[Unknown Act > Facts]
On October 12, 2009, Abel Lopez was attacked and robbed by a man he later identified as Walter Fernandez. Lopez managed to call 911, and a few minutes after the attack, police and paramedics arrived on the scene. Detectives investigated a nearby alley that was a known gang location where two witnesses told them that the suspect was in an apartment in a house just off the alley. The detectives knocked on the door of the indicated apartment, and Roxanne Rojas answered. The detectives requested to enter and conduct a search, at which point Walter Fernandez stepped forward and refused the detectives entry. They arrested Fernandez and took him into custody. Police officers secured the apartment, informed Rojas that Fernandez had been arrested in connection with a robbery, and requested to search the apartment. Rojas consented to the search verbally and in writing. During the search, officers found gang paraphernalia, a knife, and a gun.
At trial, the defendant moved to suppress the evidence seized in the warrantless search, and the trial court denied the motion. The jury found Fernandez guilty on the robbery charge, and he did not contest the charges for possession of firearms and ammunition. On appeal, the defendant argued that the trial court improperly denied his motion to suppress. The California Court of Appeal for the Second District affirmed and held that the warrantless search was lawful because a co-tenant consented.


[Unknown Act > Conclusion]
No. Justice Samuel A. Alito, Jr. delivered the opinion for the 6-3 majority. The Supreme Court held that, although a warrant is generally required for a search of a home, the ultimate touchstone of the Fourth Amendment is whether the search was reasonable. Although warrantless searches are unreasonable when two co-tenants are present and one objects to the search, the Court has held that the same search is reasonable when the objecting tenant leaves. In this case, because the objecting tenant was arrested and no longer present, the Court held that the search was reasonable because the consenting tenant had the authority to allow the police into her home.
Justice Antonin Scalia wrote an opinion concurring in the judgment in which he refused the petitioner's argument that general property law should govern in this case. Specifically, he noted that a guest could not trespass on a property if one tenant allowed that guest to enter the property despite a co-tenant's objection. Therefore, he argued that the police could not have infringed on any property rights. In his separate opinion concurring in the judgment, Justice Clarence Thomas wrote that he disagreed with a prior holding regarding warrantless searches, Georgia v. Randolph . There, the Court held that, where two co-tenants are present and one tenant consents to a police search while the other refuses, the search is not constitutional. Instead, Thomas argued that a warrantless police search is constitutional if the police obtain voluntary consent from a person authorized to give that consent.
In her dissent Justice Ruth Bader Ginsberg argued that the police, once they were aware of Fernandez' objection, should have gotten a warrant prior to searching the premises. Justices Sonia Sotomayor and Justice Elena Kagan joined in the dissent.
Learn more about the Roberts Court and the Fourth Amendment in Shifting Scales, a nonpartisan Oyez resource.


[Unknown Act > Facts]
In 2006 Gina Fiore and Keith Gipson traveled from Las Vegas, Nevada to Atlantic City, New Jersey, to San Juan, Puerto Rico before returning to Las Vegas by way of Atlanta, Georgia. The two are professional gamblers with residences in California and Las Vegas. At a Transportation Security Administration (TSA) checkpoint in San Juan, Fiore and Gipson were subjected to heightened security because they were travelling on a one-way ticket. TSA officers search the gamblers luggage and found $97,000 in U.S. currency. San Juan Drug Enforcement Administration (DEA) officers arrived and questioned the pair to determine whether the money was the proceeds of illegal drug trade. Fiore and Gipson stated that the cash was their seed money and winnings from gambling. The DEA let Fiore and Gipson board the plane to Atlanta with their luggage.
When Fiore and Gipson landed at Atlanta Hartsfield-Jackson International Airport, Anthony Walden and other DEA agents approached and questioned them. Fiore and Gipson repeated their story and produced records of their travels. When a drug-detecting dog pawed Gipson's bag once, Walden stated that he had probable cause to seize the cash and took both Fiore and Gipson's bags before allowing them to continue on to Las Vegas without the money. When Fiore and Gipson got to Las Vegas they sent records of their gambling earnings along with past tax returns to prove their status as professional gamblers to Walden. Walden refused to return the money and referred the matter to a U.S. Attorney in Georgia based on a false probable cause affidavit. The U.S. Attorney found no probable cause and ordered the money returned. The money was returned to Fiore and Gipson seven months after it was seized.
Fiore and Gipson sued Walden in the U.S. District Court for the District of Nevada alleging that the seizure violated their Fourth Amendment rights. Walden moved to dismiss for lack of personal jurisdiction, and the District Court granted the motion. The U.S. Court of Appeals for the Ninth Circuit reversed, holding that the court did have personal jurisdiction because Walden intentionally caused foreseeable harm in Nevada by falsifying the probable cause affidavit and attempting to secure the seized funds permanently for the Atlanta DEA.


[Unknown Act > Conclusion]
No, unanswered. Justice Clarence Thomas delivered the opinion for the unanimous Court. The Court held that the district court could not exercise personal jurisdiction over Walden because he lacked contacts with Nevada. The Due Process Clause of the Fourteenth Amendment requires that a non-resident defendant have a substantial connection with the state in which he is sued. This connection must arise from the contacts that the defendant himself creates; yet all of Walden's conduct occurred in Georgia. The fact that Fiore and Gibson were injured in Nevada was insufficient to establish personal jurisdiction over Walden their only connection to Nevada was that they chose to reside there during the months the money was seized.


[Unknown Act > Facts]
In October 2001, Quality Stores -- a national company -- and its affiliates commenced bankruptcy proceedings. When laying off employees, Quality Stores issued severance pay as part of its employees' gross income and reported the payments for federal income tax purposes as "wages" on W-2 forms. As required for "wages", the Federal Insurance Contributions Act (FICA) tax was paid on severance payments. FICA is a tax imposed on wages earned to fund Social Security and Medicare; both employer and employee pay part of the tax. The employee's part is withheld from his paycheck. Quality Stores contends that severance pay does not qualify as "wages", but rather payments under a Supplemental Unemployment Benefit (SUB) plan that are not taxable under FICA. SUB is a corporate program that creates severance payments in the event of involuntary termination; SUB payments do not qualify as "wages" under FICA because they are given after termination of a job rather than for work completed.
Based on this line of reasoning, Quality Stores filed for a refund from the Internal Revenue Service (IRS). The IRS did not respond to Quality Stores' request for a refund, neither by allowing the claim nor denying it, and Quality Stores sued the IRS. The federal district court agreed with Quality Stores' view on severance payments. The U.S. Court of Appeals for the Sixth Circuit affirmed the district court and held that severance pay satisfies the elements Congress set out to determine SUB payments, which therefore makes such payments exempt from FICA taxes.


[Unknown Act > Conclusion]
Yes. Justice Anthony M. Kennedy delivered the opinion for the 8-0 majority. The Court held that the Federal Insurance Contributions Act's broad definition of wages did include severance pay. Because the statutory definition of wages in FICA is "remuneration for employment," the fact that the employment has ended is irrelevant, as the severance pay is still remuneration for services rendered when the workers were still employed. The Court also held that the specific exemptions that FICA lays out indicate that anything not specifically included in the exemptions should be considered taxable wages. Given the legislative history surrounding the issue, the appropriate reading is that severance payments should be treated as wages and subject to the withholding of taxes.
Justice Elena Kagan took no part in the discussion or decision of this case.


[Unknown Act > Facts]
In November 2009, Bruce Abramski learned that his uncle wanted to purchase a new 9mm Glock handgun. Abramski offered to purchase this weapon because, as a former Virginia police officer, he could get a discount. On November 17, Abramski purchased the handgun and completed a form distributed by the Bureau of Alcohol, Tobacco, Firearms and Explosives ("ATF") on which he checked a box indicating that he was not buying the gun on behalf of another person.
In June 2010, Abramski was arrested for suspicion of committing a bank robbery. During a search of his home, the police found a receipt showing that Abramski gave the handgun to his uncle in exchange for $400. The police charged Abramski with violating federal law by making a false, material statement on an ATF form and with respect to information kept by a licensed firearms dealer. Specifically, the government argued that Abramski knowingly made a false statement to a firearms dealer, that he intended to deceive the firearms dealer, and that he made the false statement about a "material fact" when he did not disclose that he was buying the firearm for his uncle. A grand jury subsequently indicted Abramski.
Abramski moved to dismiss the indictment and suppress evidence regarding the receipt. He argued that he legally transferred the firearm to his uncle and therefore never made any false statements to the ATF or the firearms dealer. He also argued that the police violated his Fourth Amendment rights because they did not have a proper warrant to conduct the search of his home from which the receipt resulted. The trial court denied Abramski's motion, stating that, because he did not disclose that the firearm was meant for his uncle, Abramski withheld a "material fact" required when purchasing a firearm. The trial court also held that the police did not violate Abramski's Fourth Amendment rights. Abramski entered a conditional guilty plea and received five years of probation and a $200 fine. The United States Court of Appeals for the Fourth Circuit affirmed.


[Unknown Act > Conclusion]
Yes, yes. Justice Elena Kagan delivered the opinion for the 5-4 majority. The Court held that, because the statute clearly sets up a system for verifying the would-be buyer's identity and for the maintenance of the seller's records, it is evidently interested in the final purchaser and not simply the middleman who initially purchases the firearm. Therefore, the statute is meant to keep guns out of the hands of those who cannot legally posses them, and this purpose can only be served if the records reflect the information of the person who actually takes control of the gun after its purchase. Such a reading follows previously established precedent that focuses on a transaction's true participants rather than the initial, nominal ones. In this case, by hiding the fact that Alvarez was the actual buyer, Abramski prevented the gun dealer from interacting directly with Alvarez and violated the statute.
Justice Antonin Scalia wrote a dissent in which he argued that, because neither Abramski nor his uncle were legally prohibited from owning a gun, the fact that Abramski was buying the gun for his uncle was immaterial to the sale itself. In attempting to otherwise read the statute, the majority opinion ignored the plain language of the statute itself, which is solely focused on the initial sale and not its ultimate consequences. Because there are other situations in which a gun changes hands that the statute does not consider to create a nominal purchaser and a true purchaser, Justice Scalia argued that the majority opinion misconstrues the statute's intended effect and broadens the statute beyond what Congress intended. Chief Justice John G. Roberts, Jr., Justice Clarence Thomas, and Justice Samuel A. Alito, Jr. joined in the dissent.


