[Unknown Act > Facts]
Brad Hanson worked as State Office Manager for U.S. Senator Mark Dayton. Shortly after Hanson took medical leave for a heart problem, Dayton fired him. Hanson sued under the Congressional Accountability Act of 1995, claiming that Dayton had discriminated against him based on a perceived disability. Dayton filed a motion to have the case dismissed for lack of jurisdiction. He argued that he was immunized from the suit by the Speech or Debate Clause of the Constitution ("for any Speech or Debate in either House, [Senators and Representatives] shall not be questioned in any other Place.") Dayton claimed that because Hanson's duties were directly related to Dayton's legislative functions, the decision to fire him could not be challenged. The District Court denied the motion.
Overturning its own precedent, the U.S. Court of Appeals for the District of Columbia Circuit affirmed the lower court's decision that the Speech or Debate Clause does not bar the suit. The clause can be invoked to exclude evidence that would involve legislative acts, but the D.C. Circuit ruled that it is not a blanket ban on suits involving legislative employees. The employee would simply have to make his case without questioning legislative acts or motivations for legislative acts. Senator Dayton appealed directly to the Supreme Court, arguing that the Accountability Act requires the Court to hear the appeal. He also argued that Hanson's suit should be dismissed because the case had become moot after Dayton retired from the Senate.


[Unknown Act > Conclusion]
Unanswered, no, and unanswered. The Court ruled that it had no jurisdiction to hear Senator Dayton's appeal and dismissed the case without reaching the merits. Justice John Paul Stevens wrote the opinion for the 8-0 Court. The Congressional Accountability Act of 1995 only authorizes direct Supreme Court appeal of rulings "upon the constitutionality" of the statute. The Justices held that the decisions of the lower courts (holding that Hanson's suit should not be dismissed under the Speech or Debate Clause) did not qualify as rulings on the constitutional validity of the Act. They were better characterized as rulings on the Act's scope. Direct appeal was therefore not authorized by the Act, and the Court declined to grant certiorari.


[Unknown Act > Facts]
At a school-supervised event, Joseph Frederick held up a banner with the message "Bong Hits 4 Jesus," a slang reference to marijuana smoking. Principal Deborah Morse took away the banner and suspended Frederick for ten days. She justified her actions by citing the school's policy against the display of material that promotes the use of illegal drugs. Frederick sued under 42 U.S.C. 1983, the federal civil rights statute, alleging a violation of his First Amendment right to freedom of speech. The District Court found no constitutional violation and ruled in favor of Morse. The court held that even if there were a violation, the principal had qualified immunity from lawsuit. The U.S. Court of Appeals for the Ninth Circuit reversed. The Ninth Circuit cited Tinker v. Des Moines Independent Community School District , which extended First Amendment protection to student speech except where the speech would cause a disturbance. Because Frederick was punished for his message rather than for any disturbance, the Circuit Court ruled, the punishment was unconstitutional. Furthermore, the principal had no qualified immunity, because any reasonable principal would have known that Morse's actions were unlawful.


[Unknown Act > Conclusion]
Yes and not reached. The Court reversed the Ninth Circuit by a 5-4 vote, ruling that school officials can prohibit students from displaying messages that promote illegal drug use. Chief Justice John Roberts's majority opinion held that although students do have some right to political speech even while in school, this right does not extend to pro-drug messages that may undermine the school's important mission to discourage drug use. The majority held that Frederick's message, though "cryptic," was reasonably interpreted as promoting marijuana use - equivalent to "[Take] bong hits" or "bong hits [are a good thing]." In ruling for Morse, the Court affirmed that the speech rights of public school students are not as extensive as those adults normally enjoy, and that the highly protective standard set by Tinker would not always be applied. In concurring opinions, Justice Thomas expressed his view that the right to free speech does not apply to students and his wish to see Tinker overturned altogether, while Justice Alito stressed that the decision applied only to pro-drug messages and not to broader political speech. The dissent conceded that the principal should have had immunity from the lawsuit, but argued that the majority opinion was "[...] deaf to the constitutional imperative to permit unfettered debate, even among high-school students [...]."


[Unknown Act > Facts]
In 2003, Congress passed and the President signed the Partial-Birth Abortion Ban Act. The controversial concept of partial-birth abortion is defined in the Act as any abortion in which the death of the fetus occurs when "the entire fetal head [...] or [...] any part of the fetal trunk past the navel is outside the body of the mother."
Planned Parenthood sued the Attorney General of the United States, arguing that the Act was unconstitutional under the right to an abortion protected by the substantive component of the Due Process Clause of the Fifth Amendment, as interpreted by the Supreme Court in Roe v. Wade and subsequent cases. The District Court agreed and stopped the Act from going into effect.
On appeal, the U.S. Court of Appeals for the Ninth Circuit affirmed. Though the government claimed that the Act banned only a narrow, rare category of abortions, the Circuit Court ruled that the Act applied to the common abortion procedure known as "D&E" ("dilation and evacuation"), as well as to the far less common "intact D&E," sometimes called "D&X" ("dilation and extraction"). This made the ban expansive enough to qualify as an unconstitutional "undue burden" on the right to abortion, as defined in Planned Parenthood v. Casey.
The Ninth Circuit also ruled that the Act's lack of an exception for abortions necessary to protect the health of the mother rendered it unconstitutional. Congress had included in the Act a finding that partial-birth abortions were never medically necessary, but the Ninth Circuit held that the Supreme Court's decision in Stenberg v. Carhart required the health exception in all cases where medical opinion on the necessity an abortion procedure is divided.
Finally, the Circuit Court ruled that the Act was unconstitutionally vague, because the inclusion of ambiguous statutory terms such as "partial-birth abortion" would prevent physicians from knowing which methods of abortion were covered. The Circuit Court determined that the proper course of action was to block enforcement of the entire Act.


[Unknown Act > Conclusion]
No. The Court ruled by a 5-4 vote that Congress's ban on partial-birth abortion was not unconstitutionally vague and did not impose an undue burden on the right to an abortion. Justice Anthony Kennedy wrote the opinion for the majority. The Court held that, under the most reasonable interpretation, the Act applies only to the intact D&E method (also known as "partial-birth abortion") and not to the more common D&E procedure. The Act's application was limited by provisions that restrict enforcement to cases where the physician intends to perform an intact D&E and delivers the still-living fetus past specific "anatomical landmarks." Because the majority found that the Act applies only to a specific method of abortion, it held that the ban was not unconstitutionally vague, overbroad, or an undue burden on the decision to obtain an abortion. The Court also held that Congress, after finding intact D&E never to be medically necessary, could validly omit a health exception from the ban, even when "some part of the medical community" considers the procedure necessary. To require the exception whenever "medical uncertainty" exists would be "too exacting a standard to impose on the legislative power [...] to regulate the medical profession." The Court left open the possibility that an as-applied challenge could be brought against the Act if it were ever applied in a situation in which an intact D&E was necessary to preserve a woman's health. Justice Ginsburg's dissent disputed the majority's claim that the opinion was consistent with the Casey and Stenberg precedents and said "The Court's hostility to the right Roe and Casey secured is not concealed."


[Unknown Act > Facts]
In the Telecommunications Act of 1996, Congress declared that payphone service providers (PSPs) must be compensated for every completed call using their payphones. Previously, PSPs were not compensated for coinless "dial-around" long-distance calls in which the caller pays a long distance carrier rather than the PSP. The Federal Communications Commission (FCC) adopted rules requiring the carriers to pay the PSPs on a per-call basis. Metrophones Telecommunications, a PSP, sued Global Crossing Telecommunications, a long-distance carrier, alleging that Global Crossing had failed to pay for calls placed from Metrophones's payphones.
The District Court dismissed Metrophones's first complaint because the Telecommunications Act of 1996 did not create a private right of action to recover compensation from long-distance carriers. Metrophones then filed an amended complaint based on Section 201(b) of the Communications Act of 1934, which deals with "unjust and unreasonable" practices of carriers. Global Communications argued that Metrophones had no right to sue under this statute either, but the District Court disagreed and ruled for Metrophones.
The Ninth Circuit Court of Appeals affirmed this decision. The Circuit Court relied heavily on the FCC's interpretation of the statute, which was that failure to pay compensation to PSPs is an "unjust and unreasonable" practice in violation of Section 201(b) and that PSPs have a private right of action to sue carriers for such violations. The Circuit Court held that though the FCC rule on the subject was brief, it was entitled to deference from the courts in the absence of specific guidance from the statute.


[Unknown Act > Conclusion]
Yes. The Court ruled 7-2 that Section 201(b) allows PSPs to sue long distance carriers for "unjust and unreasonable practices." The opinion by Justice Stephen Breyer held that the FCC's regulation on the subject was reasonable and therefore entitled to deference. Justice Breyer wrote that "The [FCC's] determination easily fits within the language of the statutory phrase." "[I]n ordinary English," a carrier's refusal to pay compensation for a benefit received from payphone service providers can be said to be an unreasonable practice, the Court ruled. The majority also emphasized the similarities between the FCC's payphone regulation and traditional regulations of transportation communications.


[Unknown Act > Facts]
During Chapter 11 liquidation proceedings, Crown Vantage, Inc. (Crown) terminated its employee pension plan and purchased an annuity for the employee participants as a replacement. The participants advocated merging the current plan into a multiemployer PACE International Union (PACE) pension plan but Crown did not investigate the possibility. The participants alleged that Crown breached its fiduciary duties under the Employee Retirement Income Security Act of 1974 (ERISA) by not acting "solely in the interests of the participants" (Section 1104(a)(1)). A bankruptcy court ordered Crown to maintain the plan's funds until they were distributed to the participants.
A District Court affirmed, finding that Crown failed to consider its employees' interest. Crown appealed to the U.S. Court of Appeals for the Ninth Circuit, claiming that it did not consider the PACE plan because Section 4041 of ERISA prevents termination by way of a merger into a multiemployer plan. The Ninth Circuit affirmed the District Court, ruling that ERISA does allow termination by way of a merger into a multiemployer plan.


