[Unknown Act > Facts]
In 2002, Fane Lozman purchased a floating residential structure. The structure was rectangular and made of plywood. It contained no bilge pumps, no raked bow, no navigation aids, no lifeboats, no propulsion mechanism, no steering, and cleats, which were inappropriate for towing.
Lozman kept his floating home in a marina in the City of Riviera Beach. Lozman signed a lease with the city, moored the floating home to the dock, and affixed the home to land based utilities. Later, the city council passed a revised dockage agreement and accompanying Marina Rules. Pursuant to these rules, the city informed Lozman it would revoke his permission to remain on the Marina unless he executed a new agreement and complied with the new regulations. Lozman did not execute a new agreement and continued to remain at the marina.
In response, the city filed an in rem suit in federal court for trespass under federal maritime law. The city filed for partial summary judgment on its trespass claim. Lozman argued that his floating home was not a "vessel" under 1 U.S.C. § 3, and therefore not subject to maritime law. The district court granted the city's motion and held that Lozman's floating home was a "vessel" for purposes admiralty jurisdiction. The United States Court of Appeals for the Eleventh Circuit agreed with the lower court, and Lozman appealed the appellate court's determination that his floating home was a "vessel" under 1 U.S.C. § 3.


[Unknown Act > Conclusion]
No. Justice Stephen G. Breyer, writing for a 7-2 majority, reversed the 11th Circuit. The Supreme Court held that the 11th Circuit's definition of "vessel" is too broad. The Court focused on the language of the statute, which states that a vessel is "capable of being used...as a means of transportation." While the floating home can move, it is not used for transportation in a practical way. The Court employed a "reasonable observer" test, holding that something's ability to float, does not automatically make it a vessel.
Justice Sonia Sotomayor dissented, arguing that the reasonable observer test introduces a subjective element that upsets long established maritime precedent. The dissent would also remand the case to develop the record further. Justice Anthony M. Kennedy joined in the dissent.


[Unknown Act > Facts]
In 1994, the United States Patent and Trademark Office granted a patent to the Monsanto Company for genetic material from a virus that can be used to incorporate new genetic material into a plant. In 2006, Monsanto patented a gene that makes plants resistant to the glyphosate-based herbicides that farmers can use on weeds. Both patents are included in the Monsanto Technology agreement which states that growers who purchase Monsanto's products may only use the seed for a single season and may not sell the seeds to any other grower. Growers may sell the second-generation seed to a grain elevator.
Vernon Hugh Bowman, a farmer in Knox County, Indiana, began purchasing Monsanto's Pioneer Hi-Bred seed in 1999 and followed the terms of the agreement by not saving any of his seed. Also beginning in 1999, Bowman purchased second-generation seed from a grain elevator for his second planting and saved seeds from that purchase for reuse later. In 2006, Monsanto contacted Bowman to examine his planting activities and found that his second-round crops contained the patented genetic material. Monsanto sued Bowman for patent infringement. The district court granted summary judgment for Monsanto. The United States Court of Appeals for the Federal Circuit affirmed.


[Unknown Act > Conclusion]
No. Justice Elena Kagan delivered a unanimous opinion holding that the doctrine of patent exhaustion does not allow the purchaser to make copies of a patented item. Because the product in question is a seed, using the seed to grow a crop and then harvesting those seeds for future use constitutes creating copies of a patented item. In this case, Bowman's one-time purchase of Monsanto's product allowed him to take advantage of their patented product over the course of many seasons without respecting the rights of the patent holder. The Court also held that this reading of the doctrine allowed patents for plants to retain their value.


[Unknown Act > Facts]
In the early 1990s, Vernon Minton, a former securities broker, developed the Texas Computer Exchange Network (TEXCEN) software that allowed financial traders to execute trades on their own. R.M. Stark & Co. (Stark) agreed to lease TEXCEN. More than one year later, Minton filed for a patent that was granted by the United States Patent and Trademark Office on January 11, 2000.
Minton later sued the NASDAQ and the National Association of Securities Dealers (NASD) and alleged that their services infringed on his patent. NASD and NASDAQ argued that a patent is invalid when the invention claimed is sold more than a year before the patent application is filed. The district court granted summary judgment for NASD and NASDAQ. Minton retained new counsel to argue his case under the experimental use exception, which states that the patent remains valid if the invention was sold primarily for experimental, rather than commercial, use. He filed a motion for reconsideration, which the district court denied. The United States Court of Appeals for the Federal Circuit affirmed.
Minton sued his original attorneys (collectively referred to as Gunn) for legal malpractice and argued that their failure to argue the experimental use exception in the original suit cost him the case. Gunn filed for summary judgment arguing no-evidence due to the fact that the attorneys did not know of the earlier sale in order for the experimental use exception to be relevant. The trial court granted summary judgment in favor of Gunn. Minton appealed to the Second Court of Appeals for Texas. Shortly after he filed his appeal, the United States Court of Appeals for the Federal Circuit decided a case that gave jurisdiction to the federal courts in malpractice suits arising from patent litigation. Minton filed a motion to dismiss his case from the Second Court of Appeals for Texas, but the court denied his motion and affirmed the decision of the trial court. The Supreme Court of Texas reversed and dismissed the case.


[Unknown Act > Conclusion]
No. Chief Justice John G. Roberts, Jr., writing for a unanimous Court, reversed the lower court and remanded. The Supreme Court applied Grable & Sons Metal Products, Inc. v. Darue Engineering & Mfg., which provided that a case only arises under federal patent law when it "necessarily raise[s] a stated federal issue, actually disputed and substantial, which a federal forum may entertain without disturbing any congressionally approved balance of federal and state judicial responsibilities." The Court held that Minton failed to show that the federal issue in the case carried the necessary significance. The need to decide a hypothetical patent case is not substantial enough to deprive the state court of jurisdiction. A state court decision in a state law malpractice case relating to patent law will not substantially affect federal patent law.