[Unknown Act > Facts]
John Dudenhoeffer and Alireza Partivopanah are former employees of Fifth Third Bank and are participants in the Fifth Third Bancorp Master Profit Sharing Plan, an employee stock ownership plan (ESOP), which is a defined contribution retirement fund for employees with Fifth Third as a trustee. Participants make voluntary contributions to the ESOP from their salaries and Fifth Third matches the contributions by purchasing Fifth Third stock for their individual accounts. During the time period in question, a large amount of the ESOP's assets were invested in Fifth Third stock. Also during this period, Fifth Third switched from being a conservative lender to a subprime lender and the portfolio became increasingly vulnerable to risk, which it failed to disclose. The price of the stock declined drastically and caused the ESOP to lose tens of millions of dollars. The respondents sued Fifth Third and argued that Fifth Third breached its fiduciary duty as imposed by the Employee Retirement Income Security Act (ERISA) by continuing to invest in Fifth Third stock despite having knowledge of its increasingly precarious value. The federal district court granted Fifth Third's motion to dismiss and held that the plaintiffs failed to state a claim for which relief could be granted because under ERISA, the investment decisions made by ESOP fiduciaries are presumed to be prudent. The U.S. Court of Appeals for the Sixth Circuit reversed and held that, while ESOP fiduciaries have a presumption of prudence, this presumption was an evidentiary matter and thus not grounds for a motion to dismiss.


[Unknown Act > Conclusion]
No. Justice Stephen Breyer delivered the opinion for the unanimous Court. The Court held that the presumption of prudence found by the lower courts is not included in ERISA's language; instead, the presumption is a court-made response to the different fiduciary duties of an ESOP fiduciary rather than fiduciaries of other eligible retirement plans under ERISA. Unlike other plans, ESOP plans prioritize buying a company's own stock, as opposed to diversifying retirement funds across a number of different investments. For non-ESOP retirement funds, normal prudence requires fiduciaries to spread the investment risk out across multiple investments, which is a prudential standard that cannot be applied to ESOP. Therefore, some courts had held that ESOP fiduciaries were entitled to a presumption of prudence regarding their choice of whether to purchase their own company stock or not. The Supreme Court, however, held that these differing requirements did not amount to a presumption of prudence for ESOP fiduciaries. Instead, the Court found that ESOP fiduciaries have the same fiduciary duty as non-ESOP fiduciaries, except as it applies to diversification of investments. The Court remanded the case back to the district court, instructing the lower court to analyze Fifth Third's motion to dismiss under the pleading standards set forth in Ashcroft v. Iqbal and Bell Atlantic Corp. v. Twombly, requiring a plaintiff's pleadings contain enough facts to give rise to a plausible entitlement to relief.


[Unknown Act > Facts]
On January 19, 2005, Scott D. Cheever shot and killed Greenwood County Sheriff Matthew Samuels at the residence of Darrell and Belinda Coopers in Hilltop, Kansas. Samuels had gone to the Coopers' residence based on a tip to arrest Cheever for outstanding warrants. He found the Coopers, Cheever, and two others cooking and ingesting methamphetamines. In the following attempts to arrest Cheever and retrieve the injured Samuels, Cheever also shot at several other officers.
At trial, Cheever asserted a voluntary intoxication defense and argued that the methamphetamine use rendered him mentally incapable of the premeditation required for murder. During the course of the trial, the judge ordered Cheever to undergo a psychiatric examination conducted by a psychiatric hired by the government. The prosecution sought to bring the transcript of the interview into evidence to impeach Cheever's testimony regarding the order of events at the Coopers' residence, which the court allowed. After the defense rested their case, the prosecution called the psychiatrist to the stand as a rebuttal witness to respond to the defense's claims regarding Cheever's mental capacity at the time of the crime. The trial court allowed the psychiatrist's testimony as a rebuttal witness. The jury found Cheever guilty and, at a separate sentencing hearing, sentenced him to death. The Kansas Supreme Court held that the admission of the government psychiatrist's testimony into evidence violated Cheever's Fifth Amendment rights.


[Unknown Act > Conclusion]
No. Justice Sonia Sotomayor delivered the opinion for a unanimous Court. The Court held that the Fifth Amendment does not prevent the prosecution from introducing psychiatric evidence to rebut psychiatric evidence presented by the defense. To deny the prosecution that right would undermine the adversarial process, because the jury should hear both sides of any discussion of the defendant's mental state at the time of the alleged crime. The Court also held that this ruling was in line with Fifth Amendment jurisprudence that does not allow a defendant to avoid cross-examination. When the defendant's mental state is at issue and the defense offers evidence through expert testimony, it may be rebutted by expert testimony from the prosecution.


[Unknown Act > Facts]
Kevin Loughrin created a scheme to obtain cash by stealing checks from people's outgoing mail, altering them to make purchases at Target, and returning the purchases for cash. When the scheme came to an end, he and Theresa Thongsarn were indicted on six counts of bank fraud, two counts of aggravated identity theft, and one count of possession of stolen mail. Loughrin moved to dismiss the case and alleged violations of the Speedy Trial Act; the district court denied the motion to dismiss. At trial, Loughrin requested that the jury instructions specify that the jury had to find that he had the intent to defraud a financial institution in order to find him guilty of bank fraud. The district court held that such an instruction was not necessary and declined to use it. Loughrin was convicted on all counts and sentenced to 36 months in prison. The U.S. Court of Appeals for the Tenth Circuit affirmed.


[Unknown Act > Conclusion]
No. Justice Elena Kagan wrote the opinion for the unanimous Court. The Court held that, while one clause of the statute requires the intent to defraud a bank, the second clause does not require it. Instead, this second clause only requires that the defendant intend to obtain any property under the control of a bank. The Court held that requiring these two clauses to be read as having the same intent would render the second one meaningless; the structure of the statute indicated that the two clauses had different requirements. However, because the second clause should not apply to any and all fraud where the defrauder receives a check, the Court stated that the specific language limited its coverage to circumstances where the defendant's false statement "naturally induces" the bank to part with money in its control, instead of where a bank is only tangentially involved.
Justice Antonin G. Scalia wrote an opinion concurring in part and concurring in the judgment in which he argued against the "natural inducement" test promoted by the Court. He argued that the dictionary definition of "by means of" language of the second clause included tangential involvement of a bank, although he agreed that the clause should not apply to all fraud where the defrauder receives a check. Justice Clarence Thomas joined the concurrence in part and concurrence in the judgment. In his separate opinion concurring in part and concurring in the judgment, Justice Samuel A. Alito, Jr. wrote that the second clause only requires that the defendant knowingly execute a scheme to obtain bank property, instead of intentionally doing so.


[Unknown Act > Facts]
In 2007, the Massachusetts state legislature created a 35-foot buffer zone around the entrances, exits, and driveways of abortion clinics. The petitioners, individuals who routinely engage in "pro-life counseling" outside of state abortion clinics, sued in federal district court and argued that the law violated the First Amendment protection of free speech. The district court held that, although the law placed a restriction on the time, place, and manner of speech, the law was constitutional because it was content-neutral and still left adequate, if not perfect, alternative means of communications. The U.S. Court of Appeals for the First Circuit affirmed and held that the Supreme Court, in Hill v. Colorado had already affirmed a similar statute in Colorado that prohibited certain activities within 100 feet of abortion clinics.


[Unknown Act > Conclusion]
Yes, unanswered. Chief Justice John G. Roberts, Jr. delivered the opinion for the 9-0 majority. The Court held that the Massachusetts law was content-neutral on its face because a violation depends not on the speech itself but on the location of the speech, and therefore does not need to be analyzed under strict scrutiny. However, the Court also held that the law is still not sufficiently narrowly tailored to serve a significant government interest because it places too great a burden on the petitioners' First Amendment Rights. By denying the petitioners the ability to engage in conversation and leafleting on public streets and sidewalks, the law prevents the petitioners from engaging in exactly the transmission of ideas the First Amendment is meant to protect. The Court also held that, in enacting the law, Massachusetts overlooked other options that could serve the same interests without placing an undue burden on historical avenues of speech and debate.
In his opinion concurring in the judgment, Justice Antonin Scalia wrote that the law is content-based and therefore must be examined under strict scrutiny. A blanket prohibition of speech in areas where only one type of politically charged speech is likely to occur cannot be content-neutral. Justice Scalia also pointed out that the majority opinion did not address the question of whether Hill v. Colorado should be limited or overruled. Because Justice Scalia argued that the law was content-based and therefore subject to strict scrutiny, he wrote that Hill should be overruled because it contradicts First Amendment jurisprudence. Justice Anthony M. Kennedy and Justice Clarence Thomas joined in the opinion concurring in judgment. Justice Samuel A. Alito, Jr. wrote a separate opinion concurring in judgment in which he argued that the law's exemption for clinic employees and volunteers constitutes viewpoint discrimination because it silences abortion opponents while allowing clinic workers and supporters to express their views.


