[Unknown Act > Conclusion]
No. The Supreme Court reversed the Eighth Circuit holding that the time granted to prepare pretrial motions is not automatically excludable from the 70-day limit under subsection (h)(1). Rather, with Justice Clarence Thomas writing for the majority, the Court stated that such time may be excluded only when a district court grants a continuance based on appropriate findings under subsection (h)(7). The Court reasoned that the period of time sought to be excluded by the government preceded the first day upon which Congress specified that such delay may be automatically excluded. Thus, in this case, the pretrial preparation time was not automatically excludable.
Justice Ruth Bader Ginsburg wrote a separate concurring opinion. She highlighted that nothing in the majority decision prevents the Eight Circuit upon remand from considering the government's argument that Mr. Bloate's indictment and conviction remain valid. Justice Samuel A. Alito, joined by Justice Stephen G. Breyer, dissented. He argued that the neither the text nor legislative history of the Speedy Trial Act support the majority decision. Instead, he criticized the majority for creating a rule that would entitle Mr. Bloate to dismissal of his charge because his attorney persuaded a Magistrate Judge to give him more time to prepare pretrial motions.


[Unknown Act > Facts]
Among the plaintiffs in this case are supporters of the Kurdistan Workers Party ("KWP") and the Liberation Tigers of Tamil Eelam ("LTTE"). The KWP and LTTE engage in a variety of both lawful and unlawful activities. They sought an injunction to prevent the government from enforcing sections of the Antiterrorism and Effective Death Penalty Act ("AEDPA"). Section 302 authorizes the Secretary of State to designate a group as a "foreign terrorist organization." Section 303 makes it a crime for anyone to provide "material support or resources" to even the nonviolent activities of a designated organization. In previous cases, the courts have held that Section 303 was unconstitutionally vague. Congress then passed the Intelligence Reform and Terrorism Prevention Act ("IRTPA") which amended the AEDPA. It added a state of mind requirement that individuals "knowingly" provide "material support or resources" in order to violate the Act. Congress also added terms to the Act that further clarified what constituted "material support or resources." The government moved for summary judgment arguing that challenged provisions of the AEDPA were not unconstitutionally vague. The district court granted a partial motion for summary judgment, but held that some parts of the Act were unconstitutionally vague.
On appeal, the U.S. Court of Appeals for the Ninth Circuit affirmed, holding that the terms "service," "training," or "other specialized knowledge" within the AEDPA, as applied to the plaintiffs, were unconstitutionally vague.


[Unknown Act > Conclusion]
Not as applied to the plaintiffs. The Supreme Court held that the material support provision of the AEDPA is constitutional as applied to the particular forms of support that the plaintiffs seek to provide to terrorist organizations. With Chief Justice John G. Roberts writing for the majority, the Court reasoned that, as applied, the provision in question is not vague. Here, the statutory terms at issue -- "training," "expert advice or assistance," "service," and "personnel" -- are not similar to terms like "annoying" and "indecent" that the Court has struck down as being too vague. The Court recognized that the statute may not be clear in every respect, but it is clear enough with respect to the plaintiffs in this case.
Justice Stephen G. Breyer, joined by Justices Ruth Bader Ginsburg and Sonia Sotomayor, dissented. He agreed that the statute was not unconstitutionally vague. However, Justice Breyer disagreed that the Constitution permits the government to prosecute the plaintiffs criminally for engaging in coordinated teaching and advocacy furthering the designated organizations' lawful political objectives. He reasoned that the government had not met its burden to show that the speech prohibited by the statute served a compelling governmental interest.


[Unknown Act > Facts]
Applicants were denied a patent by the Patent and Trademark Office (PTO) for claims pertaining to a process of managing risk in commodities trading. The PTO examiner deemed the invention not to be of patentable subject matter under 35 U.S.C. Section 101. The Board of Patent Appeals and Interferences affirmed the decision.
On appeal, the U.S. Court of Appeals for the Federal Circuit affirmed. The court relied on Supreme Court precedent stating that an invention is patentable if: "1) it is tied to a particular machine or apparatus, or 2) it transforms a particular article into a different state or thing." Reasoning from this, it held that the applicants' invention clearly failed this test (machine-or-transformation test) and therefore did not constitute patentable subject matter.


[Unknown Act > Conclusion]
No. No. The Supreme Court affirmed the Federal Circuit, holding that the applicants' claimed invention is not patent eligible. With Justice Anthony M. Kennedy writing for the majority, the Court reasoned that the Federal Circuit did not err when it used the "machine-or-transformation test" to determine patentability. However, the Court noted, in contrast to the Federal Circuit, that the machine-or-transformation test is not the sole test for determining patent eligibility.
Justice John Paul Stevens, joined by Justices Ruth Bader Ginsburg, Stephen G. Breyer, and Sonia Sotomayor, concurred in the judgment. He disagreed with the majority to the extent it suggested that any series of steps that is not itself an abstract idea or law of nature may constitute a "process" within Section 101. Justice Stephen G. Breyer, joined by Justice Antonin Scalia, also concurred in the judgment. He noted his agreement with Justice Stevens' concurrence and also highlighted the extent to which the Court agreed on many fundamental issues of patent law raised by this case.


[Unknown Act > Facts]
Natives of Somalia filed suit against Mohamed Ali Samantar in a Virginia federal district court under the Torture Victim Protection Act ("TVPA") and the Alien Tort Statute ("ATS"). Plaintiffs alleged that Mr. Samantar committed torture and other human rights violations while he commanded Somali government agents under the regime of Mohamed Siad Barre. The district court dismissed the case, holding that Mr. Samantar was immune to suit under the Foreign Sovereign Immunities Act ("FSIA").
On appeal, the U.S. Court of Appeals for the Fourth Circuit reversed, holding that the FSIA did not render Mr. Samantar immune to suit. The court reasoned that the FSIA does not apply to foreign government officials. The court further reasoned that even if the FSIA does apply to foreign government officials, it does not apply to former foreign government officials.


[Unknown Act > Conclusion]
No. No. The Supreme Court held that the FSIA does not govern Mr. Samantar's claim of immunity. With Justice John Paul Stevens writing for the majority, the Court reasoned that there is nothing to suggest that "foreign state" within the FSIA should be read to include an official acting on behalf of that state. The Court further reasoned that the FSIA's legislative history did not indicate that Congress intended to codify official immunity within the FSIA.
Justices Samuel A. Alito, Clarence Thomas, and Antonin G. Scalia, writing in separate opinions, noted that the legislative history of the FSIA should not have been evaluated in reaching the Court's conclusion.


[Unknown Act > Facts]
The plaintiffs, employees of the Union Pacific Railroad (UPR), filed claims through their union, Brotherhood of Locomotive Engineers and Trainmen (BLET), contesting their discharge or discipline imposed by the UPR. The National Railroad Adjustment Board (NRAB) dismissed the claims for lack of jurisdiction reasoning that the BLET failed to submit conclusive evidence that the aggrieved parties had held a conference with the UPR to attempt to resolve the disputes – a prerequisite to arbitration – though conferences were in fact held. The plaintiffs appealed to a federal district where the dismissal was affirmed.
On appeal, the U.S. Court of Appeals for the Seventh Circuit reversed, holding that the NRAB denied the plaintiffs due process by requiring evidence of conferencing on the record as a prerequisite to arbitration. The court reasoned that this requirement was not clearly established in the statutes, regulations, or collective bargaining agreement and therefore the NRAB had created a new requirement, which it imposed retroactively.


[Unknown Act > Conclusion]
Yes and No. With Justice Ruth Bader Ginsburg writing for a unanimous bench, the Court held that the Seventh Circuit effectively resolved the Union's core complaint, but erred in doing so under a "constitutional, rather than statutory headline." The Court reasoned that there was no due process issue "alive" in the case. The Court further held that prearbitration settlement conferences are not a prerequisite for NRAB jurisdiction over a dispute. The Court reasoned that prearbitration conference requirements set out by the NRAB run independent of the collective bargaining process and do not bear on the merits of an actual grievance.


[Unknown Act > Facts]
In 1978, Curtis W. McGhee Jr. and Terry Harrington were convicted of murder and sentenced to life imprisonment by an Iowa state court. In 2002, Mr. McGhee's and Mr. Harrington's convictions were reversed because the prosecutor at their trial improperly withheld evidence of an alternative suspect. Subsequently, Mr. McGhee and Mr. Harrington filed civil claims in an Iowa federal court against Pottawattamie County, Iowa, and the prosecutors and officers involved in their prosecution. The defendants moved for summary judgment arguing that they were absolutely immune to civil prosecution. The district court found some defendants immune to certain claims, but denied immunity to other defendants on the other claims. The U.S. Court of Appeals for the Eighth Circuit granted interlocutory appeal on the question of whether the prosecutors were absolutely immune to civil prosecution.
The Eighth Circuit held that the prosecutors were not immune from claims that they violated Mr. McGhee's and Mr. Harrington's due process rights. The court reasoned that allegations that prosecutors obtained, manufactured, coerced, and fabricated evidence did not fall within "a distinctly prosecutorial function" and thus the prosecutors were not immune to the claims.


[Unknown Act > Conclusion]
Dismissed pursuant to the Court's Rule 46.


[Unknown Act > Facts]
This case originates in the Supreme Court. South Carolina seeks an equitable apportionment of the Catawba River, which starts in North Carolina and flows into South Carolina. The Special Master recommends that the Supreme Court (1) permit the City of Charlotte, N.C., the Catawba River Water Supply Project, and Duke Energy Carolinas LLC to intervene as defendants, and (2) deny South Carolina's motion for clarification of the Special Master's order.


[Unknown Act > Conclusion]
Yes and no. The Supreme Court held that the Catawba River Water Supply Project and Duke Energy met the standards for intervention, but Charlotte did not. "Charlotte has not carried its burden of showing a sufficient interest for intervention in this action," Justice Samuel J. Alito wrote for the 5-4 majority. "Its interest is solely as a user of North Carolina's share of the Catawba River's water."
Chief Justice John G. Roberts, Jr. filed a separate opinion concurring in the judgment in part and dissenting in part, joined by Justices Clarence Thomas, Ruth Bader Ginsburg and Sonia Sotomayor. The dissent agreed with the majority's denial of Charlotte's motion and its rejection of the more permissive intervention standard adopted by the special master, but would not have permitted the Catawba Project and Duke Energy to intervene either.