[Unknown Act > Facts]
On September 13, 2007, a jury found Matthew R. Descamps guilty of felony possession of a firearm and ammunition. Descamps already had five previous felony convictions. Under the Armed Career Criminal Act ("ACCA"), criminals with three prior convictions for violent felonies must receive a minimum sentence of 15 years for any subsequent felony conviction. The ACCA defines a violent felony as any crime involving threatened use of physical force—or burglary—and punishable by imprisonment for a term exceeding one year. The United States District Court for the Eastern District of Washington concluded that Descamps' prior convictions of robbery, burglary, and felony harassment constituted three predicate violent felonies under the ACCA. Subsequently, the district court sentenced Descamps to 262 months in custody with 5 years of supervised release.
Descamps appealed his sentence to the United States Court of Appeals for the Ninth Circuit, arguing that all prior convictions used to enhance a sentence under the ACCA must be charged in the indictment and submitted to a jury. A judge may only increase the sentence if the three prior convictions are proved beyond a reasonable doubt. The appellate court disagreed and affirmed the sentence.


[Unknown Act > Conclusion]
No. Justice Elena Kagan delivered the opinion for the 8-1 majority. The Supreme Court held that Descamps' ACCA enhancement was improper because a felony burglary conviction under the California Penal Code is not a generic burglary conviction. To count for sentence enhancement under the ACCA, a prior burglary conviction must at least match a conviction using the traditional elements of the offense: "breaking and entering a building." The Court also held that the Ninth Circuit's examination of Descamps' burglary plea hearing transcript exceeded the purview of the Court of Appeals. The Supreme Court reiterated that sentencing courts may only consult outside documents to ascertain the basis of the defendant's conviction ("modified categorical approach") when the statute defines elements in the alternative—for example, "breaking and entering a building [generic] or automobile [non-generic]." California's burglary statute does not require "unlawful entry" as an element, or an alternative element, of the offense, so courts may not use the modified categorical approach. Allowing a sentencing court to determine, from the record, whether a defendant's prior conviction could have satisfied the traditional elements of the offense "raises serious Sixth Amendment concerns," Such as encouraging ill-advised guilty pleas.
Justice Anthony M. Kennedy wrote a concurring opinion in which he agreed with the majority opinion's concern that defendants would enter guilty pleas or let certain facts go uncontested without considering the potential consequences under the ACCA. He also expressed concern over the burden the majority's opinion places on state legislatures to revise their statutes. In his opinion concurring in the judgment, Justice Clarence Thomas argued that the ACCA framework amounts to a judicial factfinding expedition that runs counter to what is allowed by previous precedent. However, because the majority opinion limited the circumstances under which courts may consult documents relating to the defendant's prior conviction, Thomas concurred in the judgment.
Justice Samuel Alito wrote a dissenting opinion in which he contended that the majority opinion artificially limits the reach of the ACCA and treats similar convictions differently based solely on the arbitrary wording of state statutes. To remedy this problem, he argued that sentencing courts should always be permitted to consult the record to determine whether the defendant's conviction matched the generic offense.


[Unknown Act > Facts]
In December 1996, Warren Hillman made his wife, Judy Maretta, the beneficiary of his Federal Employees' Group Life Insurance ("FEGLI") policy. In 1998, the two divorced and Mr. Hillman remarried. Despite the divorce, Mr. Hillman never changed the beneficiary designation on his policy to his new wife, Jacqueline Hillman. In 2008, Warren died and Jacqueline Hillman attempted to claim the death benefits under his policy. Her claim was denied because she was not the named beneficiary on her husband's policy; Ms Maretta received the death benefits instead. Mrs Hillman sued Ms Maretta for the full amount of death benefits under the policy.
When a divorce is finalized in Virginia, state law revokes any beneficiary designations between former spouses. State law also creates a cause of action against anyone who wrongfully receives FEGLI policy proceeds. However, federal law under the Federal Employees' Group Life Insurance Act dictates that death benefits from FEGLI policies shall go to the designated beneficiary, regardless of state regulation to the contrary. The trial court applied state law and granted summary judgment to Mrs. Hillman, but Ms Maretta appealed. The Supreme Court of Virginia reversed the lower court's decision and held that federal law preempted the state law; therefore Mr. Hillman's beneficiary designation was not revoked. Mrs. Hillman appealed to the Supreme Court of the United States.


[Unknown Act > Conclusion]
Yes. Justice Sonia Sotomayor delivered the opinion for the 9-0 majority. The Supreme Court held that the Federal Employees' Group Life Insurance Act (FEGLIA) preempts the Virginia law. By passing FEGLIA, Congress clearly intended that the insurance proceeds go to the named beneficiary. The state law, which allows a deceased employee's family to sue a designated beneficiary for the proceeds of a FEGLI life insurance policy, conflicts with Congress' intent.
Justice Thomas filed an opinion concurring in the judgment. He stated that he cannot join with the majority's conclusion because the consideration is unnecessary. The Supremacy Clause effectively repeals state laws that directly conflict with federal law as the Virginia law does with FEGLIA. In his separate opinion concurring in the judgment, Justice Samuel A. Alito Jr. stated that one of the purposes of FEGLIA is to implement the expressed wishes of the insured. Since the Virginia law has the effect of overriding an insured's choice of beneficiary, FEGLIA preempts it.


[Unknown Act > Facts]
In 2000, Solvay Pharmaceuticals successfully patented AndroGel, a topical gel medication. Shortly after the FDA approved the medication, generic drug manufacturers Watson Pharmaceuticals and Paddock Laboratories began developing generic versions of the gel. Solvay filed a patent infringement suit against Watson and Paddock, but the manufacturers counter-claimed that Solvay's patent was invalid to begin with. As the infringement suit progressed, Solvay feared that it would lose its monopoly on AndroGel. To prevent this, Solvay entered into a reverse payment agreement with the two manufacturers. In return for dropping the suit and maintaining exclusivity, Solvay agreed to pay the manufacturers a sizeable fee. The agreement allowed Solvay to maintain its monopoly, despite the possible invalidity of the patent, in exchange for sharing some of the profits with its potential competitors.
Shortly after entering the agreement, the Federal Trade Commission ("FTC") filed a complaint against the pharmaceutical companies. The FTC claimed that Solvay was unlikely to win the patent infringement suit; therefore the settlement unfairly protected an invalid patent monopoly. By limiting competition in the AndroGel market, the manufacturers were restraining trade in violation of antitrust laws. The manufacturers argued that the FTC failed to state a valid claim because the agreement merely protected Solvay's already existing patent rights. The United States District Court for the Northern District of Georgia agreed with the manufacturers and dismissed the case. The FTC appealed to the United States Court of Appeals for the Eleventh Circuit, which affirmed the lower court's decision. The appellate court explained that the manufacturers' reverse payment settlement is lawful as long as it restrains competition in the same way that patent protection typically restrains competition.