[Unknown Act > Facts]
In January 2010, Sprint Communications Co. filed a complaint with the Iowa Utilities Board ("IUB") asking for a declaration that it was proper to withhold certain VoIP call access charges from Windstream (formerly Iowa Telecom). Before IUB addressed the complaint, Sprint settled the dispute with Windstream and withdrew its complaint. However, IUB continued the proceeding so that it could decide a greater underlying issue of how VoIP communications should be classified under federal law. In February 2011, IUB issued an order with its own interpretation of VoIP's classification under federal law along with a determination that Sprint was liable to Windstream for the access charges.
Sprint challenged IUB's order by filing a complaint in both state court and federal district court, alleging that federal law preempts the IUB's decision. In order to proceed with the federal complaint first, Sprint filed a motion to stay the state case until resolution of the federal case. In turn, the IUB filed a motion asking the federal court to abstain and dismiss the case under the doctrine of Younger v. Harris. Generally, this doctrine states that a federal court shall abstain from hearing a case if there is a threat of interference with a state court proceeding involving important state interests. The district court granted IUB's motion and dismissed Sprint's federal complaint. Sprint appealed to the United States Court of Appeals for the Eighth Circuit, which upheld the district court's abstention, but determined that a stay on the federal proceedings was more appropriate than dismissal.


[Unknown Act > Conclusion]
No. Justice Ruth Bader Ginsburg delivered the opinion for a unanimous Court. The Court held that a federal court is not required to abstain from deciding a case simply because there is a case in state court that deals with the same subject matter. Because the Younger doctrine only required a court to abstain when there are parallel criminal cases in federal and state courts or when there are certain civil proceedings that are very similar to criminal ones, it is meant only for exceptional cases. The proceeding in question is civil, not criminal, and does not affect a state court's ability to perform its judicial function, so none of the Younger exceptions are triggered in this case.


[Unknown Act > Facts]
ICON Health & Fitness, Inc. (ICON) manufactures and sells exercise equipment throughout the United States. In 2000, ICON obtained U.S. Patent No. 6,019,710 (the '710 patent) for a system designed to link parts in elliptical exercise machines. In 2010, ICON filed a complaint against another manufacturer and seller of exercise equipment, Octane Fitness (Octane), and claimed that Octane's elliptical design infringed upon the '710 patent.
The federal district court held that Octane's design did not violate ICON's '710 patent. ICON appealed to the U.S. Court of Appeal for the Federal Circuit. Octane argued that ICON's lawsuit was not based on any real patent infringement, but instead aimed at hampering upstart competitors with expensive, frivolous lawsuits. Therefore, Octane asked the court to apply a patent law attorney fees statute, a statute that awards attorney fees when the plaintiff's suit is found to be "exceptional." The appellate court affirmed the lower court's decision, but found that ICON had not acted "exceptionally" under the statute.


[Unknown Act > Conclusion]
Yes. Justice Sonia Sotomayor delivered the opinion for the unanimous Court. The Court held that the appellate court construed the attorney fees statute in a manner that was unduly rigid. Restricting the grant of reasonable attorney fees to the prevailing party in all but two exceptions would render the statute meaningless and would contradict patent litigation norms. The appellate court’s interpretation of the statute would also impermissibly encumber the district court’s discretionary power to award such fees. The Court also held that an “exceptional” case is simply one that stands out from others because of its frivolous nature relating to the legal arguments or merits of the claim. District courts may determine exceptionalness by considering the totality of the circumstances on a case-by-case basis. Finally, the Court rejected the appellate court’s “clear and convincing evidence” standard that successful patent litigants would have to establish in order to receive fees. Instead, the Court held that a simple discretionary inquiry would serve to determine whether granting attorney fees is appropriate.


[Unknown Act > Facts]
Lexmark International, Inc. (Lexmark) is a large producer of printers and toner cartridges. In 2002, Lexmark sued Static Control Components, Inc. (SCC) and alleged that SCC violated Lexmark's intellectual property when it manufactured microchips used in the repair and resale of Lexmark toner cartridges. SCC filed a counterclaim and argued that Lexmark, among other things, violated the Lantham Act by engaging in false advertising. The district court dismissed SCC's Lantham Act claims for lack of standing. The U.S. Court of Appeals for the Sixth Circuit reversed the ruling and held that the lower court employed the wrong test to establish standing.
The Sixth Circuit relied on the "reasonable interest" test to establish standing under the Lantham Act, but unlike its sister circuits, did not use the AGC Factors, which use the same standards as those to establish an antitrust claim. Under this test, a claimant must demonstrate 1) a reasonable interest against the alleged false advertising and 2) a reasonable basis for believing that the alleged false advertising will damage that interest.


[Unknown Act > Conclusion]
No. Justice Antonin Scalia delivered the opinion for the unanimous Court. The Court held that the Lanham Act allowed any party to sue that had been injured by false advertising. However, because that language is so broad, the Court held that a determination of standing to sue should be based on proof that the plaintiffs' interests fall within the zone of interests protected by the law and that a violation of the statute was the proximate cause of the injury in question. In order to prove that the plaintiffs' interest fall within the zone of interest the Lanham Act protects, the plaintiffs must prove that they have a commercial interest in reputation or sales. To prove that the injury in question was caused by a violation of the statute, the plaintiff must show that that economic or reputational injury stemmed directly from the defendant's false advertising. The Court also held that the "reasonable interest" test the U.S. Court of Appeals for the Sixth Circuit applied was not feasible because it was too vague. In this case, Static Control Component's claim satisfied both the zone of interest and proximate cause requirements to pursue a claim under the Lanham Act.


[Unknown Act > Facts]
Pamela J. Harris is a personal care assistant who provides in-home care to disabled participants in the Home Services Program administered by a division of the Illinois Department of Human Services (Disabilities Program). The state pays the wages of assistants who work with participants in either the Disabilities Program or a program run by the Division of Rehabilitation Services (Rehabilitation Program). In 2003, a majority of the Rehabilitation Program personal assistants elected Service Employees International Union Healthcare Illinois & Indiana as their collective bargaining representative. The union and the state negotiated a collective bargaining agreement that included a "fair share" provision, which required all personal assistants who are not union members to pay a proportionate share of the costs of the collective bargaining process and contract administration. The Disabilities Program assistants rejected union membership in 2009.
In 2010, Harris and other personal assistants from both programs sued Governor Pat Quinn and the unions and claimed that the fair share fees violated their freedom of speech and freedom of association rights under the First and Fourteenth Amendments. The district court dismissed the plaintiffs' claims. On appeal, the U.S. Court of Appeals for the Seventh Circuit affirmed. The appellate court held that the state may require its employees, including personal assistants such as the plaintiffs, to pay fair share fees and further held that the claims of the Disability Program were not ripe for judicial review.


[Unknown Act > Conclusion]
Yes, undecided. Justice Samuel A. Alito, Jr. delivered the opinion for the 5-4 majority. The Court held that the apparently controlling precedent of Abood v. Detroit Board of Education, which stated the necessity of the fair share provision to prevent non-union members from taking advantage of the union's collective bargaining, cannot justify the violation of the petitioners' First Amendment rights in this case. Upon review, the Court held that the analysis in the Abood decision fundamentally misconstrued previous judicial precedent on the issue of collective bargaining as well as the differences between union relations in public-and private-sector employment. That precedent especially does not apply in this case because the petitioners are not full public-sector employees but are only considered such for the sake of limited collective bargaining. Because the union's role is so narrow in this case, there is no compelling interest served by forcing the petitioners to contribute that cannot be satisfied by less restrictive means.
Justice Elena Kagan wrote a dissent in which she argued that the precedent Abood established was highly influential in protecting the best interests of employees and government entities by enabling the government to bargain with a single body without allowing non-union members to take advantage of these benefits. Although the majority opinion focused on the ways in which the petitioners are not public-sector employees and not subject to this precedent, Justice Kagan emphasized the vast degree of oversight the state exercised over them and the state's interest in working with an effective bargaining agent. Therefore, there is no reason to differentiate this case from the ruling required by the Abood precedent. Justice Ruth Bader Ginsburg, Justice Stephen G. Breyer, and Justice Sonia Sotomayor joined in the dissent.


[Unknown Act > Facts]
After Jake LaMotta retired from boxing, he and Frank Peter Petrella (F. Petrella) created two screenplays and a book based on LaMotta's life. These works were registered with the United States Copyright Office in 1963, 1973, and 1970, respectively. In 1976, LaMotta and F. Petrella signed a written agreement that granted the exclusive rights to the book and the screenplays to Chartoff-Winkler Productions, Inc, which in turn assigned those rights to a subsidiary of Metro-Goldwyn-Mayer Studios, Inc. (MGM), United Artists Corporation. In 1980, United Artists Corporation registered a copyright for the film "Raging Bull" based on LaMotta and F. Petrella's work. When F. Petrella died in 1981, which was still within the original 28-year period of the copyright, his renewal rights passed to his heirs.
In 1991, Paula Petrella (Petrella), the daughter of F. Petrella, filed an application for the renewal of copyright rights on the 1963 screenplay. In 1998, Petrella's attorney contacted MGM and asserted that Petrella had obtained the rights to the screenplay and its derivative works, which included the movie "Raging Bull," and that MGM was infringing on those rights. MGM argued that the 1963 screenplay was a collaboration between LaMotta and F. Petrella, so MGM retained the rights to the screenplay under the agreement with LaMotta. MGM also argued that there was no "substantial similarity of protectable elements" between the 1963 screenplay and the film. In 2009, Petrella sued MGM for copyright infringement, and the federal district court granted summary judgment for MGM under the doctrine of laches, which prevents a legal claim from being enforced if a long delay in filing the claim adversely affected the defendant's ability to fight the claim. The U.S. Court of Appeals for the Ninth Circuit affirmed.