[Unknown Act > Facts]
Geertson Seed Farms ("Geertson") and Trask Family Seeds ("Trask") sought an injunction against Monsanto Company ("Monsanto") in a California federal district court. Geertson and Trask feared that the wide-scale sale of a new Monsanto alfalfa variety, resistant to one of the company's herbicides, would lead to cross-pollination with Geertson's and Trask's conventional alfalfa variety and thereby lead to its disappearance. The district court granted the injunction pending an Environmental Impact Statement ("EIS") about the effect of Monsanto's new alfalfa variety.
On appeal, the U.S. Court of Appeals for the Ninth Circuit affirmed holding that the injunction was appropriate and that an evidentiary hearing was not required before the issuance of the injunction.


[Unknown Act > Conclusion]
No. Yes. The Supreme Court first held that the plaintiffs have standing to seek injunctive relief. However, the Court further held that the district court abused its discretion when it entered an injunction absent the completed EIS. With Justice Samuel A. Alito writing for the majority, the Court reasoned that no factor favoring the imposition of an injunction yet existed.
Justice John Paul Stevens dissented. He argued that the district court's findings of fact all supported the imposition of an injunction: (1) the new alfalfa variety could contaminate other plants, (2) contamination could take place even in a controlled setting, (3) the relevant regulator has limited ability to control or limit limitations on planting, and (4) genetic contamination could decimate farmers' livelihoods all supported.


[Unknown Act > Facts]
A federal district court in New York approved an $18 million settlement in a class-action brought by freelance writers who had contracted with the defendant publishers to publish their works in print. Without authorization, the publishers reproduced the works for electronic distribution. Muchnick and others objected to the settlement.
The U.S. Court of Appeals for the 2nd Circuit overturned the settlement on the ground that the trial court lacked jurisdiction over claims relating to unregistered works. The court stated that the Copyright Act grants the federal district courts jurisdiction only over those claims that arise from registered works. Since the vast majority of the claimants in the litigation based their claims on unregistered works, the federal district court did not have the power to certify a class in the litigation.


[Unknown Act > Conclusion]
No. Writing for the majority, Justice Clarence Thomas held that Section 411(a)'s registration requirement is a precondition to filing a copyright infringement claim. The Court further held that a copyright holder's failure to comply with the registration requirement does not restrict a federal court's subject matter jurisdiction over infringement claims involving unregistered works. The Court declined to address whether Section 411(a)'s registration requirement is a mandatory precondition to suit that district courts may or should enforce on their own initiative by dismissing copyright infringement claims involving unregistered works.
Justice Ruth Bader Ginsburg, joined by Justices John Paul Stevens and Stephen G. Breyer, concurred in part and concurred in the judgment. Justice Ginsburg agreed that Section 411(a)'s registration requirement does not restrict a federal court's subject matter jurisdiction. However, she noted that tension remained between the Court's prior holdings in Arbaugh v. Y & H Corp. and Bowles v. Russell. In an attempt to stave off confusion, she attempted to reconcile the two decisions by distinguishing the cases.


[Unknown Act > Facts]
When Terrence Graham was 16 years old he was convicted of armed burglary and attempted armed robbery. He served a 12 month sentence and was released. Six months later Mr. Graham was tried and convicted by a Florida state court of armed home robbery and sentenced to life in prison without parole. On appeal, he argued that the imposition of a life sentence without parole on a juvenile, on its face, violated the Eighth Amendment and moreover constituted cruel and unusual punishment, and thus violated the Eighth Amendment. The District Court of Appeal of Florida disagreed. It held that Mr. Graham's sentence neither was a facial violation of the Eighth Amendment nor constituted cruel and unusual punishment.


[Unknown Act > Conclusion]
Yes. The Supreme Court held that the Eight Amendment's Cruel and Unusual Punishments Clause does not permit a juvenile offender to be sentenced to life in prison without parole for a non-homicidal crime. Justice Anthony M. Kennedy, writing for the majority, reasoned that because this case implicates a particular type of sentence as it applies to an entire class of offenders (juveniles), the categorical analysis under Atkins, Roper, and Kennedy governs. Under this approach, the Court must: (1) consider objective indicia of society's standards and (2) determine whether the punishment in question violates the Constitution guided by the standards elaborated by controlling precedents. Here, the Court concluded that both (1) and (2) indicated that the punishment in question for the class in question was unconstitutional. The Court made a point to note that life sentences for juveniles for non-homicidal crimes has been "rejected the world over."
Chief Justice John G. Roberts wrote separately, concurring in the judgment. He disagreed with the manner in which the majority reached its conclusion. Instead, he made his conclusion based on: (1) Supreme Court cases requiring "narrow proportionality" review of noncapital sentences and (2) the Supreme Court's conclusion in Roper that juvenile offenders are generally less culpable than adults who commit the same crimes. Justice Clarence Thomas, joined by Justice Antonin G. Scalia, and in part by Justice Samuel A. Alito, dissented. Justice Thomas reprimanded the majority for replacing its own moral judgment for that of American citizens who up to this point had been charged with making the moral distinction as to whether this sentence could ever be imposed. Justice Alito also wrote a separate dissenting opinion. He departed from Justice Thomas's dissent to note that "[n]othing in the Court's opinion affects the imposition of a sentence to a term of years without the possibility of parole." He also would not have reached the issue as to whether Mr. Graham's sentence as-applied violated the Eighth Amendment. He would only have reached the question of whether such sentences categorically violate the Eighth Amendment.


[Unknown Act > Facts]
In 2005, the Bankruptcy Abuse Prevention and Consumer Protection Act (BAPCPA) was signed into law. In part, it added a new term to the Bankruptcy Code ("Code"), "debt relief agency," and both restricted and proscribed actions by those groups falling under the definition. Subsequently, a Minnesota bankruptcy law firm sought a declaratory judgment against the United States, arguing that the BAPCPA did not apply to attorneys and law firms, and was unconstitutional as it applied to attorneys. The federal district court agreed and issued an order declaring that attorneys in the District of Minnesota were excluded from the Code's definition of "debt relief agency" and that the challenged provisions of the Code were unconstitutional as they applied to attorneys in the District of Minnesota.
On appeal, the U.S. Court of Appeals for the Eight Circuit held that attorneys who provide "bankruptcy assistance" were included within the BAPCPA's definition of "debt relief agency." However, it also held that BAPCPA provisions that prohibited a debt relief agency from advising clients to incur debt in contemplation of bankruptcy was overbroad, and thus unconstitutional.


[Unknown Act > Conclusion]
No. No. No. With Justice Sonia Sotamayor writing for the majority, the Supreme Court held that attorneys who provide bankruptcy assistance to assisted persons are debt relief agencies under the BAPCPA. The Court further held that § 526(a)(4) of the BAPCPA is not an overly broad, content based restriction on attorney-client communications. Rather, the Court reasoned that it merely prohibits a debt relief agency only from advising a debtor to incur more debt because the debtor is filing for bankruptcy. Lastly, the Court held that § 528's disclosure requirements are valid as applied to Mr. Milavetz. The Court reasoned that the disclosure requirements do not act as an affirmative limitation on speech and are reasonably related to the government's interest in preventing consumer deception.
Justice Antonin Scalia wrote a separate opinion, concurring in part and concurring in the judgment. He disagreed with the majority's use of the BAPCPA's legislative history arguing that "legislative history is irrelevant when the statutory text is clear." Justice Clarence Thomas also concurred in part and concurred in the judgment. He noted his skepticism with Zauderer and its progeny, cases at the heart of the majority's reasoning. Justice Thomas wondered whether these precedents provide sufficient First Amendment protection against government-mandated disclosure requirements.


[Unknown Act > Facts]
Antonio Jackson filed a complaint in the Nevada federal district court alleging race discrimination and retaliation. The employer, Rent-A-Center West, Inc., moved to dismiss the proceedings and compel arbitration. The district court granted the motion to dismiss and compelled arbitration.
On appeal, the U.S. Court of Appeals for the Ninth Circuit held in part that the district court was required to determine in the first instance whether the coverage and discovery provisions of the arbitration agreement were unconscionable.


[Unknown Act > Conclusion]
Yes. The Supreme Court held that under the Federal Arbitration Act ("FAA"), where an agreement to arbitrate includes a provision that the arbitrator will determine the enforceability of the agreement, if a party challenges specifically the enforceability of that particular provision, the district court considers the challenge, but if a party challenges the enforceability of the agreement as a whole, the challenge is for the arbitrator. With Justice Antonin Scalia writing for the majority, the Court reasoned that Mr. Jackson challenged the enforceability of the agreement as a whole, and thus, the determination is left to the arbitrator not the district court.
Justice John Paul Stevens, joined by Justices Ruth Bader Ginsburg, Stephen G. Breyer, and Sonia Sotomayor, dissented. He criticized the majority for adopting a position not proposed by either party during briefing or oral arguments.


[Unknown Act > Facts]
The union representing employees at a New Process Steel plant in Butler, Indiana failed to reach an agreement over a new contract with New Process Steel. The union subsequently filed unfair labor practices claims with the National Labor Relations Board ("NLRB") arguing that New Process Steel failed to honor its collective bargaining agreement to deal with the union as the exclusive representative of employees of the plant. A two-member panel of the NLRB agreed with the union. On appeal, New Process Steel argued that the NLRB's decision was invalid because 29 U.S.C. § 153(b) of the National Labor Relations Act requires that three members of the five member National Labor Relations Board shall "at all times" constitute a quorum.
The U.S. Court of Appeals for the Seventh Circuit disagreed and affirmed the judgment of the board. The court held that the NLRB had power to delegate its authority to a group of three of its members. In which case, two sitting members constituted a quorum. Therefore, the NLRB appropriately rendered its decision.


[Unknown Act > Conclusion]
No. The Supreme Court held that the NLRBA requires that when the Board delegates its authority, the delegated group must maintain a membership of three in order to exercise the delegated authority of the Board. With Justice John Paul Stevens writing for the majority, the Court reasoned that the plain language of the statute – the Board may delegate its powers to a "group of three or more members" – required that the delegated group must have at least three members to exercise such authority.
Justice Anthony M. Kennedy, joined by Justices Ruth Bader Ginsburg, Stephen G. Breyer, and Sonia Sotamayor, dissented. He criticized the majority for calling into question the more than 500 cases the NLRB address during the 26 months it carried out its responsibilities with only two members. He also disagreed with the manner in which the majority reached its conclusion.


