[Unknown Act > Conclusion]
Yes. Chief Justice John G. Roberts, Jr. delivered the opinion for the 8-1 majority. The Court held that the prosecution needed to show that Elonis intended the posts to be threats, and therefore that there was a subjective intent to threaten . An objective reasonable person standard does not go far enough to separate innocent, accidental conduct from purposeful, wrongful acts. The Court held that, in this case, an objective standard would risk punishing an innocent actor because the crucial element that makes this behavior criminal is the threat, not merely the posting.
Justice Samuel A. Alito, Jr. wrote an opinion concurring in part and dissenting in part in which he agreed that the prosecution only needed to prove negligence, but he argued that the majority opinion should have addressed what the proper instruction should be. By leaving out what the prosecution did need to show, attorneys and judges are left to guess whether knowledge or recklessness is the appropriate standard. Justice Alito also argued that recklessness should be the standard because a higher standard would effectively change the law rather than clarify it.
Justice Clarence Thomas wrote a dissent in which he argued that nine of the eleven circuit courts of appeals had already addressed this issue and resolved it with a general intent standard. The majority opinion not only overturns their rulings but also leaves the courts uncertain as to whether an intent to threaten is required or whether recklessness will suffice. Justice Thomas also argued that knowledge of posting the relevant threats is enough to establish the intent element because knowledge of those facts is required to make the actions illegal; ignorance of those actions being illegal should not provide shelter from the law.


[Unknown Act > Facts]
On March 27, 2012, a Nebraska K-9 police officer pulled over a vehicle driven by Dennys Rodriguez after his vehicle veered onto the shoulder of the highway. The officer issued a written warning and then asked if he could walk the K-9 dog around Rodriguez's vehicle. Rodriguez refused, but the officer instructed him to exit the vehicle and then walked the dog around the vehicle. The dog alerted to the presence of drugs, and a large bag of methamphetamine was found.
Rodriguez moved to suppress the evidence found in the search, claiming the dog search violated his Fourth Amendment right to be free from unreasonable seizures. The district court denied the motion. On appeal, the United States Court of Appeals for the Eighth Circuit affirmed, holding the search was constitutional because the brief delay before employing the dog did not unreasonably prolong the otherwise lawful stop.


[Unknown Act > Conclusion]
Yes. Justice Ruth Bader Ginsburg delivered the opinion for the 6-3 majority. The Court held that the use of a K-9 unit after the completion of an otherwise lawful traffic stop exceeded the time reasonably required to handle the matter and therefore violated the Fourth Amendment’s prohibition against unreasonable searches and seizures. Because the mission of the stop determines its allowable duration, the authority for the stop ends when the mission has been accomplished. The Court held that a seizure unrelated to the reason for the stop is lawful only so long as it does not measurably extend the stop’s duration. Although the use of a K-9 unit may cause only a small extension of the stop, it is not fairly characterized as connected to the mission of an ordinary traffic stop and is therefore unlawful.
Justice Clarence Thomas wrote a dissent in which he argued that the use of a K-9 unit at the conclusion of an otherwise lawful traffic stop did not violate the Fourth Amendment as long as it was conducted reasonably, which this one was. Justice Thomas also argued that the rule announced in the majority’s opinion would result in arbitrary enforcement of Fourth Amendment protections and created artificial lines between common police practices at traffic stops. Additionally, there was no Fourth Amendment violation in this case because the police officer had a reasonable suspicion to continue to hold Rodriguez and use the K-9 unit. Justice Samuel A. Alito, Jr., and Justice Anthony M. Kennedy joined in the dissent. In his separate dissent, Justice Kennedy noted that the appellate court did not address the issue of whether the officer had a reasonable suspicion to use the K-9 unit, and that court should be allowed to do so. Justice Alito also wrote a separate dissent in which he argued that the majority opinion’s analysis was arbitrary because it relied on the order in which the officer conducted his inquiries.


[Unknown Act > Facts]
Baker Botts, LLP, along with Jordan, Hyden, Womber, Culbreth & Holzer, PC, was awarded about $120 million in fees for representing Asarco, LLC in its Chapter 11 bankruptcy case, from which Asarco had emerged in 2009 with a reorganization plan that would pay its creditors in full. Baker Botts then filed for a final fee request, which Asarco contested. The bankruptcy court awarded Baker Botts more than $117 million to cover the fees in addition to $5 million for expenses incurred defending the fee claims. The district court affirmed. The U.S. Court of Appeals for the Fifth Circuit held that the Bankruptcy Code did not allow the firms to recover $5 million spent defending the fee request against Asarco's opposition.


[Unknown Act > Conclusion]
No. Justice Clarence Thomas delivered the opinion of the 6-3 majority. The Court held that the American rule of attorney fee structure—that each litigant pays for his own attorney’s fees—can only be altered through an explicit statutory provision. The Bankruptcy Code does not explicitly depart from this rule; instead it allows for “reasonable compensation” for services rendered, which cannot be properly construed as including litigation regarding a contested fee request. Additionally, the established policy that, absent express statutory language, no attorneys receive compensation for costs incurred litigating fee challenges means that this reading of the statute creates no unfairness in the profession. Therefore, the American rule should still be assumed in force in cases such as this one.
In her opinion concurring in part and concurring in the judgment, Justice Sonia Sotomayor wrote that, because the statutory language is clear in this case, the majority opinion should not have considered the policy argument.
Justice Stephen G. Breyer wrote a dissenting opinion in which he argued that the Bankruptcy Code grants courts a great deal of discretion in determining how to award “reasonable compensation” for services rendered, and therefore the courts can consider situations such as the costs of fee-related litigation in making such a determination. Because the costs of litigating fee challenges can be so high, factoring those costs into fee determinations can be the only way to ensure that the compensation is “reasonable” as the Bankruptcy Code requires. The American rule can only remain in force if not overridden by statute, and the Bankruptcy Code provides a sufficient statutory exception. Justice Ruth Bader Ginsburg and Justice Elena Kagan joined in the dissent.


[Unknown Act > Facts]
In 2010, Congress passed the Affordable Care Act (ACA) to increase the number of Americans covered by health insurance and decrease the cost of health care. The ACA required each state to establish an "exchange" through which people could purchase health care coverage, and if a state elected not to do so, the federal government would establish one through the Secretary of Health and Human Services. The ACA also required people to obtain the minimum essential coverage or pay a tax penalty unless they fell within an unaffordability exemption for low-income individuals. To limit the number of people that would fall into such an exemption, the ACA provided for tax credits that are calculated based on the health plan in which an individual enrolls through the exchange. Although the legislative language of the ACA pertaining to the tax credits only referred to the exchanges established by the states, the Internal Revenue Service (IRS) created a regulation that made the tax credits available to those enrolled in plans through federal as well as state exchanges.
Virginia declined to establish a state-run exchange and has one operated by the federal government. The plaintiffs are a group of Virginia residents who, without the tax credits, would fall under the unaffordability exception and be exempt from having to purchase health insurance. They sued and argued that the IRS regulation exceeded the agency's statutory authority, is arbitrary and capricious, and is contrary to the law in violation of the Administrative Procedure Act. The district court granted the defendants' motion to dismiss, and the U.S. Court of Appeals for the Fourth Circuit affirmed.


[Unknown Act > Conclusion]
Yes. Chief Justice John G. Roberts, Jr. delivered the opinion for the 6-3 majority. The Court held that Congress did not delegate the authority to determine whether the tax credits are available through both state-created and federally created exchanges to the Internal Revenue Service, but the language of the statute clearly indicates that Congress intended the tax credits to be available through both types of exchanges. When the plain language of the section in question is considered in the context of the statute as a whole, it is evident that the federally-created exchanges are not meaningfully different from those the states created, and therefore federally-created exchanges are not excluded from the language referring to exchanges created by the states. This reading is also in line with the Congressional intent of covering as many qualified individuals as possible, as the alternative would mean that federally-created exchanges do not contain qualified individuals and operate entirely differently from the state-created ones.
Justice Antonin Scalia wrote a dissent in which he argued that that the plain language of the statute clearly limits the tax credits to state-created exchanges. The majority opinion’s attempt to use context to justify a more expansive reading that is at odds with the clear meaning of the text distorts statutory interpretation and amounts to rewriting the statute. Justice Scalia also argued that reading the language of the section in question to refer to both state-created and federally-created exchanges fails to give effect to the times when Congress explicitly chose to conflate the two types of exchanges as opposed to the times it did not. The reading that some parts of the statute refer to both types of exchanges and other parts do not is more consistent with the statute as a whole and gives better effect to Congress’ intent in enacting it. The majority opinion’s use of Congressional intent to support its holding errs by focusing only on one of the goals of the legislation to the exclusion of others, and in doing so oversteps the bounds of its judicial authority. Justice Clarence Thomas and Justice Samuel A. Alito, Jr. joined in the dissent.


[Unknown Act > Facts]
Louis Bullard borrowed $387,000 from Hyde Park Savings to buy his property in Massachusetts. In December 2010, he filed for Chapter 13 of the Bankruptcy Code and proposed a plan in which he offered to pay the bank back the value of the property in a loan that was secured by the actual property and then put the rest of the home loan into a pool with other debts that would be paid at a different rate. The bankruptcy court rejected this plan because it believed this hybrid plan was inconsistent with certain provisions of the Bankruptcy Code. The bankruptcy appellate panel agreed but stated the order was appealable because Bullard could simply propose another plan. Bullard petitioned for an appeal but the bankruptcy appellate panel denied the petition because the petitioner had already filed his notice of appeal to the U.S. Court of Appeals for the First Circuit. The First Circuit held that it did not have jurisdiction, as courts of appeals only have jurisdiction over "final decisions, judgments, orders and decrees."