[Unknown Act > Conclusion]
No. Justice Ruth Bader Ginsburg delivered the opinion of the 6-3 majority. The Court held that the doctrine of laches could not be used to bar a copyright suit that seeks relief for damages that occurred within the three-year timeframe allowed by the Copyright Act. This limitation prevents a defendant from being held liable for multiple violations of the same work. Because Petrella did not seek relief for damages prior to three years before the filing of her suit, the doctrine of laches does not apply to this case. The Court also held that the doctrine of laches has never been used to bar claims for wrongs that occurred within the acceptable timeframe, so there was no precedent for the type of reading that MGM argued was necessary. Because laches originally served as a guide to adjudicating copyright disputes when there was no statutory limitation, there is no reason to use the doctrine to interpret the statute.
Justice Stephen G. Breyer wrote a dissent in which he argued that the doctrine of laches must be applied to the three-year statute of limitations in order for the courts to protect the equity of the legal system. Allowing the three-year limitation to control every copyright case regardless of the circumstances could create loopholes such as permitting plaintiffs to sue for copyright violations on the same work every three years or to wait long enough that evidence that could be used to defend against the suit is lost. Justice Breyer also argued that judicial precedent held that statutory limitations are subject to further adjustment in the name of equity. Chief Justice John G. Roberts, Jr. and Justice Anthony M. Kennedy joined in the dissent.


[Unknown Act > Facts]
Section 125 of the Aviation Transportation Safety Act (ATSA) states that an air carrier who voluntarily reports suspicious transactions or behavior shall not be "civilly liable." The immunity does not apply to disclosures made with "actual knowledge" that the disclosure is false, inaccurate, or misleading. Likewise, the immunity does not extend to an air carrier that makes a disclosure with "reckless disregard" as to its truth or falsity.
William Hoeper, a pilot for Air Wisconsin, made four unsuccessful attempts to become certified to fly another type of aircraft after Air Wisconsin discontinued use of the type of plane that Hoeper had previously piloted. During his fourth and final opportunity to pass the test, Hoeper abruptly ended the test because he believed that the test administrators were deliberately sabotaging his efforts to pass. One test administrator knew that the Transportation Security Administration (TSA) had issued a firearm to Hoeper in his role as a federal flight deck officer (FFDO). FFDO pilots are not allowed to carry the firearm while traveling as passengers. This administrator booked Hoeper on a flight from the testing center in Virginia to Hoeper's home in Denver and then called the TSA to report that Hoeper was a disgruntled, and possibly armed, employee. In response, TSA officials arrested and searched Hoeper.
Hoeper sued Air Wisconsin in a Colorado state court and alleged defamation under Virginia law. Air Wisconsin moved for a directed verdict based on the argument that it was immune from civil liability under ATSA. Air Wisconsin also argued that Hoeper could not prove "actual malice" because its statements were "substantially true" and therefore protected by the Free Speech Clause of the First Amendment. The trial court denied the motion to dismiss. The jury found that Air Wisconsin's statements to the TSA were false and that it made at least one statement with reckless disregard for the truth, so the jury awarded Hoeper damages. A Colorado appellate court affirmed the verdict. The Colorado Supreme Court held that the trial court's submission of the matter to the jury was improper; however, the error was harmless in this case because Air Wisconsin was not entitled to claim immunity under ATSA. The Colorado Supreme Court further held that substantial evidence supported the jury's finding that the statements were false.


[Unknown Act > Conclusion]
No. Justice Sonia Sotomayor delivered the opinion for the 6-3 majority. The Court held that ATSA immunity protects false statements, as long as they are not materially false within the ATSA context, which means that they would not affect a reasonable security officer's perception of and response to a particular threat. Although Air Wisconsin's report to the TSA contained slight inaccuracies, they would not have influenced a TSA security officer's desire to investigate Hoeper, given the true facts that he was an FFDO and upset about losing his job. The Court further held that the Colorado Supreme Court erred in its analysis of material falsity and that Air Wisconsin was entitled to ATSA immunity as a matter of law.
Justice Antonin Scalia wrote an opinion concurring in part and dissenting in part in which he argued that, while he agreed with the majority opinion's ATSA immunity analysis, he would have remanded the case for further proceedings. He argued that the issue of material falsity was an important question for the jury and that a reasonable jury could find that Hoeper's conduct did not justify the making of any report to the TSA. Justice Clarence Thomas and Justice Elena Kagan joined in the opinion concurring in part and dissenting in part.


[Unknown Act > Facts]
During the 2004 presidential campaign, President George W. Bush's team scheduled a campaign stop in Jacksonville, Oregon. With the approval of local law enforcement agencies, opponents of President Bush organized a peaceful demonstration to protest his policies. The demonstration took place at a public park before moving to the street near the local inn where the President was staying. Eventually, both opponents and supporters of President Bush gathered on the street of near the entrance to the inn, and each group had equal access to deliver its message to the President at the time of his arrival. Before the President arrived, Secret Service agents ordered local police to push protestors away from the immediate area for security reasons. The agents then ordered that the protesters be driven farther away from the inn onto the east side of 5th street. However, agents failed to give the same directive for supporters who remained stationed on the streets close to the inn. The plaintiffs alleged that the orders to move were unintelligibly given and that police proceeded to use force before confirming that the orders were understood or were being followed.


[Unknown Act > Conclusion]
Yes, no. Justice Ruth Bader Ginsburg delivered the opinion for the unanimous Court. The Court held that the agents had not violated any clearly established law in their attempt to maintain an appropriate level of protection for the President despite his unscheduled detour. Because the plaintiffs were unable to establish that the Secret Service agents engaged in crowd control should have been aware of their duty to ensure that different groups obtained equal access to the President, the agents are eligible for qualified immunity. The Secret Service agents' actions were in direct response to the relative security risks the groups posed based on their locations, and so their actions did not violate the First Amendment.


[Unknown Act > Facts]
In August 2000, Vonlee Nicole Titlow helped his aunt Billie Rogers murder his wealthy uncle Donald Rogers. After Titlow was charged with first-degree murder, the prosecution offered him a plea bargain. In exchange for testifying against Billie Rogers, Titlow could plead guilty to manslaughter and receive a reduced sentence. After consulting with his attorney, Titlow accepted the deal. However, before sentencing, Titlow spoke to a sheriff's deputy who suggested that he withdraw his guilty plea and consult another attorney. Titlow followed the deputy's advice, hired a new attorney and withdrew his guilty plea.
Following his trial, a jury convicted Titlow of second-degree murder and sentenced him to 20-to-40 years in prison. This led Titlow to accuse his second attorney of ineffective assistance of counsel for allowing him to withdraw the original guilty plea. Both the trial court and the Michigan Court of Appeals rejected Titlow's claim. Titlow petitioned the Michigan Supreme Court to hear his case, but they refused to do so.
Titlow then petitioned for federal habeas corpus relief, but the district court denied his claim as well. The district court held that Titlow failed to meet the standard for overturning a state-court conviction under the Antiterrorism and Effective Death Penalty Act ("AEDPA"). The Court of Appeals for the Sixth Circuit reversed the lower court's decision and ordered the state to reoffer Titlow's original plea agreement. The appellate court held that Titlow's second attorney was ineffective for failing to investigate his claims further, failing to obtain documents from the first attorney, and failing to convince Titlow to take the plea bargain.


[Unknown Act > Conclusion]
No; no; unanswered. Justice Samuel A. Alito, Jr. delivered the opinion for the 9-0 majority. The Supreme Court held that, when a state prisoner asks a federal court to set aside a sentence due to ineffective assistance of counsel, the AEDPA requires the Court of Appeals to apply a "doubly-deferential" standard in which both the state court and the defense attorney are given the benefit of the doubt. Because the state court's factual determination is assumed to be correct, the state prisoner has the burden to disprove that determination with clear and convincing evidence. In this case, the Court held that there was no convincing evidence that the new counsel's advice did not stem from the defendant's continued protestations of innocence. In the absence of such evidence, the new counsel's advice was reasonable and the defendant could not prove that he received ineffective assistance of counsel.
In her concurring opinion, Justice Sonia Sotomayor wrote that the defendant had the burden to prove that the new counsel acted ineffectively and that the state court decided the case incorrectly—both burdens that the defendant did not meet. Justice Sotomayor also emphasized the limited scope of the ruling in this case, which referred only to the facts at hand. Justice Ruth Bader Ginsburg wrote a separate concurring opinion in which she argued that the plea deal became invalid when the defendant refused to testify against her aunt, so the prosecutor could not be directed to renew a plea deal that could no longer exist. Without the existence of a still-possible plea deal, there was no reversible error in the trial.


[Unknown Act > Facts]
Between 1969 and 1980, Dr. Morton Mower worked with Dr. Mieczyslaw Mirowski to develop the implantable cardioverter defibrillator (ICD) and the cardiac resynchronization therapy device (CRT), both devices that are meant to treat different kinds of heart failure. Mirowski Family Ventures (MFV) held both patents and licensed them to Guidant Corp. In 1991, Medtronic, a manufacturer of medical devices and equipment, entered into a sublicense agreement with Eli Lilly & Co., Guidant Corp's predecessor-in-interest regarding these patents. The agreement obligated MFV to inform Medtronic which items were covered by which patents, and if Medtronic disagreed, Medtronic could retain patent rights and file for a declaratory judgment of non-infringement on the patents. In October and November of 2007, MFV identified several Medtronic products that it believed infringed on its patents, and Medtronic subsequently sued for a declaratory judgment of non-infringement.
In the bench trial in district court, the court, relying on precedent, stated that the patent holder bears the burden of proving that infringement occurred and found in favor of Medtronic. MFV appealed and argued that the burden falls on the alleged patent infringer to prove that infringement did not occur. The United States Court of Appeals for the Federal Circuit held that, because Medtronic is the party seeking relief from the court, it bears the burden to prove that it did not infringe on MFV's patents.


[Unknown Act > Conclusion]
Yes. Justice Stephen G. Breyer delivered the opinion for the unanimous Court. The Supreme Court held that judicial precedent supports the view that the burden of proof in patent cases always rests with the owner of the patent, regardless of the type of legal action in question. To shift the burden based on the type of legal action could create ambiguity regarding the rights of each party. Because the public interest favors a well-functioning patent system, it is in the best interest of the public not to shift the ordinary rule regarding burden of proof in patent cases.