[Unknown Act > Facts]
The Maine Public Utilities Commission along with the attorneys general of Connecticut and Massachusetts filed for petitions of review of orders of the Federal Energy Regulatory Commission (FERC). FERC approved a settlement and redesigned New England's "capacity" electricity market, which Maine, Connecticut, and Massachusetts were subject to, even though they were not parties to the settlement. FERC denied their request for rehearing.
On appeal to the U.S. Court of Appeals for the District of Columbia, Maine, Connecticut, and Massachusetts argued that FERC erred in finding that "transition payments" under the settlement should be reviewed under the "public interest" standard as dictated by Mobile-Sierra rather than the "just and reasonable" standard. The District of Columbia Circuit agreed holding that the Mobile-Sierra doctrine should not apply to non-parties to the settlement agreement. It reasoned that the Mobile-Sierra doctrine is premised on the existence of a "voluntary contract" between the parties. Maine, Connecticut, and Massachusetts never entered a voluntary agreement with FERC and therefore the standard was inappropriate.


[Unknown Act > Conclusion]
Yes. The Supreme Court reversed U.S. Court of Appeals for the District of Columbia to the extent that it rejected the application of Mobile-Sierra to non-contracting parties. With Justice Ruth Bader Ginsburg writing for the majority and joined by Chief Justice John G. Roberts, and Justices Antonin G. Scalia, Anthony M. Kennedy, Clarence Thomas, Stephen G. Breyer, Samuel A. Alito, and Sonia Sotamayor, the Court held that Mobile-Sierra controls the FERC as well as challenges to contract rates brought by contracting and non-contracting parties. The Court reasoned that Mobile-Sierra is not an exception to the just-and-reasonable standard, but rather an application of that standard to the context of rates set by contract.
Justice John Paul Stevens wrote a separate dissenting opinion. He argued in part that this case was clearly outside the context of the Mobile-Sierra doctrine. He further argued that the majority's decision imposes "a special burden" on non-contracting parties attempting to exercise their rights to object to unreasonable rates. He reasoned that such a rule was a "quantum leap" from the origins of the Supreme Court's rate setting jurisprudence.


[Unknown Act > Facts]
In-state and out-of-state retail natural gas suppliers sued Ohio's Tax Commissioner in an Ohio federal district court alleging that Ohio's tax scheme was unconstitutional. The plaintiffs argued that because four local natural gas distribution companies benefited from certain tax exemptions that did not benefit the plaintiffs, despite their similar circumstances, the tax scheme violated the Commerce Clause and Equal Protection Clause. The district court dismissed the case for lack of jurisdiction, but the U.S. Court of Appeals for the Sixth Circuit reversed.
The Sixth Circuit held that federal comity concerns do not bar an action that challenges the tax benefits provided to just four specific entities, but not others similarly situated. The court recognized a circuit split over whether federal comity concerns prevent federal court jurisdiction over a matter. In reaching its conclusion, the Sixth Circuit sided with the Seventh and Ninth Circuits which have interpreted Hibbs v. Winn to mean that comity prevents federal court jurisdiction only when state taxpayers seek federal court orders allowing them to avoid paying state taxes. This was not at issue in this case, and the plaintiffs' success would not significantly intrude upon traditional matters of state taxation in Ohio; thus, the federal court had jurisdiction. The Sixth Circuit remanded the case in order for it to proceed.


[Unknown Act > Conclusion]
No. Yes. The Supreme Court reversed the Sixth Circuit, holding that under the comity doctrine, a taxpayer's complaint of allegedly discriminatory state taxation must proceed originally in state court. With Justice Ruth Bader Ginsburg writing for the majority, the Court reasoned that its decision in Hibbs did not narrow the comity doctrine. Moreover, the Court reasoned that the Ohio courts are better positioned to determine whether Ohio's taxation scheme is unconstitutional.
Justice Anthony M. Kennedy wrote separately, concurring. He noted that he joined the majority position with the understanding it did not expand the holding in Hibbs. Justice Clarence Thomas, joined by Justice Antonin G. Scalia, concurred in the judgment. He also noted his skepticism of Hibbs. Moreover, Justice Thomas argued that this case should have been dismissed for lack of jurisdiction.


[Unknown Act > Facts]
This appeal is the consolidation of three separate cases that involved defendants' conviction for possession of cocaine in a Virginia state court. On appeal, the defendants argued that the admission into evidence of a certificate of analysis in the absence of testimony at trial from the person who performed the analysis and prepared the certificate, pursuant to Virginia Code Section 19.2-187, violated the Confrontation Clause of the Sixth Amendment. The Supreme Court of Virginia disagreed, holding that the provisions of Section 19.2-187 did not violate a defendant's Confrontation Clause rights. Moreover, the court held that the defendants in these cases knowingly, intelligently, and voluntarily waived their Sixth Amendment rights to confront the forensic analysts when they failed to call them as witnesses at trial.


[Unknown Act > Conclusion]
In a short per curiam opinion, the Court vacated the judgment of the Supreme Court of Virginia, remanding the case for further proceedings in light of Melendez-Diaz v. Massachusetts decided the previous Term.


[Unknown Act > Facts]
Kevin D. Powell was convicted in a Florida state court of being a felon in possession of a firearm and sentenced to 10 years in prison. Mr. Powell appealed arguing that his Miranda warning was invalid because the written form used by the Tampa police at his arrest did not explicitly indicate that he had a right to an attorney at his questioning. The court of appeals agreed and reversed the conviction. On appeal, the Florida Supreme Court affirmed, holding that informing a defendant that he has the right to "talk with an attorney" is not sufficient to inform him of his right to have counsel present.


[Unknown Act > Conclusion]
Yes. No. The Supreme Court held that it retained jurisdiction over the case. Justice Ruth Bader Ginsburg wrote for the majority, joined by Chief Justice John G. Roberts, and Justices Antonin G. Scalia, Anthony M. Kennedy, Clarence Thomas, Samuel Alito, and Sonia Sotamayor, and Justice Stephen G. Breyer as to Part II. Justice John Paul Stevens dissented joined in part by Justice Breyer. The majority recognized that the Florida Supreme Court relied in part on its own state Constitution in addition to Miranda in reaching its decision. However, Justice Ginsburg reasoned that when a state court decision fairly appears to rest on federal law, or is interwoven with federal law, and the adequacy and independence of the state-law ground is unclear from the opinion, as in this case, it is presumed that federal law controlled the state court's decision. Hence, the Supreme Court retained jurisdiction.
The Supreme Court also reversed the Florida Supreme Court, holding that while Miranda requires that a suspect "be warned prior to any questioning" and "that he has the right to the presence of an attorney, "it does not dictate the words in which the essential information must be conveyed. Rather, to determine whether police warnings are satisfactory, the inquiry is simply whether the warnings reasonably conveyed to a suspect his rights as required by Miranda. Here, Mr. Powell received warnings that satisfied this standard.
In his dissent, Justice Stevens argued that the Supreme Court's power to review the Florida Supreme Court's decision was at best doubtful and that the Florida court had a better view of the case on the merits. Justice Stevens counseled that the Supreme Court should limit applying the presumption that federal law controlled a state court's decision only in truly ambiguous cases. He reasoned that this was not such a case. Justice Stevens further argued that the warnings Mr. Powell received did not reasonably convey to him that he had the right to a lawyer during his interrogation.


[Unknown Act > Facts]
Francisco J. Espinosa filed for Chapter 13 bankruptcy and proposed a plan that provided for the repayment of student loans to United Student Aid Funds, Inc. ("Funds"). After Funds was notified, it filed a proof of claim roughly $4,500 greater than that was included in the plan. The bankruptcy court approved the original plan and Funds was notified it would be paid the lower figure. Mr. Espinosa subsequently completed the plan and his loans were discharged by the court. Three years later, Funds began intercepting Mr. Espinosa's income tax refunds to satisfy the unpaid portion of his student loans (the $4,500 figure). Mr. Espinosa petitioned the bankruptcy court for an order holding Funds in contempt for violating the discharge injunction. In response, Funds argued that Mr. Espinosa's student loans were improperly discharged because student loans cannot be discharged unless the debtor can show "undue hardship." This can only be shown in an adversary proceeding, which did not take place. Moreover, it argued the lack of an adversary proceeding denied Funds its Fourteenth Amendment due process rights. These arguments were rejected by the bankruptcy court, but, on appeal, were accepted by the Arizona federal district court.
On appeal, the U.S. Court of Appeals for the Ninth Circuit reversed. It held that simply because Mr. Espinosa failed to comply with additional procedures required by the Bankruptcy Code to discharge student loan debt was not sufficient to set aside the discharge of his student loans, considering Funds had actually been notified of the Chapter 13 plan. It also held that Fund's due process rights were not violated because Fund's had received actual notice of Mr. Espinosa's Chapter 13 plan, even though he had not commenced the adversary proceedings.


[Unknown Act > Conclusion]
Yes. No. The Supreme Court held that the Bankruptcy Court's confirmation order is not void. With Justice Clarence Thomas writing for a unanimous Court, it reasoned that because the Bankruptcy Court's order was final, it could only be rendered void if the order was premised on either a jurisdictional error or on a violation of due process. Here, there was neither a jurisdictional error nor a violation of due process. The Court further reasoned that the Bankruptcy Court's failure to find undue hardship was mere legal error and did not rise to the level of a jurisdictional or due process error that would render the order void.


[Unknown Act > Facts]
In 2005, the Georgia Department of Human Resources (DHR) and related state agencies settled a class action lawsuit with plaintiff foster children under the care of the DHR. However, the parties could not agree on the appropriate amount of attorneys' fees to be included in the settlement. Subsequently, the plaintiffs filed a motion in a Georgia federal district court for that court to make a fee determination and award. The plaintiffs argued that they were owed over $7 million for services rendered and also deserved a $7 million fee enhancement for a job well done. The district court largely agreed with the plaintiffs and awarded $10,522,405.08 in compensation, over $4 million of which was a fee enhancement. The district court reasoned that "the superb quality of counsel's representation far exceeded what could reasonably be expected for the standard hourly rates used to calculate the fee" and thus justified the enhancement.
On appeal, the Eleventh Circuit affirmed, holding that the district court did not abuse its discretion when it enhanced the lodestar figure (hours reasonably expended multiplied by a reasonable hourly rate) because of counsel's skill, commitment, dedication, and professionalism. The Court reasoned that the enhancement of the lodestar amount of attorney's fees may be allowed for superior representation coupled with the exceptional nature of results.