[Unknown Act > Conclusion]
No. Justice Stephen G. Breyer delivered the opinion for the 5-3 majority. The Court held that reverse payment settlements are not presumptively unlawful and that the FTC's lawsuit should have been allowed to proceed. Although patent-based settlement agreements can sometimes violate anti-trust laws, the Court declined to apply an all-or-nothing rule regarding these agreements. Instead, the Court stated that there are five considerations that should have allowed the consideration of FTC's case. These considerations are: 1) that specific restraints in the settlement agreement had the potential to adversely effect competition; 2) that certain anti-trust consequences will sometimes prove unjustified; 3) that if a reverse payment settlement can cause anticompetitive harm, the patent-holder likely has the power to bring about that harm as well; 4) an anti-trust claim may be more administratively feasible than the lower court believed; and 5) the fact that a large, unjustified reverse payment settlement risks anti-trust liability does not prevent litigating parties from settling their lawsuits. The Court held that these considerations outweighed the lower court's decision to provide anti-trust immunity to reverse payment settlements.
Chief Justice John Roberts wrote a dissent in which he argued that the majority's decision discourages generic pharmaceutical companies from challenging patents because it eliminates the possibility of meaningful settlements. He argued that this decision instead forces generic companies into costly litigation that could be more efficiently handled through settlement negotiations. Justice Antonin Scalia and Justice Clarence Thomas joined in the dissent.


[Unknown Act > Facts]
From 1993 through 2000, the United States Army Corps of Engineers imposed a temporary flood regime around the Dave Donaldson Black River Wildlife Management Area. The flood regime caused flooding across the region encompassed by the wildlife management area, which restricted access to and destroyed or degraded thousands of timber trees.
The petitioners brought a case in federal court in an attempt to recover under the takings clause of the Fifth Amendment for the loss of their property resulting from the United State's flood regime. The federal court held that the flood regime constituted a Fifth Amendment taking and that the United States owed petitioners approximately $5.6 million as just compensation.
The government appealed, and the appellate court reversed the lower court's judgment. The appellate court reasoned that the flood regime was a temporary government action, and that only a permanent flooding condition would constitute a taking under the Fifth Amendment. The petitioners appealed the appellate court's decision.


[Unknown Act > Conclusion]
Yes, in some cases. Justice Ruth Bader Ginsburg, writing for an 8-0 majority, reversed the Federal Circuit and remanded for further proceedings. The Supreme Court held that there is no temporary flooding exception to the Takings Clause. Prior precedent clearly establishes that a temporary interference with property can constitute a compensable taking. The length and severity of the interference is just one factor among many a court must consider when determining whether a specific action was a taking. Other factors include the intent behind the action and the degree to which the interference was a foreseeable result of an authorized government action. On remand, the Federal Circuit must decide whether the circumstances in this case constituted a Fifth Amendment taking.


[Unknown Act > Facts]
Genesis Healthcare Corporation ("Genesis") employed Laura Symczyk as a registered nurse between April 2007 and December 2007. During her employment, Genesis implemented a policy that automatically deducted pay for employees' meal breaks whether or not they worked during those breaks. This prompted Symczyk to file a collective action on behalf of herself and all similarly situated individuals, alleging violation of the Fair Labor Standards Act ("FLSA"). In February 2010, Genesis offered to pay all of Symczyk's unpaid wages and attorney's fees. Symczyk did not respond to the offer. Genesis filed a motion to dismiss for lack of subject matter jurisdiction, claiming that Symczyk no longer had a real interest in the outcome of the action since they offered her full relief.
Since Genesis made an offer of judgment and no one had yet joined Symczyk's collective action, the District Court dismissed the case. Symczyk appealed, and the U.S. Court of Appeals for the Third Circuit reversed and remanded. The Third Circuit held that a full offer of relief does not cause an FLSA collective action suit to be dismissed.


[Unknown Act > Conclusion]
Yes. Justice Clarence Thomas delivered the opinion of the 5-4 majority. The Supreme Court held that established mootness principles determined that, in cases that lack other claimants, the suit on behalf of other "similarly situated" employees becomes moot when the individual claim does. Since Symczyk no longer had a personal interest and was not representing the interests of a broader class, the case was properly dismissed.
In her dissenting opinion, Justice Elena Kagan argued that the premise on which the majority's decision is based—that Symczyk's individual claim is moot—is incorrect. She wrote that, because Symczyk rejected the settlement offer, she retained her personal interest in the case, and there was no reason to consider her claim moot. Justice Ruth Bader Ginsburg, Justice Stephen G. Breyer, and Justice Sonia Sotomayor joined in the dissent.


[Unknown Act > Facts]
In 2008 the General Counsel for the Office of the State Comptroller of New York advised against investing in a fund managed by FA Technology Ventures. The investment would have given FA Technology millions in service fees. The General Counsel received an anonymous email of "blackballing a recommendation on a fund" and threatened to disclose the General Counsel's extramarital affair to his wife, to the Comptroller, and to others if he did not change his recommendation within 36 hours. On the advice of law enforcement, the General Counsel asked for more time, which the individual granted. The FBI traced the emails to Giridahr Sekhar, a managing partner of FA Technology. Sekhar later admitted to sending the emails.
Sekhar was charged with one account of extortion and six counts of interstate transmission of extortionate threats under the Hobbs Act. The Hobbs Act prohibits obtaining property by threats. Sekhar moved to dismiss, arguing that the General Counsel's recommendation was not property. The district court denied the motion to dismiss, holding that the General Counsel's right to make professional decisions without outside influence was intangible personal property. Sekhar was convicted on six of the seven counts and sentenced to 15 months in jail. The U.S. Court of Appeals for the Second Circuit affirmed.