[Unknown Act > Facts]
In 2009 the U.S. Corps of Engineers contracted with Atlantic Marine Construction Company (Atlantic) to build a child development center at Fort Hood, a military base located in the western district of Texas. Atlantic then subcontracted with J-Crew Management, Inc. (J-Crew) to provide labor and materials. The subcontract agreement contained a forum selection clause stating that any dispute would be litigated in Circuit Court for the City of Norfolk, Virginia, or the U.S. District Court for the Eastern District of Virginia, Norfolk Division. Despite this clause, J-Crew brought suit against Atlantic in the U.S. District Court for the Western District of Texas for failure to pay for work J-Crew performed.
Atlantic moved to dismiss the suit under Federal Rule of Civil Procedure 12(b)(3) and 28 U.S.C. §1406, arguing that the forum selection clause required the suit to be brought in Virginia. Atlantic also moved, in the alternative, to transfer the case to the Eastern District of Virginia under 28 U.S.C. §1404(a). The district court denied Atlantic's motions, holding that Atlantic did not show why the interest of justice or the convenience of the parties weighed in favor of Virginia. Atlantic petitioned the U.S. Court of Appeals for the Fifth Circuit for a writ of mandamus ordering the district court to dismiss the case or transfer it to Virginia. The court of appeals held that the district court did not abuse its discretion and venue was proper in the Texas court because the parties entered into and performed the agreement in that district.


[Unknown Act > Conclusion]
Yes; the party acting in violation of the forum-selection clause. Justice Samuel A. Alito, Jr. delivered the opinion for the unanimous Court. The Court held that Section 1404 codified a doctrine of transfer that allowed cases to be transferred to a more convenient forum rather than being dismissed. Because both Section 1404 and the forum non conveniens doctrine from which it derives depend on a balancing-of-interests standard, courts should use that standard when evaluating claims under Section 1404. The Court also held that, when parties have agreed to a forum-selection clause, a court should transfer the case to that forum unless there are exceptional factors at work. Therefore, the party requesting the change of forum should bear the burden of proving that such a change is necessary.


[Unknown Act > Facts]
Harvey N. Levin was hired as an Illinois Assistant District Attorney on September 5, 2000. On May 12, 2006 when he was fired, Levin was over the age of sixty, and he believed that he was fired due to his age and gender. He was replaced by a female attorney in her thirties. Levin sued the state of Illinois, the Illinois Attorney General Lisa Madigan in both her individual and official capacities, and four other Attorney General employees under the Age Discrimination Employment Act (ADEA), the Civil Rights Act of 1964, and the Equal Protection Clause of the Fourteenth Amendment. The defendants moved to dismiss the suit by arguing that either the claim under the ADEA precluded the Civil Rights Act claim or that they were entitled to qualified immunity under the ADEA. The district court originally ruled that the ADEA did not prevent the claim from proceeding under the Civil Rights Act and granted the qualified immunity. After the case was reassigned to a different district court judge, the district court held that Levin was not an employee for the purpose of the Civil Rights Act and the ADEA, so he could not pursue those claims, and that the defendants were not entitled to qualified immunity. The U.S. Court of Appeals for the Seventh Circuit affirmed.


[Unknown Act > Conclusion]
Unanswered. In an unsigned, per curiam opinion, the Court dismissed the case as improvidently granted.


[Unknown Act > Facts]
On January 25, 1997, a sixteen-year-old girl was kidnapped, murdered, and raped. After an investigation, the police arrested Robert Woodall, who subsequently pled guilty to capital murder, capital kidnapping, and first-degree rape. At trial, Woodall invoked his Fifth Amendment right to avoid self-incrimination and declined to testify, and so he asked the judge to instruct the jury not to make any adverse inferences from that decision. The judge refused to issue the "no adverse inference" instruction and stated that, by entering a guilty plea, Woodall waived his right to be free from self-incrimination. The jury found Woodall guilty on all charges and the judge sentenced him to the death penalty and two subsequent life sentences.
Woodall appealed to the Kentucky Supreme Court, which affirmed both Woodall's conviction and sentence. In 2006, Woodall filed a habeus corpus petition in federal court, and that court held that the trial court violated Woodall's Fifth Amendment right when it refused to offer the requested jury instruction. In addition, that court also held that Woodall's Fifth, Eighth, and Fourteenth Amendment rights were violated when the trial court allowed the state to dismiss an African-American juror without a mandatory hearing for cause. On appeal, the U.S. Court of Appeals for the Sixth Circuit affirmed the district court's decision on the issue of self-incrimination but did not address the other issues.


[Unknown Act > Conclusion]
No, unanswered. Justice Antonin Scalia delivered the opinion of the 6-3 majority. The Court held that the trial court did not violate Woodall's Fifth Amendment rights by not providing a "no adverse influence" jury instruction because Woodall's guilty plea negated the possibility of any adverse influence. Because Woodall admitted to the elements of the case that the prosecution would otherwise have had to prove, there was no inference left for the jury to make. The Court therefore held that the state courts' rejection of Woodall's Fifth Amendment claim was not objectively unreasonable and should not have proceeded to federal courts.
Justice Stephen G. Breyer wrote a dissenting opinion in which he argued that a criminal defendant is entitled to a "no adverse influence" jury instruction at the penalty phase of a capital trial just as he is during the guilt phase if he requests one. Justice Breyer wrote that there was no reason to deviate from established Fifth Amendment jurisprudence on this issue and that, in doing so, the majority opinion construes the precedent too narrowly. Justice Ruth Bader Ginsburg and Justice Sonia Sotomayor joined in the dissent.


[Unknown Act > Facts]
In 1995, Congress enacted the Private Securities Litigation Reform Act (PSLRA), which was meant to combat issues such as nuisance filings, targeting of specific clients, and client manipulation in class action suits. To prevent plaintiffs from filing class action suits in state courts in order to get around the restrictions of PSLRA, Congress enacted the Securities Litigation Uniform Standards Act (SLUSA), which provided for the dismissal or removal of a class action suit brought by more than 50 plaintiffs in connection with a "covered security." The term "covered security" was limited to a subset of securities that were traded on a national exchange or issued by a federally registered investment company.
In 2009, the Securities and Exchange Commission (SEC) sued the Stanford Group Company and other holdings of R. Allen Stanford for allegedly perpetrating a massive Ponzi scheme. Two groups of Louisiana investors also sued Stanford holdings for their roles in the Ponzi scheme and for violations of the Louisiana Securities Act. These cases were consolidated with two others against Stanford holdings and moved to the district court for the Northern District of Texas. The defendants moved to dismiss the complaints under SLUSA and argued that the court should adopt an expansive interpretation of "covered securities." The district court held that the funds were not covered securities, but it granted the dismissal because the funds were represented as covered securities and because it was likely that at least one of the plaintiffs liquidated a retirement account, which a covered security, in order to purchase the funds in question. The U.S. Court of Appeals for the Fifth Circuit reversed and held that there was not a sufficient connection between the misrepresentation and the stock sale to consider them connected and for the securities to function as "covered" for the purposes of a SLUSA dismissal.


[Unknown Act > Conclusion]
No. Justice Stephen G. Breyer delivered the opinion for the 7-2 majority. The Court held that the scope of SLUSA does not extend beyond misrepresentations that are material to the purchase or sale of a covered security. Because the focus of SLUSA deals with covered securities, the purchase or sale of uncovered securities is beyond SLUSA's purview. The Court also held that nothing in the language of SLUSA itself or the underlying regulatory statutes suggests that the relevant language should be interpreted more broadly. To do so would prohibit more lawsuits and interfere with state efforts to provide remedies to victims of frauds.
In his concurring opinion, Justice Clarence Thomas wrote that, while SLUSA precludes class action cases dealing with fraud "in connection with" covered securities, the connection does not extend to all securities.
Justice Anthony M. Kennedy wrote a dissent in which he argued that the majority's opinion unnecessarily narrows and constricts protection from fraud in national securities markets. Justice Kennedy argued that the relevant language must be interpreted broadly in order for SLUSA to accomplish its purpose of protecting the integrity of the markets. If misrepresentations were made relating to covered securities to perpetrate fraud, federal regulation is necessary, and it is this interest that Congress intended SLUSA to protect. Justice Samuel A. Alito, Jr. joined in the dissent.


[Unknown Act > Facts]
The National Labor Relations Act (NLRA) established the National Labor Relations Board (Board) to decide labor disputes among employers, unions, and employees. Parties first file unfair labor practice allegations to a Regional Office, which then conducts an investigation and, if necessary, files a complaint. An Administrative Law Judge (ALJ) presides over the hearing on the complaint and issues a recommendation to the Board. Unless a party to the dispute files a timely appeal, the ALJ's recommendation becomes the final order of the Board. To hear a case and issue a ruling, the Board must have at least three of its five members present. The NLRA allows parties to appeal a Board ruling to the U.S. Court of Appeals for the area where the alleged unfair labor practice occurred or to the U.S. Court of Appeals for the District of Columbia Circuit. Board members are appointed by the president and serve five-year terms.
In 2010, Noel Canning, a bottler and distributor of Pepsi-Cola products, was engaged in negotiations with its employee union, the International Brotherhood of Teamsters Local 760 (Union). During the final bargaining session that December, Noel Canning agreed to submit two wage and pension plans to a vote by the Union membership. The membership approved the union's preferred proposal. However, Noel Canning argued that the discussions did not amount to a binding agreement and refused to incorporate the changes into a new collective bargaining agreement. The Union filed a complaint with the Board alleging that Noel Canning's actions constituted an unfair labor practice in violation of the NLRA. An ALJ determined that the agreement was binding and ordered Noel Canning to sign the collective bargaining agreement. The Board affirmed the ruling against Noel Canning.
Noel Canning appealed to the U.S. Court of Appeals for the District of Columbia Circuit, which held that the Board's ruling was invalid because not enough members of the Board were present. The panel that heard the Noel Canning case consisted of one member who was appointed by President Barack Obama and confirmed by the Senate in 2010 and two members whom President Obama appointed without Senate confirmation in January 2012. Although the Recess Appointments Clause allows the president to fill vacancies that occur while Congress is in recess, between December 2011 and the end of January 2012, the Senate met in pro forma meetings every three business days. Therefore, the Court of Appeals determined that the Senate was not in recess on the days the Senate did not meet because, for the purpose of the Recess Appointments Clause, recess is defined as the time in between sessions of Congress.