[Unknown Act > Conclusion]
No. In a unanimous opinion authored by Justice Antonin Scalia, the Court held that "merger is not a permissible method of terminating a single-employer defined-benefit pension plan." Therefore, PACE's argument that Crown was required by ERISA to consider merger as a method of terminating the pension plan was rejected. Since ERISA does not expressly list merger as a method of termination, the Court relied on the view of the Pension Benefit Guaranty Corporation (PBGC) that merger is not covered under the statute's residual clause. This interpretation was supported by the structure of ERISA, which deals with mergers in a separate section.


[Unknown Act > Facts]
A Washington State jury sentenced Cal Brown to death for murder. Brown protested that unfair jury selection had guaranteed a "verdict of death." One potential juror who expressed willingness to impose the death penalty only in "severe situations" was dismissed by the judge for cause. The Washington Supreme Court upheld the dismissal.
Brown appealed first to a federal district court and then to the U.S. Court of Appeals for the Ninth Circuit, which ruled that the dismissed juror was not "substantially impaired" in his ability to follow the law. Supreme Court precedent required that jurors only be dismissed if their personal views prevent them from performing their duties. The prosecution unsuccessfully petitioned for the Ninth Circuit to rehear the case en banc on the ground that the Anti-Terrorism and Effective Death Penalty Act required appeals courts to give deference to trial judges' evaluations of jurors.


[Unknown Act > Conclusion]
Yes. The Court reversed the Ninth Circuit and ruled that appellate courts "owe deference to the trial court, which is in a superior position to determine the demeanor and qualifications of a potential juror." Justice Anthony Kennedy wrote the opinion for the 5-4 majority. The substance of the potential juror's comments had indicated confusion over the proper application of Washington's death penalty law, so the trial court had acted reasonably when it found the juror substantially impaired and excused him. The Court held that the trial judge was especially entitled to deference because the trial judge, unlike appellate judges, has access to contextual information that is not reflected in the transcript of the jury selection questioning. The Court also considered it significant that, although the defense counsel vigorously objected to other juror dismissals, he originally made no objection to the dismissal of the juror at issue in the subsequent appeal. Justice John Paul Stevens argued in dissent that "the Court has fundamentally redefined--or maybe just misunderstood--the meaning of 'substantially impaired,' and, in doing so, has gotten it horribly backwards."


[Unknown Act > Facts]
Jesse Williams died of lung cancer at age 67 after a life spent smoking three packs of Marlboro cigarettes per day. His widow sued Phillip Morris, the maker of Marlboro cigarettes, alleging that the company had engaged in a deliberate, wide-spread campaign of misinformation on the dangers of smoking. The jury found for Williams and awarded her $821,485.50 in compensatory damages and $79.5 million in punitive damages. However, the trial judge found the punitive damages excessive and reduced them to $32 million.
Under the Supreme Court's decision BMW v. Gore, punitive damages must be reasonably related to the harm done to the plaintiff, but larger punitive damage awards may be appropriate if the defendant displayed reprehensible conduct. Citing Gore, the Oregon Court of Appeals reinstated the $79.5 million award, holding that Phillip Morris's conduct was reprehensible enough to warrant the large amount.
The Oregon Supreme Court declined to take the case. However, the U.S. Supreme Court sent the case back for consideration in light of State Farm v. Campbell, which held that punitive damages can normally only be as much as nine times greater than compensatory damages. The Oregon Court of Appeals again affirmed the $79.5 million award, ruling that the reprehensibility of Phillip Morris's conduct justified the larger ratio. The Oregon Supreme Court upheld the decision.
Phillip Morris appealed to the Supreme Court, arguing that the court had unreasonably exceeded federal guidelines on punitive damages. Phillip Morris also argued that it was unfair to punish the company for its actions toward other smokers who were not parties to the suit.


[Unknown Act > Conclusion]
1) Unconsidered and 2) no. The Court ruled 5-4 that "the Constitution's Due Process Clause forbids a State to use a punitive damages award to punish a defendant for injury that it inflicts upon nonparties." The opinion by Justice Stephen Breyer held that it would be unfair to allow courts to award punitive damages for harm done to "strangers to the litigation," because defendants cannot defend themselves against such limitless and arbitrary charges. The Court did note that "risk of harm to the general public" can be taken into account as a component of the reprehensibility of the defendant's actions. Highly reprehensible actions may warrant a larger award of punitive damages, but the award cannot be increased as a direct result of harms inflicted on non-parties. The Court decided not to rule on the question of whether the $79.5 million award was excessive.


[Unknown Act > Facts]
Billing and other investors filed a class action lawsuit against Credit Suisse and other Wall Street investment firms. The lawsuit alleged that the firms had violated the Sherman Antitrust Act by conspiring to drive up the cost of initial public offering (IPO) securities during the stock market boom of the 1990s. The firms allegedly entered into illegal contracts with IPO purchasers, requiring subsequent investors to pay artificially inflated prices for the secutities. Credit Suisse argued that the suit should be dismissed, because the firms had implied antitrust immunity. It claimed that the firms' conduct was normal business practice, and was closely regulated by the Securities and Exchange Commission. If plaintiffs were able to bring antitrust suits against investment firms for securities violations, Credit Suisse argued, the plaintiffs would be able to subvert the securities laws that Congress intended to govern such suits.
The federal District Court agreed with Credit Suisse and dismissed the lawsuit. On appeal, however, the U.S. Court of Appeals for the Second Circuit reversed the lower court and reinstated the suit. The Second Circuit held that there was no evidence that Congress had intended securities laws like the Securities Act of 1933 to foreclose antitrust suits challenging practices like those engaged in by Credit Suisse.


[Unknown Act > Conclusion]
Yes. The Court reversed the Second Circuit and ruled that the applicable securities laws granted the defendant implied antitrust immunity. The 7-1 ruling by Justice Stephen G. Breyer noted four factors indicating that the Securities Act of 1933 foreclosed antitrust lawsuits in cases of alleged artificial inflation of aftermarket IPO share prices. First, the challenged conduct fell within "an area of conduct squarely within the heartland of securities regulations." Second, securities laws gave the Securities and Exchange Commission (SEC) clear authority to regulate in this area. Third, the SEC in fact actively regulated the challenged conduct. Fourth, overlapping antitrust and securities-law regimes would risk producing "conflicting guidance, requirements, duties, privileges, or standards of conduct." To allow the blunter instrument of antitrust law to govern the conduct at issue in the case would be to risk chilling legitimate business practices in an area that requires diligent regulation by the SEC to separate disapproved conduct from necessary, approved conduct. In a lone dissent Justice Clarence Thomas argued that the savings clause of the Securities Act - preserving "[...] any and all other rights and remedies that may exist in law [...] - was broad enough that it preserved the right to sue under antitrust laws.


[Unknown Act > Facts]
Juan Resendiz-Ponce, a Mexican national, was convicted of kidnapping and deported. When Resendiz-Ponce tried to reenter the U.S. using false identification, he was arrested and indicted for attempting to reenter the country after being deported. Resendiz-Ponce moved to dismiss his indictment because it failed to allege that he had "committed an overt act that was a substantial step toward reentering" - an essential element of the criminal offense. The trial judge denied the motion and the jury convicted Resendiz- Ponce.
On appeal, the U.S. Court of Appeals for the Ninth Circuit reversed the trial judge's decision to deny the motion. The Ninth Circuit ruled that because the indictment failed to explicitly mention that Resendiz-Ponce had physically crossed the border and presented false identification, it was insufficient and should be dismissed. The government argued that the omission was "harmless error," a minor mistake that would not invalidate the indictment, but the Circuit Court ruled that the omission was instead a "fatal flaw."


[Unknown Act > Conclusion]
Unanswered. The Court ruled that Resendiz-Ponce's indictment was not defective at all, and thus it did not reach the question of whether a failure to state each element of the charged crime can ever be harmless error. Justice John Paul Stevens wrote the opinion for the 8-1 majority. The Court held that the indictment's language stating that Resendiz-Ponce had "attempted" to illegally reenter the United States was sufficient, even without a more detailed description of his actions. The majority reasoned that "the word 'attempt' [...] encompasses both the overt act and intent elements." Therefore, Resendiz-Ponce's indictment did not lack any essential element of the crime. In a lone dissent, Justice Scalia argued that the word "attempt" did not necessarily imply an action that would constitute a "substantial step" toward reentering. Justice Scalia would have affirmed the Ninth Circuit and dismissed the indictment as structurally flawed.


[Unknown Act > Facts]
Jeff and Sandee Winkelman claimed that Parma City School District failed to give their disabled son Jacob a "free appropriate public education" as required by the Individuals with Disabilities Education Act (IDEA). Despite the Winkelmans' opposition, the school district planned to place Jacob in a public elementary school. After a preliminary school district hearing affirmed Jacob's placement, the Winkelmans placed Jacob in a private school at their own expense and petitioned a federal District Court for reimbursement.
The District Court ruled for the School District. On appeal, the U.S. Court of Appeals for the Sixth Circuit dismissed the suit because the Winkelmans lacked a lawyer. The Winkelmans argued that according to the IDEA, "any party aggrieved by the findings" of a preliminary school district hearing may appeal in a federal court. Also, because the IDEA demands active parental involvement in order to enforce proper child placement, the parent should be able to appear in court "pro se" - without a lawyer. The Sixth Circuit rejected both arguments and held that the IDEA does not establish any right of a non-lawyer parent to represent his disabled child in federal court. Non-lawyer parents cannot represent themselves either, the Circuit Court ruled, because the IDEA protects the rights of the child, not the parents.


[Unknown Act > Conclusion]
Yes. The Court reversed the Sixth Circuit by a 7-2 vote, ruling that "[p]arents enjoy rights under IDEA; and they are, as a result, entitled to prosecute IDEA claims on their own behalf." Justice Anthony Kennedy's majority opinion held that since the IDEA gives parents enforceable rights in the administrative stage of disputes over "free appropriate public education," it would be inconsistent if they could not exercise the same rights in federal court. An interpretation where some rights inhere and both parents and child while others inhere only in the child would be unnecessarily confusing and was not indicated by the text and structure of IDEA. Therefore the Court ruled that a parent can be a "party aggrieved" under the statute and that sections referring to the rights of the child need not be read to exclude the parent. The dissenters would have held that IDEA gives parents the right to represent themselves in court when they seek reimbursement or challenge violations of their own procedural rights, but not when they challenge the adequacy of their child's free appropriate public education. Justice Antonin Scalia argued that the child, as the one who is receiving the education, is the only one with a right to it, and he accused the majority of "spraying statutory sections about like buckshot [to] create a substantive parental right to education where none exists."