[Unknown Act > Conclusion]
Yes. The Supreme Court held that the calculation of an attorney's fee based on the lodestar may be increased due to superior performance, but only in extraordinary circumstances. With Justice Samuel A. Alito writing for the majority, the Court rejected the contention that a fee determined by the lodestar method may not be enhanced in any situation. The Court then explained that there were circumstances where superior attorney performance is not adequately taken into account by the lodestar. However, the Court counseled that such enhancements should not be awarded without specific evidence that the lodestar fee would not have been "adequate to attract competent counsel."
Justice Anthony M. Kennedy wrote separately, concurring. He lauded the Court for rejecting that all enhancements under the lodestar method should be barred. Justice Clarence Thomas also wrote separately, concurring. He was careful to note that the majority opinion placed precise limitations on the availability of lodestar enhancements. Justice Stephen G. Breyer, joined by Justices John Paul Stevens, Ruth Bader Ginsburg, and Sonia Sotomayor, concurred in part and dissented in part. He agreed that lodestar enhancements may sometimes be permissible. However, he would have affirmed the Eleventh Circuit because the Supreme Court was too far removed from the fact intensive inquiry as to whether a fee enhancement in this case was warranted.


[Unknown Act > Facts]
In 1998 National Australia Bank (NAB), an Australian company, acquired Homeside Lending Inc. (Homeside), an American company. In 2001, NAB announced that it would incur a $450 million write-down for inaccurately calculating the fees Homeside would generate for servicing mortgages, which had been calculated as present assets. Its stock price then dropped 5 percent. Later that year, NAB announced a second write-down of $1.75 billion to amend for other inaccurate calculations that had been booked as present assets. NAB's stock price tumbled an additional 13 percent. Subsequently, four owners of NAB stock filed suit against NAB and Homeside in a New York federal district court alleging violations of the Securities and Exchange Act of 1934. Three of the plaintiffs purported to represent a class of non-American purchasers of NAB stock because they bought their shares abroad. The district court held that it lacked subject matter jurisdiction over the class of non-American purchasers.
On appeal, the U.S. Court of Appeals for the Second Circuit affirmed. The court reasoned that subject matter jurisdiction exists over claims only "if the defendant's conduct in the United States was more than merely preparatory to fraud, and particular acts or culpable failures to act with the United States directly caused losses to foreign investors abroad." Here, the court noted that (1) the issuance of fraudulent statements from NAB's corporate headquarters in Australia were more central to the fraud than Homeside's manipulation of financial data on which NAB based its statements, (2) there was no effect on U.S. capital markets, and (3) the lengthy chain of causation from NAB receiving inaccurate information from Homeside before passing the information along to its investors suggested that the district court lacked subject matter jurisdiction.


[Unknown Act > Conclusion]
No. Not answered. The Supreme Court affirmed the Second Circuit, but held that it erred when it raised the question of subject matter over the case. Instead, the Court held that the Securities and Exchange Act does not provide a cause of action to foreign plaintiffs suing foreign and American defendants for misconduct in connection with securities traded on foreign stock exchanges. With Justice Antonin Scalia writing for the majority, the Court reasoned that "longstanding principle" dictated that the legislation of Congress, unless expressly stated otherwise, only applies within the territorial jurisdiction of the United States. Here, the Court further reasoned that the section of the Securities and Exchange Act in question dealt with transactions in securities listed on domestic exchanges and domestic transactions which was not present in this case.
Justice John Paul Stevens, joined by Justice Ruth Bader Ginsburg, concurred in the judgment. He agreed with Court's conclusion but disagreed that the Court employed a new test to determine the reach of the Securities and Exchange Act – only extending to "transactions in securities listed on domestic exchanges and domestic transactions." He stated that the federal courts have been construing the Act's scope under a different test which did not warrant abandonment.


[Unknown Act > Facts]
Gas station franchisees won a verdict against franchisor Motiva in the Massachusetts federal district court for violations of the Petroleum Marketing Practices Act. The franchisees argued that new leases that changed the way rent was calculated and which amounted to increased rents were made in bad faith and meant to drive them out of business. They claimed that the new lease terms amounted to "constructive nonrenewal," prohibited by the PMPA, even though they signed the agreements. On appeal, the U.S. Court of Appeals for the First Circuit reversed in part, holding that the PMPA did not support a claim for constructive nonrenewal under the circumstances in the case. It reasoned that the PMPA requires franchisees faced with objectionable contract terms to refrain from ratifying those terms by executing the contract, as the franchisees did in this case.


[Unknown Act > Conclusion]
No. In a unanimous opinion written by Justice Samuel A. Alito, the court held that a franchisee cannot recover for constructive termination under the PMPA if the franchisor's allegedly wrongful conduct did not compel the franchisee to abandon its franchise. The Court further held that a franchisee who signs and operates a renewal agreement with a franchisor may not maintain a constructive nonrenewal claim under the PMPA. The Court reasoned when a franchisee signs a renewal agreement, there has been no "failure to renew," and, thus no violation.


[Unknown Act > Facts]
Several states belonging to the Southeast Interstate Low-Level Radioactive Waste Management Compact ("Compact") and the commission created by the compact ("Commission") filed suit against North Carolina. The plaintiffs allege that North Carolina was designated as a host state for a waste management facility, accepted $80 million to build the facility, but then declined to fund, license, build, and operate it. The plaintiffs seek to recover the $80 million, a $10 million sanction, and attorneys' fees.
The Supreme Court assigned the case to a Special Master who conducted proceedings and filed two reports. The Preliminary Report recommended denying North Carolina's motion to dismiss on sovereign immunity grounds; denying plaintiffs' motion for summary judgment as to Count I which sought enforcement of sanctions against North Carolina; granting North Carolina's motion to dismiss Count I; and denying North Carolina's motion to dismiss Counts II-V. The Special Master's Second Report recommended denying Plaintiffs' motion for summary judgment and granting North Carolina's motion for summary judgment on Count II; and denying North Carolina's motion for summary judgment on Counts III-V. The parties then filed a total of nine exceptions to the Special Master's Reports.


[Unknown Act > Conclusion]
The Supreme Court held that the plaintiffs' seven exceptions are overruled. With Justice Antonin Scalia writing for the majority, the Court reasoned that the Compact does not authorize the Commission to impose monetary sanctions against North Carolina. Moreover, the Court reasoned that North Carolina did not breach its contractual obligation. The Court further held that North Carolina's two exceptions are overruled. The Court reasoned that the Special Master acted reasonably in denying North Carolina's motion for summary judgment with respect to Counts III-V.
Justice Anthony M. Kennedy, joined by Justice Sonia Sotamayor, concurred in part and concurred in the judgment. He stated that, despite some reservations, the majority was correct to reject the plaintiffs' final exception to the Special Master's Reports. Chief Justice John G. Roberts, joined by Justice Clarence Thomas, concurred in part and dissented in part. He argued that Arizona v. California, relied on heavily by the majority, was a case "built on sand," and thus, not sufficient to support the majority's conclusions. Justice Stephen G. Breyer, joined by Chief Justice Roberts, concurred in part and dissented in part. He argued that North Carolina did breach the Compact when it suspended its efforts to build a waste disposal facility.


[Unknown Act > Facts]
AnimalFeeds International Corp. on behalf of a class of plaintiffs filed suit in a Pennsylvania federal district court against Stolt-Nielsen among others alleging defendants were engaged in a "global conspiracy to restrain competition in the world market for parcel tanker transportation services." After the case was transferred to the Connecticut federal district court, Stolt-Nielsen filed a motion to compel arbitration, which was denied. On appeal, the U.S. Court of Appeals for the Second Circuit reversed. During arbitration, AnimalFeeds filed a demand to proceed as a class. A panel was appointed to determine whether the language of the Clause Construction Award permitted AnimalFeeds to proceed as a class and answered in the affirmative. Stolt-Nielsen then petitioned the Connecticut federal district court to vacate the panel's determination, which was granted.
On appeal, the U.S. Court of Appeals for the Second Circuit reversed and reinstated the panel's decision. The court held that the arbitration panel did not manifestly disregard the law when reaching its conclusion that the Clause Construction Award permitted AnimalFeeds to proceed as a class, even though the Award was silent on whether proceeding as a class was permitted. The court reasoned that when parties agree to arbitrate, the question of whether an agreement permits class arbitration is generally left to the arbitrators, not the courts.


[Unknown Act > Conclusion]
No. The Supreme Court reversed, holding that imposing class arbitration on parties who have not agreed to authorize class arbitration is inconsistent with the Federal Arbitration Act ("FAA"). With Justice Samuel A. Alito writing for the majority, the Court reasoned that in this case the arbitration panel exceeded its powers by imposing its own policy choice instead of identifying and applying a rule derived from the FAA or from maritime or New York law. The Court emphasized that the FAA adopts the basic principle that arbitration is a matter of consent, not coercion. Here, there was no consent.
Justice Ruth Bader Ginsburg, joined by Justices John Paul Stevens and Stephen G. Breyer, dissented. She argued first that the petition for certiorari in this case was improvidently granted because the Court overturned the ruling of "experienced arbitrators." Moreover, even by reaching the merits of the case, she would have affirmed the Second Circuit and adhered to the "strict limitations" the FAA places on judicial review.


[Unknown Act > Facts]
In 1934, the Veterans of Foreign Wars built a wooden cross on top of Sunrise Rock in the Mojave National Preserve (Preserve) as a memorial to those who died in World War I. The original cross no longer exists, but has been rebuilt several times. Frank Buono, a former Preserve employee, filed suit in a California federal district court seeking to prevent the permanent display of the cross. The genesis of his suit occurred in 1999 when a request to build a Buddhist shrine in the Preserve, near the cross, was denied. He argued that the cross' display on federal property violated the Establishment Clause of the First Amendment. The district court agreed and the cross was covered.
While the case was pending, Congress designated Sunrise Rock a national memorial and barred its dismantling with the use of federal funds. One year later, by land swap, Congress made Sunrise Rock private property in exchange for another parcel of land. Mr. Buono moved to not only enforce the previous court order preventing the display of the cross, but also to prohibit the land swap. The district court granted both motions. The Secretary of the Interior appealed, arguing that the district court abused its discretion.
On appeal, the U.S. Court of Appeals for the Ninth Circuit held that the district court did not abuse its discretion. The court reasoned that the government failed to show that the district court's fact findings or legal standards were clearly erroneous, nor did it show that the district court made an error in judgment.