[Unknown Act > Conclusion]
No, no. Justice Stephen G. Breyer delivered the opinion for the 9-0 majority. The Court held that a pro forma session does not create a recess long enough to trigger the Recess Appointments Clause. While the term "recess" in the Clause refers both to inter-and intra-session recesses, its legislative history and historical context indicate that the term should be presumed to mean a recess of substantial length. The Court held that the three-day break that occurs during pro forma sessions does not represent a significant interruption of legislative business and therefore cannot justify the exercise of the Clause. Additionally, a pro forma session cannot be viewed as a single, long recess because the Senate retains its capacity to conduct business during such sessions. Because recess appointments made during a recess that was shorter than ten days have been so historically rare, the Court held that ten days was the appropriate presumptive lower limit to place on the exercise of the Clause. The Court also held that the Clause applies to vacancies that occur during a recess as well as those that originally occur before a recess but continue to exist at the time of the recess. Although a plain reading of the Clause does not require such an interpretation, the historical context of the wording favors the more broad reading because a vacancy can be considered a continuing state.
Justice Antonin Scalia wrote a concurrence in judgment in which he argued that the Recess Appointments Clause was only meant to cover breaks between congressional sessions rather than breaks within them. Therefore, the appointments in question are invalid because they were made during the session. Justice Scalia argued that a plain reading of the text as well as the historical meaning of the term "recess" clearly places it in opposition to the term "session," and it is therefore illogical to interpret the Clause as allowing appointments while Congress is in session. In offering a broader reading of the Clause, the majority opinion disregards the Clause's purpose: to preserve the balance of power between the President and the Senate regarding appointments. Justice Scalia also argued that the majority's ten-day rule cannot stand because it is based purely on judicial interpretation of historical practices without any textual basis. For these same reasons, the Clause should be read as only granting the President the power to fill vacancies that originally occurred during a recess. Chief Justice John G. Roberts, Jr., Justice Clarence Thomas, and Justice Samuel A. Alito, Jr. joined in the concurrence in judgment.


[Unknown Act > Facts]
Bellingham Insurance Agency, Inc. (BIA) was a company owned by Nicholas Paleveda and his wife, Marjorie Ewing. Shortly before BIA filed for voluntary Chapter 7 bankruptcy in 2006, the company assigned the insurance commission from one of its largest clients to Peter Pearce, a long-time employee. Additionally, Paleveda used BIA funds to incorporate the Executive Benefits Insurance Agency, Inc. (EBIA). Pearce then deposited over $100,000 into an account held jointly by EBIA and another company owned by Paleveda and Ewing. The Trustee, Peter Arkison, filed a claim against EBIA in the BIA bankruptcy proceeding. Arkison alleged fraudulent conveyances and that EBIA, as a successor corporation, was liable for BIA's debts. The bankruptcy court granted summary judgment in favor of the Trustee and the district court affirmed.
On appeal to the U.S. Court of Appeals for the Ninth Circuit, EBIA argued, for the first time, that the bankruptcy judge's entry of a final judgment on the Trustee's claims was unconstitutional. The Court of Appeals affirmed the district court's decision. It held that, while a bankruptcy court may not decide a fraudulent conveyance claim, it may hear the claim and make a recommendation for review by a district court. Additionally, the Court of Appeals determined that EBIA, by failing to object to the bankruptcy court's jurisdiction, waived its Seventh Amendment right to a hearing before an Article III court.


[Unknown Act > Conclusion]
Yes and Undecided. Justice Clarence Thomas delivered the opinion for the unanimous Court. The Court began by noting that, under federal law, issues related to a bankruptcy proceeding fall into one of two categories: "core" and "non-core." Bankruptcy courts may render final decisions, subject to appeal, on "core" issues, but when an issue is "non-core," the bankruptcy court may only issue proposed findings of fact and conclusions of law, which are to be reviewed de novo by district courts. However, bankruptcy courts may render final decisions on "non-core" issues if both parties consent. In Stern v. Marshall, the Supreme Court held that some claims labeled as "core," specifically those considered "public rights," could not be adjudicated by bankruptcy courts because they do not comply with the constitutional requirements in Article III and thus Congress can only grant them limited subject matter jurisdiction. While a fraudulent conveyance claim may be the type of "core" claim on which Stern prohibits bankruptcy courts from ruling, here the claim was related to the bankruptcy proceedings and should thusly be treated as a "non-core" issue, which would allow the bankruptcy judge to submit proposed findings to a district court. The Court found it unnecessary to address the petitioner's issue regarding consent, because although the bankruptcy court had rendered a final decision on the claim instead of a proposed finding, the district court had reviewed the bankruptcy court's holding de novo, which meant that it had effectively treating the claim as if it had been a "non-core" claim.


[Unknown Act > Facts]
At midnight on July 18, 2004, West Memphis Police Officer Forthman pulled over Donald Rickard's vehicle because of an inoperable headlight. After Officer Forthman noticed damage on the vehicle and asked Rickard to step out of the car, Rickard sped away. Officer Forthman called for backup and pursued Rickard from West Memphis, Arkansas to Memphis, Tennessee. The police officers were ordered to continue the pursuit across the border and ultimately surrounded Rickard in a parking lot in Memphis, Tennessee. When Rickard again attempted to flee, the police fired shots into the vehicle, ultimately killing both Rickard and Kelley Allen, a woman who had been a passenger in the vehicle. The entire exchange was captured on police video.
Rickard and Allen's families sued the police officers, the chief of police, and the mayor of West Memphis under federal and state law claims. The families argued that the police used excessive force when pursuing and ultimately killing Rickard and Allen and that using that force violated the Fourth Amendment. They also brought claims of assault, battery, malicious prosecution, intentional infliction of emotional distress, false imprisonment, and abuse of process. The government argued that, because the police acted in their official capacity, they were entitled to either absolute or qualified immunity from any lawsuit. The district court refused to dismiss the case against the government, and the U.S. Court of Appeals for the Sixth Circuit affirmed the decision of the trial court. The Court of Appeals held that qualified immunity only applies when officers are acting reasonably, and after reviewing subsequent cases, held that the police did not act reasonably in this case. Additionally, because the video evidence showed that the police fired on unarmed, fleeing drivers, a jury could determine that the police were not acting reasonably.


[Unknown Act > Conclusion]
Yes and yes. Justice Samuel Alito delivered the opinion for the unanimous Court. The Court held that the requirement that a final decision be made by a district court prior to an appeal does not apply to motions for summary judgment when the motion is based on a claim of qualified immunity. Because the determination of qualified immunity is not merely a defense but actually immunity from the suit, it cannot be effectively reviewed after a final judgment at which point the protection from suit would have been “irretrievably” lost. The Court also held that the evidence showed that Rickard was still attempting to flee when the officers opened fire and that the officers reasonably could have believed that if the chase resumed Rickard would once again pose a deadly threat to others on the road. Furthermore, the total number of shots fired also did not qualify as excessive force. Therefore, if officers are justified in opening fire to end a threat to public safety, they are similarly justified in continuing to fire until the threat to public safety has ended.


[Unknown Act > Facts]
In 1999, Gary Woods and Billy McCombs became investors in two partnerships. Those partnerships then transferred their assets to a corporation that was jointly owned by Woods and McCombs, which caused the partnerships to be considered liquidated for tax purposes. Because the value of a liquidated asset is equal to the partner's basis in the investment, the partnerships reported their losses on their tax reports as equal to the purchased options Woods' and McCombs' separate companies originally contributed to the partnerships. After conducting an audit, the Internal Revenue Service (IRS) determined that the partnership transactions served no business purpose and were solely for the purpose of tax avoidance. Therefore they had no legal basis and the IRS did not consider the partnerships valid. The IRS imposed accuracy-related penalties for understatements of income and gross valuation misstatements.
In 2005, Woods (as the tax matters representative for the partnership) brought the matter before a district court and argued that penalties were inappropriate because the tax consequences of the transactions were accurately reported. The district court held that the transactions "lacked economic substance" and that their reported losses should be disregarded. The court also held that, because the transactions had no economic substance, the valuation misstatement penalties did not apply. The United States appealed the decision with regard to the valuation misstatement penalties, and the U.S. Court of Appeals for the Fifth Circuit affirmed the lower court's ruling.


[Unknown Act > Conclusion]
Yes; yes. Justice Antonin Scalia delivered the opinion for a unanimous Court. The Court held that, under the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA), a court in a partnership-level proceeding has the jurisdiction to consider the applicability of any penalty that relates to the partnership. Therefore, a district court must determine whether the partnership situation in question had the potential to trigger a penalty, as happened in this case. The Court also held that a transaction that was determined to lack economic substance can still trigger the penalty for overstatement because the overstatement and the action that led to it are inherently tied together.


[Unknown Act > Facts]
On August 23, 2004, Unite Here Local 355 (UHL) entered an agreement with Mardi Gras Gaming (Mardi Gras), the owner of a casino and dog track in Florida. Under the terms of the agreement, UHL would pay for advertisements to support a gambling ballot initiative that Mardi Gras wanted to pass, and Mardi Gras would facilitate the union organizing Mardi Gras' workers by providing the union with access to work premises, employee information, and neutrality toward the unionization of their employees. UHL also agreed not to strike, protest, picket or otherwise pressure the company's business.
Martin Mulhall, a Mardi Gras employee, sued both Mardi Gras, and UHL. He opposed the agreement and argued that it violates the Labor Management Relations Act (LMRA), which prohibits an employer giving or a union receiving a "thing of value." The district court dismissed the lawsuit for lack of standing, holding that Mulhall was not injured by UHL merely seeking to represent him. Mulhall appealed. The U.S. Court of Appeals for the Eleventh Circuit reversed and remanded. On remand, the district court dismissed the complaint for failure to state a claim. Mulhall appealed again and the Court of Appeals again reversed and remanded.