[Unknown Act > Conclusion]
No. Justice Antonin Scalia delivered the opinion for the 9-0 majority. The Court held that attempting to compel a person to issue a favorable recommendation does not amount to extortion under the Hobbs Act. The Court determined that the right of the General Counsel to issue a professional recommendation is not transferrable, and therefore lacks an essential characteristic of extorted property.
Justice Samuel A. Alito, Jr. wrote an opinion concurring in the judgment in which he argued that the key question was whether the General Counsel’s recommendation constituted property. As internal recommendations are not property, the issue of transferability became irrelevant. Justice Anthony M. Kennedy and Justice Sonia Sotomayor joined the concurrence in the judgment.


[Unknown Act > Facts]
After James E. McCutchen suffered a serious injury in a car accident, a benefit plan administered by US Airways paid $66,866 to cover his medical expenses. The plan requires the beneficiary to pay back the medical expenses out of any amount recovered from third parties. Once McCutchen recovered over $100,000 from third parties in a separate suit, the plan demanded that McCutchen reimburse them for the full amount they paid out. McCutchen argued that US Airways did not take into account his legal fees, which reduced his recovery amount from third parties to less than the amount demanded. US Airways then filed suit for "appropriate equitable relief" under the Employment Retirement Security Income Act (ERISA). The district court ordered McCutchen to pay the full $66,866.
The U.S. Court of Appeals for the Third Circuit vacated the district court's judgment, holding that ERISA is subject to equitable limitations. To determine appropriate equitable relief, the district court must take into account the distribution of the amount recovered from third parties between McCutchen and his attorneys.


[Unknown Act > Conclusion]
Maybe. Justice Elena Kagan, writing for a 5-4 majority, vacated the Third Circuit and remanded. The Supreme Court held that equitable limitations did not apply to the benefit plan as a whole because the plan is a valid contract and the parties are only demanding what they bargained for under that contract. The common fund doctrine, however, may provide relief because the benefit plan is silent on the allocation of attorney fees. The common fund doctrine allows a litigant to recover attorney fees from a fund that is created, increased, or protected by that litigant. Because the parties did not contract otherwise, the common fund doctrine provides the best indication of the parties' intent. The case was remanded for further proceedings consistent with this opinion.
Justice Antonin Scalia dissented, arguing that the majority should not have discussed the plan's lack of a provision for attorney fees because it was not included in the question presented. Chief Justice John G. Roberts, Jr., Justice Clarence Thomas, and Justice Samuel A. Alito, Jr. joined in the dissent.


[Unknown Act > Facts]
The level of pollution detected in the Santa Clara River, the Los Angeles River, the San Gabriel River, and Malibu Creek—collectively known as the Watershed Rivers—far exceeds what is allowed by the National Pollutant Discharge Elimination System permit held by Los Angeles County. The National Resource Defense Council (NRDC) and other environmental organizations brought legal action against the county and the district, alleging that the county violated the Clean Water Act. The allegations stem from the fact that the county and district allowed untreated storm water that had collected myriad pollutants to run unchecked through storm sewers and into the rivers. The county and district did not contest the fact that the amount of pollutants was high but rather contested the allegations that they were solely responsible.
The federal district court found for county and the district and held that there was no evidence that they were directly responsible. The United States Court of Appeals for the Ninth Circuit upheld the district court's decision with respect to the Santa Clara River and the Malibu Creek but reversed the decision with respect to the San Gabriel River and the Los Angeles River.


[Unknown Act > Conclusion]
No. Justice Ruth Bader Ginsburg delivered the opinion of the 9-0 majority. The Court held that the pumping of polluted water from one portion of a waterway to another section of the same waterway did not constitute pollution under the Clean Water Act. Based on the text of the CWA, the "discharge of a pollutant" refers to the addition of a pollutant to a waterway. Because the pollutant is coming from farther up the same waterway, it cannot be considered an addition. Justice Samuel A. Alito, Jr. concurred in the judgment.


[Unknown Act > Facts]
In 2002, Jonathan Edward Boyer and his brother Anthony walked along a roadway in Sulphur, Louisiana. When Bradlee Marsh gave the brothers a ride, Boyer demanded money from Marsh. Marsh refused, and Boyer shot him in the head three times and took his money and a silver chain. Marsh died from his injuries.
Boyer was indicted in Louisiana state court on second-degree murder and armed robbery with a firearm charges. The jury found Boyer guilty on both counts. Boyer filed a motion for a new trial, but was denied. He was sentenced to life in prison without parole for the second-degree murder charge, and 104 years without parole for the armed robbery charge. On appeal, Boyer argued that that the trial court erred in determining his mental competency, by sustaining the State's objection to Boyer's attempt to present testimony showing his brother - Anthony - had violent tendencies, and by giving Jonathan Boyer an excessively long sentence. The court of appeals affirmed the convictions, holding that the trial court did not abuse its discretion and did not prejudice Boyer.


[Unknown Act > Conclusion]
In a per curiam opinion, the Supreme Court dismissed the case as improvidently granted.
Justice Samuel A. Alito, Jr. concurred, writing that the majority of the delay in the trial was due to the defendant himself. The defendant even moved to delay a hearing to solve the funding issue multiple times. The record did not support a finding that lack of funding was a significant cause of the delay. Justice Antonin Scalia and Justice Clarence Thomas joined in the concurrence.
Justice Sonia Sotomayor dissented, arguing that the Court should defer to the lower court's finding that the majority of the delay was caused by a lack of funding. If the Court had addressed the question presented, Justice Sotomayor would hold that a delay due to lack of funding weighs against the State when determining whether there was a Sixth Amendment violation. Justice Ruth Bader Ginsburg, Justice Stephen G. Breyer, and Justice Elena Kagan joined in the dissent.