[Unknown Act > Facts]
Oneida and Herkimer counties adopted a local "flow control" ordinance requiring locally-produced garbage to be delivered to local publicly-owned facilities. The United Haulers Association filed suit in federal district court, arguing that by prohibiting the export of waste and preventing waste haulers from using less expensive out-of-state facilities, the ordinance ran afoul of the dormant Commerce Clause. The Supreme Court has held that the Commerce Clause forbids any state law that regulates interstate commerce. The District Court ruled against United Haulers and held that the ordinance was constitutional because it did not discriminate against out-of-state businesses.
On appeal, the U.S. Court of Appeals for the Second Circuit affirmed. The Court of Appeals ruled that even if the ordinance imposed a slight burden on interstate commerce, the effect was outweighed by the ordinance's local benefits.


[Unknown Act > Conclusion]
No. The Court voted 6-3 to affirm the Second Circuit and uphold the ordinance. Chief Justice John Roberts's majority opinion distinguished the Oneida- Herkimer ordinance from previous ordinances that were struck down by the Court by emphasizing that the favored waste-disposal facilities were publicly operated. The majority found that "[t]he flow control ordinances in this case benefit a clearly public facility, while treating all private companies exactly the same." After deeming the ordinance nondiscriminatory, the Court balanced its burden on commerce against its financial, health, and environmental benefits. The Court found that it imposed only an "incidental burden." The majority declined to "rigorously scrutinize" the economic effects of the ordinance, preferring to leave the policy analysis to local government. The dissent by Justice Alito would have held that the ordinance discriminated against commerce and was thus unconstitutional.


[Unknown Act > Facts]
Keith Bowles was convicted of murder. He filed a petition for habeas corpus in federal District Court, and was denied. Bowles did not receive timely notice of the District Court's ruling, so he missed the deadline for appeal. He filed a motion under Federal Rule of Appellate Procedure 4(a)(6) to reopen the appeal period. The District Court granted Bowles's motion, and gave him until February 27, 2004 to file his appeal. However, Rule 4(a)(6) allows only a 14-day extension of the appeal period, which would put the deadline on February 24, 2004. Bowles filed his appeal on February 26 - on time according to the court's deadline, but untimely according to Rule 4(a)(6).
The U.S. Court of Appeals for the Sixth Circuit at first declined to dismiss Bowles's appeal. Later, on its own motion, the Sixth Circuit "correct[ed] [its] error" and dismissed the appeal, saying Rule 4(a)(6) "is not susceptible to extension through mistake, courtesy, or grace."


[Unknown Act > Conclusion]
Yes. The Court ruled that, even though Bowles was relying on the mistaken order of the District Court, the Circuit Court was correct to dismiss his untimely appeal. Justice Clarence Thomas's opinion for the 5-4 majority held that statutory time limits for filing a notice of appeal are jurisdictional, and therefore the Circuit Court had no choice but to dismiss Bowles's appeal once it found that the appeal was filed too late. The Court ruled that it had no authority to create an exception for Bowles under the little-used doctrine of "unique circumstances," and it overruled its precedents "to the extent they purport to authorize an exception to a jurisdictional rule." The majority left it to Congress to change the rule if Congress thought it unfair. In dissent, Justice David Souter wrote: "It is intolerable for the judicial system to treat people this way, and there is not even a technical justification for condoning this bait and switch."


[Unknown Act > Facts]
William Twombly and other consumers brought a class action lawsuit against Bell Atlantic Corp. and other telecommunications companies. Twombly alleged that the companies had violated Section 1 of the Sherman Act by conspiring to end competition among themselves and to stifle new competition. In the suit, Twombly claimed that the companies had agreed not to branch out into and compete in one another's territories, even though the Telecommunications Act of 1996 might have made it relatively inexpensive to do so.
The District Court granted Bell Atlantic's motion to dismiss the suit, however, because Twombly had failed to "allege sufficient facts from which a conspiracy can be inferred." In order to sufficiently claim a Section 1 violation, the court held, the plaintiffs needed to establish a "plus factor" - a piece of evidence showing that the defendants' behavior would be against their economic self-interest unless there was a conspiratorial agreement. Twombly had not established a plus factor, the court held, because the companies' defensive behavior could have been motivated by economic factors rather than conspiracy.
Twombly appealed to the U.S. Court of Appeals for the Second Circuit, which reversed the lower court. The Second Circuit ruled that Twombly needed only to allege a conspiracy and specific facts that would support a Section 1 violation. Since he had alleged that the companies had engaged in suspicious "parallel conduct" and conspired to preserve monopoly conditions, his claim was sufficient and the suit could proceed.


[Unknown Act > Conclusion]
No. The Court ruled 7-2 that a plaintiff claiming a Section 1 violation must also allege facts that, if true, would suggest a conspiratorial agreement. The opinion by Justice David Souter held that "Without more, parallel conduct does not suggest conspiracy [...]" and "A statement of parallel conduct [...] needs some setting suggesting the [conspiratorial] agreement [...]" The Court laid out a "plausibility standard" for the pleading stage of Section 1 suits. Claims are valid only if they allege facts that plausibly suggest a conspiracy. To allege facts that are merely consistent with a conspiracy is not sufficient. The suggestive facts need only be alleged; a suit can go forward even if the facts are unlikely to be proven by the plaintiff. The Court held that Twombly's claim should be dismissed, because he had failed to identify any facts that suggested illegal conspiracy over the alternative: a concurrent appraisal of the economic situation by several telecomm companies. The dissenting Justices accused the majority of acting on the basis of practical concerns over "enormously expensive" antitrust lawsuits with the potential to confuse juries.


[Unknown Act > Facts]
Teleflex sued KSR International (KSR), alleging that KSR had infringed on its patent for an adjustable gas-pedal system composed of an adjustable accelerator pedal and an electronic throttle control. KSR countered that Teleflex's patent was obvious, and therefore unenforceable. Under 25 U.S.C. Section 103(a), obvious inventions cannot be patented. A federal District Court granted summary judgment for KSR, accepting KSR's argument that the invention was obvious because each of the invention's components existed in previous patents. Anyone with knowledge or experience in the industry, the District Court ruled, would have considered it obvious that the two components could be combined. Teleflex appealed to the Court of Appeals for the Federal Circuit, which reversed the District Court. The Circuit Court found the lower court's analysis incomplete, because the District Court had not applied a full "teaching-suggestion-motivation test." Under this test, in order to label the patent obvious the District Court would have needed to identify the specific "teaching, suggestion, or motivation" that would have led a knowledgeable person to combine the two previously-existing components. KSR appealed to the Supreme Court, arguing that the Circuit Court's test conflicted with Supreme Court precedent and that it would allow too many patents of obvious inventions.


[Unknown Act > Conclusion]
No. The Court ruled unanimously that the Federal Circuit "analyzed the issue in a narrow, rigid manner inconsistent with [Section 103(a)] and our precedents." Justice Anthony Kennedy wrote the opinion for the Court, which ruled in favor of KSR and reversed the Court of Appeals. The opinion acknowledged that a patent is not necessarily obvious by virtue of being a combination of two previously existing components and that it can be helpful in such cases for a court to identify a reason that would have motivated a knowledgeable person to combine the components. However, the Court held that Federal Circuit's "teaching-suggestion-motivation test" was not to be applied as a mandatory rule. This test for determining obviousness was too narrow, because it only took into account teachings on the specific problem the patentee was attempting to solve. Teleflex's gas pedal patent was inspired by previous inventions aimed at different problems. Even though no one had combined the pre-existing adjustable gas pedal and electronic sensor technology in the precise way Teleflex's patent did, the Court held that the existence of the technology would have caused any person of ordinary skill to see the obvious benefit of combining the two. Consequently, Teleflex's patent was obvious and therefore invalid.


[Unknown Act > Facts]
In 1994, Andre Wallace was arrested and charged with murder. Two years later he was convicted and sent to prison. Wallace appealed, arguing that the police had arrested him without probable cause and coerced him into confessing to the crime. In 1998, an appeals court agreed that Wallace had been arrested without probable cause and granted him a new trial. Finally, in 2002, the prosecution dropped its case against him. The next year Wallace sued the police officers and the city of Chicago for violating his Fourth Amendment rights through false arrest.
The District Court ruled against Wallace, because his suit was time-barred. In Illinois there is a two-year statute of limitations on false-arrest claims. Since Wallace had not brought suit within two years of either his arrest or the time the arrest was declared invalid, his time was up. Wallace appealed to the Seventh Circuit Court of Appeals, arguing that the two-year limit did not begin until his conviction was finally set aside in 2002.
The Circuit Court upheld the District Court, ruling against Wallace. The Circuit Court panel acknowledged that other Circuits had failed to agree on the question of when the statute of limitations for a false arrest claim should begin. The Seventh Circuit opted for a clear rule - the two-year limit starts at the time of the arrest, and therefore Wallace's suit was too late


[Unknown Act > Conclusion]
By a 7-2 vote, the Court affirmed the Seventh Circuit. The opinion by Justice Antonin Scalia held that "the statute of limitations begins to run when the alleged false imprisonment ends." Since false imprisonment is detention without legal process, the Court ruled, the false imprisonment ends when legal processes begin. At that point, the clock begins to run on the time limit for filing a false imprisonment claim.


[Unknown Act > Facts]
Lisa Watson filed a class action lawsuit against the tobacco company Philip Morris, claiming that the company had violated Arkansas law by misrepresenting the amount of tar and nicotine in cigarettes branded as "light." Seeking to have the case removed to federal court, Philip Morris invoked 28 U.S.C. 1442(a)(1), which allows removal when a party is sued for actions taken while "acting under" a federal officer. Philip Morris claimed that it was acting under the direct control of regulations promulgated by the Federal Trade Commission (FTC), so 28 U.S.C. 1442(a)(1) applied. After the federal District Court denied Watson's motion to have the case sent back to state court, Watson appealed.
The dispute centered on the degree of control exercised by the FTC over Philip Morris. The U.S. Court of Appeals for the Eighth Circuit affirmed the lower court's ruling in favor of Philip Morris, allowing the case to continue in the federal court system. The Eighth Circuit held that the question of whether 28 U.S.C. 1442(a)(1) applies "depends on the detail and specificity of the federal direction of the defendant's activities and whether the government exercises control over the defendant." In the case of the tobacco industry, the Eighth Circuit found "unprecedented" government involvement, including detailed FTC regulations concerning the testing and disclosure of tar and nicotine levels. Therefore, Philip Morris was "acting under a federal officer" and consequently entitled to remove the case to federal court.


