrowly tailored to further a compelling government interest. The judgment of the Wisconsin Supreme Court was reversed, and the case was remanded for further proceedings. View "Catholic Charities Bureau, Inc. v. Wisconsin Labor and Industry Review Commission" on Justia Law

BLOM Bank SAL v. Honickman

2025-06-05T10:35:11-08:00

Plaintiffs, victims and families of victims of terrorist attacks carried out by Hamas between 2001 and 2003, sued BLOM Bank SAL under the Anti-Terrorism Act, alleging that the bank aided and abetted the attacks by providing financial services to Hamas-affiliated customers. BLOM argued that the complaint failed to state a claim, and plaintiffs affirmed they would not seek to amend their complaint if dismissed. The District Court dismissed the complaint with prejudice, finding that plaintiffs had not adequately alleged BLOM's general awareness for aiding-and-abetting liability and denied leave to amend due to plaintiffs' refusal to amend earlier. The Second Circuit affirmed the dismissal, noting that the District Court applied too stringent a standard for general awareness but concluded that plaintiffs' claims still failed under the correct standard. Plaintiffs then moved under Federal Rule of Civil Procedure 60(b)(6) to vacate the final judgment to file an amended complaint. The District Court denied the motion, ruling that the Second Circuit’s clarification did not constitute "extraordinary circumstances" required for Rule 60(b)(6) relief and that plaintiffs' prior choices not to amend counseled against relief. The Second Circuit reversed, holding that district courts must balance Rule 60(b)’s finality principles with Rule 15(a)’s liberal amendment policy. The Supreme Court of the United States held that relief under Rule 60(b)(6) requires extraordinary circumstances, and this standard does not become less demanding when the movant seeks to reopen a case to amend a complaint. A party must first satisfy Rule 60(b) before Rule 15(a)’s liberal amendment standard can apply. The Court reversed the Second Circuit’s decision, emphasizing that the District Court correctly applied the Rule 60(b)(6) standard and provided substantial justification for its conclusion. The case was remanded for further proceedings consistent with this opinion. View "BLOM Bank SAL v. Honickman" on Justia Law

CC/Devas (Mauritius) Ltd. v. Antrix Corp.

2025-06-05T10:35:09-08:00

Devas Multimedia Private Ltd. entered into a satellite-leasing agreement with Antrix Corporation Ltd., a company owned by the Republic of India. The agreement was terminated by Antrix under a force majeure clause when the Indian Government decided it needed more satellite capacity for itself. Devas initiated arbitration, and the arbitral panel awarded Devas $562.5 million in damages plus interest. Devas sought to confirm the award in the United States District Court for the Western District of Washington, which confirmed the award and entered a $1.29 billion judgment against Antrix. The United States Court of Appeals for the Ninth Circuit reversed the District Court's decision, finding that personal jurisdiction was lacking. The Ninth Circuit held that under the Foreign Sovereign Immunities Act of 1976 (FSIA), personal jurisdiction over a foreign state requires not only an immunity exception and proper service but also a traditional minimum contacts analysis as set forth in International Shoe Co. v. Washington. The court concluded that Antrix did not have sufficient suit-related contacts with the United States to establish personal jurisdiction. The Supreme Court of the United States reviewed the case and held that personal jurisdiction under the FSIA exists when an immunity exception applies and service is proper. The Court determined that the FSIA does not require proof of minimum contacts beyond the contacts already required by the Act’s enumerated exceptions to foreign sovereign immunity. The Court reversed the Ninth Circuit's decision and remanded the case for further proceedings consistent with its opinion. View "CC/Devas (Mauritius) Ltd. v. Antrix Corp." on Justia Law