[Unknown Act > Facts]
In 1978, Randy Curtis Bullock became the trustee of his father's trust. The trust's only asset was his father's life insurance policy, and Bullock and his four siblings were the trust's only beneficiaries. As trustee, Bullock was only allowed to borrow from the trust to pay the life insurance premiums and to satisfy a withdrawal request from another trustee. Despite these restrictions, Bullock borrowed from the trust three times: to satisfy a debt on his father's business, to allow him and his mother to purchase certificates of deposit, and to allow him and his mother to purchase real estate. All of the loans were fully repaid.
When Bullock's two brothers learned of the existence of the trust and their brother's actions, they sued him in Illinois state court. They claimed that Bullock had breached his fiduciary duty by taking loans that violated the guidelines of the trust. The brothers moved for summary judgment and the court granted it. The court ordered Bullock to pay $250,000 in damages for the benefits he received from his dealings with the trust, $35,000 in attorneys' fees, and placed the property Bullock purchased—a mill in Ohio—in a constructive trust. The constructive trust was awarded to BankChampaign, which replaced Bullock as the trustee of his father's trust. Bullock was unable to sell the mill to satisfy the Illinois judgment.
In 2009, Bullock filed for bankruptcy under Chapter 7 to discharge his debt from the Illinois judgment. The bank started an adversary proceeding in bankruptcy court where it argued that debts arising out of "fraud or defalcation while acting in a fiduciary capacity" are not dischargeable by bankruptcy. The bank moved for summary judgment and the bankruptcy court granted the motion. Bullock appealed the bankruptcy court's judgment to district court, and the district court affirmed. The district court recognized that the only way for Bullock to satisfy the judgment debt was to sell the mill, and the bank could not hold it in perpetuity, so the district court concluded that the bank was abusing its power; however, it still affirmed the decision of the bankruptcy court. The U.S. Court of Appeals for the Eleventh Circuit affirmed the judgment of the bankruptcy court and held that Bullock's conduct met the standard for defalcation because it was objectively reckless and constituted a known breach of a fiduciary duty.


[Unknown Act > Conclusion]
No. Justice Stephen J. Breyer delivered a unanimous opinion holding that a bankruptcy proceeding resulting from "fraud or defalcation" is not dischargeable and that the term "defalcation" encompasses knowledge of or grossly reckless behavior in a fiduciary capacity. The Court held that the term should include a knowledge or intent requirement because such a reading follows statutory and judicial precedent. Additionally, this interpretation differentiates the term from others in the statute and provides a clear definition on which courts may rely. The Court then vacated the lower court's judgment and remanded the case to determine if further proceedings were necessary under this heightened standard.


[Unknown Act > Facts]
American Express Company provides charge card services to supermarkets and other merchants throughout the United States. When a store decides to accept American Express cards, it must enter into a Card Acceptance Agreement. This standard form contract outlines the basic relationship between American Express and the merchant. A clause within the agreement requires arbitration of all claims brought against American Express and prohibits merchants from bringing any class action claims.
Several merchants, including Italian Colors Restaurant, brought individual lawsuits against American Express, claiming that the Card Acceptance Agreement violates U.S. antitrust laws. The United States District Court for the Southern District of New York consolidated the cases and American Express moved to dismiss in order to force the merchants to arbitrate. The district court enforced the arbitration clause and dismissed the case. The merchants appealed and the United States Court of Appeals for the Second Circuit held that the arbitration clause, in particular the class action waiver, is unenforceable because it would essentially protect American Express from antitrust suits. American Express further appealed and the United States Supreme Court granted certiorari. The Court vacated the ruling and remanded for further proceedings in light of its decision in Stolt-Nielsen v. Animalfeeds International. The appellate court reevaluated its decision and still found the class action waiver to be unenforceable. The Supreme Court granted certiorari again to resolve this issue.


[Unknown Act > Conclusion]
Yes. Justice Antonin Scalia delivered the opinion for the 5-3 majority. The Court held that the prohibitively high cost of arbitration is not a sufficient reason for a court to overrule an arbitration clause that forbids class action suits. Federal law does not guarantee that a claim will be resolved affordably. The fact that it can be more expensive to litigate individual arbitrations than they are worth does not negate the right to pursue a statutory remedy. Therefore, no exception to the Federal Arbitration Act (FAA) can be applied.
Justice Elena Kagan wrote a dissent in which she argued that the purpose of the FAA is to resolve disputes and facilitate compensation of injuries. By barring any means of sharing or shrinking arbitration costs, the arbitration clause in the American Express form contract functions to confer immunity from potentially meritorious federal claims, which runs counter to the purpose of the FAA. The contract also violates the Sherman Act by depriving parties of a chance to challenge allegedly monopolistic conduct. Justices Ruth Bader Ginsburg and Stephen G. Breyer joined in the dissent.
Justice Sonia Sotomayor did not participate in the discussion or decision of the case.


[Unknown Act > Facts]
PPL Corporation held a 25 percent stake in South Western Electricity Board, a utility in England subject to a onetime windfall tax. After PPL paid the tax, it claimed a foreign tax credit under I.R.C. §901 on its U.S. tax return. §901 allows a credit for foreign taxes on "income, war, profits, [or] excess profits." The Internal Revenue Service (IRS) denied the tax credit and issued a notice of deficiency. PPL then filed a petition in Tax Court to challenge the IRS's determination. The Tax Court agreed with PPL and the Commissioner of Internal Revenue (CIR) appealed to the U.S. Court of Appeals for the Third Circuit, arguing that §901 does not cover the windfall tax because it is a tax on the company's value, not its profits. PPL argued that, looking beyond the face of the statute, the windfall tax was intended to act as a tax on excess profits. The Third Circuit ruled in favor of the CIR, holding that the windfall tax is not eligible for credit.