[Unknown Act > Conclusion]
Yes. Yes. The Supreme Court reversed the Ninth Circuit. With Justice Anthony M. Kennedy writing for the plurality, the Court held that Mr. Buono has standing to maintain this action. Justice Kennedy reasoned that when a party obtains a judgment in its favor, like Mr. Buono, it acquires a "judicially cognizable" interest in ensuring compliance with that judgment. The plurality also held that the district court erred in preventing the government from implementing the land-transfer statute in order to protect Mr. Buono's rights. A court may not order an injunction when it fails to consider all the circumstances bearing on the need for preventive relief. The district court failed to consider the context in which the land-transfer statute was enacted. Justice Kennedy concluded that upon remand the court should conduct a proper inquiry into the continued need for preventive relief in light of the statute.
Justice Samuel A. Alito wrote separately, concurring in part and concurring in the judgment. The district court should not reach the issue whether the implementation of the land-transfer statute would violate the district court's injunction or the Establishment Clause of the First Amendment. Justice Antonin G. Scalia, joined by Justice Clarence Thomas, also wrote separately, concurring in the judgment. Mr. Buono lacked standing; and therefore, the Supreme Court should not have addressed the merits of his claim. Justice John Paul Stevens, joined by Justices Ruth Bader Ginsburg and Sonia Sotamayor, dissented. The district court was correct in preventing the enforcement of Congress' land-transfer statute because the statute was designed to leave the cross in place thus violating the Establishment Clause.


[Unknown Act > Facts]
Frank Spisak was convicted of murder in an Ohio state court and sentenced to death. Subsequently, he was granted partial habeas corpus relief by the U.S. Court of Appeals for the Sixth Circuit. The court held that Mr. Spisak received ineffective counsel at sentencing and the jury instructions at this phase unconstitutionally required the jury to be unanimous when finding mitigating evidence to his sentence. The court ordered a new sentencing trial. The Supreme Court granted certiorari, vacated the judgment, and remanded the case for reconsideration in light of Musladin and Landrigan.
On remand, the Sixth Circuit reinstated its original holding. It reasoned that Musladin and Landrigan were readily distinguishable from Mr. Spisak's case and therefore he was still entitled to habeas corpus relief. Moreover, the court noted that although the Supreme Court had not ruled on a set of facts identical to those in Mr. Spisak's case, the court of appeals was not precluded from finding that the Ohio state court had unreasonably applied federal law.


[Unknown Act > Conclusion]
Yes. Yes. With Justice Stephen G. Breyer writing for the majority and joined by Chief Justice John G. Roberts, and Justices Antonin G. Scalia, Anthony M. Kennedy, Clarence Thomas, Ruth Bader Ginsburg, Samuel A. Alito, and Sonia Sotamayor, and Justice John Paul Stevens in part, the Supreme Court reversed the Sixth Circuit. The Court held that the jury instructions in Mr. Spisak's trial were not "contrary to" and did not "involve[] an unreasonable application of, clearly established Federal law." The Court further held that even though Mr. Spisak's counsel's closing argument was inadequate, it reasoned that there was no "reasonable probability" that a better closing argument would have made a significant difference in Mr. Spisak's sentence.
Justice John Paul Stevens wrote a separate opinion, concurring in part and concurring in the judgment. He argued that the Sixth Circuit correctly concluded that errors occurred during Mr. Spisak's trial that violated clearly established federal law. However, Justice Stevens agreed that those errors did not entitle Mr. Spisak to relief as his own conduct "alienated and ostracized the jury" and "his crimes were monstrous."


[Unknown Act > Facts]
A Kansas federal bankruptcy court denied objections to a Chapter 13 debtor's repayment plan. The Bankruptcy Appellate Panel of the Tenth Circuit affirmed the lower court's decision. On appeal, the U.S. Court of Appeals for the Tenth Circuit affirmed, holding that the starting point for calculating a Chapter 13 debtor's "projected disposable income" is presumed to be the debtor's current monthly income. However, the court stated that the calculation is subject to a showing that there is a substantial change in circumstances. The court remanded the case to the bankruptcy court to determine whether the debtor had shown there was a substantial change in her circumstances.


[Unknown Act > Conclusion]
Yes. The Supreme Court affirmed the Tenth Circuit, holding that a bankruptcy court may account for changes in the debtor's income or expenses that are "known or virtually certain" at the time of confirmation when it calculates a debtor's projected disposable income. With Justice Samuel A. Alito writing for the majority, the Court reasoned that the plain meaning of "projected disposable income" within the statute supports the Court's holding.
Justice Antonin Scalia dissented. He disagreed with the majority's interpretation of the term "projected." He maintained that the term did allow for a bankruptcy court to depart from the "inflexible formula" provided by the statute.


[Unknown Act > Facts]
Jose Padilla was indicted by a Kentucky grand jury on counts of trafficking in marijuana, possession of marijuana, possession of drug paraphernalia, and operating a tractor/trailer without a weight and distance tax number. On advice from his lawyer, he entered a guilty plea with respect to the three drug charges in exchange for dismissal on the final charge. He subsequently filed for post-conviction relief arguing that he was misadvised about the potential for deportation as a consequence of his guilty plea. The Kentucky Court of Appeals reversed Mr. Padilla's conviction and remanded the case for an evidentiary hearing.
On appeal to the Kentucky Supreme Court, the court, relying on its decision in Commonwealth v. Fuartado, reversed the court of appeals. It held that collateral consequences of advice by counsel is outside the scope of the guarantee of the Sixth Amendment's right to counsel. It reasoned that counsel's advice on the consequences of a plea with respect to immigration is not required and therefore cannot constitute ineffectiveness.


[Unknown Act > Conclusion]
No. Not answered. The Supreme Court held that counsel must inform a client whether his plea carries a risk of deportation. With Justice John Paul Stevens writing for the majority, the Court reasoned that counsel's advice with respect to deportation is not categorically removed from the scope of the Sixth Amendment. Here, Mr. Padilla's Sixth Amendment right to counsel was violated because counsel could have easily determined that a guilty plea would make Mr. Padilla eligible for deportation. The Court did not address whether Mr. Padilla was prejudiced by his counsel's deficiency and entitled to relief. The Court then remanded the case to the Supreme Court of Kentucky for proceedings consistent with the opinion.
Justice Samuel A. Alito, joined by Chief Justice John G. Roberts, wrote separately, concurring. He criticized the Court for adopting a halfway standard where defense counsel must advise a client on immigration law when it is "succinct and straightforward" but not necessarily in other situations. He predicted that this instruction would lead to confusion and needless litigation. Justice Antonin Scalia, joined by Justice Clarence Thomas, also wrote separately, dissenting. He criticized the majority for expanding the text of the Sixth Amendment beyond merely providing the defendant counsel to providing him "sound advice about the collateral consequences of conviction." He mused that the Constitution is not an "all-purpose tool" to create a perfect world.


[Unknown Act > Facts]
Plaintiffs were investors in several mutual funds managed by Harris Associates. They filed suit in an Illinois federal district court arguing Harris' fees were too high and thus violated Section 36(b) of the Investment Company Act of 1940. The district court dismissed the case.
On appeal, the U.S. Court of Appeals for the Seventh Circuit affirmed. The court held that Section 36(b) did not permit judicial regulation of mutual fund management fees. It acknowledged that management had a fiduciary duty to investors, but that did not imply judicial regulation of management's fees was appropriate. Rather, the court stated that market forces were best able to determine the appropriateness of fees.


[Unknown Act > Conclusion]
Yes. The Supreme Court held that the Seventh Circuit erred by not applying the Court's standard enunciated in Gartenberg v. Merrill Lynch Asset Management, Inc.. There, the Court held that in determining whether a claim is cognizable under Section 36(b) of the Investment Company Act requires a determination that the adviser charge a fee that is "so disproportionately large it bears no reasonable relationship to the services rendered." With Justice Samuel A. Alito writing for unanimous Court, it reasoned that the Gartenberg standard reflected the importance of determining whether a fee structure was the result of "arm's length bargaining" while also understanding that the Act provided other avenues to protect investors.
Justice Clarence Thomas wrote separately, concurring. He disagreed that the Court was simply endorsing a Gartenberg standard. Rather, he noted that the Court did not endorse a "free-ranging judicial fairness review of fees" that Gartenberg, itself, might endorse.


[Unknown Act > Facts]
Jose Angel Carachuri-Rosendo was admitted to the United States in 1993 and became a lawful permanent resident. In 2004, he pled guilty to misdemeanor possession of marijuana. One year later, he pled guilty to misdemeanor possession of Xanax, but was not tried as a recidivist. In 2006, Mr. Carachuri was notified that he was removable from the United States. He applied for removal cancellation, which was denied. The Board of Immigration Appeals affirmed the decision.
On appeal, the U.S. Court of Appeals for the Fifth Circuit affirmed, holding that Mr. Carachuri was ineligible for cancellation of removal. The court reasoned that because Mr. Carachuri's second drug conviction could have been punished as a felony under the Controlled Substances Abuse Act, had he been prosecuted in federal court, the conviction qualified as an "aggravated felony" making him ineligible for cancellation of removal.


[Unknown Act > Conclusion]
No. The Supreme Court held that a minor drug offense is not automatic grounds for deportation of a legal immigrant. Writing for the majority, Justice John Paul Stevens reasoned that "although a federal immigration court may have the power to make a recidivist finding in the first instance, it cannot, ex post, enhance the state offense of record just because facts known to it would have authorized a greater penalty under either state or federal law." Justice Antonin Scalia and Clarence Thomas each filed an opinion concurring in the judgment only.