[Unknown Act > Conclusion]
No. In a unanimous opinion written by Justice Stephen Breyer, the Court ruled that Philip Morris could not remove its case to federal court, because it was not "acting under a federal officer" in the sense of the statute. Justice Breyer wrote that "broad language is not limitless. And a liberal construction nonetheless can find limits in a textís language, context, history, and purposes." The Court held that the phrase "acting under" connotes a subordinate acting to assist his superior. A company complying with a regulation, no matter how restrictive, was not in the type of relationship covered by the statute. Philip Morris analogized its situation to government contractors that have been held to fall under the statute, but the Court ruled that the contractor's contractual "principal/agent" relationship assisted the government in a way that Philip Morris's mere compliance with stringent regulations did not.


[Unknown Act > Facts]
Jose Lopez, a Mexican national living in South Dakota, was convicted of aiding and abetting the possession of cocaine. The crime is a felony under South Dakota law, but only a misdemeanor under the federal Controlled Substances Act.
The Immigration and Naturalization Service began proceedings to remove Lopez from the country. Lopez applied for a cancellation of his removal, citing the Immigration and Naturalization Act (INA). The INA allows an alien to avoid removal if he meets certain qualifications and has no prior "aggravated felony" convictions. Lopez argued that he was eligible for cancellation of his removal because his drug offense was only a misdemeanor under federal law.
An Immigration Judge denied Lopez's request for cancellation, and the Board of Immigration Appeals affirmed, on the grounds that Lopez had committed an aggravated felony. Lopez then sued the Attorney General and brought his case to the Court of Appeals for the Eighth Circuit. The Circuit Court affirmed the lower courts, ruling that a crime is an aggravated felony under the INA if it is a felony under either federal or state law.


[Unknown Act > Conclusion]
No. The Court ruled 8-1 that a drug crime must be a felony under the federal Controlled Substances Act (CSA) in order to count as an aggravated felony for purposes of the INA. The opinion by Justice David Souter rejected as unnatural the government's interpretation of the term "aggravated felony" in the INA as encompassing any state-law felony punishable under the CSA, whether as a felony or not. Instead, the Court looked to the crimes classified as felonies in the CSA in order to define INA aggravated felonies. Illicit trafficking is a felony drug crime under the CSA, but the Court ruled that Lopez's drug-possession crime could not be considered "trafficking." The Court's approach avoided state-by-state disparities in the types of crimes that can be used to justify deportation.


[Unknown Act > Facts]
Under 12 U.S.C. Section 484(a), states do not have regulatory powers over national banks. In 2001 the federal Office of the Comptroller of Currency (OCC) issued federal regulation 12 C.F.R. 7.4006, which applied 12 U.S.C. Section 484(a) to state-chartered operating subsidiaries of national banks. Wachovia Mortgage was an operating subsidiary of the national bank Wachovia Bank, and was registered with the state of Michigan.
When Michigan attempted to exercise its regulatory powers over Wachovia Mortgage, Wachovia Bank sued Watters, a Michigan official, seeking a judgment that Michigan's laws on operating subsidies of national banks were superceded by 12 U.S.C Section 484(a). Michigan argued that the OCC had exceeded the authority given it by Congress by extending the definition of "national bank" to cover state-registered operating subsidiaries. Michigan also argued that the extension of federal authority over state entities like Wachovia Mortgage violates the Tenth Amendment, which reserves to states all powers not delegated to the federal government.
The District Court rejected these arguments and ruled for Wachovia, and the U.S. Court of Appeals for the Sixth Circuit affirmed. The Circuit Court found that the decision of the OCC to apply rules for national banks to their operating subsidiaries was a reasonable interpretation of Congress's intent, and therefore entitled to deference under Chevron U.S.A. v. Natural Resources Defense Council. The Sixth Circuit also held that Congress had the power to regulate operating subsidiaries of national banks under the Commerce Clause, so the Tenth Amendment did not reserve that power to the states.


[Unknown Act > Conclusion]
Unanswered and no. The Court ruled 5-3 that state-chartered operating subsidiaries of national banks are subject to regulation by the federal Office of the Comptroller of Currency and not by the states in which they are located. The opinion by Justice Ruth Bader Ginsburg held that "[...] the level of deference owed to the regulation is an academic question," because "Section 7.4006 merely clarifies and confirms what the [National Bank Act, 12 U.S.C. Section 484(a)] already conveys: A national bank has the power to engage in real estate lending through an operating subsidiary, subject to the same terms and conditions that govern the national bank itself; that power cannot be significantly impaired or impeded by state law." The Court interpreted the statute broadly, as a shield against burdensome state regulation of national banks and their subsidiaries, so the OCC's regulation preempting Michigan's regulatory laws was firmly grounded in the statute. The Court briefly and definitively disposed of Watters's Tenth Amendment argument, holding that the regulation of subsidiaries of national banks is a legitimate application of Congress's Commerce Power and therefore is not reserved to the states.


[Unknown Act > Facts]
Jalil Abdul-Kabir was convicted of murder and sentenced to death. At his sentencing, Abdul-Kabir presented mitigating evidence of his destructive family background and neurological defects. The jury was instructed to give effect to all mitigating evidence by making yes-or-no determinations on Texas's two "special issues" for capital sentencing: the deliberateness of the crime and the future dangerousness of the criminal. After his sentencing, Abdul-Kabir filed a petition for habeas corpus in federal District Court, arguing that the special issues had not allowed the jury to give full consideration and effect to his mitigating evidence as required by the Supreme Court in Penry v. Johnson. The District Court denied Abdul-Kabir habeas relief, and the U.S. Court of Appeals for the Fifth Circuit affirmed.
The Fifth Circuit held that the mitigating evidence was not "constitutionally relevant," and that in any case the jury could have given it consideration as part of the "deliberateness" and "dangerousness" determinations. After the Supreme Court rejected the "constitutional relevance" test, the Fifth Circuit reaffirmed its decision that Abdul-Kabir's mitigating evidence had been given full consideration and effect under the Texas special issues. The case was consolidated with Brewer v. Quarterman No. 05-11287.


[Unknown Act > Conclusion]
No. The Court ruled 5-4 that the Texas jury instructions conflicted with Supreme Court precedents requiring that jurors be given the opportunity "to give meaningful consideration and effect to all mitigating evidence that might provide a basis for refusing to impose the death penalty." The majority opinion by Justice John Paul Stevens found Texas's scheme of yes-or-no determinations of deliberateness and future dangerousness to be far too constraining. This was particularly true when the defense offers "double edged" evidence, which can be mitigating or aggravating depending on the jury's interpretation. The Court faulted the Fifth Circuit for not recognizing that Abdul-Kabir had presented mitigating evidence of his deprived childhood and his lack of self-control in order to show his relative lack of moral culpability - not to dispute either the deliberateness of his crime or his likely future dangerousness (which indeed might be aggravated by the evidence). Since the instruction did not allow the jury to consider the evidence as mitigating in the sense Abdul-Kabir intended, it was unconstitutional.


[Unknown Act > Facts]
The Seattle School District allowed students to apply to any high school in the District. Since certain schools often became oversubscribed when too many students chose them as their first choice, the District used a system of tiebreakers to decide which students would be admitted to the popular schools. The second most important tiebreaker was a racial factor intended to maintain racial diversity. If the racial demographics of any school's student body deviated by more than a predetermined number of percentage points from those of Seattle's total student population (approximately 40% white and 60% non-white), the racial tiebreaker went into effect. At a particular school either whites or non-whites could be favored for admission depending on which race would bring the racial balance closer to the goal.
A non-profit group, Parents Involved in Community Schools (Parents), sued the District, arguing that the racial tiebreaker violated the Equal Protection Clause of the Fourteenth Amendment as well as the Civil Rights Act of 1964 and Washington state law. A federal District Court dismissed the suit, upholding the tiebreaker. On appeal, a three-judge panel the U.S. Court of Appeals for the Ninth Circuit reversed.
Under the Supreme Court's precedents on racial classification in higher education, Grutter v. Bollinger and Gratz v. Bollinger, race-based classifications must be directed toward a "compelling government interest" and must be "narrowly tailored" to that interest. Applying these precedents to K-12 education, the Circuit Court found that the tiebreaker scheme was not narrowly tailored. The District then petitioned for an "en banc" ruling by a panel of 11 Ninth Circuit judges. The en banc panel came to the opposite conclusion and upheld the tiebreaker. The majority ruled that the District had a compelling interest in maintaining racial diversity. Applying a test from Grutter, the Circuit Court also ruled that the tiebreaker plan was narrowly tailored, because 1) the District did not employ quotas, 2) the District had considered race-neutral alternatives, 3) the plan caused no undue harm to races, and 4) the plan had an ending point.


[Unknown Act > Conclusion]
No, no, and yes. By a 5-4 vote, the Court applied a "strict scrutiny" framework and found the District's racial tiebreaker plan unconstitutional under the Equal Protection Clause of the Fourteenth Amendment. Chief Justice John Roberts wrote in the plurality opinion that "The way to stop discrimination on the basis of race is to stop discriminating on the basis of race." The Court acknowledged that it had previously held that racial diversity can be a compelling government interest in university admissions, but it ruled that "[t]he present cases are not governed by Grutter." Unlike the cases pertaining to higher education, the District's plan involved no individualized consideration of students, and it employed a very limited notion of diversity ("white" and "non-white"). The District's goal of preventing racial imbalance did not meet the Court's standards for a constitutionally legitimate use of race: "Racial balancing is not transformed from 'patently unconstitutional' to a compelling state interest simply by relabeling it 'racial diversity.'" The plans also lacked the narrow tailoring that is necessary for race-conscious programs. The Court held that the District's tiebreaker plan was actually targeted toward demographic goals and not toward any demonstrable educational benefit from racial diversity. The District also failed to show that its objectives could not have been met with non-race-conscious means. In a separate opinion concurring in the judgment, Justice Kennedy agreed that the District's use of race was unconstitutional but stressed that public schools may sometimes consider race to ensure equal educational opportunity.