[Unknown Act > Conclusion]
Justice Clarence Thomas, writing for a unanimous Court, held that courts should apply a common-sense, substance-based approach when considering the effect of a foreign tax. Using this approach, the Court held that the U.K. tax is creditable under §901. The predominant character of the windfall tax was, for all intents and purposes, an income tax under U.S. definitions. The Court also held that the windfall tax should not fall under the same approach as a general tax on value. Value taxes, such as gift and estate taxes in the U.S., use past profits to estimate the tax value of future income. Conversely, the windfall tax is solely based on past, realized net income.
Justice Sonia Sotomayor concurred in the judgment, but noted that an argument could have been made that the windfall tax was a tax on values as opposed to an excess profits or income-based tax. However, because that argument was not raised in oral arguments, she declined to rule on that issue.


[Unknown Act > Facts]
In 2003, Caroline Behrend, along with Stanford Glaberson, Joan Evanchuk-Kind, and Eric Brislawn, brought an antitrust class action suit against Comcast Corporation. The petitioners were all Comcast cable customers, alleging that the company obtained a monopoly on the cable market in violation of the Sherman Antitrust Act. By contracting with competitors to swap customers and subsume the regional cable markets, the company excluded and prevented competition amongst cable providers in the Philadelphia area. The proposed class of plaintiffs included all cable television customers in the Philadelphia area who subscribe or subscribed to Comcast's video programming services since December 1999.
In May 2007, the US District Court for the Eastern District of Pennsylvania certified the class, allowing the case to move forward. In light of a new antitrust decision in 2008 on class certification from the U.S. Court of Appeals for the Third Circuit, the District Court reconsidered its certification decision. The court held evidentiary hearings in October 2009, which consisted of dozens of expert testimonies and depositions. Following the hearings, the District Court recertified the class, finding sufficient evidence of a common impact amongst class members and a common methodology available to measure damages on a class-wide basis. Comcast subsequently appealed and the Court of Appeals affirmed the lower court decision.


[Unknown Act > Conclusion]
No. In a 5-4 majority opinion, Justice Antonin Scalia, joined by Chief Justice Roberts and Justices Alito, Thomas, and Kennedy, held that the plaintiff’s class action was improperly certified under Federal Rule of Civil Procedure 23(b)(3) because the lower courts failed to entertain competing arguments against the plaintiff’s claim for damages. Specifically, Justice Scalia noted that the lower courts only required that the plaintiffs provide a method to measure and quantify damages for the class without deciding whether such a method was a just and reasonable inference or if it was based on speculation. Because the lower courts failed to adequately establish the economic impact Comcast’s actions had on the plaintiffs, the lower courts were reversed.
Justice Ruth Bader Ginsburg and Justice Stephen Breyer wrote a joint dissent joined by Justices Sotomayor and Kagan. They argued that the Supreme Court did not actually decide the issue granted in the writ of certiorari. Instead, they argued that the court addressed the “merits arguments” present in Federal Rule of Civil Procedure 23. Because the question was reformed, it was inadequately addressed and the Court should not have issued a ruling.


[Unknown Act > Facts]
Calvin Smith and John Raynor, along with four others, were tried together and convicted on multiple charges including drug conspiracy and RICO act violations. The defendants filed motions for a new trial on various grounds, including that the leaders of the conspiracy, Rodney Moore and Kevin Gray, split up before the relevant statute of limitations period. Because of this, the jury did not have sufficient evidence to prove that all defendants were part of a single conspiracy. The defendants argued that the government had the burden to prove that the conspiracy continued into the valid statute of limitations period. The court denied the motions. On appeal, the U.S. Court of Appeals for the District of Columbia Circuit affirmed.


[Unknown Act > Conclusion]
No. Justice Antonin Scalia delivered the opinion for the unanimous court. The Court held that the defendant has the burden of proving withdrawal from a conspiracy regardless of when the withdrawal took place. Placing the burden on the defense does not violate the Due Process Clause because a defense of withdrawal does not negate an element of the crime of conspiracy. Instead, it assumes that the crime has occurred and starts the clock on the statute of limitations period for the prosecution. The Court held that a defense of withdrawal is considered an affirmative defense that places the burden of proof on the defendant. The Court also held that placing the burden on the prosecution to prove the withdrawal never happened would be a nearly impossible task, as witnesses would invoke the Fifth Amendment rather than discuss their criminal associations with the defendant.


[Unknown Act > Facts]
Adrian Moncrieffe, a native of Jamaica, was admitted to the United States as a lawful permanent resident in 1984. In 2008, police arrested Moncrieffe while he was in possession of 1.3 grams of marijuana. Moncrieffe pleaded guilty in a Georgia court to possession of marijuana with intent to distribute.
In 2010, the department of Homeland Security started removal proceedings against Moncrieffe for being an alien convicted of an aggravated felony and as an alien convicted of a controlled substance offense. Moncrieffe did not dispute his conviction but argued that that the conviction was not an "aggravated felony" and did not make him removable.
An immigration judge ruled that Moncrieffe was removable, holding that the petitioner's conviction was an aggravated felony because Moncrieffe was convicted under a state law which was similar to a federal law which made possession of marijuana with intent to distribute a felony. Moncrieffe appealed and argued that possession of such a small amount of marijuana would not be a felony under federal law, but rather a misdemeanor. The Board of Immigration Appeals rejected Moncrieffe's argument and dismissed the appeal. The United State Court of Appeals for the Fifth Circuit upheld the deportation order.