Smith & Wesson Brands, Inc. v. Estados Unidos Mexicanos

2025-06-05T10:35:07-08:00

The Government of Mexico filed a lawsuit against seven American gun manufacturers, alleging that the companies aided and abetted unlawful gun sales that routed firearms to Mexican drug cartels. Mexico claimed that the manufacturers failed to exercise reasonable care to prevent trafficking of their guns into Mexico, resulting in harm from the weapons' misuse. The complaint included allegations that the manufacturers knowingly supplied firearms to retail dealers who sold them illegally to Mexican traffickers, failed to impose controls on their distribution networks, and made design and marketing decisions to stimulate demand among cartel members. The U.S. District Court dismissed the complaint, but the Court of Appeals for the First Circuit reversed the decision. The First Circuit found that Mexico had plausibly alleged that the defendants aided and abetted illegal firearms sales, thus satisfying the predicate exception under the Protection of Lawful Commerce in Arms Act (PLCAA). The Supreme Court of the United States reviewed the case and held that Mexico's complaint did not plausibly allege that the defendant gun manufacturers aided and abetted gun dealers' unlawful sales of firearms to Mexican traffickers. The Court concluded that the allegations did not meet the requirements for aiding and abetting liability, as they did not show that the manufacturers took affirmative acts to facilitate the illegal sales or intended to promote the criminal activities. Consequently, PLCAA barred the lawsuit, and the Supreme Court reversed the judgment of the Court of Appeals and remanded the case for further proceedings consistent with its opinion. View "Smith & Wesson Brands, Inc. v. Estados Unidos Mexicanos" on Justia Law

Ames v. Ohio Department of Youth Services

2025-06-05T10:35:05-08:00

Marlean Ames, a heterosexual woman, worked for the Ohio Department of Youth Services since 2004. In 2019, she applied for a management position but was passed over in favor of a lesbian woman. Subsequently, Ames was demoted from her role as a program administrator, and a gay man was hired to fill her previous position. Ames filed a lawsuit under Title VII, alleging discrimination based on her sexual orientation. The District Court granted summary judgment to the agency, applying the McDonnell Douglas framework for evaluating disparate-treatment claims. The court held that Ames failed to make a prima facie case of discrimination because she did not show "background circumstances" suggesting the agency discriminated against majority-group members. The Sixth Circuit affirmed, requiring Ames to meet this additional burden as a straight woman. The Supreme Court of the United States reviewed the case. The Court held that the Sixth Circuit's "background circumstances" rule, which imposes a heightened evidentiary standard on majority-group plaintiffs, is inconsistent with Title VII's text and precedents. Title VII prohibits discrimination against any individual based on protected characteristics without distinguishing between majority and minority groups. The Court vacated the judgment and remanded the case for application of the proper prima facie standard under Title VII. View "Ames v. Ohio Department of Youth Services" on Justia Law

Seven County Infrastructure Coalition v. Eagle County

2025-06-02T08:35:07-08:00

A group of seven Utah counties, known as the Seven County Infrastructure Coalition, applied to the U.S. Surface Transportation Board for approval to construct an 88-mile railroad line in Utah's Uinta Basin. This project aimed to connect the oil-rich region to the national freight rail network, facilitating crude oil transportation to Gulf Coast refineries. The Board prepared a 3,600-page Environmental Impact Statement (EIS) addressing the project's significant environmental effects and feasible alternatives. However, the EIS did not fully analyze the potential environmental impacts of increased upstream oil drilling and downstream oil refining. The U.S. Court of Appeals for the D.C. Circuit reviewed the case after petitions were filed by a Colorado county and several environmental organizations. The D.C. Circuit found numerous violations of the National Environmental Policy Act (NEPA) in the EIS, specifically criticizing the Board for not sufficiently analyzing the environmental effects of upstream oil drilling and downstream oil refining. Consequently, the D.C. Circuit vacated both the EIS and the Board's final approval order for the railroad line. The Supreme Court of the United States reviewed the case and reversed the D.C. Circuit's decision. The Court held that the D.C. Circuit failed to afford the Board the substantial judicial deference required in NEPA cases. The Supreme Court clarified that NEPA requires agencies to focus on the environmental effects of the proposed project itself, not on separate projects that are distinct in time or place. The Court concluded that the Board's EIS complied with NEPA's procedural requirements by addressing the environmental effects of the 88-mile railroad line, without needing to evaluate the impacts of upstream oil drilling or downstream oil refining. The case was remanded for further proceedings consistent with this opinion. View "Seven County Infrastructure Coalition v. Eagle County" on Justia Law