[Unknown Act > Facts]
Police stopped Karen Simeroth's car for having expired registration tabs. Bruce Brendlin, who had a warrant out for his arrest, was riding in the passenger seat. Police found methamphetamine, marijuana, and drug paraphernalia in the car and on Simeroth's person. In a California trial court, Brendlin filed a motion to suppress the evidence obtained at the traffic stop, claiming that the stop was an unreasonable seizure in violation of the Fourth Amendment. The trial court found that Brendlin had never been detained or "seized" within the meaning of the Fourth Amendment. It denied the motion, and Brendlin pleaded guilty to manufacturing methamphetamine. A California Court of Appeal reversed, holding that a traffic stop necessarily results in a Fourth Amendment seizure.
The California Supreme Court reversed the Court of Appeal and ruled for California. The court held that the driver of the car is the only one detained in a traffic stop. The movement of any passengers is also stopped as a practical matter, but the court considered this merely a necessary byproduct of the detention of the driver. The court held that Brendlin had been free to leave the scene of the traffic stop or to simply ignore the police. Since he was never "seized," however, he could not claim a violation of the Fourth Amendment.


[Unknown Act > Conclusion]
Yes. In a unanimous opinion written by Justice David Souter, the Court held that when a vehicle is stopped at a traffic stop, the passenger as well as the driver is seized within the meaning of the Fourth Amendment. The justices said, "We resolve this question by asking whether a reasonable person in Brendlin's position when the car stopped would have believed himself free to 'terminate the encounter' between the police and himself." The Court held that Brendlin would have reasonably believed himself to be intentionally detained and subject to the authority of the police. Thus, he was justified in asserting his Fourth Amendment protection against unreasonable seizure. The Court noted that its ruling would not extend to more incidental restrictions on freedom of movement, such as when motorists are forced to slow down or stop because other vehicles are being detained. To accept the state's arguments, however, would be to "invite police officers to stop cars with passengers regardless of probable cause or reasonable suspicion of anything illegal."


[Unknown Act > Facts]
At Stephen Danforth's trial for sexual abuse of a six-year-old boy, the victim was found incompetent to testify in court, so his videotaped testimony was shown instead. Danforth was convicted and his appeals were unsuccessful. After Danforth's case became final, the Supreme Court ruled in Crawford v. Washington that pre-recorded testimony without the possibility of cross-examination is unconstitutional. Danforth filed a second petition for postconviction relief, seeking to have the Crawford decision applied retroactively to his case. Supreme Court decisions announcing constitutional rules of criminal procedure are applied retroactively only in certain circumstances, which are specified in Teague v. Lane. The state court of appeals declined to retroactively apply Crawford.
On appeal to the Minnesota Supreme Court, Danforth raised an alternative argument, claiming that the state court was free to apply a broader standard of retroactivity than the one in Teague. Under Minnesota state retroactivity principles, Danforth argued, the Crawford case met the criteria for retroactive application. In Danforth's interpretation, the Teague standard was mandatory for federal habeas corpus proceedings but not for state postconviction proceedings. The Minnesota Supreme Court rejected Danforth's arguments, ruling that only U.S. Supreme Court decisions determine the proper standard for retroactive application of constitutional criminal procedure. The Supreme Court subsequently ruled in Whorton v. Bockting that Crawford does not apply retroactively under Teague, but it agreed to consider Danforth's alternative argument.


[Unknown Act > Conclusion]
In a 7-2 opinion written by Justice John Paul Stevens, the Court held that the federal case law precedent, including Teague did not constrain the authority of state courts to give broader effect to new rules of criminal procedure than was required by the precedent. The precedent applied only to federal habeas corpus petitions and had no bearing on state post-conviction proceedings. Chief Justice John G. Roberts Jr. wrote a dissenting opinion in which Justice Anthony Kennedy joined.


[Unknown Act > Facts]
Paul Holowecki and other employees of Federal Express sued the corporation for age discrimination under the Age Discrimination in Employment Act (ADEA). A district court judge dismissed the complaint on the ground that none of the plaintiffs had met the time limits and filing requirements of the ADEA. The ADEA requires that a plaintiff file a "charge" with the Equal Employment Opportunity Commission (EEOC) 60 days prior to filing suit. Upon receiving the charge of discrimination, the EEOC notifies the employer of the accusation, investigates the matter, and offers to mediate. THE EEOC has an "Intake Questionnaire" form and a "Charge" form, but the EEOC regulations state only that "A charge shall be in writing and shall name the prospective respondent and shall generally allege the discriminatory act(s)." One of the plaintiffs completed an intake questionnaire, but the EEOC did not take the steps it should have taken after the filing of a charge. Holowecki sued over 60 days later, but the judge ruled that the intake questionnaire did not qualify as a charge for purposes of the AEDA.
The U.S. Court of Appeals for the Second Circuit reversed, allowing Holowecki's suit to go forward. The Second Circuit ruled that the minimal written information required for a charge was contained in the intake questionnaire. The questionnaire also met the ADEA's implicit requirement that the charge be intended to start the process of an ADEA suit. The Second Circuit did not consider it significant that the EEOC did not act on the questionnaire, apparently not believing it to count as a charge. To dismiss a complaint based on the EEOC's inaction would be to hold the plaintiff accountable for the failings of the agency.


[Unknown Act > Conclusion]
The Court, in a 7-2 opinion, upheld the Second Circuit, stating that the procedure used to file the document was consistent with the design and purpose of the ADEA. In his majority opinion, Justice Anthony Kennedy accepted the EEOC's position that a filing would be considered a "charge" if it could be reasonably construed as a request for the agency to take remedial action to protect the employee's rights or otherwise settle a dispute between the employer and the employee. Kennedy felt that Holowecki's charge met these requirements. Justices Clarence Thomas and Antonin Scalia dissented from the Court's judgment.


[Unknown Act > Facts]
Two Kentucky inmates challenged the state's four-drug lethal injection protocol. The lethal injection method calls for the administration of four drugs: Valium, which relaxes the convict, Sodium Pentathol, which knocks the convict unconscious, Pavulon, which stops his breathing, and potassium chloride, which essentially puts the convict into cardiac arrest and ultimately causes death. The Kentucky Supreme Court held that the death penalty system did not amount to unconstitutional cruel and unusual punishment.


[Unknown Act > Conclusion]
In a 7-2 decision with four concurrences and a dissent, the Court held that Kentucky's lethal injection scheme did not violate the Eighth Amendment. Noting that the inmates had conceded the "humane nature" of the procedure when performed correctly, the divided Court inmates had failed to prove that incorrect administration of the drugs would amount to cruel and unusual punishment. However, the Court also suggested that a state may violate the ban on cruel and unusual punishment if it continues to use a method without sufficient justification in the face of superior alternative procedures. Chief Justice John G. Roberts, Jr. announced the judgment and issued an opinion joined by Justices Anthony Kennedy and Samuel A. Alito. Justice John Paul Stevens wrote a separate concurring opinion supporting the judgment but for the first time stated his opposition to the death penalty. Justice Antonin Scalia, joined by Justice Clarence Thomas, wrote a separate concurring opinion in support of the judgment. Justice Alito also issued a separate concurring opinion. Justice Ruth Bader Ginsburg, joined by Justice David Souter, dissented.


[Unknown Act > Facts]
Two workers involved in the manufacture of electrical supplies for the Navy's billion-dollar guided missile destroyers brought a whistleblower case alleging that subcontractors performed faulty work. The two charged that the companies employed unqualified workers, installed leaky gearboxes and used defective temperature gauges. After a five-week trial, the district court granted judgment as a matter of law for the companies, concluding that the False Claims Act under which the suits were brought requires that defendants "present" the fraudulent claims to the government. Because the subcontractors actually invoiced the general contractor and not the government, the court ruled that the presentment requirement had not been met. The appeals court reversed, holding that the Act should be liberally construed to discourage private companies from defrauding the government.


[Unknown Act > Conclusion]
Yes. Writing for a unanimous Court, Justice Samuel A. Alito made clear that a plaintiff must prove more than that the false statement's use resulted in payment or approval or that Government money was used to pay the claim. Instead, a plaintiff must show that the defendant intended the false statement to be "material" to the Government's decision to pay or approve the false claim.


[Unknown Act > Facts]
James LaRue participated in a 401(k) retirement savings plan administered by his employer, the management consulting firm DeWolff, Boberg & Associates. Employee benefit plans are regulated under a federal law, the Employee Retirement Income Security Act of 1974 (ERISA). LaRue sought to exercise his option to make certain changes in his investment plan, but DeWolff neglected to make the changes. LaRue claimed that DeWolff's omission had cost him $150,000, and he sued the firm for breach of fiduciary duty, seeking to recover the money. In response, DeWolff argued that ERISA does not provide for the type of individual monetary award sought by LaRue.
Section 502(a)(2) allows plan participants to sue plan administrators for breach of fiduciary duty in order to "make good to such plan any losses to the plan resulting from each such breach." DeWolff argued that LaRue's suit was not of the type contemplated by the text of ERISA because LaRue sued to recover losses caused to his own personal retirement plan rather than suing to vindicate the interests of the plan as a whole. LaRue also invoked Section 502(a)(3), which allows plan participants to sue to obtain "other appropriate equitable relief."
The U.S. District Court held that LaRue was not entitled to relief under ERISA, and the U.S. Court of Appeals for the Fourth Circuit affirmed. The Fourth Circuit ruled that Section 502(a)(2) was concerned with protecting entire plans from misuse of plan assets and not with providing recovery for losses suffered by individual accounts. The court also rejected LaRue's Section 502(a)(3) claim. It ruled that the phrase "equitable relief" rarely includes relief in the form of a monetary award and only when the money has been unjustly possessed by the defendant.