[Unknown Act > Conclusion]
No. Chief Justice John G. Roberts delivered the opinion for the unanimous Court, which held that a bankruptcy court’s order denying confirmation of a proposed repayment plan is not a “final” order for the purposes of immediate appeal. The Court noted that, because bankruptcy cases typically involve many controversies that could stand on their own, an order is appealable if it finally disposes of a concrete dispute within the larger case. Because denial of confirmation of a plan indicates that a plan needs further consideration, it is not a final disposition of a concrete issue, unless it results in dismissal of the case. The Court held that the asymmetry of allowing confirmation to be a final order, but not denial of a confirmation, is acceptable because only confirmation alters the legal relationships between the parties by allowing the bankruptcy proceedings to proceed. Additionally, there are other safeguards in place, such as interlocutory appeals, to ensure the system is not unfair to debtors.


[Unknown Act > Facts]
In August 2009, the Texas division of the Sons of Confederate Veterans (Texas SCV), a non-profit organization that works to preserve the memory and reputation of soldiers who fought for the confederacy in the Civil War, applied to have a new specialty license plate issued by the Texas Department of Motor Vehicles (TDMV). The proposed license plate had two confederate flags on it: one in the organization's logo, and one faintly making up the background of the plate. The TDMV had a policy stating that it "may refuse to create a new specialty license plate if the design might be offensive to any member of the public." The board in charge of approving new specialty plates received multiple negative comments from the public regarding this plate and ultimately voted to deny Texas SCV's application.
Texas SCV sued in federal district court claiming their First and Fourteenth Amendment rights were violated. The TDMV argued that the Free Speech Clause did not apply in this case because license plates are a form of government speech; therefore, they were within their rights to choose which messages and views they wanted to express on the plates. The district court disagreed and held that the plates were private, non-governmental speech, and that the TDMV's denial was a reasonable, content-based restriction of speech in a non-public forum. The United States Court of Appeals for the Fifth Circuit reversed and held that TDMV's denial was a form of viewpoint discrimination that "discriminated against Texas SCV's view that the Confederate flag is a symbol of sacrifice, independence, and Southern heritage."


[Unknown Act > Conclusion]
Yes, no. Justice Stephen G. Breyer delivered the opinion of the 5-4 majority. The Court held that the government choosing the content of its speech is not unconstitutional viewpoint discrimination because that expression is the product of the democratic electoral process. Based on the analysis from Pleasant Grove City v. Summum, Texas’s specialty license plate is an example of such government speech (as opposed to a forum open for private expression) because Texas and other states have long used license plates to convey messages. Moreover, the public associates license plates with the State. Finally, Texas maintains direct control over the messages on its specialty plates from design to final approval.
Justice Samuel A. Alito, Jr., wrote a dissent in which he argued that, with over 350 varieties of specialty plates, an observer would think that the plates were the expression of the individual drivers, not Texas. Because the specialty license plates are a limited public forum for private expression, Texas rejecting the confederate flag design because it might be offensive is unconstitutional viewpoint discrimination. Chief Justice John G. Roberts, Jr., Justice Antonin Scalia, and Justice Anthony M. Kennedy joined in the dissent.


[Unknown Act > Facts]
The federal Medicaid Act requires that state Medicaid plans contain procedures to ensure that reimbursement rates for healthcare providers "are consistent with efficiency, economy, and quality of care and are sufficient to enlist enough providers" to meet the need for care and services in the geographic area. Ninth Circuit precedent also requires that reimbursement rates bear a reasonable relationship to Medicaid provider costs, and where rates do not "substantially reimburse providers their costs," a state cannot justify its rates with "purely budgetary reasons." Richard Armstrong, the Director of Idaho's Department of Health and Welfare, and others (the Directors) conducted provider cost studies and recommended increasing reimbursement rates but ultimately did not increase rates for budgetary reasons.
A group of Idaho Medicaid providers (the Providers) sued the Directors and claimed that, based on the new cost information, the Department's failure to raise rates was not consistent with the Ninth Circuit's requirements. The Directors argued that the Supremacy Clause of the federal Constitution does not give providers a private right of action and that the existing rates were consistent with the Medicaid Act's requirements of efficiency, economy, and quality of care. The district court granted the Providers' motion for summary judgment and held that the failure to increase rates led to a failure to substantially reimburse providers. The U.S. Court of Appeals for the Ninth Circuit affirmed.


[Unknown Act > Conclusion]
No. Justice Antonin Scalia delivered the opinion for the 5-4 majority. The Court held that the Supremacy Clause instructs courts to defer to federal law when federal and state law contradict each other, but it does not create a private right of action. If the Supremacy Clause were interpreted to include a private right of action, it would mean that the Constitution would require Congress to allow private actors to implement its laws, which would curtail Congress’ ability to guide implementation of federal laws. Although judicial precedent allows for suits to prevent state and federal officers from violating federal laws, that precedent stems from a long history of the jurisprudence of the courts of equity, not the Supremacy Clause. The Court also held that the Idaho Medicaid Providers could not circumvent Congress’ exclusion of a private right of action under the Medicaid Act.
In his opinion concurring in part and concurring in the judgment, Justice Stephen G. Breyer wrote that federal courts may not grant injunctive relief against state officers who violate federal law when the relevant statute does not provide for that kind of relief. In this case, the Medicaid Act does not do so because such relief could result in increased litigation, inconsistent results, and the disorderly administration of complex federal programs, which Congress could not have intended.
Justice Sonia Sotomayor wrote a dissenting opinion in which she argued that suits to restrain state officials from executing laws contrary to the Constitution have such a long history in American jurisprudence that there needs to be substantial evidence of congressional intent to restrict such suits in a statute, and the language of the Medicaid Act does not provide such evidence. Because such suits argue that state law contravenes federal law, they are essentially constitutional in nature and stem from the Supremacy Clause. Therefore, even if there is no implied right of action in the Supremacy Clause, it can still be the basis for suits similar to the one in this case. Justice Anthony M. Kennedy, Justice Ruth Bader Ginsburg, and Justice Elena Kagan joined in the dissent.


[Unknown Act > Facts]
David Caulkett’s property was subject to two mortgage liens when he filed for bankruptcy. Because the debt owed on the first mortgage exceeded the value of the property, the second mortgage, which Bank of America held, was considered “underwater.” When Caulkett filed for bankruptcy, he moved the bankruptcy court to void Bank of America’s lien on the second mortgage and argued that Section 506(d) of the Bankruptcy Code allowed a debtor filing for bankruptcy to void a second mortgage when the debt owed on the first mortgage exceeded the value of the collateral property. The bankruptcy court granted the motion, and both the district court and the U.S. Court of Appeals for the Eleventh Circuit affirmed.
This case was consolidated with a similar case, Bank of America v. Toledo-Cardona, which had substantially the same facts and an identical procedural history.


[Unknown Act > Conclusion]
No. Justice Clarence Thomas delivered the opinion of a unanimous Court, which held that Section 506(d) of the Bankruptcy Code allows a debtor to void a mortgage “[t]o the extent that [the] lien secures a claim against the debtor that is not an allowed secured claim.” Although a straightforward reading of this provision appears to favor the debtors, in Dewsnup v. Timm, the Court held that a “secured claim” is one supported by a security interest in property, regardless of whether the value of that property would be sufficient to cover the claim. Thus, even if the second mortgage is underwater, the debtor cannot void that mortgage in bankruptcy proceedings.


[Unknown Act > Facts]
Noel Reyes Mata, a citizen of Mexico, was convicted of assaulting a woman he was dating; he was deported in 2010. His appeal to the Board of Immigration Appeals (BIA) was dismissed after his attorney failed to file an appellate brief. Mata subsequently moved to reopen his case based on ineffective assistance of counsel, but the BIA denied Mata's motion as untimely because it was filed well after the 90 days allowed. Mata appealed the BIA's denial of his motion to the U.S. Court of Appeals for the Fifth Circuit and argued that the BIA should not have enforced the filing period limitation because his attorney's failure to file a brief deprived him of his due process rights. The appellate court held that such a motion was subject to the complete discretion of the BIA, and thus the appellate court lacked the jurisdiction to review the decision.


[Unknown Act > Conclusion]
Yes. Justice Elena Kagan delivered the opinion for the 8-1 majority. The Court held that precedent establishes that circuit courts of appeals have jurisdiction to review an alien’s appeal of the Board of Immigration Appeals (BIA) decision to deny a motion to reopen proceedings. Although Congress has limited the appellate courts’ authority over BIA decisions in other ways, this authority has remained in place. Additionally, while the appellate courts may lack the jurisdiction to decide the merits of whether the case should be reopened, the lack of jurisdiction over that issue does not affect the appellate court’s jurisdiction over the BIA’s decision to deny the motion.
Justice Clarence Thomas wrote a dissenting opinion in which he argued that, prior to determining whether it had jurisdiction, the U.S. Court of Appeals for the Fifth Circuit should have construed the ambiguous motion in question as either invoking statutory relief or requesting that the BIA assert its inherent authority to reopen the case.


[Unknown Act > Facts]
In 1949 the U.S. Department of Agriculture implemented the Marketing Order Regulating the Handling of Raisins Produced from Grapes Grown in California (Marketing Order). The Marketing Order authorized the federal government to reserve a percentage of the yearly California raisin crop to stabilize the supply, and thus the price, of California raisins. Under the Marketing Order, farmers are entitled to a share of the proceeds acquired when, or if, the government sells the reserved raisins. Marvin Horne, a farmer and raisin producer, attempted to skirt the Marketing Order by processing his own raisins, which he claimed exempted his raisins from the Marketing Order's reserve requirement. The Department of Agriculture claimed Horne's raisins were still subject to the Market Order, and following administrative proceedings, Horne was fined nearly $700,000.
Horne sued the Department of Agriculture and claimed that the Marketing Order violated his Fifth Amendment rights against uncompensated takings. The district court found in favor of the Department of Agriculture. The U.S. Court of Appeals for the Ninth Circuit held that it lacked standing to address Horne's claim, because Fifth Amendment takings claims are within the jurisdiction of the Court of Federal Claims. The United States Supreme Court held that the appellate court did have jurisdiction and remanded the case. On remand, the appellate court found for the Department of Agriculture by holding that the reserve requirement did not act as a per se taking because Horne's raisins constituted personal property rather than real property. The appellate court also held that the Marketing Order did not constitute a taking because there was a sufficient nexus, and rough proportionality, between the reserve requirement and the specific interest the government seeks to protect, which in this case is the government's interest in stabilizing raisin prices.