[Unknown Act > Conclusion]
No. Justice Sonia Sotomayor delivered the opinion of the 7-2 majority. The Court held that a categorical approach must be used to determine whether a state offense is comparable to one listed in a federal statute. Because the Controlled Substances Act contains provisions for the conviction of the possession of marijuana as both a felony and a misdemeanor, it is unclear which one aligns with a conviction for the possession of marijuana under the Georgia state statute. Under the categorical approach, it is not possible to tell whether Moncrieffe's conviction under the Georgia state statute would constitute an aggravated felony. The Court held that if a noncitizen's conviction for possession of a controlled substance fails to establish whether remuneration or more than a small amount of marijuana, it cannot be considered an aggravated felony.
Justice Clarence Thomas wrote a dissenting opinion in which he argued that, because the Georgia state statute punishes Moncrieffe's offense as a felony, and it is punishable as a felony under the Controlled Substances Act, the conviction should be considered an aggravated felony. He also argued that the majority's opinion allows state felonies to be treated as federal misdemeanors, which runs counter to existing precedent. In his separate dissent, Justice Samuel A. Alito, Jr. wrote that the majority's decision allows the leeway for convicted drug traffickers to remain in the country, which runs counter to the government's interest and existing precedent. Rather than following a purely categorical approach, the majority's decision creates a great deal of variation in the consequences for the conviction of the possession of a controlled substance based on the different state laws. He also argued that, because Moncrieffe did not prove that his offense falls under the definition of a misdemeanor, the deportation decision should be upheld.


[Unknown Act > Facts]
In December 2004, Karen Bartlett's doctor prescribed Sulindac, a generic anti-inflammatory medication, to help treat her shoulder pain. Within months she began suffering from a severe reaction called Stevens-Johnson syndrome, which caused the skin condition toxic epidermal necrolysis. This condition deteriorated over 60 percent of her skin to the point of causing open wounds. As a result, she has suffered permanent and serious injuries, including near-blindness.
Bartlett filed a lawsuit against the Sulindac medication manufacturer, Mutual Pharmaceutical Company. Bartlett initially presented several negligence and product liability claims, but only her design defect product liability claim made it to trial. Beginning in August 2009, a jury at the Federal District Court for the District of New Hampshire heard evidence that Sulindac was unreasonably dangerous to consumers and therefore was defectively designed. Mutual countered, among several other defenses, that federal law governs generic drug manufacturers' conduct; therefore Karen could not pursue a state design defect claim.
After 14 days of trial, the jury deliberated and sided with Bartlett, awarding over $20 million in compensatory damages. Mutual appealed the decision for several reasons, including the following: the district court misunderstood New Hampshire product liability law; and, the court improperly admitted several pieces of evidence and the jury award of damages was excessive. Mutual also reasserted its claim that federal law should prevail over a state defective design claim. Despite Mutual's arguments, the United States Court of Appeals for the First Circuit affirmed the lower court's decision. Mutual appealed further to the Supreme Court of the United States, which granted certiorari.


[Unknown Act > Conclusion]
Yes. Justice Samuel A. Alito Jr. delivered the opinion for the 5-4 majority. The Court held that state law design-defect claims regarding the adequacy of a drug’s warnings are pre-empted by federal law which prohibits generic drug manufacturers from independently changing Food and Drug Administration (FDA) approved drug labels. New Hampshire state law obligates Mutual Pharmaceutical to place a stronger warning on the generic drug labels, a requirement that is irreconcilable with federal requirements. Therefore, the state law is pre-empted by the Supremacy Clause, which states that federal law supersedes that of the states.
Justice Sonia Sotomayor wrote a dissent in which she argued that state law should not be pre-empted without evidence that Congress acted with the intent to supersede state law, especially in fields historically dominated by states. The objective of Congress in creating the law prohibiting the alteration of labels was to prevent misbranding as a protection for the consumer; state law requiring adequate warnings on labels complements this purpose. The New Hampshire design-defect laws are an incentive to avoid strict-liability not a mandate that product labels must be altered, so they are not irreconcilable with the federal law. She also argues that design-defect claims are distinct from failure-to-warn claims. Justice Ruth Bader Ginsburg joined in the dissent. In his separate dissent, Justice Stephen G. Breyer wrote a dissent arguing that Mutual Pharmaceutical could comply with both state and federal law by not doing business in the state. However, if Mutual Pharmaceutical options are limited by the conflicting laws to paying a substantial damages remedy or leaving New Hampshire and these options are an obstacle to the goals of the federal law, then the relevant state law is pre-empted. Without any direction from the relevant federal agency, the FDA, or a general pre-emption clause in the federal statute, he concludes that the New Hampshire law is not a substantial obstacle and should not be pre-empted. Justice Elena Kagan joined in the dissent.


[Unknown Act > Facts]
John Ivan Sutter and Oxford Health Plans entered into a Primary Care Physician Agreement (PCPA). Under this agreement, Sutter provided primary care health services to patients in Oxford's care network in exchange for reimbursement by Oxford. The contract also included a general arbitration clause, which stated, in part, "No civil action concerning any dispute arising under this Agreement shall be instituted before any court." In 2002, Sutter initiated a class action, on behalf of himself and other health care providers under the PCPA, against Oxford, alleging breach of contract and violations of New Jersey law. Oxford moved to compel arbitration. The arbitrator found that the arbitration clause was so general that it encompassed any conceivable court action, including class actions. The arbitrator certified the class, and Oxford moved to vacate that decision in district court arguing the arbitration clause did not encompass class actions and the arbitrator exceeded his authority. The district court denied the motion and class wide arbitration proceeded.
In 2010, the U.S. Supreme Court decided Stolt-Neilson S.A. v. AnimalFeeds International Corp., which held that an arbitrator exceeded his authority by allowing class arbitration when the parties had no agreement on the issue. Oxford moved for reconsideration from the arbitrator in light of Stolt-Neilson, and then moved in district court to vacate the arbitrator's most recent award. Both motions were unsuccessful. On appeal, the U.S. Court of Appeals for the Third Circuit affirmed.


[Unknown Act > Conclusion]
No. Justice Elena Kagan, delivered the opinion for the unanimous Court. The Court held that the arbitrator's interpretation, deciding that the parties intended to authorize class-wide arbitration, did not exceed his powers. When parties agree to arbitration, the price of that decision is that an arbitrator may not interpret the contract correctly. Under the Federal Arbitration Act a court cannot overrule the arbitrator as long as the arbitrator provides an interpretation of the contract.
Justice Samuel A. Alito Jr. wrote a concurrence in which he noted that absent members of the plaintiff class did not consent to the arbitrator's authority and that an arbitrator may only authorize class-wide arbitration when given permission. However, since the petitioner submitted to the arbitration the question of abitrability cannot be raised. Justice Clarence Thomas joined in the concurrence.