[Unknown Act > Conclusion]
In a per curiam opinion, the Court dismissed the writ of certiorari as improvidently granted.
Justice Stephen G. Breyer wrote a dissenting opinion in which he argued that, rather than dismissing the writ of certiorari as improvidently granted, the Court should have asked for briefs addressing issues antecedent to the one brought up by the case. The Court could then determine whether the case was moot because the contract expired in 2011 and whether Mulhall had Article III standing, as well as whether there is a private right of action in this case. Justice Breyer argued that it was important that the Court address the issues presented in this case because the outcome could negatively affect the collective bargaining process. Justice Sonia Sotomayor and Justice Elena Kagan joined in the dissent.


[Unknown Act > Facts]
In 2005, a grand jury began investigating Kerri Kaley and her husband Brian Kaley for stealing prescription medical devices from hospitals. In February 2007, the grand jury indicted the Kaleys on seven criminal counts. One of these counts was a criminal forfeiture count, which would require the Kaleys to forfeit all property that could be traced to their offenses. This property included a certificate of deposit for $500,000, which the Kaleys intended to use to pay their defense attorneys.
Following the indictment, the district court issued a protective order preventing the Kaleys from transferring or disposing of any property in the forfeiture count. The Kaleys moved to vacate the order because it prevented them from hiring their attorneys in violation of their right to counsel protected by the Sixth Amendment to the U.S. Constitution. The district court denied their motion without granting a pretrial evidentiary hearing. The Kaleys appealed to the United States Court of Appeals for the Eleventh Circuit, which reversed and remanded.
On remand, the district court granted a pretrial hearing, but limited it to the question of whether the property in the forfeiture count was traceable to the Kaleys' offenses. When the Kaleys failed to present evidence regarding traceability, the district court refused to vacate the protective order. The Kaleys appealed again, arguing that they should have been allowed to challenge the validity of the indictment in the pretrial hearing. The appellate court disagreed and affirmed the lower court's decision.


[Unknown Act > Conclusion]
No. Justice Elena Kagan delivered the opinion for the 6-3 majority. The Court held that the Fifth and Sixth Amendments do not allow a defendant to use ill-gotten gains to pay an attorney. The Court also held that, since the government had the power to restrain persons given probable cause that they committed a crime, it follows that the government can constitutionally restrain property as well. Similarly, because the criminal justice system entrusts to the grand jury the determination of whether there is probable cause to restrain a defendant prior to trial, there is not reason to use another method to determine whether there is probable cause to restrain a defendant's property. The Court also held that the alternative ruling, which would allow a judge to overrule a grand jury's finding of probable cause, could have destructive impacts on the criminal justice system as a whole. Previous precedent has maintained that there is no need for an adversarial hearing to determine probable cause because it is such a relatively low standard of proof, and the Court found no reason to depart from that precedent in this case.
In his dissent, Chief Justice John G. Roberts, Jr. wrote that, while the Sixth Amendment right to counsel does not equate to an absolute right to choice of counsel, the right cannot be denied based on the discretion of the prosecutor. Chief Justice Roberts argued that the issue of the forfeiture of assets is entirely separate from the issue of indictment for a crime and requires different evidence. Therefore, a hearing to determine whether the Kaleys' assets were forfeitable would not be relitigating a decided issue but rather allowing a judge to determine whether the government met its burden. Chief Justice Roberts also argued that the majority opinion essentially allows the government to deprive defendants of the counsel of their choice, which is fundamentally at odds with the ideals of the criminal justice system. While the government does have a legitimate interest in ensuring that ill-gotten assets are available to be returned if the defendant is convicted, there are other ways to protect the assets that do not require the defendant to forfeit his right to the counsel of his choice. Justice Stephen G. Breyer and Justice Sonia Sotomayor joined in the dissent.


[Unknown Act > Facts]
The town of Greece, New York, is governed by a five-member town board that conducts official business at monthly public meetings. Starting in 1999, the town meetings began with a prayer given by an invited member of the local clergy. The town did not adopt any policy regarding who may lead the prayer or its content, but in practice, Christian clergy members delivered the vast majority of the prayers at the town's invitation. In 2007, Susan Galloway and Linda Stephens complained about the town's prayer practices, after which there was some increase in the denominations represented.
In February 2008, Galloway and Stephens sued the town and John Auberger, in his official capacity as Town Supervisor, and argued that the town's practices violated the Establishment Clause of the First Amendment by preferring Christianity over other faiths. The district court found in favor of the town and held that the plaintiffs failed to present credible evidence that there was intentional seclusion of non-Christian faiths. The U.S. Court of Appeals for the Second Circuit reversed and held that the practices violated the Establishment Clause by showing a clear preference for Christian prayers.


[Unknown Act > Conclusion]
No. Justice Anthony Kennedy delivered the opinion for the 5-4 majority. The Court held that the context and jurisprudence surrounding the First Amendment suggested that the Establishment Clause was never meant to prohibit legislative prayer, which created the proper deliberative mood and acknowledged religion's role in society. The content of this prayer does not need to be non-sectarian, because such a requirement would place the courts in the role of arbiters of religious speech, which would involve the government in religion to an extent that is impermissible under the Establishment Clause. The Court thus held that the prayers in question do not violate this tradition and are therefore acceptable under the First Amendment. Justice Kennedy further argued that legislative prayer is primarily for the members of the legislative body, and therefore such prayers do not coerce the public into religious observance. Though the respondents testified that they felt offended by these prayers, Justice Kennedy distinguished between offense and coercion and noted that the former does not violate the Establishment Clause. Justice Antonin Scalia and Justice Clarence Thomas did not join in this portion of the opinion.
In his concurring opinion, Justice Samuel A. Alito, Jr. wrote that there is a long tradition of constitutionally permissible legislative prayer and that such prayer need not be non-sectarian, especially when such a requirement would place the government in the position of policing prayer. Justice Thomas wrote a separate opinion concurring in part and concurring in the judgment in which he argued that the Establishment Clause should be read as a federalist provision that protected states' rights rather than individual rights.
Justice Stephen G. Breyer wrote a dissent in which he argued that, as the Court of Appeals held, the Town of Greece must do more to make its legislative prayer inclusive of other faiths. Despite the fact that the town is not exclusively Christian, the town made no significant effort to inform non-Christian clergy about the possibility of delivering an invocation, and in doing so, marginalized religious minority populations. Justice Elena Kagan wrote in a separate dissent that the town's failure to represent a variety of religions in its meetings amounted to the unconstitutional preference of one religion over others. To do so in a public forum where people come to participate in the political process forces individuals who do not agree with the beliefs represented in the prayer to either acquiesce or visibly make their dissent known. Justice Ruth Bader Ginsburg, Justice Sonia Sotomayor, and Justice Breyer joined in the dissent.
"


[Unknown Act > Facts]
In 2002, Congress passed the Bipartisan Campaign Reform Act (BCRA), which established two sets of limits to campaign contributions. The base limit placed restrictions on how much money a contributor—defined broadly as individuals, partnerships, and other organizations—may give to specified categories of recipients. The aggregate limit restricted how much money an individual may donate in a two-year election cycle. The limits were periodically recalibrated to factor in inflation.
Shaun McCutcheon is an Alabama resident who is eligible to vote. In the 2011-2012 election cycle, he donated to the Republican National Committee, other Republican committees, as well as individual candidates. He wished to donate more in amounts that would be permissible under the base limit but would violate the aggregate limit. McCutcheon and the other plaintiffs sued the Federal Election Commission, arguing that the aggregate limit violated the First Amendment by failing to serve a "cognizable government interest" and being prohibitively low. The district court held that the aggregate limit served government interests by preventing corruption or the appearance of corruption and was set at a reasonable limit.


[Unknown Act > Conclusion]
No. Chief Justice John G. Roberts, Jr. delivered the opinion for the four-justice plurality. The plurality held that the aggregate limit did little to address the concerns that the Bipartisan Campaign Reform Act was meant to address and at the same time limited participation in the democratic process. Because the aggregate limit fails to meet the stated objective of preventing corruption, it does not survive the "rigorous" standard of review laid out by previous precedent dealing with campaign contributions from a First Amendment perspective and is therefore unconstitutional. The aggregate limit also prevents a donor from contributing beyond a specific amount to more than a certain number of candidates, which may force him to choose which interests he can seek to advance in a given election. The plurality held that the collective interest in combating corruption can only be pursued as long as it does not unnecessarily curtail an individual's freedom of speech, and in this case the aggregate limit is not sufficiently closely tailored to accomplish this goal. The plurality also noted that there are many other means by which the government may fight election corruption without setting an aggregate limit on campaign contributions.
Justice Clarence Thomas wrote an opinion concurring in the judgment in which he argued that the Court's decision in Buckley v. Valeo, a previous case dealing with limits on campaign contributions, should be overruled because it denigrates the core values of the First Amendment. Because the reasoning in Buckley v. Valeo could not sufficiently justify using a standard lower than strict scrutiny to examine limits on campaign contributions, Justice Thomas wrote that Buckley should be overruled and the BCRA should be subject to strict scrutiny.
In his dissent, Justice Stephen G. Breyer wrote that the plurality's opinion misconstrues the nature of competing constitutional issues and destroys campaign finance laws, which causes great harm to the democratic process. Justice Breyer argued that the plurality's opinion was based on a definition of corruption that is too narrow to be effective. He went on to state the reasoning that the aggregate limit is faulty is because there is no substantial mismatch between Congress' goal of combating corruption and the means established to achieve it. Justice Ruth Bader Ginsburg, Justice Sonia Sotomayor, and Justice Elena Kagan joined in the dissent.