[Unknown Act > Conclusion]
No, no, yes. Chief Justice John G. Roberts, Jr. delivered the opinion for the 8-1 majority. The Court held that the Takings Clause of the Fifth Amendment applies with equal force to personal as well as real property; therefore the Marketing Order’s reserve requirement constituted a taking under the Fifth Amendment because it deprives the owners of their property rights to “possess, use, and dispose of” the raisins. Because a physical taking has occurred, returning the net proceeds of the sale of the raisins to the owners does not exempt the government from paying just compensation for the taking itself. The Court also held that making the reserve requirement a condition on legally participating in the raisin market effects a per se taking because it cannot be properly characterized as a voluntary exchange for a governmental benefit. Therefore, the government should pay a just compensation for the taking, which the government has already calculated in its attempt to fine the Hornes the fair market value of the raisins at issue, by rescinding the fine it had imposed.
In his concurring opinion, Justice Thomas wrote that the Takings Clause only requires the government to pay just compensation when the taking results in a public legal right to the property. Because it is not clear that such a right is being granted when the government enforces the reserve requirement, there is no reason to calculate what such “just compensation” would be in this case.
Justice Stephen G. Breyer wrote an opinion concurring in part and dissenting in part in which he argued that the Court should remand the case to the appellate court to calculate what “just compensation” should be in this case. If the Marketing Order is determined to afford just compensation, when taking into account the benefit to the market that the reserve requirement confers, then the reserve requirement does not violate the Takings Clause. Justices Ruth Bader Ginsburg and Elena Kagan joined in the partial concurrence and partial dissent.
Justice Sonia Sotomayor wrote a dissent in which she argued that a per se taking only occurs when the government deprives an individual of every property right regarding the property in question. Because the reserve requirement allows the owner to retain interest in the property in the form of the net proceeds from the disposition of the raisins, the Marketing Order does not deprive the individual of all property rights and therefore is not a per se taking. Justice Sotomayor also argued that precedent establishes that the government may require an individual to give up some property rights as a condition of engaging in regulated commerce.


[Unknown Act > Facts]
Stephen McFadden sold overstocked products on the Internet to augment his income. In 2011, McFadden noticed that a lot of businesses where he lived were selling a product known as "bath salts," an aromatherapy product that emits a stimulating vapor when burned. After confirming that bath salts were not illegal, McFadden began selling them like his other products. He continued to sell them until he learned they had been placed on the list of substances that the Controlled Substances Act (CSA) prohibited.
The government prosecuted McFadden under the Controlled Substances Analogue Enforcement Act of 1986, which allows substances not listed as "controlled" to be treated as illegal if the analogue has effects and a chemical make-up that are "substantially similar" to those listed in the CSA. At trial, McFadden argued that the state needed to prove that he was aware, or actively resisted finding out, that the bath salts were substantially similar to a controlled substance and constituted an analogue. Instead, the district court held that the state only needed to prove that the petitioner knew "the products were intended for human consumption." The U.S. Court of Appeals for the Fourth Circuit affirmed.


[Unknown Act > Conclusion]
Yes. Justice Clarence Thomas delivered the opinion of the 9-0 majority. The Court held that, in order to fulfill the intent element, the defendant may either know that the substance in question is a controlled substance without knowing what the substance is, or may know what the substance is but not know that it is controlled. In either scenario, the defendant is aware of all he needs to know to fulfill the knowledge element. A complete and thorough knowledge of the law surrounding controlled substances is not necessary to fulfill the knowledge requirement, and even in a case where the defendant does not know of the Analogue Act, he may be found guilty because ignorance of the law is no excuse.
Chief Justice John G. Roberts, Jr., wrote an opinion concurring in part and concurring in the judgment in which he argued that knowledge of the identity of the substance fell short of satisfying the knowledge element. In this instance, ignorance of the law could be a defense because the individual could lack knowledge of the legal element: the fact that the substance is controlled.


[Unknown Act > Facts]
In February 2010, Charles Harris filed for bankruptcy under Chapter 13 of the Bankruptcy Code. The approved plan instructed Harris to make monthly payments to the trustee Mary Viegelahn for sixty months, as well as monthly payments directly to Chase, which held his mortgage. After the mortgage and secured creditors debts were paid off, the payments would go to Harris' unsecured creditors. In October 2010, Chase moved to lift the automatic stay of Harris' home for his failure to make the mortgage payments, and Harris moved out of his house when the stay was lifted in November 2010. At that point, Viegelahn held the portion of the monthly payments intended to go to Chase. After Harris voluntarily converted his bankruptcy case to Chapter 7, Viegelahn distributed those funds to Harris' creditors. Harris sued for that money and argued that Viegelahn had no authority to disburse funds after conversion of the case. The bankruptcy court issued an order compelling the return of the funds and the district court affirmed. However, the U.S. Court of Appeals for the Fifth Circuit reversed and held that the undistributed payments that the Chapter 13 trustee holds at the time of the case's conversion to Chapter 7 must be distributed to creditors pursuant to the Chapter 13 plan.


[Unknown Act > Conclusion]
The undistributed funds should be returned to the debtor. Justice Ruth Bader Ginsburg delivered the opinion for the unanimous Court, which held that filing for Chapter 7 bankruptcy only affects the debtor’s assets from prior to the filing. Assets the debtor acquired after filing for Chapter 7 bankruptcy, as were the assets in this case, remain the property of the debtor. The Court held that Congress intended to allow a debtor to make a “fresh start” by converting a Chapter 13 bankruptcy to Chapter 7 in good faith, and therefore no penalty should be exacted in the form of requiring the disbursement of assets acquired after the filing date. Therefore, once a Chapter 13 bankruptcy is converted to a Chapter 7 one, unless the conversion is in bad faith, any assets acquired after the filing of the Chapter 13 petition revert back to the debtor.


[Unknown Act > Facts]
The 1990 amendments to the Clean Air Act require that the Environmental Protection Agency (EPA) regulate electric utility steam generating units (EGUs) if it finds that such regulation was "appropriate and necessary" after conducting a utility study. In December 2000, the EPA issued a notice that such regulation was necessary based on the results of the utility study, which showed that the mercury emissions from EGUs were a threat to public health. In 2005, the EPA reversed its findings and determined that it was not "appropriate and necessary" to regulate coal-and oil-fired EGUs. States and other groups petitioned for review, and the U.S. Court of Appeals for the District of Columbia Circuit held that the EPA's attempt to reverse its findings was unlawful because it could not remove pollutant sources from the regulation list once they were on it. In 2012, the EPA confirmed that EGU regulation was necessary and promulgated emission standards. State, industry, and labor groups petitioned the appellate court for review of the EPA's interpretation of the "appropriate and necessary" requirement with respect to these regulations. The appellate court denied the petition.


[Unknown Act > Conclusion]
Yes. Justice Antonin Scalia delivered the opinion of the 5-4 majority. The Court held that federal administrative agencies must engage in “reasoned decisionmaking,” which requires the agency to consider all relevant factors. Because the cost to power plants is certainly a relevant factor when deciding whether to regulate electric utility steam generating units (EGUs), the Environmental Protection Agency (EPA), should have considered the cost to power plants in making its decision. The EPA erred in interpreting the “appropriate and necessary” requirement of the Clean Air Act because it was unreasonable to interpret the phrase as not requiring the EPA to consider all relevant factors, including cost to power plants.
In his concurring opinion, Justice Clarence Thomas wrote that, although precedent established that the courts grant agencies a great deal of deference when agencies interpret statutes that Congress left ambiguous, such deference might result in courts allowing an unconstitutional delegation of legislative power.
Justice Elena Kagan wrote a dissent in which she argued that the EPA’s decision was reasonable because it fully intended to consider the cost-benefit analysis at a later stage in its decisionmaking process and in fact did so. Therefore, the majority opinion essentially finds the EPA’s decision unreasonable because the EPA did not conduct a thorough cost-benefit analysis as the initial step of its decisionmaking. Because it is reasonable for the EPA to decide to consider costs after determining that regulation was “appropriate and necessary,” the courts cannot interfere in the agency’s regulatory decisions. Justices Ruth Bader Ginsburg, Stephen G. Breyer, and Sonia Sotomayor joined in the dissent.


[Unknown Act > Facts]
Groups of same-sex couples sued their relevant state agencies in Ohio, Michigan, Kentucky, and Tennessee to challenge the constitutionality of those states' bans on same-sex marriage or refusal to recognize legal same-sex marriages that occurred in jurisdictions that provided for such marriages. The plaintiffs in each case argued that the states' statutes violated the Equal Protection Clause and Due Process Clause of the Fourteenth Amendment, and one group of plaintiffs also brought claims under the Civil Rights Act. In all the cases, the trial court found in favor of the plaintiffs. The U.S. Court of Appeals for the Sixth Circuit reversed and held that the states' bans on same-sex marriage and refusal to recognize marriages performed in other states did not violate the couples' Fourteenth Amendment rights to equal protection and due process.