[Unknown Act > Facts]
Joseph Kindler was convicted of first degree murder in a Pennsylvania state court and sentenced to death. He subsequently filed motions for post-conviction relief, but while the motions were pending, he escaped from prison. Pennsylvania immediately moved to dismiss the motions arguing that Mr. Kindler had waived any right to have his post-conviction motions considered because he was a fugitive. The trial court agreed and dismissed them. After recapture, Mr. Kindler moved to reinstate his post-conviction motions, which was denied. Both the Pennsylvania Superior Court and Pennsylvania Supreme Court affirmed the trial court's decision.
In 2000, Mr. Kindler filed a petition for federal habeas corpus relief in a Pennsylvania federal district court. The State of Pennsylvania argued that habeas corpus relief was unavailable to Mr. Kindler because Pennsylvania's fugitive waiver rule was an "independent and adequate" state ground that precluded federal habeas review. The district court disagreed and granted the petition. On appeal, the U.S. Court of Appeals for the Third Circuit affirmed. Relying on its decision in Doctor v. Walters, it held that Pennsylvania's fugitive waiver rule was not an independent and adequate state ground that precluded federal habeas review.


[Unknown Act > Conclusion]
Maybe. The Supreme Court vacated the decision of the Third Circuit holding that a discretionary state procedural rule can serve as an adequate ground to bar federal habeas corpus review. With Chief Justice John G. Roberts writing for the majority, the Court reasoned that to hold otherwise would pose an unnecessary dilemma for the states: "States could preserve flexibility by granting courts discretion to excuse procedural rules, but only at the cost of undermining the finality of state court judgments. Or States could preserve the finality of their judgments by withholding such discretion, but only at the cost of precluding any flexibility in applying the rules."
Justice Anthony M. Kennedy, joined by Justice Clarence Thomas, wrote a separate concurring opinion. He noted that while the Court did not have the opportunity to address the matter, "[i]n a proper case," "[i]t seems most doubtful that this Court can or should require federal courts to disregard a state procedural ground that was not in all respects explicit before the case when it was first announced, absent a showing of a purpose or pattern to evade constitutional guarantees."


[Unknown Act > Facts]
A New York federal district court convicted Glenn Marcus of violating sex trafficking and forced labor provisions of the Trafficking Victims Protection Act ("TVPA"). The TVPA was enacted after Mr. Marcus engaged in some of the behavior for which he was charged. Yet, the jury was not instructed as to the date when the TVPA was enacted in relation to Mr. Marcus' allegedly illegal behavior. On appeal, he argued that the TVPA was applied retroactively, and, thus, violated the Ex Post Facto Clause of the Constitution. The United States Court of Appeals for the Second Circuit agreed and reversed the district court. Applying a "plain-error" standard of review, the court held that Mr. Marcus was entitled to a new trial on Ex Post Facto grounds. The court reasoned that if it was possible for the jury, who had not been given instructions regarding the date of the TVPA's enactment, to convict exclusively on the defendant's pre-enactment conduct, then the conviction violates the Ex Post Facto clause.


[Unknown Act > Conclusion]
Yes. The Supreme Court reversed, holding that the Second Circuit's plain-error standard stands in conflict with the Court's own interpretation of the plain-error rule. Writing for the majority, Justice Stephen G. Breyer stated that an appellate court may, in its discretion, correct an error not raised at trial only when the appellant demonstrates that: (1) there is an error; (2) the error is clear and obvious; (3) the error affected the appellant's substantial rights; and (4) the error seriously affects the fairness, integrity, or public reputation of judicial proceedings. Here, the Second Circuit's standard conflicted with the third and fourth of these criteria.
Justice John Paul Stevens dissented. He noted that while the Second Circuit reached its decision in an unusual manner, he agreed with its conclusion. Justice Stevens thought the Second Circuit properly exercised its discretion to remedy an error by ordering a retrial.


[Unknown Act > Facts]
Four former executives of Hollinger International were convicted of mail and wire fraud under 18 U.S.C. Section 1346 by an Illinois federal district court. In part, they had paid themselves $5.5 million in fees without the knowledge of the company's audit committee or board of directors. At trial, the jury was instructed that it could find the defendants guilty if it deemed they had schemed to deprive Hollinger and its shareholders "of their intangible right to the honest services of the corporate officers, directors, or controlling shareholders of Hollinger," and if the objective of the scheme was "private gain." On appeal, the defendants explained that while their objective was "private gain," the compensation had been crafted in order to avoid paying taxes to the Canadian government. Therefore, they argued that because their "private gain" was intended to be purely at the expense of the Canadian government and not the company, their actions did not violate the intent of Section 1346.
The U.S. Court of Appeals for the Seventh Circuit disagreed and affirmed the district court. It held that the deprivation of honest services owed to an employer is not mitigated simply because the inducement was a tax benefit obtained from a third party. The court reasoned that had the defendants disclosed to Hollinger's audit committee and board of directors that the compensation was meant to bring about tax benefits, the committee and board very well may have reduced the pay-out in light of the tax benefits.


[Unknown Act > Conclusion]
Not answered. No. With Justice Ruth Bader Ginsburg writing for the majority, the Supreme Court held that based on its decision in Skilling v. United States, Section 1346 criminalizes only schemes to defraud that involve bribes or kickbacks. Therefore, the "honest services fraud" instruction given in this case was incorrect. The Court further held that Mr. Black and his co-defendants secured their right to challenge the "honest services fraud" jury instructions on appeal because they properly objected to the instructions at trial. The Court noted that it expressed no opinion as to whether the jury instruction prejudiced the defendants and left it for the district court to determine.
Justice Antonin Scalia, joined by Justice Clarence Thomas, concurred in part and concurred in the judgment. He disagreed that the Court used the Notes of the Advisory Committee in rendering its decision. He also viewed the "honest services fraud" jury instruction to be error because it was given at all. Justice Anthony M. Kennedy concurred in part and concurred in the judgment. He viewed Section 1346 as being unconstitutionally vague.


[Unknown Act > Facts]
An Alabama state court convicted Billy Joe Magwood of murder and sentenced him to death. Subsequently, an Alabama federal district court partially granted Mr. Magwood's petition for federal habeas corpus relief. The court upheld his conviction but instructed the state court to look at mitigating evidence when resentencing Mr. Magwood. Upon resentencing, the state court sentenced Mr. Magwood to death once again. Mr. Magwood filed a second petition for federal habeas corpus relief with the federal district court arguing that a judicial rule was retroactively applied in his case and that he lacked effective counsel at sentencing. The district court granted the petition and vacated Mr. Magwood's death sentence.
On appeal, the U.S. Court of Appeals for the Eleventh circuit reversed, holding that prisoners may not raise challenges to an original sentence that could have been raised in an earlier petition. The court also held that Mr. Magwood's counsel was not ineffective because he failed to raise an argument that had already been decided by the state's highest court adverse to his client's position.


[Unknown Act > Conclusion]
No. The Supreme Court held that because Mr. Magwood's habeas application challenges new judgments for the first time, it is not "second or successive" under the Antiterrorism and Effective Death Penalty Act ("AEDPA") With Justice Clarence Thomas writing for the majority, the Court determined that the text of the AEDPA counseled in favor of the Court's conclusion.
Justice Stephen G. Breyer, joined by Justices John Paul Stevens and Sonia Sotomayor, concurred in part and concurred in the judgment. He noted that the Court was not expanding its holding from Panetti v. Quarterman. Justice Anthony M. Kennedy, joined by Chief Justice John G. Roberts and Justices Ruth Bader Ginsburg and Samuel A. Alito, dissented. He argued that a straightforward application of Panetti, consistent with all of the courts of appeals to rule on the issue, would have dictated an opposite result from the Court's.


[Unknown Act > Facts]
Robert Stevens was convicted under 18 U.S.C. Section 48 in a Pennsylvania federal district court for "knowingly selling depictions of animal cruelty with the intention of placing those depictions in interstate commerce for commercial gain." His conviction stems from an investigation into the selling of videos related to illegal dog fighting. Mr. Stevens appealed his conviction arguing that 18 U.S.C. Section 48, on its face, was unconstitutional because it violated the Free Speech Clause of the First Amendment
The U.S. Court of Appeals for the Third Circuit agreed with Mr. Stevens and reversed his conviction, holding unconstitutional 18 U.S.C. Section 48. The court reasoned that the dog fighting videos he sold were protected speech and that 18 U.S.C. Section 48 did not serve a compelling governmental interest.


[Unknown Act > Conclusion]
Yes. The Supreme Court held that 18 U.S.C. § 48 is substantially overbroad, and therefore invalid under the First Amendment. With Chief Justice John G. Roberts writing for the majority, the Court reasoned that depictions of animal cruelty are not categorically unprotected by the First Amendment. The Court further reasoned that because a "substantial number" of § 48's applications are unconstitutional, the law is overbroad and, thus, invalid.
Justice Samuel A. Alito dissented. He disagreed with the majority opinion arguing that § 48 was not intended to suppress speech, but rather to "prevent horrific acts of animal cruelty." He was concerned that the majority holding will practically legalize the sale of such videos and spur the resumption of their production.


[Unknown Act > Facts]
A Massachusetts federal district court convicted Martin O'Brien and Arthur Burgess of attempted robbery and related weapons crimes. One of the weapons used by the defendants was an AK-47 assault rifle. At a pre-trial conference, the district court ruled that the nature of the weapon (i.e. semi-automatic, automatic, etc.) was an element of the crime and, thus, a matter for the jury to decide. After sentencing, the government appealed, arguing that the nature of the weapon was a sentencing element, and, thus a matter for the judge to decide. The U.S. Court of Appeals for the First Circuit affirmed, holding that under 18 U.S.C. Section 924(c) the nature of the weapon is an element of the crime that must be decided by the jury "beyond a reasonable doubt."


[Unknown Act > Conclusion]
The Supreme Court affirmed, holding that the fact that a firearm was a machinegun is an element to be proved to the jury beyond a reasonable doubt, not a sentencing factor to be proved to the judge at sentencing. With Justice Anthony M. Kennedy writing for the majority, the Court reasoned that Congress determines whether a fact is an element or a sentencing factor. But when Congress is not explicit, the courts look to a statute's provision and framework for guidance. Under this analysis, the Court determined that the fact a firearm was a machine gun is an element of the crime.
Justice John Paul Stevens wrote separately, concurring. He argued that McMillan and Harris, two cases holding that "sentencing factors" need only be proved by a preponderance of the evidence, should be overruled. Justice Clarence Thomas also wrote separately, concurring in the judgment. He agreed with the majority's conclusion, but argued that the better approach is to treat any sentencing facts that increase the mandatory minimum sentence as an "element of a separate, aggravated offense that is submitted to a jury and proved beyond a reasonable doubt."