[Unknown Act > Facts]
Michael H. Boulware founded a coffee and bottled water company known as Hawaiian Isles Enterprises. As his company became profitable in 1987, he began transferring money – a total of $4.5 million – from his company to his mistress. Seven years later, in the midst of a divorce, his mistress refused to return the money when asked, contending that it was a gift. A Hawaii court eventually held that the woman had been holding the money in constructive trust for the company's benefit. Seven years after that, the federal government indicted Boulware for failing to pay taxes on the disputed funds as well as $6 million more that he had received from the company. Boulware argued that under the "return of capital" rule, holding that when unprofitable companies distribute money to shareholders, the money is considered a nontaxable return of capital up to the shareholder's basis in the stock, he owed no taxes. The Ninth Circuit rejected that argument.


[Unknown Act > Conclusion]
A unanimous Court reversed Boulware's conviction for tax evasion. In an opinion written by Justice David Souter, the Court held that a defendant in a criminal tax case does not need to show a contemporaneous intent to treat diversions as returns of capital to demonstrate no taxes were owed. All that mattered, according to the Court, was whether the corporation had earnings or profits and the taxpayer's basis for his stock. Based on these considerations, the Court determined that there had been no improper action on Boulware's part.


[Unknown Act > Facts]
Before his transfer to a new prison, prisoner Abdus-Shahid M. S. Ali temporarily left his two bags of possessions with a police officer. When the bags arrived, Ali noticed that several items were missing. He filed an administrative tort claim with the Bureau of Prisons seeking to recover the items. After the claim was denied, he brought his case to U.S. District Court. The court dismissed the case for lack of jurisdiction, ruling that the government had immunity from the lawsuit under the Federal Tort Claims Act (FTCA). The FTCA establishes a general waiver of sovereign immunity for tort claims against the government, but it also makes several exceptions to the waiver. One exception is for "[a]ny claim arising in respect of [...] the detention of any goods, merchandise, or other property by any officer of customs or excise or any other law enforcement officer." Ali argued that in context the phrase "other law enforcement officer" referred only to officers working in customs and related activities, but the court applied the exception to any detention of goods by any law enforcement officer.
The U.S. Court of Appeals for the Eleventh Circuit affirmed the dismissal of Ali's claim. It ruled that the phrase "any other law enforcement officer" in the FTCA was not merely a supplementary catch-all relating to the government's immunity in tax collection and customs situations. Rather, it was itself a broad grant of sovereign immunity covering any instance of detention of goods by law enforcement officers.


[Unknown Act > Conclusion]
The Court agreed with the 11th Circuit and, in a 5-4 majority opinion written by Justice Clarence Thomas, held that the use of the word "any" should be given its normal interpretation, encompassing all federal officers whether or not they were involved in enforcing customs or excise laws. Justices Antonin Scalia, Ruth Bader Ginsburg and Samuel A. Alito, along with Chief Justice John G. Roberts, Jr., joined in the opinion.
Justice Anthony Kennedy, joined by Justices John Paul Stevens, David H. Souter, and Stephen G. Breyer, dissented in the judgment, arguing that if Congress intended to include officials other than customs or excise officials it would have listed them in the law. Justice Breyer wrote a separate dissent, jointed by Justice Stevens, suggesting that the context of the statute made clear that Congress intended it only to refer to federal officials likely to deal with property loss or damage, a group that, according to Breyer, did not include police officers.


[Unknown Act > Facts]
In 1999, Ahmed Ressam, the so-called "Millennium Bomber," was arrested attempting to cross the Canadian-U.S. border in a rental car loaded with explosives and other bomb-making materials. Ressam planned to detonate the explosives at Los Angeles International Airport on New Year's Eve. Ressam was charged with several crimes, including carrying an explosive device during the commission of a felony under 18 U.S.C. Section 844. The felony charge was lying to a customs agent.
Ressam argued, and the U.S. Court of Appeals for the Ninth Circuit agreed, that the statute required the explosive device to be carried in relation to the underlying felony and, therefore, should not be applied to Ressam in this case. The Ninth Circuit noted Congressional amendment of a substantially similar statute to include such "in relation to" language, indicating the legislature's intent that a connection between the explosives and the underlying felony is indispensable to the claim. The government, noting the case's importance in the realm of terror prosecutions, urged the Court to grant certiorari based on decisions reaching the opposite conclusion in both the Third and Fifth Circuits.


[Unknown Act > Conclusion]
Yes. The Court determined 8-1 that because Ressam was in possession of the explosives at the time he made the false statement to the customs agent he was therefore carrying them during the commission of that felony. Justice John Paul Stevens, in his majority opinion, refused to over-analyze the language of the statute and applied the word "during" in its most obvious sense. Justice Stephen Breyer dissented, reading the statute to mean that the explosives must have facilitated or aided the false statements and suggesting that merely possessing the weapons at the time of the statements would not suffice for a conviction.


[Unknown Act > Facts]
In 2005, Mohammad Munaf was arrested on suspicion of kidnapping by U.S. military officers acting as part of a multinational force in Iraq. Munaf's sister petitioned on his behalf for habeas corpus in the U.S. District Court in the District of Columbia. Soon after the petition was filed, Munaf was informed that he would be tried in an Iraqi court and transferred to Iraqi custody if convicted. Munaf filed a temporary restraining order attempting to block custody transfer.
After the Iraqi court sentenced him to death and the district court dismissed his case for lack of jurisdiction, Munaf appealed to the U.S. Court of Appeals for the D.C. Circuit which granted an injunction against the transfer. However, the D.C. Circuit, like the district court, eventually concluded that it did not have jurisdiction over Munaf's claim, basing its decision largely on the Court's ruling in Hirota v. MacArthur 338 U.S. 197 (1948). That decision prohibited Japanese citizens held abroad by U.S. troops from filing habeas petitions to challenge sentences handed down by a military tribunal sitting in Japan but including U.S. military personnel. Petitioner urges the Court to set aside Hirota and its ruling and to base its reasoning on a string of cases reaching the opposite result. The case will be consolidated and heard along with another D.C. case, Geren v. Omar, 07-394, in which the D.C. Circuit allowed a habeas petition by a U.S. citizen held in Iraq because he had not yet been charged or convicted by an Iraqi court.


[Unknown Act > Conclusion]
Yes they do. Chief Justice John G. Roberts, writing for a unanimous Court, held that the habeas corpus statute extends to American citizens held overseas by American forces operating subject to an American chain of command even if part of a larger multinational force. The Court pointed specifically to the statute's application to individuals held in custody "under color of the authority of the United States" to hold that actual Government custody is sufficient for jurisdiction in federal courts.


[Unknown Act > Facts]
In an effort to address the problem of tobacco use by minors, the Maine legislature passed the Tobacco Delivery Law, which imposes requirements on air and motor carriers that transport tobacco products. One provision of the law requires tobacco retailers to only use carriers that verify the age of each tobacco purchaser, and another provision requires that carriers ensure that no tobacco is shipped to unlicensed retailers. The New Hampshire Motor Transport Association sued, arguing that the state law was preempted by a federal law, the Federal Aviation Administration Authorization Act of 1994 (FAAAA). The preemption provision of the FAAAA prohibits state from enacting laws "related to" the prices, routes, or services of air and motor carriers. The Association argued that the Tobacco Delivery Law placed such a burden on the delivery procedures of carriers that significantly affected their prices and services. The state countered that the FAAAA was only meant to preempt traditional economic regulation by states, and therefore laws enacted pursuant to the state's police power - the power of a state to regulate for the health, safety, and welfare of its citizens - were permissible. The U.S. District Court ruled that the law was preempted by the FAAAA.
The U.S. Court of Appeals for the First Circuit affirmed the lower court. The First Circuit held that a police power exception to the general rule of preemption would be far too broad and was not intended by Congress. Maine could validly ban all unlicensed tobacco products within its borders, but the FAAAA prohibited the state from implementing this goal by imposing requirements on carriers that significantly alter their delivery procedures.


[Unknown Act > Conclusion]
The Court affirmed both lower courts, holding that the FAAAA preempted the state laws. In a unanimous decision written by Justice Stephen Breyer, the Court asserted that the state laws were directly connected with motor carrier services and therefore had a significant and adverse impact on the congressional goal of precluding state regulation in lieu of competitive market forces. The Court further stated that the FAAAA did not allow any exceptions for police powers or public health concerns of the State.


[Unknown Act > Facts]
Jack Davis, a wealthy Democratic candidate for Congress from New York's 26th Congressional District, brought this claim challenging the constitutionality of the so-called 'Millionaire's Amendment' to the 2002 campaign finance law. Davis argued in the district court that the law, which basically raises the contribution cap for individuals running against self-financed candidates, violated the First Amendment and the Equal Protection principle implicit in the Fifth Amendment. The district court rejected both of these claims, stating first that the law did not implicate the First Amendment because it did not impede Davis' ability to spend money in support of his message, noting that it actually led to a higher level of speech in the race overall. The district court similarly rejected Davis' Fifth Amendment claim, reasoning that although Davis may have been held to higher reporting standards than his opponent, his disproportionate wealth meant that the two candidates were not similarly situated and, therefore, the Equal Protection Clause did not apply. The campaign finance law allows direct appeal to the Court, which will consider whether Davis has standing to bring the First Amendment claim before deciding the case on the merits.


[Unknown Act > Conclusion]
Yes. Although all nine Justices agreed that Davis had standing to argue his case before the Court, only a 5-4 majority held that the contribution limits violated the First Amendment. In his majority opinion, Justice Samuel Alito noted that the Court had never upheld the constitutionality of a law imposing different contribution limits for candidates competing against one another. Because the Court found the laws in violation of the First Amendment, it did not reach the question of whether the Fifth Amendment was also violated. Justice John Paul Stevens, joined by Justices David Souter, Ruth Bader Ginsburg, and Stephen Breyer, filed an opinion concurring in part and dissenting in part, agreeing with the majority that Davis had standing but citing the reasoning of the district court to argue that the contribution cap did not violate the First or Fifth Amendment. Justice Ginsburg, joined by Justice Breyer, wrote a separate opinion concurring in part and dissenting in part, agreeing with Justice Stevens's argument but basing it on slightly different grounds.