[Unknown Act > Conclusion]
Yes, yes. Justice Anthony M. Kennedy delivered the opinion for the 5-4 majority. The Court held that the Due Process Clause of the Fourteenth Amendment guarantees the right to marry as one of the fundamental liberties it protects, and that analysis applies to same-sex couples in the same manner as it does to opposite-sex couples. Judicial precedent has held that the right to marry is a fundamental liberty because it is inherent to the concept of individual autonomy, it protects the most intimate association between two people, it safeguards children and families by according legal recognition to building a home and raising children, and it has historically been recognized as the keystone of social order. Because there are no differences between a same-sex union and an opposite-sex union with respect to these principles, the exclusion of same-sex couples from the right to marry violates the Due Process Clause of the Fourteenth Amendment. The Equal Protection Clause of the Fourteenth Amendment also guarantees the right of same-sex couples to marry as the denial of that right would deny same-sex couples equal protection under the law. Marriage rights have traditionally been addressed through both parts of the Fourteenth Amendment, and the same interrelated principles of liberty and equality apply with equal force to these cases; therefore, the Constitution protects the fundamental right of same-sex couples to marry. The Court also held that the First Amendment protects the rights of religious organizations to adhere to their principles, but it does not allow states to deny same-sex couples the right to marry on the same terms as those for opposite-sex couples.


[Unknown Act > Conclusion]
couplesequalprotectionunderthelaw.MarriagerightshavetraditionallybeenaddressedthroughbothpartsoftheFourteenthAmendment,andthesameinterrelatedprinciplesoflibertyandequalityapplywithequalforcetothesecases;therefore,theConstitutionprotectsthefundamentalrightofsame-sexcouplestomarry.TheCourtalsoheldthattheFirstAmendmentprotectstherightsofreligiousorganizationstoadheretotheirprinciples,butitdoesnotallowstatestodenysame-sexcouplestherighttomarryonthesametermsasthoseforopposite-sexcouples.
Chief Justice John G. Roberts, Jr. wrote a dissent in which he argued that, while same-sex marriage might be good and fair policy, the Constitution does not address it, and therefore it is beyond the purview of the Court to decide whether states have to recognize or license such unions. Instead, this issue should be decided by individual state legislatures based on the will of their electorates. The Constitution and judicial precedent clearly protect a right to marry and require states to apply laws regarding marriage equally, but the Court cannot overstep its bounds and engage in judicial policymaking. The precedents regarding the right to marry only strike down unconstitutional limitations on marriage as it has been traditionally defined and government intrusions, and therefore there is no precedential support for making a state alter its definition of marriage. Chief Justice Roberts also argued that the majority opinion relied on an overly expansive reading of the Due Process and Equal Protection Clauses of the Fourteenth Amendment without engaging with the judicial analysis traditionally applied to such claims and while disregarding the proper role of the courts in the democratic process. Justice Antonin Scalia and Justice Clarence Thomas joined in the dissent. In his separate dissent, Justice Scalia wrote that the majority opinion overstepped the bounds of the Court’s authority both by exercising the legislative, rather than judicial, power and by doing so in a realm that the Constitution reserves for the states. Justice Scalia argued that the question of whether same-sex marriage should be recognized is one for the state legislatures, and that for the issue to be decided by unelected judges goes against one of the most basic precepts of the Constitution: that political change should occur through the votes of elected representatives. In taking on this policymaking role, the majority opinion departed from established Fourteenth Amendment jurisprudence to create a right where none exists in the Constitution. Justice Thomas joined in the dissent. Justice Thomas also wrote a separate dissent in which he argued that the majority opinion stretched the doctrine of substantive due process rights found in the Fourteenth Amendment too far and in doing so distorted the democratic process by taking power from the legislature and putting it in the hands of the judiciary. Additionally, the legislative history of the Due Process Clause in both the Fifth and Fourteenth Amendments indicates that they were meant to protect people from physical restraint and from government intervention, but they do not grant them rights to government entitlements. Justice Thomas also argued that the majority opinion impermissibly infringed on religious freedom by legislating from the bench rather than allowing the state legislature to determine how best to address the competing rights and interests at stake. Justice Scalia joined in the dissent. In his separate dissent, Justice Samuel A. Alito, Jr. wrote that the Constitution does not address the right of same-sex couples to marry, and therefore the issue is reserved to the states to decide whether to depart from the traditional definition of marriage. By allowing a majority of the Court to create a new right, the majority opinion dangerously strayed from the democratic process and greatly expanded the power of the judiciary beyond what the Constitution allows. Justice Scalia and Justice Thomas joined in the dissent.


[Unknown Act > Facts]
In May 2010, Michael Kingsley, who was being held as a pretrial detainee in Monroe County Jail, was ordered to take down a piece of paper covering the light above his cell bed but refused to do so. After Sergeant Stan Hendrickson ordered Kingsley to take down the paper several times and each time was met with refusal, Lieutenant Robert Conroy, the jail administrator, ordered the jail staff to take down the paper and transfer Kingsley to another cell. During the transfer, Kingsley refused to act as ordered, so the officers pulled him to his feet in such a manner that his feet hit the bedframe, which caused pain and made him unable to walk or stand. In the new cell, when Kingsley resisted the officers' attempts to remove the handcuffs, Hendrickson put his knee in Kingsley's back and Kingsley yelled at him. Kingsley also claimed that Hendrickson smashed his head into the concrete bunk. After further verbal exchange, another officer applied a taser to Kingsley's back.
Kingsley sued Hendrickson and other jail staff members and claimed that their actions violated his due process rights under the Fourteenth Amendment. The jury found the defendants not guilty. Kingsley appealed and argued that the jury was wrongly instructed on the standards for judging excessive force and intent. The U.S. Court of Appeals for the Seventh Circuit reversed.


[Unknown Act > Conclusion]
Yes. Justice Stephen G. Breyer delivered the opinion of the 5-4 majority. The Court held that, in a claim regarding whether an officer used excessive force against a pretrial detainee, the plaintiff is not required to prove that the defendant thought the force was excessive but that the force was excessive based on an objective standard. Therefore, the court must determine whether, from the perspective of a reasonable officer on the scene at the time, the use of force in question was excessive. The Court held that the objective standard is in line with existing precedent that holds that the Due Process Clause protects pretrial detainees from excessive force that amounts to punishment, which can be shown through evidence that proves that the force in question was not reasonably related to the legitimate purpose of holding detainees for trial. The objective standard also protects an officer who acts in good faith by taking into account the situation as the officer was aware of it at the time. The Court also noted that the use of force in question must be deliberate in order to give rise to an excessive force claim.
Justice Antonin Scalia wrote a dissenting opinion in which he argued that, while the Due Process Clause protects pretrial detainees from conditions that amount to punishment, objectively unreasonable force does not rise to the level of intentional punishment that the Due Process Clause prohibits. Because punitive intent cannot be inferred simply from the fact that an officer used more force than was objectively necessary, simply showing that the force in question was objectively unreasonable does not violate a pretrial detainees rights under the Due Process Clause. Chief Justice John G. Roberts, Jr. and Justice Clarence Thomas joined in the dissent. In his separate dissent, Justice Samuel A. Alito, Jr. wrote that the Court should have dismissed this case as improvidently granted because such a case should be examined under Fourth Amendment search and seizure analysis before the Court addresses the due process claims brought here.


[Unknown Act > Facts]
On April 29, 2014, Oklahoma executed Clayton Lockett using a three-drug lethal injection procedure. The procedure went poorly; Lockett awoke after the injection of the drugs that were supposed to render him unconscious and did not die until about 40 minutes later. Oklahoma suspended all subsequent executions until the incident could be investigated and subsequently adopted a new protocol that placed a higher emphasis on making sure the injection was done properly. The new protocol also allowed for four alternative drug combinations, one of which used midazolam as the initial drug, as did the protocol used in the Lockett execution.
Charles Warner and 20 other death row inmates sued various state officials and argued that the use of midazolam as the initial drug in the execution protocol violated the Eighth Amendment's prohibition against cruel and unusual punishment. Warner and three other plaintiffs also moved for a preliminary injunction to prevent Oklahoma from moving forward with their executions. A federal district court denied the injunction and held that the plaintiffs had not provided sufficient evidence that they would prevail on the merits of their claims and that they had failed to identify a "known and available" alternative to the drug in question. The U.S. Court of Appeals for the Tenth Circuit affirmed.
On January 15, 2015, the Supreme Court declined to grant the petition for a writ of certiorari, and Charles Warner was subsequently executed. Richard E. Glossip and the other two death row inmates petitioned the Court again.


[Unknown Act > Conclusion]
No. Justice Samuel A. Alito, Jr. delivered the opinion of the 5-4 majority. The Court held that there was insufficient evidence that the use of midazolam as the initial drug in the execution protocol entailed a substantial risk of severe pain, compared to known and available alternatives, in violation of the Eighth Amendment. Because capital punishment has been held to be constitutional and some risk of pain is inherent in execution, the Eighth Amendment does not require that a constitutional method of execution be free of any risk of pain. Instead, a successful Eighth Amendment method-of-execution claim must identify a reasonable alternative that presents a significantly lower risk of pain, which the petitioners in this case were unable to do. Because the district court is entitled to a high degree of deference in its determination, the petitioners would have to prove that the district court’s factual findings were clearly erroneous in order for the Court to overturn the ruling. In this case, the medical testimony supports the district court’s determination that the use of midazolam did not create a substantial risk of severe pain, particularly in light of the safeguards the state imposed on the process.
In his concurring opinion, Justice Antonin Scalia wrote that the Constitution expressly contemplates the death penalty when it considers the possibility that someone may be “deprived of life,” and therefore capital punishment cannot be unconstitutional. The arguments that it is arbitrary and unreliable, and therefore cruel, deal with the concerns about conviction, not the punishment itself, and are dangers inherent in the jury trial process. The decision of whether to impose the death penalty encompasses the type of moral calculus that should remain in the hands of the jury, as the Constitution provides. Justice Clarence Thomas joined in the concurrence. Justice Thomas also wrote a separate concurrence in which he argued that the studies cited in support of the arbitrariness of the imposition of the death penalty are themselves unreliable because they require that the moral reasons to execute someone be reduced to a metric by academics who were not present at trial. Justice Scalia joined in the concurring opinion.