[Unknown Act > Facts]
A Virginia federal district court remanded Bridget Hardt's claim for long-term disability benefits from Reliance Standard Life Insurance ("Reliance"). The court asked Reliance to reconsider its denial of Ms. Hardt's claim. Upon remand and after Ms. Hardt presented new evidence, Reliance changed its earlier stance and awarded Ms. Hardt full long-term disability benefits. Ms. Hardt then filed a motion for attorneys' fees based on her status as a prevailing party. The district court granted her motion and awarded her $39,149 in fees.
On appeal, Reliance argued that Ms. Hardt was not a "prevailing party" as understood by the Employee Retirement Income Security Act and thus was not eligible for an award of attorneys' fees. The U.S. Court of Appeals for the Fourth Circuit agreed and reversed the district court. The court held that the district court's decision to remand Ms. Hardt's claim to Reliance did not constitute an enforceable judgment that Ms. Hardt prevailed on her claim because Reliance could have decided to deny her coverage.


[Unknown Act > Conclusion]
Yes. Yes. The Supreme Court reversed, holding that a fee claimant need not be a "prevailing party" to be eligible for an attorney's fees award. With Justice Clarence Thomas writing for the majority, the Court reasoned that because Congress failed to include an express "prevailing party" requirement, to say otherwise would more closely resemble "inventing a statute rather than interpreting one." The Supreme Court also held that a court may award fees and costs under the statute so long as the fee claimant has achieved "some degree of success on the merits." Here, Ms. Hardt met this standard even though she failed to win summary judgment on her benefits claim. The Court reasoned that the district court found compelling evidence that she was totally disabled and obtained the remand of her case after which Reliance awarded her benefits.
Justice John Paul Stevens wrote separately, concurring in part and concurring in the judgment. He cautioned that in the future the Court should examine the text, structure, and history of any other federal statute authorizing an award of fees before concluding that Congress intended the same approach as in this case.


[Unknown Act > Facts]
In 2006, Norman Carpenter, a Shift Supervisor at a Mohawk Industry manufacturing facility, was fired after violating Mohawk's Code of Ethics. He subsequently filed suit for wrongful termination in a Georgia federal district court. He argued that he was fired, not for violating company protocols, but for reporting immigration violations to Mohawk's human resources department. Mr. Carpenter stated that after filing his report, a Mohawk company attorney met with him and attempted to persuade him to recant. The report would have been detrimental to Mohawk as it was then involved in a class action lawsuit which charged the company with conspiring to hire illegal immigrants.
Before trial and as part of discovery, Mr. Carpenter requested information from Mohawk related to his meeting with its attorney. Mohawk contended that the information was protected by the attorney-client privilege. The federal district court ordered Mohawk to disclose the information, but permitted the company to appeal. On appeal, the U.S. Court of Appeals for the Eleventh Circuit held that it lacked jurisdiction to review the order for discovery. It reasoned that while the Supreme Court's decision in Cohen v. Beneficial Industrial Loan Corp. provided an exception to the finality requirement necessary for an appellate court to have jurisdiction over appeals, the appeal of a discovery order involving attorney-client privilege did not qualify for exception.


[Unknown Act > Conclusion]
No. The Supreme Court held that disclosure orders that are adverse to the attorney-client privilege do not qualify for immediate appeal under the collateral order doctrine. With Justice Sonia Sotamayor writing for the majority and joined by Chief Justice John G. Roberts, John Paul Stevens, Antonin G. Scalia, Anthony M. Kennedy, Ruth Bader Ginsburg, Stephen G. Breyer, and Samuel A. Alito, the Court reasoned that postjudgment appeals, "together with other review mechanisms," suffice to protect the rights of litigants.
Justice Clarence Thomas filed a separate opinion, concurring in part and concurring in the judgment. He argued that the Eleventh Circuit should have been affirmed on the ground that any "avenue for immediate appeal" should be left to the "rulemaking process." Instead, the Court "subordinated what the appellate jurisdiction statute says to what the Court thinks is a good idea."


[Unknown Act > Facts]
In 1994, Holly Wood was convicted in an Alabama state court of capital murder during a first-degree burglary and sentenced to death. Both the Alabama Court of Criminal Appeals and the Alabama Supreme Court affirmed the conviction and sentence. Mr. Wood subsequently filed for post-conviction relief under Alabama Rule of Criminal Procedure 32, arguing that he was mentally retarded and thus not eligible for a death sentence and that his trial counsel was ineffective. The Rule 32 court disagreed and denied his petition. Mr. Wood then filed for federal habeas corpus relief in an Alabama federal district court. The district court granted relief, agreeing that Mr. Wood's counsel was ineffective at sentencing because they failed to present evidence of Mr. Wood's deficient intellectual deficiencies.
On appeal, the U.S. Court of Appeals for the Eleventh Circuit reversed. It held that Mr. Wood's counsel was not ineffective. The court reasoned that Mr. Wood's attorneys acted reasonably when they decided it was in Mr. Wood's best interest to leave out information that illustrated his mental deficiencies. Moreover, the court recognized that while Mr. Wood's counsel included an inexperienced attorney, he merely acted as an assistant to the two experienced attorneys chiefly responsible for the case.


[Unknown Act > Conclusion]
No. Not answered. The Supreme Court held that the state court's conclusion that counsel made a strategic decision not to pursue or present evidence of Mr. Wood's mental deficiencies was not an unreasonable determination under the facts. With Justice Sonia Sotamayor writing for the majority and joined by Chief Justice John G. Roberts and Justices Antonin G. Scalia, Clarence Thomas, Stephen G. Breyer, and Samuel A. Alito, the Court reasoned that the state court's conclusion was not unreasonable merely because a federal habeas court would have reached a different conclusion. Moreover, the evidence in the record indicated that counsel's failure to pursue or present evidence of the defendant's mental deficiencies was the result of a deliberate decision to focus on other defenses.
Justice John Paul Stevens, joined by Justice Anthony M. Kennedy, wrote a separate dissenting opinion. Justice Stevens noted that the majority failed to distinguish between a decision not to introduce evidence at the guilt phase of trial and a failure to investigate mitigating evidence at the penalty phase. He argued that, contrary to the majority's conclusion, the evidence indicated that the decision of Mr. Wood's counsel was the result of "inattention and neglect," rather than strategy.


[Unknown Act > Facts]
Michael Barber petitioned for habeas corpus relief in a federal district court. Mr. Barber argued that the Bureau of Prisons (BOP) inaccurately calculated his good time credit toward the service of his federal sentence. The good time credit statute provides that a prisoner "may receive credit toward the service of his sentence... of up to 54 days at the end of each year of the prisoner's term." Mr. Barber argued that the BOP should calculate good time credit based on the sentence imposed rather than the time an inmate has actually served in prison. The district court denied his petition.
On appeal, the U.S. Court of Appeals for the Ninth Circuit affirmed, citing its decision in Tablada v. Daniels as controlling. There, the court held upheld the BOP's method for calculating good time credit. The court had reasoned that the good time credit statute was ambiguous and the BOP's interpretation of the statute was reasonable.


[Unknown Act > Conclusion]
Yes. Not answered. The Supreme Court affirmed the Ninth Circuit, holding that the BOP's method for calculating good time credit was lawful. With Justice Stephen G. Breyer writing for the majority, the Court reasoned that the statute's language and purpose supported the BOP's construction of the statute.
Justice Anthony M. Kennedy, joined by Justices John Paul Stevens and Ruth Bader Ginsburg, dissented. He disagreed with the majority's interpretation of the statute, arguing that it would impose "tens of thousands of years of additional prison time on federal prisoners according to a mathematical formula they will be unable to understand."


[Unknown Act > Facts]
In 2007, Wanda Krupski booked a trip with Costa Cruise Lines. On February 21 while on the trip, Ms. Krupski allegedly tripped over a loose cable and broker her femur. She filed suit in a Florida federal district court against Costa Cruise Lines. One year and four days after her alleged injury, Costa Cruise Lines informed Ms. Krupski that it was merely the North American sales and booking agent for the carrier, Costa Crociere. The district court allowed Ms. Krupski to amend her complaint to include Costa Crociere and dismissed the action against Costa Cruise Lines. Costa Crociere then moved for summary judgment arguing the ticket sold to Ms. Krupski stipulated that suits must be filed against it within one year of the alleged injury. Therefore, Ms. Krupski was out of time. The district court agreed and granted Costa Crociere's motion for summary judgment.
On appeal, Ms. Krupski argued that her amended complaint against Costa Crociere related back to her original filing and thus should be considered timely filed against Costa Crociere. The U.S. Court of Appeals for the Eleventh Circuit disagreed and affirmed the district court. The court held that her amended complaint did not relate back to her original complaint. The court reasoned that Ms. Krupski was aware that Costa Crociere was the carrier all along. Thus, to relate her amended complaint back to the original complaint was not the sort of mistaken identity correction contemplated by Federal Rule of Civil Procedure15(c)(1)(C).


[Unknown Act > Conclusion]
Yes. The Supreme Court reversed the Eleventh Circuit, holding that relating back under Rule 15(c)(1)(C) depends on what the party to be added knew or should have known, not on the amending party's knowledge or timeliness in seeking to amend the pleading. With Justice Sonia Sotamayor writing for the majority, the Court reasoned that the text of Rule 15 asks what the prospective defendant "knew or should have known", not what the plaintiff "knew or should have known" as determined by the Eleventh Circuit. Here, the Court further reasoned that Cost Crociere should have known that Ms. Krupski's failure to name it as a defendant was due to a mistake concerning the proper party's identity. Thus, Ms. Krupski should be allowed to add Costa Crociere in her complaint.
Justice Antonin Scalia wrote separately, concurring in part and concurring in the judgment. He noted that he did not support the majority's use of the Notes of the Advisory Committee to the Federal Rules of Civil Procedure in reaching its decision.


[Unknown Act > Facts]
When Joe Sullivan was 13 years old, he was convicted of sexual battery by a Florida state court and sentenced to life in prison without parole. On appeal to the District Court of Appeal of Florida, Mr. Sullivan argued that his sentence was cruel and unusual and thus violated both the Eighth and Fourteenth Amendments. The court of appeals affirmed Mr. Sullivan's sentence without comment.


[Unknown Act > Conclusion]
The writ of certiorari was dismissed as improvidently granted.