[Unknown Act > Facts]
Walter Rothgery was arrested in Texas as a felon in possession of a firearm. Rothgery was taken before a judge for processing and, upon learning that seeking legal assistance would delay the proceedings, waived his Sixth Amendment right to counsel. No prosecutor was present at this hearing. Rothgery posted bail and was released, but was rearrested after a grand jury indictment several months later hiked his bail to a sum he could not afford. Throughout this entire period Rothgery continued to pursue legal counsel and only obtained such counsel approximately one week after the grand jury indictment. Rothgery's attorney produced evidence that Rothgery was in fact not a felon and he was released from custody. Rothgery brought suit against Gillespie County, TX for violating his civil rights by not appointing counsel as required under the Sixth Amendment.
Both the district court and the Fifth Circuit rejected his claim, the Fifth Circuit stating that Rothgery's Sixth Amendment rights were not implicated because no prosecutor was present at the initial hearing. In his petition for certiorari, Rothgery argued that both federal and state case law indicate that the Sixth Amendment right to counsel applies to any hearing where a defendant is advised of his rights and the charges against him, regardless of whether or not a prosecutor is present.


[Unknown Act > Conclusion]
Yes. In an 8-1 ruling, the Court held that a criminal defendant's initial appearance before a judge marks the beginning of the proceedings against him and triggers the defendant's Sixth Amendment right to counsel whether or not a prosecutor is aware of or involved in that appearance. This right to counsel applies whenever a defendant learns of the charges against him and has his liberty subject to restriction. The opinion was penned by Justice David Souter. Justice Clarence Thomas wrote the only dissent, arguing that the phrase "criminal prosecution" as used in the Sixth Amendment should not include a defendant's initial appearance in the absence of a prosecutor. Chief Justice John G. Roberts, joined by Justice Antonin Scalia, chose to write a concurring opinion pointing out the validity of Thomas' argument but reasoning that Court precedent required him to agree with the majority. Justice Samuel Alito also filed a concurring opinion, stating that Rothgery's right to counsel certainly arose at the time of his appearance but reserving judgment on whether the County's actions infringed on that right in this case.


[Unknown Act > Facts]
Charles Lickteig is a deputy sheriff in Kentucky. Because he is a hazardous duty worker, he is eligible to retire at age 55. Kentucky Retirement Systems offers a two-tier calculation of so-called "disability retirement benefits." If hazardous duty workers like Lickteig opt to keep working and then become disabled, they receive only their scheduled retirement benefits. In contrast, workers who become disabled before reaching age 55 receive payments that reflect not only their actual years of service but the number of years remaining until they would have reached 55. In effect, if two workers were otherwise identical, the one who retired on disability before 55 would always get benefits equal to or greater than those of the post-55 retiree.
Lickteig decided against retirement at 55. Six years later, he became disabled because of "a deteriorating vertebra, arthritis, nerve damage, and Parkinson's disease," and stopped working. When he applied for disability retirement benefits, he received word that he was eligible only for standard retirement.
The Equal Employment Opportunity Commission argued unsuccessfully in federal district court that the two-tier system violated the Age Discrimination in Employment Act (ADEA). The U.S. Court of Appeals for the Sixth Circuit affirmed. The appellate court reheard the case en banc and reversed, holding that the simple act of treating younger disabled retirees better than older ones was sufficient to make out a prima facie ADEA violation.


[Unknown Act > Conclusion]
No. Writing for a slim 5-4 majority, Justice Stephen Breyer held that the Kentucky system does not discriminate against workers who become disabled after becoming eligible for retirement based on age. According to Breyer, the circumstances of the case indicated that differences in treatment were not "actually motivated" by age but rather by pension status. He also noted that the ADEA treats system-wide rules involving pensions more flexibly than individual employment decisions. Justice Anthony Kennedy authored a dissenting opinion, arguing that age is in fact the deciding factor in determining disability benefits and that, therefore, the Kentucky plan violates the ADEA.


[Unknown Act > Facts]
When the New York-based federal research laboratory Knolls Atomic Power Lab instituted a downsizing program, it asked supervisors to rank employees based on three factors: performance, flexibility, and the criticality of their skills, and then to add points for years of service in order to determine who would be dismissed. Of the thirty-one employees who were let go, all but one were over the age of forty. Twenty-six of these dismissed employees filed suit against Knolls for age discrimination in violation of the Age Discrimination in Employment Act (ADEA). A jury found for the employees and the U.S. Court of Appeals for the Second Circuit affirmed.
However the U.S. Supreme Court vacated the judgment, relying on its 2005 decision in Smith v. City of Jackson to hold that "an employer is not liable under the ADEA so long as the challenged employment action, in relying on specific non-age factors, constitutes a reasonable means to the employer's legitimate goals." On remand, the Second Circuit vacated its previous decision and held that the employees had failed to carry their burden of proving the evaluation system unreasonable. In seeking Supreme Court review, the employees argued that it should be Knolls, not them, who must prove the reasonableness of an action that would otherwise be prohibited.


[Unknown Act > Conclusion]
Yes. Writing for a 7-1 majority on the issue of burden of proof, Justice David Souter stated that the text and structure of the ADEA indicated that it is the employer, not the employee, who must bear both the burden of production and the burden of persuasion for the use of "reasonable factors other than age" in the decision to terminate employment. Justice Antonin Scalia concurred in the judgment, suggesting that the Congress left the determination of these issues in the hands of the Equal Opportunity Employment Commission. Justice Clarence Thomas concurred in part and dissented in part. In his brief dissent, Thomas noted his belief that "disparate-impact claims" such as this one, which allege a discriminatory result rather than discriminatory intent, should not be allowed under the ADEA. Justice Stephen Breyer took no part in the decision because he is a significant shareholder in Knolls' parent company.


[Unknown Act > Facts]
The Long family, members of the Sioux nation, owned a cattle company that had been doing business with the Plains Commerce Bank for seven years when the family patriarch died. Because Plains Commerce was reluctant to grant operating loans to younger generation family members, it struck a deal with the Longs agreeing to provide the operating loans if the Longs deeded their farmland and house to the bank. According to the Longs the bank never followed through on its promise to provide the operating loans, and after the bank attempted to foreclose on the land the Longs brought suit in a local tribal court seeking a temporary restraining order blocking the land transfer as well as charging the bank with tortuous discrimination. The tribal court returned an award of $700,000 for the Longs, after which Plains Commerce filed suit in federal district court claiming that the tribal court had improperly exercised jurisdiction over the case.
The district court decided that the tribal court had jurisdiction over the claim, and the U.S. Court of Appeals for the Eighth Circuit affirmed. In seeking Supreme Court review, Plains Commerce argued that the tribal court should not have had jurisdiction, and the Eighth Circuit erred in deciding so, because the claim did not fit into one of the exceptions granting such jurisdiction set forth by the Supreme Court in _Montana v. U.S. _ On the other hand, the Longs argued that federal courts whose geographic reach encompasses tribal lands have repeatedly allowed tribal courts to adjudicate civil suits against non-members who voluntarily did business with members.


[Unknown Act > Conclusion]
Generally yes, but not in cases such as this one where the conflict arises over the sale of a piece of land. On this issue, the Court held unanimously that tribal courts do not have jurisdiction to hear disputes concerning non- Indian banks' sales of their own lands. Writing for the Court, Chief Justice John G. Roberts stated that although tribal courts have jurisdiction to regulate conduct occurring on tribal lands, that jurisdiction is lost once title to the land passes into the hands of non-Indians. Justice Ruth Bader Ginsburg, joined by Justices John Paul Stevens, David Souter, and Stephen Breyer, wrote an opinion concurring and dissenting in part, agreeing that the tribal court did not have jurisdiction to disturb the bank's land sale but suggesting that certain damages for discrimination, awarded based on the bank's mistreatment of the Longs due to their Indian heritage, should not have been overturned.


[Unknown Act > Facts]
In 1986, during the Reagan administration's anti-drug initiative, Congress enacted a federal sentencing policy of punishing crimes involving crack cocaine at a 100-to-1 ratio compared to crimes involving powder cocaine. For example, the sentencing guidelines prescribe the same sentence for a defendant convicted of dealing 500 grams of powder cocaine as they do for a defendant convicted of dealing only five grams of crack cocaine. Congress declined to repeal the 100-to-1 ratio despite the U.S. Sentencing Commission's contention that the ratio led to exaggerated sentences for crack dealers.
Derrick Kimbrough pleaded guilty to distributing fifty or more grams of crack cocaine, along with other drug-and firearm-related offenses. The federal sentencing guidelines prescribed a sentence of between 19 and 22.5 years, but the district court judge considered this sentence "ridiculous." Citing the Sentencing Commission's reports, the judge decided to depart from the 100-to-1 ratio and hand down a sentence of 15 years. Since the Supreme Court's decision in United States v. Booker the sentencing guidelines have been advisory only, but the guidelines range is still among the factors a court must consider before handing down a reasonable sentence.
On appeal, the U.S. Court of Appeals for the Fourth Circuit rejected the below-guidelines sentence as unreasonable. The Fourth Circuit ruled that trial judges act unreasonably when they depart from the guidelines on the basis of a disagreement with a congressional sentencing policy. Therefore, judges cannot hand down below-guidelines sentences merely in order to avoid the sentencing disparity caused by the 100-to-1 ratio.


[Unknown Act > Conclusion]
Justice Ruth Bader Ginsburg authored the Court's 7-2 majority opinion reversing the Fourth Circuit and affirming the sentence handed down by the trial judge. Ginsburg noted that the drug trafficking statute still had some minimum sentencing requirements, and expressed the Court's confidence that district courts could maintain reasonably uniform approaches to cocaine sentencing. She also referred to the Court's assertion in Booker that, by making the Federal Sentencing Guidelines advisory, the Court was willing to accept some non-uniformity in sentencing. Justices Clarence Thomas and Samuel A. Alito dissented in the opinion.


[Unknown Act > Facts]
During Charles Riegel's angioplasty, his surgeon used an Evergreen Balloon Catheter to dilate his coronary artery. The catheter burst, causing extreme complications. Riegel sued the manufacturer, Medtronic, for negligence in the design, manufacture, and labeling of the device. Medtronic argued that Riegel could not bring these state-law negligence claims because they were preempted by Section 360k(a) of the Medical Device Amendments (MDA) to the Food, Drug, and Cosmetic Act. The MDA establishes a federal regulatory process for ensuring the safety of medical devices, and it provides that no state may set requirements that differ from or add to the federal ones. The District Court dismissed Riegel's claims as preempted by the MDA.
The U.S. Court of Appeals for the Second Circuit agreed that the suits based on medical devices like the Evergreen Balloon Catheter are preempted by the MDA. The catheter had been through the exceptionally rigorous "premarket approval" (PMA) process, by which federal regulators ensured that it met federal requirements. To allow state common-law suits for PMA-approved devices, the court ruled, would be to add a state requirement to the regulatory process despite the MDA's preemption clause.