[Unknown Act > Conclusion]
toimposethedeathpenaltyencompassesthetypeofmoralcalculusthatshouldremaininthehandsofthejury,astheConstitutionprovides.JusticeClarenceThomasjoinedintheconcurrence.JusticeThomasalsowroteaseparateconcurrenceinwhichhearguedthatthestudiescitedinsupportofthearbitrarinessoftheimpositionofthedeathpenaltyarethemselvesunreliablebecausetheyrequirethatthemoralreasonstoexecutesomeonebereducedtoametricbyacademicswhowerenotpresentattrial.JusticeScaliajoinedintheconcurringopinion.
Justice Stephen G. Breyer wrote a dissent in which he argued that the constitutionality of a punishment must be evaluated based on currently prevailing social and legal standards; therefore, the death penalty is no longer constitutional. Justice Breyer pointed to studies that show that the exoneration rate is disproportionately high with capital crimes, which reflects both cases in which the defendant was actually innocent and cases in which there was procedural error; therefore, the death penalty is not reliably applied to cases in which the defendant has been properly convicted of crimes that society harshly condemns. Additionally, studies have shown that factors other than the egregiousness of the crime—such as the races and genders of the defendant and the victim, the location of the crime, and political pressures—influence the imposition of the death penalty, and such arbitrariness results in the punishment being unconstitutionally cruel. Because the imposition of the death penalty requires additional procedural safeguards, there are often long delays between sentencing and execution, if the execution happens at all, which is cruel in and of itself and also divorces the punishment from its punitive purposes of deterrence and retribution. Justice Breyer also argued that the nation has consistently been moving away from the use of the death penalty, to the point that it is used so rarely as to be considered “unusual” for the purpose of the Eighth Amendment. Justice Ruth Bader Ginsburg joined in the dissent. In her separate dissent, Justice Sonia Sotomayor wrote that the district court erred in holding that the use of midazolam did not create a substantial risk of severe pain. Instead, the scientific evidence supports the view that, while midazolam can induce unconsciousness, it is not sufficient to maintain unconsciousness through the effects of the rest of the execution cocktail. Because the petitioners sufficiently demonstrated that the risk of severe pain was substantial and that the state’s safeguards do not appropriately mitigate that risk, the use of midazolam violates the Eighth Amendment’s prohibition against cruel and unusual punishment. Justice Sotomayor also argued that there is no requirement that petitioners for relief under the Eighth Amendment provide a reasonable alternative, because a cruel method of execution does not become constitutional simply due to a lack of alternatives. Justice Breyer, Justice Ginsburg, and Justice Elena Kagan joined in the dissent.


[Unknown Act > Facts]
Abercrombie & Fitch Stores, Inc. (Abercrombie) is a national chain of clothing stores that requires its employees to comply with a "Look Policy" that reflects the store's style and forbids black clothing and caps, though the meaning of the term cap is not defined in the policy. If a question arises about the Look Policy during the interview or an applicant requests a deviation, the interviewer is instructed to contact the corporate Human Resources department, which will determine whether or not an accommodation will be granted.
In 2008, Samantha Elauf, a practicing Muslim, applied for a position at an Abercrombie store. She wore a headscarf, or hijab, every day, and did so in her interview. Elauf did not mention her headscarf during her interview and did not indicate that she would need an accommodation from the Look Policy. Her interviewer likewise did not mention the headscarf, though she contacted her district manager, who told her to lower Elauf's rating on the appearance section of the application, which lowered her overall score and prevented her from being hired.
The Equal Employment Opportunity Commission (EEOC) sued Abercrombie on Elauf's behalf and claimed that the company had violated Title VII of the Civil Rights Act of 1964 by refusing to hire Elauf because of her headscarf. Abercrombie argued that Elauf had a duty to inform the interviewer that she required an accommodation from the Look Policy and that the headscarf was not the expression of a sincerely held religious belief. The district court granted summary judgment for the EEOC. The U.S. Court of Appeals for the Tenth Circuit reversed and held that summary judgment should have been granted in favor of Abercrombie because there is no genuine issue of fact that Elauf did not notify her interviewer that she had a conflict with the Look Policy.


[Unknown Act > Conclusion]
Yes. Justice Antonin Scalia delivered the opinion of the 7-2 majority. The Court held that, to hold an employer liable under Title VII of the Civil Rights Act of 1964, an applicant for a position must only show that her need for an accommodation was a motivating factor in the employer’s decision not to hire her. The disparate-treatment provision of Title VII does not contain a knowledge requirement but rather forbids certain motives, regardless of the employer’s knowledge about the applicant. If the applicant can show that the employer’s decision not to hire an applicant was based on a desire to avoid having to accommodate a religious practice, then the employer has violated Title VII. The Court also held that Title VII does not demand mere neutrality; instead it creates an affirmative duty to accommodate religious practices.
In his opinion concurring in the judgment, Justice Samuel A. Alito, Jr. wrote that, while the applicant has to show that the employer had knowledge of the applicant’s religious practice, the applicant does not have a duty to notify the employer. Justice Alito argued that the statutory language would not make sense without any knowledge requirement because such a reading would allow an employer to be held liable without fault.
Justice Clarence Thomas wrote an opinion concurring in part and dissenting in part in which he argued that the application of a neutral policy cannot constitute intentional discrimination that violates Title VII. Although the strict application of the employer’s policy may have disproportionately affected those who wear headscarves for religious reasons, the policy still treated all potential applicants in the same manner, and therefore an applicant who was denied a position because of her religious headscarf did not suffer from disparate treatment. Additionally, Title VII disparate-treatment precedent does not hold that a failure to accommodate is intentional discrimination. Justice Thomas also argued that the statutory language should be construed narrowly so as to only punish employers who act with a discriminatory motive.


[Unknown Act > Facts]
In early 2002, a many years-long effort by Senators John McCain and Russell Feingold to reform the way that money is raised for--and spent during-- political campaigns culminated in the passage of the Bipartisan Campaign Reform Act of 2002 (the so-called McCain-Feingold bill sometimes referred to as BCRA). Its key provisions were a) a ban on unrestricted ("soft money") donations made directly to political parties (often by corporations, unions, or wealthy individuals) and on the solicitation of those donations by elected officials; b) limits on the advertising that unions, corporations, and non-profit organizations can engage in up to 60 days prior to an election; and c) restrictions on political parties' use of their funds for advertising on behalf of candidates (in the form of "issue ads" or "coordinated expenditures").
The campaign finance reform bill contained an unusual provision providing for an early federal trial and a direct appeal to the Supreme Court of the United States, by-passing the typical federal judicial process. In May a special three-judge panel struck down portions of the Campaign Finance Reform Act's ban on soft-money donations but upheld some of the Act's restrictions on the kind of advertising that parties can engage in. The ruling was stayed until the Supreme Court could hear and decide the resulting appeals.


[Unknown Act > Conclusion]
With a few exceptions, the Court answered "no" to both questions in a 5-to-4 decision written by Justices Sandra Day O'Connor and John Paul Stevens. Because the regulations dealt mostly with soft-money contributions that were used to register voters and increase attendance at the polls, not with campaign expenditures (which are more explicitly a statement of political values and therefore deserve more protection), the Court held that the restriction on free speech was minimal. It then found that the restriction was justified by the government's legitimate interest in preventing "both the actual corruption threatened by large financial contributions and... the appearance of corruption" that might result from those contributions.
In response to challenges that the law was too broad and unnecessarily regulated conduct that had not been shown to cause corruption (such as advertisements paid for by corporations or unions), the Court found that such regulation was necessary to prevent the groups from circumventing the law. Justices O'Connor and Stevens wrote that "money, like water, will always find an outlet" and that the government was therefore justified in taking steps to prevent schemes developed to get around the contribution limits.
The Court also rejected the argument that Congress had exceeded its authority to regulate elections under Article I, Section 4 of the Constitution. The Court found that the law only affected state elections in which federal candidates were involved and also that it did not prevent states from creating separate election laws for state and local elections.
[In total, the Court addressed 21 sections of federal law. We have distilled these disparate components into 12 separate votes which we detail at the end of this document.]


[Unknown Act > Facts]
Timothy Lee Hurst was charged and convicted of first-degree murder for killing his co-worker, Cynthia Harrison, during a robbery of the Popeye’s restaurant where they both worked. He was sentenced to death and appealed. On appeal, Hurst was granted a new sentencing trial because the Supreme Court of Florida found that his counsel should have investigated and presented evidence of Hurst’s borderline intelligence and possible organic brain damage. At his new sentencing trial, Hurst was prevented from presenting mental retardation evidence as an absolute bar to the imposition of the death penalty, though he was allowed to present it as mitigating evidence. The jury again sentenced Hurst to the death penalty by a vote of seven to five, and the Supreme Court of Florida affirmed.
In 2002, the Supreme Court decided the case Ring v. Arizona, in which the Court held that the Sixth Amendment required that the presence of aggravating factors, which Arizona’s death penalty sentencing scheme viewed as essentially elements of a larger offense, be determined by the jury. The Supreme Court of Florida had previously held that the decision in Ring v. Arizona did not apply to Florida’s death penalty sentencing scheme generally and specifically did not require that a jury’s recommendation of the death penalty be unanimous or that a jury determine the factual issue of a defendant’s potential mental retardation.