[Unknown Act > Facts]
Shippers sued the ocean carrier and rail carrier it used to ship products from China to the United States in a California state court to recover for damages. During the transport of the shippers' products, a train derailed damaging the products. The case was removed to a California federal district court only to be dismissed. The district court held that the contracts between the parties did not cover claims for cargo damage.
On appeal, the U.S. Court of Appeals for the Ninth Circuit held that the district court erred in its analysis. The court reasoned that the Carriage of Goods by Sea Act ("COGSA") does not govern the inland transport of goods, unless the parties opted out of coverage by the Carmack Amendment to Interstate Commerce Act. The Carmack Amendment governs damage claims against motor and rail carriers, and narrowly limits the venues in which such suits can be brought. Because the district court did not consider whether the parties opted out of the COGSA by the Carmack Amendment, the Ninth Circuit remanded the case for that determination.


[Unknown Act > Conclusion]
No. The Supreme Court held that because the Carmack Amendment does not apply to a shipment originating overseas under a single through bill of lading, the parties' agreement to litigate these cases in Tokyo, Japan is binding. With Anthony M. Kennedy writing for the majority, the Court reasoned that, as illustrated in Norfolk Southern R. Co. v. James N. Kirby, when a a bill of lading requires "substantial carriage of goods by sea," like in this case, "its purpose is to effectuate maritime commerce." Under such circumstances, applying state law undermines maritime law. Therefore, the Carmack Amendment is inapplicable to this case.
Justice Sonia Sotomayor, joined by Justices John Paul Stevens and Ruth Bader Ginsburg, dissented. She argued that the Carmack Amendment applies to circumstances like at issue in this case unless the parties have contracted around Carmack's requirements. Here, she viewed the Carmack Amendment as providing the default legal regime for rail transportation in the United States and, consequently, would have reached the issue as to whether Union Pacific, one of the paties, was free to opt out of Carmack.


[Unknown Act > Facts]
The City of New York sued several out-of-state cigarette vendors under the Racketeer Influenced and Corrupt Organizations Act (RICO) for failing to report sales made to individuals over the Internet as required by the federal Jenkins Act. The State of New York and City of New York rely on this information to collect taxes imposed on cigarettes sold in the state and city. The U.S. District Court for the Southern District of New York dismissed the City of New York's suit, holding that its claim did not meet the "causation" requirements set forth under RICO. On appeal, the U.S. Court of Appeals for the Second Circuit reversed, holding that the City of New York met the RICO "causation" requirements and thus maintained a cause of action. The court reasoned that the defendants' conduct prevented the City from collecting taxes and thus directly injured it. Moreover, the court reasoned that the loss of taxes injured the City's "business or property."


[Unknown Act > Conclusion]
No. The Supreme Court reversed the Second Circuit holding that because the City of New York cannot show that it lost revenue "by reason of" the alleged RICO violation, it cannot state a RICO claim. With Chief Justice John G. Roberts writing for the majority and joined by Justices Antonin G. Scalia, Clarence Thomas, and Samuel A. Alito, and Justice Ruth Bader Ginsburg in part, the Court reasoned that to establish that an injury came about "by reason of" a RICO violation, a plaintiff must show both, "but for" and "proximate" causation. Here, the Court concluded that the City's causal theory was even more remote than in cases where the Court had failed to find proximate cause.
Justice Ruth Bader Ginsburg wrote a separate opinion, concurring in part and concurring in the judgment. She criticized the City for attempting to bring a claim for fraud that arose under violations of the Jenkins Act, but failed to actually bring a claim for violations under the Jenkins Act. Justice Stephen G. Breyer, joined by Justices John Paul Stevens and Anthony M. Kennedy, wrote a separate dissenting opinion. In contrast to the majority, he argued that Hemi Group's failure to provide New York State with the names and addresses of its New York City cigarette customers proximately caused New York City to lose tobacco tax revenue.


[Unknown Act > Facts]
These cases involve malpractice suits against Public Health Service ("PHS") employees. The plaintiffs filed actions recognized by Bivens v. Six Unknown Named Agents of the Federal Bureau of Narcotics in a California federal district court alleging violations of the Fifth and Eighth Amendments. The PHS sought a dismissal arguing that the Federal Tort Claims Act (FTCA) preempted Bivens claims. The district court rejected the argument and denied the motion to dismiss.
On appeal, the Ninth Circuit affirmed, holding that FTCA did not preempt Bivens claims. The court reasoned that the FTCA was enacted six months prior to the Supreme Court's decision in Bivens and, thus, could not have been intended as a substitute.


[Unknown Act > Conclusion]
Yes. The Supreme Court held that the immunity provided by the FTCA precludes Bivens actions against individual PHS officers or employees for harms arising out of constitutional violations committed while acting within the scope of their offices or employment. Justice Sonia Sotamayor, writing for a unanimous Court, reasoned that 42 U.S.C. § 233(a) plainly and clearly provides that the FTCA is the "exclusive" avenue for claims like those at issue in this case.


[Unknown Act > Facts]
Shady Grove Orthopedics Associates (Shady Grove), on behalf of a class of plaintiffs, sued Allstate Insurance Company (Allstate) in part for Allstate's alleged failure to pay interest penalties on overdue insurance payments as prescribed by New York statute. Allstate moved to dismiss relying on New York's rules of civil procedure which instruct that class action lawsuits are inappropriate unless specifically prescribed by statute. The U.S. District Court for the Eastern District of New York agreed that Shady Grove's class action claim was not authorized and thus dismissed its claim.
On appeal, Shady Grove argued that the New York rules of civil procedure conflict with Rule 23 of the Federal Rules of Civil Procedure and thus were not applicable. The U.S. Court of Appeals for the Second Circuit disagreed with Shady Grove and affirmed the district court. The Second Circuit, reasoning from the Supreme Court's decision in Erie Railroad Co. v. Tomkins, stated that the New York rules of civil procedure did not conflict with Rule 23 and thus Rule 23 did not control.


[Unknown Act > Conclusion]
No. No. The Supreme Court held that §901(b) of the New York rules of civil procedure does not preclude a federal court sitting in diversity from entertaining a class action under Rule 23 of the federal rules of civil procedure. With Justice Antonin Scalia writing for the majority as to Parts I and II-A, the Court stated that if Rule 23 answers the question in dispute, it governs, unless it exceeds its statutory authorization or Congress' rulemaking power. Here, the Court reasoned that Rule 23 answers the question in dispute – whether Shady Grove's suit may proceed as a class action – and is therefore controlling. With Justice Scalia writing for a plurality as to Parts II-B and II-D, he stated that the Rules Enabling Act, not Erie controls the validity of a federal rule of civil procedure, even if that results in opening the federal courts to class actions that cannot proceed in state court. With Justice Scalia writing for a distinct plurality as to Part II-C, he concluded that the concurrence's analysis conflicted with the Court's precedent in Sibbach – that the federal rules "really regulate procedure."
Justice John Paul Stevens wrote separately, concurring. He agreed that Rule 23 applies in this case, but also recognized that in some cases federal courts should apply state procedural rules in diversity cases because they function as part of the state's definition of substantive rights and remedies. Justice Ruth Bader Ginsburg, joined by Justices Anthony M. Kennedy, Stephen G. Breyer, and Samuel A. Alito, dissented. She criticized the majority opinion for using Rule 23 to override New York's statutory restriction on the availability of damages and consequently turning a $500 case into a $5,000,000 one. She cautioned that it is important to interpret the federal rules with sensitivity to state regulatory policies.


[Unknown Act > Facts]
Brian Russell Dolan pleaded guilty to assault resulting in bodily harm in the New Mexico federal district court. He was sentenced to twenty-one months in prison and ordered to pay the victim $250 per month in restitution. Mr. Dolan appealed arguing that because the district court failed to award restitution within ninety days of Mr. Dolan's sentencing, the district court lacked the authority to do so.
The U.S. Court of Appeals for the Ninth Circuit affirmed the district court. The court held that the time limits established by the Mandatory Victims Restitution Act are not jurisdictional and, thus, the district court's tardiness in entering the order does not relieve the defendant of his obligation to pay.


[Unknown Act > Conclusion]
Yes. The Supreme Court held that a court, which has missed the 90-day deadline still has the power to order restitution, at least under certain circumstances. The majority held that the consequences of missing a statutory deadline where the statute is silent on the subject depends on the statutory language and the relevant context and what they reveal about the purpose of the deadline. Some deadlines are "jurisdictional," so that their expiration deprives a court of the authority to take the action to which the deadline attaches. Others are "claims-processing rules" that regulate the timing of motions or claims brought before the court; these deadlines are waived unless the opposing party brings them to the court's attention. Still others simply seek speedy disposition of matters by "creating a time-related directive that is legally enforceable but does not deprive a judge . . . of the power to take the action" if the deadline is missed. Chief Justice John G. Roberts, Jr. dissented, joined by Justices John Paul Stevens, Antonin Scalia and Anthony Kennedy.


[Unknown Act > Facts]
Current and former employees of Xerox Corp. sued the company in a New York federal district court under the Employee Retirement Income Security Act ("ERISA"). Plaintiffs had left the employer, been paid a lump sum, and after rehire had alleged Xerox improperly calculated their benefits. Xerox argued that release forms signed by some of the plaintiffs barred their ERISA claims. The district court disagreed and then crafted a remedy to compensate the plaintiffs for their lost benefits.
On appeal, the U.S. Court of Appeals for the Second Circuit held that the district court crafted an appropriate remedy, but erred in finding that the release forms signed by some plaintiffs were unenforceable. Rather, the court reasoned that the release forms were signed knowingly and voluntarily, making them enforceable.


[Unknown Act > Conclusion]
Yes. The Supreme Court held that the district court should have applied a deferential standard of review to the Plan Administrator's interpretation of the pension plan. With Chief Justice John G. Roberts writing for the majority, the Court reasoned that its decision in Firestone Tire & Rubber Co. v. Bruch established that when a trust instrument, like the pension plan, gives the trustee the "power to construe disputed or doubtful terms," the trustee's interpretation will not be disturbed "if reasonable." Here, the Second Circuit carved out an exception to the rule holding that a court need not apply a deferential standard when the trustee's previous construction of the same terms was found to violate ERISA. The Second Circuit erred in doing so.
Justice Stephen G. Breyer, joined by Justices John Paul Stephens and Ruth Bader Ginsburg, dissented. He noted several mistakes made by Xerox, the district court, and the majority of the Court. With respect to the majority opinion, Justice Breyer disagreed that trust law imposes no such inflexible requirement that a court give deference to a plan administrator, as the majority held in this case.