[Unknown Act > Facts]
The Patent Act allows a court to award reasonable attorneys fees in exceptional cases in which the lawsuit is objectively baseless and brought in bad faith. Allcare Management Systems, Inc. (Allcare) owns a patent that covers a computer-based method of generating treatment options based on symptom data entered by a physician. This process can help an insurance company determine whether to approve a particular treatment for a patient. In 2003, Highmark, Inc. (Highmark), a health insurance company, sought a declaratory judgment of non-infringement of Allcare's patent. Allcare filed a counterclaim and alleged that Highmark infringed on two sections of its patent. The federal district court awarded summary judgment in favor of Highmark. The court also found that Allcare had willfully pursued frivolous infringement claims and ordered it to pay Highmark's attorney's fees and costs. On appeal, the U.S. Court of Appeals for the Federal Circuit independently reviewed the district court's determination that Allcare's claims were objectively baseless. The appellate court affirmed the lower court's finding with respect to one of Allcare's claims and reversed the court regarding Allcare's second claim.


[Unknown Act > Conclusion]
Yes. Justice Sonia Sotomayor delivered the opinion for the unanimous Court. The Court held that a district court is in the best position to determine whether a lawsuit is objectively baseless and, as such, is entitled to deference upon appeal. The Federal Circuit applied too strict of a standard in its independent review of the case, which should be reserved for questions of law. The Court remanded the proceedings and instructed the Federal Circuit to examine the district court’s findings for abuse of discretion.


[Unknown Act > Facts]
In 2001, James Alvin Castleman was charged and pleaded guilty to one count of misdemeanor domestic assault under the relevant Tennessee statute, which dealt with knowingly or intentionally causing bodily harm to the mother of the defendant's child. Seven years later, federal agents discovered that Castleman and his wife were buying firearms from dealers and selling them on the black market. Because Castleman's domestic assault conviction prohibited him from purchasing firearms, Castleman's wife bought the weapons in her own name. Castleman was indicted in federal district court and charged with two counts of possessing a firearm after being convicted of a misdemeanor crime of domestic violence. The district court dismissed the charges and held that Castleman's misdemeanor domestic assault conviction under Tennessee law did not constitute the misdemeanor crime of domestic violence as required by the federal statute. The U.S. Court of Appeals for the Sixth Circuit affirmed.


[Unknown Act > Conclusion]
Yes. Justice Sonia Sotomayor delivered the opinion for the 9-0 majority. The Court held that, because the statute in question—that prevents people convicted of misdemeanor domestic violence from possessing firearms—incorporates an element regarding the use of physical force, it includes those convicted of domestic assault under state law. This reading of the statute is consistent with the common-law meaning of violence, and to read it otherwise would have meant that the statute was ineffective in many states at the time of its enactment. Because the Tennessee statute under which Castleman was convicted necessarily involved the use of physical force, it should be considered a misdemeanor domestic violence conviction for the purpose of the federal statute.
In his opinion concurring in part and concurring in the judgment, Justice Antonin Scalia wrote that the majority opinion could have settled the case on much narrower grounds than it did. Because the meaning of the Tennessee statute in question categorically includes the meaning of "physical force," a conviction under that statute qualifies as a misdemeanor crime of domestic violence. Justice Samuel A. Alito, Jr. wrote a separate opinion concurring in the judgment in which he argued that the reasoning in the majority opinion purports to rely on the reasoning in Johnson v. United States, but because the majority opinion in this case holds that force does not need to be violent, it is an improper application of the precedent. Justice Clarence Thomas joined in the opinion concurring in the judgment.


[Unknown Act > Facts]
In 1908, the United States granted land, known as a right-of-way (ROW) to the Hahn's Peak and Pacific Railway Company to build a 66-mile railway from Laramie, Wyoming to Colorado. In 1976, the United States granted Fox Park, Wyoming⎯land that surrounds the ROW⎯to Melvin and Lula Brandt. In 1986, a new company, the Wyoming and Colorado Railway Company, acquired the ROW. The company operated the ROW until it officially abandoned the land in 2003. Following the abandonment, the United States sued the Brandt Revocable Trust and other potential property owners under 42 USC 912, a statute governing the disposition of abandoned or forfeited railroad grants. The government argued that this statute reverts abandoned ROWs back to the federal government's exclusive possession. The United States sought a judicial order of abandonment and exclusive possession of the ROW. The Brandt Revocable Trust and property owners filed a countersuit seeking full possession of the ROW, insofar as it cut through their land. They argued that the statute only granted an easement to the United States, not full possession. The district court granted the interest in the ROW to the United States and the US. Court of Appeals for the Tenth Circuit affirmed.


[Unknown Act > Conclusion]
No. Chief Justice John G. Roberts, Jr. delivered the opinion of the 8-1 majority. The Court held that the language, legislative history, and subsequent administrative interpretation of the General Railroad Right-of-Way Act of 1875 (1875 Act) clearly grants an easement for the railroad's land and not a more enduring property interest. When the United States granted Fox Park to Melvin and Lula Brandt, it did not reserve for itself any additional interest in the railroad property. Therefore, pursuant to the 1875 Act, when the railroad company abandoned the land, it should have been settled as an easement. When an easement is abandoned, the easement disappears and the land reverts to its previous owner, so in this case, the land would revert to the Brandt Revocable Trust and property owners.
Justice Sonia Sotomayor wrote a dissent in which she argued that there is judicial precedent to support the view that, in granting land to railroad companies, Congress did not intend to allow those land grants to be disposed at the will of the private companies. Justice Sotomayor also argued that the majority opinion failed to take into account the fact that railroad rights have historically not been treated as property rights that can be decided simply on the basis of common law principles. Therefore, even if the 1875 Act only granted an easement, it should not be treated as an ordinary easement. Instead, such an easement should be settled according to the presumption in favor of the sovereign grantor, the United States, as has typically governed railroad ROW property.


[Unknown Act > Facts]
In August 2007, Justus Rosemond and Ronald Joseph met Ricardo Gonzalez in a Tooele, Utah, park to sell him a pound of marijuana. When Gonzalez attempted to take the marijuana without paying, he was fired upon while fleeing. The government charged Justus Rosemond with several drug-and firearm-related offenses. At trial, the government alleged that Rosemond was either the shooter or that he aided and abetted the shooter. The jury convicted Rosemond on all charges.On appeal, Rosemond argued that the trial court's instructions to the jury regarding the aiding and abetting theory were insufficient and that the jury must find that Rosemond "intentionally took some action to facilitate or encourage the use of a firearm" to convict. The Tenth Circuit affirmed Rosemond's conviction.


[Unknown Act > Conclusion]
Yes. Justice Elena Kagan delivered the opinion for the 7-2 majority. The Court held that the government must prove that the defendant actively participated in a drug or violent crime intending to see it succeed and knew in advance that one of his coconspirators had a gun during the crime. Whether the defendant approved or disapproved of having or using the gun is irrelevant, as long as he participated in the underlying drug or violent crime with knowledge of a gun. Proof that the defendant knew that a gun was used sometime in the commission of the crime is insufficient; if, as in this case, a defendant learns of a gun upon seeing or hearing an accomplice fire shots after the criminal scheme has begun, he cannot be held liable for aiding and abetting under this statute. The State must prove as part of the knowledge element that the accomplice had the opportunity to walk away after learning of the gun but chose to proceed thereby incurring the liability of this statute.
Justice Samuel A. Alito, Jr. wrote an opinion concurring in part and dissenting in part, disagreeing only with the majority's new rule that the State prove that the aider and abetter had an opportunity to refrain from the criminal conduct after learning of a gun. His dissent rests on the position that this requirement deviates from the traditional aiding and abetting doctrine, and it opens up the affirmative defense of necessity or duress for the accomplice that does not object to having a gun for fear violence might be directed at him. Justice Clarence Thomas joined in the partial concurrence and partial dissent.


[Unknown Act > Facts]
A collective bargaining agreement directed Ray Holuch Gravel, a landscape supply company, to remit contributions to several benefit funds affiliated with the Central Pension Fund, a labor union which represents landscape supply company employees. After conducting an audit of the company's books in 2009, the union sued for additional remittances of past unreported work. They also sued for attorney's fees. The district court ruled in favor of the labor union on both issues with respect to one employee, but ruled against them with respect to employees who could not be identified because the landscape supply company failed to keep the required records. The two decisions were announced separately and one week apart. The labor union appealed both rulings within thirty days of the second ruling, but more than thirty days after the first ruling. The U.S. Court of Appeals for the First Circuit held that the appeal was timely because the attorney's fees are a merits issue, so the first decision was not final until the lower court had decided both cases.


[Unknown Act > Conclusion]
Yes. Justice Anthony M. Kennedy delivered the opinion of the unanimous Court. The Supreme Court held that the decision on the merits, even if the issue of attorney's fees remains unresolved, is the final decision for the purpose of appeal. Because attorney's fees do not remedy the injury giving rise to the action and are often available to the defendant(s) as well as the plaintiff(s), the issue is generally not considered part of a merits decision. Although this distinction could lead to piecemeal litigation, the Court held that the concern was counterbalanced by the clarity that such a uniform rule provided to the appeals process.


[Unknown Act > Facts]
Former shareholders of Halliburton Company (Halliburton) filed a class action lawsuit against the company and argued that Halliburton falsified its financial statements and misrepresented projected earnings between 1999 and 2001. In their petition for class certification, the shareholders invoked the "fraud on the market" presumption to demonstrate their class-wide reliance on Halliburton's statements. The "fraud on the market" theory assumes that, in an efficient market, the price of a security reflects any material, public representation affecting that security. Therefore, under this theory, the law presumes that investors have relied on a material misstatement when they purchase a security at an artificially high or low price. The federal district court certified the shareholders as a class and prevented Halliburton from introducing evidence that the statements did not impact its stock prices at all. The U.S. Court of Appeals for the Fifth Circuit affirmed and held that Halliburton could not rebut the presumption that the plaintiffs relied on the statements until a trial on the merits of the plaintiffs' claims.