[Unknown Act > Conclusion]
Florida’s death sentencing scheme violated the Sixth Amendment in light of the Supreme Court’s decision in Ring v. Arizona. Justice Sonia Sotomayor delivered the opinion for the 8-1 majority. The Court held that the Sixth Amendment requires a jury, not a judge, to find each element necessary to impose the death sentence. Although the Florida sentencing scheme required that the jury recommend a death sentence in order to impose the death penalty, the judge was only required to take the jury recommendation under consideration. Because the Supreme Court held in Ring v. Arizona that the Sixth Amendment required that a jury make all the critical findings necessary to impose the death penalty, the Florida sentencing scheme violated the Sixth Amendment in the same way the Arizona one did in Ring. In his opinion concurring in the judgment, Justice Stephen G. Breyer wrote that the Eighth Amendment required jury sentencing in capital cases.
Justice Samuel A. Alito, Jr. wrote a dissent in which he argued that that the Sixth Amendment did not require that a jury make the specific findings authorizing the imposition of the death penalty. The Florida sentencing scheme is different from the one the Supreme Court found unconstitutional in Ring v. Arizona because in the Arizona scheme the jury did not make any recommendation about the death penalty at all. Although the judge could choose not to follow the jury’s recommendation, no Florida court has done so for more than 15 years. Justice Alito also argues that, if there was error, the error was harmless in this case because the jury recommended that Hurst be sentenced to death.


[Unknown Act > Facts]
In 1963, Henry Montgomery was found guilty and received the death penalty for the murder of Charles Hunt, which Montgomery committed less than two weeks after he turned 17. He appealed to the Louisiana Supreme Court, and his conviction was overturned because of community prejudice. At his new trial, Montgomery was again convicted, but he was sentenced to life without parole.
In 2012, the U.S. Supreme Court decided Miller v. Alabama, in which the Court held that mandatory sentencing schemes requiring children convicted of homicide to be sentenced to life imprisonment without parole violate the Eighth Amendment. In light of that decision, Montgomery filed a motion in state district court to correct what he argued was now an illegal sentence. The trial court denied Montgomery’s motion, and the Louisiana Supreme Court denied Montgomery’s application by holding that the decision in Miller does not apply retroactively.


[Unknown Act > Conclusion]
The Supreme Court had jurisdiction to review the Louisiana Supreme Court’s decision, and the Supreme Court’s decision in Miller v. Alabama, which prohibits sentencing schemes that impose a punishment of mandatory life without parole for juvenile offenders convicted of homicide, applied retroactively. Justice Anthony M. Kennedy delivered the opinion for the 6-3 majority. The Court held that, when the Court establishes a substantive constitutional rule, that rule must apply retroactively because such a rule provides for constitutional rights that go beyond procedural guarantees. When a state court fails to give effect to a substantive rule, that decision is reviewable because failure to apply a substantive rule always results in the violation of a constitutional right, while failure to apply a procedural rule might or might not result in an illegitimate verdict. The Court held that Miller established a substantive rule because it prohibited the imposition of a sentence of life without parole for juvenile offenders. The Court’s analysis in that case was based on precedent that established that the Constitution treats children as different from adults for the purposes of sentencing. Therefore, the rule the Court announced in Miller made life without parole an unconstitutional punishment for a class of defendants based on their status as juveniles, and such a rule is substantive rather than procedural.
In his dissent, Justice Antonin Scalia wrote that the Court did not have jurisdiction to decide this case. Because Supreme Court precedent treated cases on collateral review from state court decisions differently from those on direct review from federal courts, the principle of finality of decisions dictates that whether new constitutional rule will be applied to a final state court conviction is entirely a matter of state choice. Therefore, a state court need only apply the constitutional rule that existed at the time of the conviction, and the Court does not have the jurisdiction to review that decision. Justice Scalia argued that the precedent the majority relied on for its conclusion was not binding and did not directly apply to the case at hand. Additionally, the language of Miller itself stated that it did not create a substantive rule but instead established a process that required courts to consider a juvenile offender’s age before imposing a particular penalty. Crucially, Miller still allowed for the imposition of life without parole on a juvenile offender if the crime(s) in question reflect “permanent incorrigibility.” Justice Clarence Thomas and Justice Samuel A. Alito, Jr. joined in the dissent. Justice Thomas also wrote a separate dissent in which he argued that the Supreme Court did not have jurisdiction to decide this case. The question of whether a constitutional right is retroactive asks whether there is an appropriate remedy, not whether the right was violated in the first place. Because the Supreme Court cannot force state courts to apply constitutional rules that did not exist at the time of the conviction, there is no constitutional mechanism to provide a remedy that would make the constitutional right in question apply retroactively.


[Unknown Act > Facts]
On September 7, 2008, Amy Imburgia filed a class action lawsuit against DIRECTV, Inc. (DIRECTV), and argued that DIRECTV had improperly charged early termination fees to its customers. In 2011, the U.S. Supreme Court decided AT&T Mobility LLC v. Concepcion, in which the Court held that the Federal Arbitration Act preempted California precedent that had previously held that, in certain circumstances, arbitration clauses in customer agreements were unenforceable. Less than one month after that decision, DIRECTV moved to stay or dismiss the plaintiffs’ case and compel arbitration, which DIRECTV argued it had not done previously because it thought the arbitration clause in its customer agreement was void under California precedent. The trial court denied the motion and the California Court of Appeal for the Second District affirmed by holding that the language of the customer agreement subjected the arbitration clause to state law.


[Unknown Act > Conclusion]
The Federal Arbitration Act preempts state law, so the court has to enforce the arbitration agreement. Justice Stephen G. Breyer delivered the opinion of the 6-3 majority. The Court held that requiring contract enforcement under California state law that the Supreme Court had held was invalid under AT&T Mobility LLC v. Concepcion would conflict with the Federal Arbitration Act. Absent any indication that the language of the contract is meant to refer to invalid state law, it should be construed as only referring to valid state law, which is consistent with California state law. The Court also noted that there was no indication that a California court would apply state law that has been held to be invalid because it conflicts with federal law to any other context. Even in the canon of cases that determine that ambiguous language in a contract should be construed against the party that drafted the language, there is no case that goes so far as to apply invalid state law.
Justice Clarence Thomas wrote a dissent in which he argued that the Federal Arbitration Act did not apply to state courts and therefore did not require the court to order arbitration in this case. In her separate dissent, Justice Ruth Bader Ginsburg wrote that the provision should be construed against the drafting party so as to give the consumer the ability to pursue class-based litigation. Because the relevant question should be whether both parties agreed to be bound by relevant state law as framed by the state legislature without considering the preemptive effect of federal law, the California state court’s decision should control this case. Although the Federal Arbitration Act contains a presumption in favor of arbitration, the presumption only applies when the express agreement to arbitrate was validly formed, which is not the case when consumers lack bargaining power in the creation of such contracts. Justice Sonia Sotomayor joined in the dissent.


[Unknown Act > Facts]
In late 2008, Robert Montanile was involved in a car accident that resulted in significant injuries. Montanile was covered by an employee welfare benefit plan administered by the Board of Trustees of the National Elevator Industrial Health Benefit Plan (Plan). After Montanile’s accident, the Plan dispersed over $120,000 to cover Montanile’s medical expenses. Montanile later sued the driver of the other car involved in the accident, eventually obtaining a $500,000 settlement. Per its terms, the Plan then requested that Montanile reimburse the initial $120,000 disbursement. When Montanile and the Plan were unable to reach an agreement, the Plan sued Montanile.
The Plan is governed by the Employee Retirement Income Security Act of 1974 (ERISA), which allows plan administrators to recover overpayment from a beneficiary when the recovery would constitute “appropriate equitable relief”. The trial court held that the terms of the Plan required Montanile to repay the initial $120,000, and that this repayment was appropriate equitable relief in part because the Plan was able to identify a source of funds within Montanile’s possession—the $500,000 settlement. Montanile appealed and claimed that the repayment would not be equitable relief because the settlement had been spent or disbursed to other parties. The U.S. Court of Appeals for the Eleventh Circuit held that, because the Plan had a right to reimbursement, the Plan’s lien against Montanile’s $500,000 settlement attached before Montanile spent or disbursed the funds. Therefore, Montanile could not evade the repayment by claiming the settlement funds had been spent or disbursed.


[Unknown Act > Conclusion]
If a third party asset has been wholly disbursed on non-traceable items (such as services), ERISA does not allow for a suit to recover reimbursement of that asset. Justice Clarence Thomas delivered the opinion of the 8-1 majority. The Court held that, while the Plan had a claim under ERISA to the settlement fund when it was in Montanile’s possession, the claim does not extend beyond the dissipation of the fund in question. When the fund is completely dissipated on non-traceable items, such as services, there is no fund to which the Plan would have a claim, and the Board may not then seek to attach the claim to the plan-beneficiary’s general assets. The Court also held that its precedent on “appropriate equitable relief” does not dictate a different result.
Justice Ruth Bader Ginsburg wrote a dissent in which she argued that allowing a plan-beneficiary to escape his reimbursement obligation by disbursing his settlement fund on non-traceable items would undo nearly forty years of Supreme Court precedent regarding “appropriate equitable relief.”


[Unknown Act > Facts]
In December 2000, brothers Jonathan and Reginald Carr committed a series of crimes in Wichita, Kansas, known as “The Wichita Massacre,” which included assault, robbery, rape, and the murder of five people. The Carrs were prosecuted jointly. They moved to sever their cases and argued that being tried jointly would be prejudicial because they intended to mount antagonistic defenses and introduce evidence that would be admissible or non-prejudicial only in separate trials. The trial judge denied the motion, and the Carrs were later jointly convicted on numerous counts and sentenced to death. The jury instructions at the sentencing trial did not state that mitigating circumstances need not be proven beyond a reasonable doubt.
On appeal, the Carrs argued that their Eighth Amendment rights to individualized sentencing were violated both by the trial judge’s refusal to sever their cases and the failure to affirmatively instruct the jury that mitigating circumstances need not be proven beyond a reasonable doubt. The Kansas Supreme Court agreed and reversed the death sentences by holding that the trial judge failed to do the necessary analysis and carefully consider the severance issue. The court also held that the jurors may have been prevented from giving meaningful effect to mitigating evidence because they were not instructed that mitigating circumstances need not be proven beyond a reasonable doubt.
In the consolidated case, Kansas v. Gleason, Gleason was convicted of capital murder for the killings of several people in connection with a robbery. He was also convicted of pre-meditated murder, aggravated kidnapping, aggravated robbery, and criminal possession of a firearm. The jury sentenced Gleason to death for the capital murder charge and a consecutive sentence of life in prison without the possibility of parole for 50 years for the other charges. Gleason appealed his convictions, and the Kansas Supreme Court vacated his conviction of life imprisonment because it was multiplicitous with his death sentence and vacated his death sentence because the jury was not properly instructed on how to consider mitigating circumstances.