[Unknown Act > Conclusion]
The Court, in an 8-1 decision, affirmed the Second Circuit and granted summary judgment in favor of Medtronic. The Court's opinion, written by Justice Antonin Scalia, noted that the MDA pre-empted state common law claims for defective devices such as this one. Riegel's negligence and strict liability claims relating to the safety and effectiveness of the catheter were based on New York's requirements and were therefore "different from, or in addition to" the federal requirements. Only Justice Ruth Bader Ginsburg dissented.


[Unknown Act > Facts]
In capital murder trial of Allen Snyder, an African-American, the prosecution used peremptory (automatic) challenges to dismiss five African-American prospective jurors. This resulted in Snyder being tried by an all-white jury, which found him guilty and approved the death penalty. The defense argued that the prosecution's striking of the black jurors was racial discrimination in violation of the Equal Protection Clause, according to the standard set forth by the Supreme Court in Batson v. Kentucky. As part of its case for the prosecution's alleged discriminatory intent, the defense cited two of the prosecutor's statements comparing the case to the O.J. Simpson murder trial. After having indirectly referred to the Simpson trial before jury selection, the prosecutor had invoked the case again during the sentencing phase, comparing aspects of Snyder's case to Simpson's and noting that the latter defendant "got away with it." The trial court applied the Batson framework and denied the defense's challenges.
On appeal, the Louisiana Supreme Court upheld the trial court, ruling that the trial judge had not acted unreasonably when he accepted the prosecution's race-neutral justifications for the dismissals of the black jurors. The court ruled that the O.J. Simpson references were harmless comparisons made in the course of a rebuttal, and it noted that the prosecution had not mentioned Simpson's or Snyder's race. When the Supreme Court instructed the state court to reconsider the case in light of Miller-El v. Dretke, which requires that courts consider the totality of the circumstances when evaluating discriminatory intent, the court affirmed the trial court a second time.


[Unknown Act > Conclusion]
The Court reversed the Louisiana Supreme Court in a 7-2 majority opinion written by Justice Samuel A. Alito. Alito concluded that the trial judge had acted improperly in allowing the peremptory strikes of the black jurors, pointing out that the reasons given by the prosecution for striking the jurors applied equally well to the white jurors the prosecution chose to keep. Justice Clarence Thomas, joined by Justice Antonin Scalia, filed a dissenting opinion, arguing that Batson does not require the exacting scrutiny imposed on the trial judge by the majority.


[Unknown Act > Facts]
Myrna Gómez-Pérez worked as a clerk for the United States Postal Service (USPS) in Puerto Rico. Gómez alleged that she was subject to retaliatory treatment after filing an age discrimination complaint against her supervisors under section 15 of the Age Discrimination in Employment Act (ADEA). A federal district court granted summary judgment to the USPS on the ground that the United States had not waived sovereign immunity as to retaliation claims under the ADEA.
Gómez appealed to the United States Court of Appeals in the First Circuit. It held that the USPS and Potter have waived sovereign immunity with respect to ADEA suits, but that Section 15 of the ADEA does not provide a cause of action for retaliation by federal employers.


[Unknown Act > Conclusion]
Yes, the ADEA prohibits retaliation against federal employees. Writing for a six-Justice majority, Justice Samuel A. Alito, Jr. relied on prior Court rulings holding that retaliation is covered by similar language in other antidiscrimination statutes. Noting the similarity between these statutes and the ADEA, Alito concluded that Congress had intended to include a retaliation prohibition in the ADEA. Chief Justice John G. Roberts and Justice Clarence Thomas filed dissenting opinions each joined in part by Justice Antonin Scalia.


[Unknown Act > Facts]
In 2004, New Mexico resident Larry Begay was arrested after brandishing and unsuccessfully shooting a rifle while begging his sister for money. Begay pleaded guilty to possessing the rifle. Prior to the firearm arrest, Begay had been convicted twelve times of driving while intoxicated. Under New Mexico law, each DWI conviction after the first three were considered felonies. The court concluded that the DWI convictions were violent felonies, triggering the federal career criminal law's 15-year mandatory minimum sentence. A deeply divided court of appeals panel affirmed the decision to treat the DWIs as violent felonies.


[Unknown Act > Conclusion]
In a 6-3 vote, the Court held that Begay's DWI convictions did not qualify as "violent felonies" because they were too different from the violent felony examples provided by Congress in the Armed Career Criminal Act (such as burglary, arson and extortion). Therefore, Begay should not have been subject to the mandatory sentencing hike. Justice Stephen Breyer wrote the majority opinion with Justice Antonin Scalia concurring and Justice Samuel Alito, joined by Justices Clarence Thomas and David Souter, dissenting


[Unknown Act > Facts]
Wanda Glenn, a long-time employee of Sears and manager of its women's department, was covered by the company's long-term disability plan. In 2000, Glenn took medical leave from Sears based on an ailing heart condition and submitted a disability claim under her ERISA plan. Metlife, the insurance carrier, approved the claim and told Glenn to seek social security payments which could then be deducted from her Metlife payments. However, after an administrative law judge determined, based in part on information provided by Metlife, that Glenn was disabled and eligible for social security payments, Metlife revised its own opinion and decided Glenn was no longer eligible for disability benefits.
Glenn brought suit against Metlife in district court, where Metlife's change of heart was vindicated, however the U.S. Court of Appeals for the Sixth Circuit reversed. In making its decision, the Sixth Circuit took into account Metlife's dual role as both the entity determining when disability awards should be paid out as well as the entity actually funding those payments, noting the possible conflicts of interest that could arise based on this arrangement. In seeking Supreme Court review, Metlife drew attention to circuit splits on the issue of whether these conflicts should be taken into account in determining the validity of Metlife's decisions on disability. In addition to the conflict of interest argument, Glenn pointed out that Metlife's flip-flop did not take into account certain of Glenn's doctor evaluations and that Metlife's representations to the administrative judge were at odds with its own eventual determination that she was not disabled.


[Unknown Act > Conclusion]
Maybe. The Court, in a 7-2 opinion, relied on its prior ruling in Firestone Tire & Rubber Co. v. Bruch to hold that a possible conflict of interest such as MetLife's should be taken into account in determining the legality of a claim denial. The significance and severity of the conflict must be determined by the facts of each individual case. Here, the Court found that the evidence was sufficient to prove that a strong conflict of interest existed. Based on the principle of deference to lower court decisions, the Court affirmed the Sixth Circuit. Justice Stephen Breyer delivered the opinion of the Court. Chief Justice John G. Roberts concurred in part and dissented in part, framing his dissent around his view that conflicts should be taken into account only where there is evidence that the benefits denial was motivated or affected by the administrator's conflict. Justice Anthony Kennedy also concurred in part and dissented in part, suggesting that the case should be remanded to the Sixth Circuit where it could apply the majority opinion to the facts of the case on its own. Justice Antonin Scalia, joined by Justice Clarence Thomas, dissented, finding the mere fact that an entity both determines claims and funds those claims insufficient to prove a conflict of interest.


[Unknown Act > Facts]
MeadWestvaco, an Ohio company, sold its lucrative Lexis/Nexis division for a $1 billion profit in 1994. Illinois attempted to claim a portion of that profit when collecting taxes from MeadWestvaco for doing business in the state. Illinois argued that Lexis/Nexis was an "operational" part of Mead's business and therefore subject to taxation outside Mead's home state. Mead countered that Lexis/Nexis was merely an "investment," whose sale was immune from taxation from outside jurisdictions. The trial court found that the division was key to Mead's operations, and therefore taxable, and the Illinois Appellate Court agreed.


[Unknown Act > Conclusion]
The Court sent the case back to the state appellate court holding that the court had previously applied the wrong test in defining the relationship between Lexis/Nexis and Meadwestvaco. Writing for seven of his colleagues, Justice Samuel A. Alito said that the appellate court, rather than applying an "operational function" test, should have looked for the existence of "functional integration, centralized management and economies of scale" between the two companies to determine whether or not they were a unitary business for tax purposes. Justice Clarence Thomas wrote a concurring opinion arguing that the Court should refuse jurisdiction over such state tax cases.


[Unknown Act > Facts]
Jose Medellin, a Mexican national, was convicted and sentenced to death for participating in the gang rape and murder of two teenage girls in Houston. Medellin raised a post-conviction challenge arguing that the state had violated his rights under the Vienna Convention, a treaty to which the United States is a party. Article 36 of the Vienna Convention gives any foreign national detained for a crime the right to contact his consulate. After his petition was ultimately dismissed by the Supreme Court (see Medellin v. Dretke ), Medellin's case returned to the Texas Court of Criminal Appeals. Medellin's argument rested in part on a ruling of the International Court of Justice (ICJ) holding that the U.S. had violated the Vienna Convention rights of 51 Mexican nationals (including Medellin) and that their convictions must be reconsidered. Medellin argued that the Vienna Convention granted him an individual right that state courts must respect, a possibility left open by the Supreme Court's 2006 decision in Sanchez-Llamas v. Oregon. Medellin also cited a memorandum from the President of the United States that instructed state courts to comply with the ICJ's rulings by rehearing the cases. Medellin argued that the Constitution gives the President broad power to ensure that treaties are enforced, and that this power extends to the treatment of treaties in state court proceedings.
The Texas Court of Criminal Appeals rejected each of Medellin's arguments and dismissed his petition. The court interpreted Sanchez-Llamas as standing for the principle that rulings of the ICJ are not binding on state courts. The Texas court stood by its position that allowing Medellin to raise the Vienna Convention issue after his trial would violate state procedural rules, and that those rules were not supplanted by the Convention. The President had no authority to order the enforcement in state court of an ICJ ruling, because that would imply a law-making power not allocated to him by the Constitution.