[Unknown Act > Conclusion]
The Eighth Amendment does not require that a jury be affirmatively instructed that mitigating circumstances do not need to be proven beyond a reasonable doubt, nor does the Eighth Amendment require that the sentencing phase of a joint trial be severed. Justice Antonin Scalia delivered the opinion of the 8-1 majority. The Court held that death penalty case law does not require a court to give the jury express instructions on how to consider mitigating evidence, and no reasonable juror would have understood the instructions as requiring that defense counsel prove the existence of mitigating circumstances beyond a reasonable doubt. The Court also held that the Eighth Amendment does not govern procedural issues, such as the claim that each defendant was prejudiced by evidence relating to the other during the joint sentencing phase at issue. Instead, such claims are governed by the Due Process Clause. Moreover, in this case, there is no evidence that the jury was impermissibly prejudiced by the presentation of evidence during a joint sentencing phase for both defendants.
Justice Sonia Sotomayor wrote a dissent in which she argued that the Kansas state courts had not violated any federal constitutional right, and therefore there was no reason for the Supreme Court to intervene. Because this case turns on a question about a state sentencing scheme, it is unlikely to apply to other states. By granting certiorari in such a case and determining that no constitutional right was violated, as the majority did in this case, the Court creates a risk that such decisions will discourage states from adopting additional procedural protections via state law.


[Unknown Act > Facts]
William Thompson suffered a head injury aboard the SS. Rosina Marron after an attack by a fellow crewmember. After several months of recuperation, Thompson signed an agreement releasing Costal Oil Company from liability in exchange for $4000. Later, Thompson discovered the damage from his injury was much more extensive than originally thought. Thomson sued to recover damages from his injury. The district court upheld the release, noting that Thompson adamantly refused to consult an attorney, although he had many opportunities to do so, and freely entered into the agreement. The U.S. Court of Appeals for the Third Circuit reversed.


[Unknown Act > Conclusion]
In a per curiam opinion, the Supreme Court reversed the Third Circuit opinion. Justice John M. Harlan concurred, but would have remanded the case to determine whether the vessel was unseaworthy. Justice Stanley Reed, Justice Felix Frankfurter, Justice Harold Burton, and Justice Sherman Minton dissented.


[Unknown Act > Facts]
Nelson, a member of the Communist Party, was convicted of violating the Pennsylvania Sedition Act. This Act was implemented prior to Congress's adoption of the Smith Act of 1940 (amended in 1948) which prohibited the same conduct as Pennsylvania's law.


[Unknown Act > Conclusion]
Yes. The Court held that Pennsylvania's law was unenforceable and was superseded by the federal act. Chief Justice Warren argued that the scheme of federal regulation of seditious activities was "pervasive" and "left no room for the states to supplement it." Furthermore, the federal act dealt with an issue of primary importance to the national government which made any enforcement of similar state laws potentially harmful to the smooth execution of national statutes.


[Unknown Act > Facts]
New York City municipal charter provision §903 required discharge of any municipal employee who invokes the Fifth Amendment protection against self-incrimination in a legally authorized inquiry into that employee’s official conduct. Harry Slochower, a tenured professor at Brooklyn College, invoked this privilege in a congressional committee investigation into his past Communist Party membership. Despite his tenured status, which required notice and a hearing before termination, the city terminated him immediately. The state trial court dismissed a motion to review the discharge and the Court of Appeals of New York affirmed.


[Unknown Act > Conclusion]
Yes. Justice Tom C. Clark, writing for a 5-4 majority, reversed the lower court. The Supreme Court held that dismissal of the review motion was improper. §903 is unconstitutional as applied in this case because it denies due process of law. The Court emphasized that invoking the Fifth Amendment does not amount to an admission of guilt. Justices Hugo L. Black and William O. Douglas concurred, writing that they also adhered to the views in their dissents in Garner v. Board of Public Works, Adler v. Board of Education, and their concurrence in Weiman v. Updegraff
Justice Stanley Reed dissented, expressing that New York City had a reasonable ground to require employees to give information about their official conduct or give up their positions. Justices Sherman Minton and Harold Burton joined in the dissent. Justice John M. Harlan wrote a separate dissent, stating that no Due Process violation occurred in this case.


[Unknown Act > Facts]
The Food and Drug Administration ("FDA") fired Kendrick Cole when it determined that his employment was not "clearly consistent with the interests of national security." Mr. Cole was a food and drug inspector and a "preference-eligible veteran," but was charged with having "a close association with individuals reliably reported to be Communists." Mr. Cole appealed his discharge to the Civil Service Commission, which denied his appeal, finding that the Veterans' Preference Act did not afford Mr. Cole a right of appeal under the circumstances. Mr. Cole brought an action seeking declaratory judgment in the District of Columbia federal district court alleging that his discharge was invalid and that the Civil Service Commission improperly denied his appeal. The district court dismissed the case and the U.S. Court of Appeals for the District of Columbia affirmed.


[Unknown Act > Conclusion]
The Supreme Court reversed the D.C. Circuit, holding that the discharge of an employee without determination that his position was one in which he could adversely affect national security was unauthorized by the Veterans' Preference Act. With Justice John Marshall Harlan II writing for the majority, the Court reasoned that the Act's use of "national security" only relates to the nation's safety, and not the general welfare. Moreover, there was no determination that Mr. Cole's position within the FDA affected national security as the term is used in the Act. Therefore, the Court concluded, Mr. Cole's discharge was invalid.


[Unknown Act > Facts]
Mrs. Covert killed her husband on an airbase in England. Pursuant to a “status-of-forces” executive agreement with England, she was tried and convicted by US court-martial without a jury trial under the Uniform Code of Military Justice (UCMJ). She petitioned a writ of habeas corpus on the grounds that the conviction violated her Fifth & Sixth Amendment rights to be tried by a jury after indictment by a grand jury.


[Unknown Act > Conclusion]
U.S. citizen civilians outside of the territorial jurisdiction of the United States cannot be tried by U.S. military tribunal, but instead retain the protections guaranteed by the United States Constitution.
In a decision authored by Justice Hugo Black, the Court held that U.S. citizen civilians abroad have the right to Fifth Amendment and Sixth Amendment constitutional protections. The Court agreed with the petitioners, concluding that as United States citizens they were entitled to the protections of the Bill of Rights, notwithstanding that they committed crimes on foreign soil. Justice Black declared: "The concept that the Bill of Rights and other constitutional protections against arbitrary government are inoperative when they become inconvenient or when expediency dictates otherwise is a very dangerous doctrine and if allowed to flourish would destroy the benefit of a written Constitution and undermine the basis of our government."
While a majority of the Court agreed with the ultimate result, they did so for different reasons. Concurring in the decision, Justice Felix Frankfurter rejected the idea that the Necessary and Proper Clause could prevent Congress from mandating the court martial of civilians in all cases. He opposed what he termed a "recourse to the literal words" of the Constitution. Merely to hold that Mrs. Covert could not stand trial before a military tribunal since she was not a member of the armed forces signified too narrow a review. In his opinion, that determination required the Court to assess the Constitution in its entirety and not simply the single provision granting Congress the power to regulate the nation's land and naval forces. He advocated a balancing test that would require a court to weigh "all the factors involved...in order to decide whether [military dependents] are so closely related to what Congress may allowably deem essential for the effective...regulation of the land and naval forces that they may be subjected to court-martial jurisdiction in...capital cases, when the consequence is loss of [their constitutional] protections."
Also concurring in the judgment, Justice John Marshall Harlan II essentially agreed with Frankfurter. Accordingly, he saw the determination as "analogous to issues of due process." Having first determined that military dependents overseas bear a rational connection to the armed forces such that they could be validly subjected to court martial, he then asserted that the analysis turned on a question of what process was due a military dependent under the "particular circumstances of a particular case." While capital cases such as this one certainly necessitated a full Article III trial, most petty offenses committed by military dependents almost certainly would not. He thus advocated a case-by-case approach, rejecting the sweeping conclusion set forth by the plurality. Since Harlan had originally voted with the majority in the initial decision of this case, his concurrence on rehearing was narrow but significant. Perhaps as a consequence of his earlier vote in the previous term, his opinion on rehearing was considerably less at odds with the arguments set forth in the dissent written by Justice Tom C. Clark and joined by Justice Harold Burton.
In that staunch dissent, Clark gave substantial weight to historical practice. He asserted that the "military has always exercised jurisdiction by court-martial over civilians accompanying armies in time of war," and that for explicit reasons of policy concerning military morale and discipline, none of the Court's relevant precedents had ever questioned that authority. He pointed out several troublesome and practical consequences of the Court's holding. Not least among these were the vast distances between the United States and its various military instillations around the world. By setting forth an overly broad standard, the plurality, argued Clark, had opened the door to a myriad of petty offenses to be tried in the federal court system, thus incurring needless cost, delay, and disruption.
Justice Charles Whitaker took no part in the decision.
Historical Note


[Unknown Act > Conclusion]
everquestionedthatauthority.HepointedoutseveraltroublesomeandpracticalconsequencesoftheCourt'sholding.NotleastamongthesewerethevastdistancesbetweentheUnitedStatesanditsvariousmilitaryinstillationsaroundtheworld.Bysettingforthanoverlybroadstandard,theplurality,arguedClark,hadopenedthedoortoamyriadofpettyoffensestobetriedinthefederalcourtsystem,thusincurringneedlesscost,delay,anddisruption.JusticeCharlesWhitakertooknopartinthedecision.HistoricalNote
Reid v. Covert has the distinction of being the only case in the history of the Supreme Court in which the Court reversed itself on rehearing. In successfully persuading the Court to do so, Mrs. Covert's lawyer, Colonel Frederick Bernays Wiener, secured for himself a seat among the giants of the legal profession. A seasoned veteran of Supreme Court litigation, Colonel Wiener considered his triumph in Reid v. Covert to be among his greatest professional accomplishments. His oral argument in the case has attained legendary status and remains a preeminent exemplar in the art of persuasion and appellate advocacy.
Matthew Lognion contributed this abstract.


[Unknown Act > Facts]
Judson Griffin and James Crenshaw were indicted for armed robbery in Cook County, Illinois. Following their conviction, in preparation for filling for an appeal, Griffin and Crenshaw requested a transcript of their trial proceedings without cost, on the basis that they could not afford the standard fee for the transcript. The lower court dismissed the petition without hearing evidence.


[Unknown Act > Conclusion]
Yes. In a 5–4 decision authored by Justice Hugo L. Black, the Court reasoned that there is "no meaningful distinction" between denying indigent defendants the right to appeal and denying them a trial. Because Illinois conceded that Griffin and Crenshaw could not file for appeal without a transcript, the Court found that their rights to due process and equal protection had been denied.


[Unknown Act > Facts]
An Oklahoma law prohibited persons who were not licensed optometrists or ophthalmologists to fit lenses for eyeglasses. Non-licensed individuals were also prohibited from duplicating optical instruments without written prescriptions from licensed ophthalmologists. The Lee Optical Company challenged the law.


[Unknown Act > Conclusion]
In a unanimous decision authored by William Orville Douglas, the Court held that while the law may have been "needless" and "wasteful," it was the duty of the legislature, not the courts, "to balance the advantages and disadvantages of the new requirement." That is, Courts should not be able to invalidate state economic regulations on the grounds that they disagree with the theories supporting them. Even if the state law imposes burdens or waste, the legislature has the sole authority over weighing its benefits against its costs. In sum, the opticians could not prove that the law had no rational relationship to legitimate state objectives.


[Unknown Act > Facts]
After its decision in Brown v. Board of Education of Topeka (Brown I), which declared racial discrimination in public education unconstitutional, the Court convened to issue the directives which would help to implement its newly announced constitutional principle. The cases stemmed from many different regions of the United States with distinctive conditions and problems.


[Unknown Act > Conclusion]
The Brown I decision shall be implemented "with all deliberate speed."
The Court held that the problems identified in Brown I required varied local solutions. Chief Justice Warren conferred much responsibility on local school authorities and the courts which originally heard school segregation cases. They were ordered to implement the principles which the Supreme Court embraced in its first Brown decision. Warren urged localities to act on the new principles promptly and to move toward full compliance with them "with all deliberate speed."


[Unknown Act > Facts]
New York state law authorized the legal counsel for a municipality to seek an injunction against and the destruction of material deemed by the courts to be obscene. Peter Campbell Brown, Corporation Counsel for the City of New York, sought such an injunction against several bookstores. The process of review that followed was a civil, rather than criminal procedure, and the courts ultimately granted the injunction and sought to destroy the obscene material.


[Unknown Act > Conclusion]
No. In a 5–4 opinion authored by Justice Felix Frankfurter, the Court concluded that the civil procedure complied with the requirements of due process. Justice Frankfurter noted that the procedural safeguards were not significantly different from many state criminal misdemeanor procedures, nor were the penalties any more severe. The opinion also reaffirmed the existing notion that the constitutional protection of speech does not extend to obscene material.


[Unknown Act > Facts]
John H. Griffin’s book The Devil Rides Outside traces the spiritual development of an unnamed American musician as he vacillates between choosing a life in a Benedictine monastery and the lustfulness of the outside world. When Alfred Butler, the Detroit district sales manager of Pocket Books, sold a copy of the book to a police officer, he was arrested and charged with violating a Michigan obscenity statute. At trial, the judge held that the book contained obscene language that could lead to the corruption of minors and that the passages in question lacked redeeming literary value. Butler was convicted and fined $100. Butler appealed and argued that the statute violated his right to free speech under the First and Fourteenth Amendments. The Supreme Court of Michigan denied Butler’s application for leave to appeal.


[Unknown Act > Conclusion]
Yes. Justice Felix Frankfurter delivered the opinion of the 9-0 majority. The Court held that the Michigan statute unduly restricted the freedom of speech because it took only a single trial judge’s determination that the material could potentially corrupt minors to prohibit its dissemination. The Court noted that, although the State may attempt to protect juvenile innocence as part of its power to promote general welfare, the restrictions should be reasonably related to the evils of obscene material.
Justice Hugo L. Black concurred without writing a separate opinion.


[Unknown Act > Facts]
Not Available.


[Unknown Act > Conclusion]
Not Available.


[Unknown Act > Facts]
Clinton Jencks, a union leader, was charged with falsely filing an Affidavit of Non-Communist Union Officer with the National Labor Relations Board. Two undercover informants for the Federal Bureau of Investigation (FBI) testified against Jencks, and reported that he had been seen at Communist Party events and working with Communist Party members. The evidence provided against Jencks was entirely circumstantial, and the prosecution's evidence rested largely on the testimonies and reports of the undercover informants. Jencks requested the testimony of the informants to review their credibility and admissibility in court. The trial court denied his request without stating the reasons, and Jencks was found guilty on two counts of communist activity and sentenced to five years imprisonment for each offense. Jencks appealed the lower court's decision on the grounds that the informants' reports should have been provided for review to determine their use in the trial and on the grounds that the jury was improperly instructed on the definitions of political party membership. The U.S. Court of Appeals for the Fifth Circuit affirmed the decision of the lower court.


[Unknown Act > Conclusion]
Yes. Justice William J. Brennan, Jr. wrote the opinion for the 7-1 majority. The Court held that the government's reports should have been produced for review for their admission in court. A concern for national security must be weighed against prosecuting criminal action if the criminal action prosecution relies on documents that, if released, would threaten national security. Based on this weighing test, the documents should have been provided for review of admissibility in a new trial. Criminal action must be dismissed if the government refuses to release information as a matter of national security.
Justice Harold Burton wrote a concurring opinion in which he agreed that the accused had the right to review the documents as evidence against him but argued that the disclosure of the documents should not guarantee a new trial. Rather, the documents should be reviewed and, if found to contain information that discredited the FBI informants’ testimony, then there should be a new trial. However, in this case Justice Burton agreed there should be a new trial on the grounds that the jury was improperly instructed on the requirements of membership to a political party. Justice John M. Harlan joined in the concurrence.
Justice Tom C. Clark dissented and argued that, if information containing national secrets and issues of national security were available for the accused in criminal prosecutions, then national security would be greatly compromised. Justice Clark also wrote that the jury was properly instructed on the definition of membership to a political party.
Justice Charles E. Whittaker did not participate in the discussion or decision of this case.


[Unknown Act > Facts]
In December 1938, Thomas Leiter conveyed approximately 8,711 acres of land in Plaquemines Parish, Louisiana to the United States. The deed contained a mineral reservation under which Leiter retained the right to mine and remove all valuable minerals until April 1, 1945. The deed allowed for the extension of this reservation for an additional five years so long as operations were conducted profitably during the previous five years for an average of fifty days a year. If at the end of the original term or an additional extended term the operation had not carried on for fifty days a year, Leiter’s right to mine would terminate, and complete title would become vested in the United States. No mineral operations were conducted on the land in question during the original term.
On March 1, 1949, the United States conveyed the operating rights under lease to Frank J. and Albert Lobrano, who then conveyed those rights to The California Company. The California Company drilled and completed eighty wells, producing $3,500,000 in royalties for the United States. Leiter Minerals, Inc. then filed an action in state court against Allen L. Lobrano and The California Company based on a Louisiana law allegedly making a reservation of mineral rights to the United States “imprescriptible”. The United States was not a party to the suit. Leiter Minerals claimed that it was the fee simple owner of all the oil, gas and mineral rights in or on the land acquired by the United States from Thomas Leiter.
The United States then brought an action in district court; it sought to quiet Leiter Minerals’ title and rights and to enjoin Leiter Minerals from further asserting any claims in state court. The United States argued in part that irreparable injury in the form of lost royalties would result from any dispossession to its lessees. The district court granted the injunction, holding that the action could only be tried in federal court because the United States was not a party to the state court action.


[Unknown Act > Conclusion]
No. In an 8-1 decision written by Justice Felix Frankfurter, the Court held that the district court properly granted the injunction. Justice Frankfurter first looked to federal law, which specified that a court of the United States may not enjoin state court proceedings except 1) as expressly authorized by congress, 2) to aid its jurisdiction, or 3) to protect or effectuate its judgments. He also looked to the Court’s past interpretations of the Norris-La Guardia Act, where it determined that statutes generally divesting persons of pre-existing rights and privileges only divest the United States of those rights and privileges when there are expressed words to that effect.
Justice Frankfurter then turned to the purpose behind the restriction of the federal courts’ injunction power, arguing that the interest in restricting this power was strongest when the state court litigation was between private parties. Here, in contrast, the United States was arguably attempting to prevent injury to the national interest. Justice Frankfurter also emphasized that the United States was not a party to the state court action, and that the United States’ position in its claim was essentially defensive. The Court remanded the case to the state court, directing it to interpret and apply the Louisiana statute in question.
Justice William Douglas dissented in part, questioning the majority’s decision to remand the case to Louisiana state court. He argued that Congress tasked the federal courts with deciding mixed questions of state and federal law.


[Unknown Act > Facts]
In 1954, John Watkins, a labor organizer, was called upon to testify in hearings conducted by the House Committee on Un-American Activities. Watkins agreed to describe his alleged connections with the Communist Party and to identify current members of the Party. Watkins refused to give information concerning individuals who had left the Communist Party. Watkins argued that such questions were beyond the authority of the Committee.