[Unknown Act > Facts]
Several groups, including attorneys, journalists, and human rights organizations, brought a facial challenge to a provision of the Foreign Intelligence Surveillance Act (FISA). The provision creates new procedures for authorizing government electronic surveillance of non-U.S. persons outside the U.S. for foreign intelligence purposes. The groups argue that the procedures violate the Fourth Amendment, the First Amendment, Article III of the Constitution, and the principle of separation of powers. The new provisions would force these groups to take costly measures to ensure the confidentiality of their international communications. The District Court for the Southern District of New York granted summary judgment for the government, holding that the groups did not have standing to bring their challenge. The groups only had an abstract subjective fear of being monitored and provided no proof that they were subject to the FISA. The U.S. Court of Appeals for the Second Circuit reversed, holding that the groups had standing based on a reasonable fear of injury and costs incurred to avoid that injury.


[Unknown Act > Conclusion]
No. Justice Samuel A. Alito, writing for a 5-4 majority, reversed and remanded for further proceedings. The Court held that the respondents did not have standing under Article III of the U.S. Constitution because no injury occurred. Claiming a reasonable likelihood that their communications would be intercepted under FISA is not enough to show future injury for standing purposes. The Court also refused to acknowledge a present injury stemming from the respondents' choice to take costly measures to protect their confidential communications.
Justice Stephen G. Breyer dissented, arguing that the future harm to respondents is not speculative and therefore should be sufficient to establish standing. Since there is a high probability that the government will intercept at least some of the respondents' communications, the respondents should have standing to bring the suit. Justice Ruth Bader Ginsburg, Justice Sonia Sotomayor, and Justice Elena Kagan joined in the dissent.


[Unknown Act > Facts]
In 1999, Tara Williams was charged with the 1993 robbery-murder of Hung Mun Kim. During jury deliberations at Williams' trial, the judge received a jury note saying that one of the jurors, juror number six, expressed an intention to disregard the law due to a concern about the severity of the charge of first-degree murder. After an inquiry and evidentiary hearing, the judge dismissed the juror for bias.
Williams appealed, claiming that the trial court abused its discretion when it removed juror number six, because the removal of the "lone holdout" juror violated Williams' Sixth Amendment right to a unanimous jury. The California Court of Appeals rejected her claim as meritless, and the California Supreme Court denied further direct appellate review.
Williams filed a state habeas corpus petition in Los Angleles County Superior Court. The court denied the petition, ruling that the issues raised in the petition were issues for direct appeal, not collateral attack. Williams next filed a federal habeas corpus petition, in which she again challenged the removal of juror number six. The magistrate judge concluded that the trial court's factual finding of bias was entitled to deference and that the discharge of juror number six did not constitute a constitutional violation. The district court adopted the report of the magistrate judge and dismissed the petition with prejudice.
Williams appealed to the United States Court of Appeals for the Ninth Circuit. The appellate court reversed the district court, holding that the deferential-review standard did not apply because the California Court of Appeal had only reviewed her state claim and had not adjudicated her federal constitutional claim. The appellate court then conducted a review of Williams' federal claim and concluded that the Sixth Amendment does not allow a trial judge to discharge a juror on account of his views on the merits of the case. The State of California appealed to the appellate court's decision.


[Unknown Act > Conclusion]
Yes. Justice Samuel A. Alito Jr. delivered a unanimous opinion reversing the Ninth Circuit's judgment and remanding for further proceedings. The Court held that Williams' entire claim had been "adjudicated on the merits," even though the California court did not expressly address the federal law claim. To adjudicate a claim on its merits, a state court is only required to evaluate the evidence and arguments; it is not required to expressly address every single claim. When a defendant presents a federal claim to a state court and the state court denies relief, it must be presumed that the state court adjudicated the claim on its merits. It is up to the defendant to rebut this presumption in order to seek federal habeas relief. To rule otherwise would unreasonably burden the state courts and require them to spend time expressly addressing even the most insignificant claims.


[Unknown Act > Facts]
When the biological mother of Baby Girl became pregnant she did not live with the father and the father did not support the mother financially. The mother sent the father a text message asking if he would rather pay child support or relinquish his parental rights. He sent a text back, saying that he would relinquish his rights, though he later testified that he thought he was relinquishing his rights only to the mother. The biological father was a registered member of the Cherokee Nation. The biological mother attempted to verify this status, but spelled the father's name wrong and misrepresented his birthday in the request, so the Nation could not locate the father's registration. The mother listed Baby Girl's ethnicity as "Hispanic" instead of "Native American" on the birth certificate. The mother decided to put Baby Girl up for adoption because she had two other children that she struggled to support.
Adoptive Couple, who resided in South Carolina, began adoption proceedings in that state. The Cherokee Nation finally identified the father as a registered member and filed a notice of intervention, stating that Baby Girl was an "Indian Child" under the Federal Indian Child Welfare Act (ICWA). The father stated that he did not consent to the adoption and would seek custody of Baby Girl. After trial, the family court denied Adoptive Couple's petition for adoption and granted custody to the biological father. The court held that the biological father was a "parent" under the ICWA because of his paternity and pursuit of custody as soon as he learned that Baby Girl was being put up for adoption. Adoptive Couple did not follow the procedural directives in the ICWA to obtain the father's consent prior to initiating adoption proceedings. The Supreme Court of South Carolina affirmed.


[Unknown Act > Conclusion]
No, a non-custodial parent cannot invoke the ICWA to block an adoption voluntarily and lawfully initiated by a non-Indian parent. The Court did not rule on the definition of "parent," but, for the sake of argument, assumed that the biological father was a "parent" under the ICWA. Justice Samuel A. Alito, Jr. delivered the opinion of the 5-4 majority. The Court held that the ICWA was designed to stop the practice of unwarranted removal of Indian children from Indian families "due to the cultural insensitivity and bias of social workers and state courts." In this case, however, the Court noted that the biological father never had either legal or physical custody of Baby Girl and had previously relinquished his parental rights. Because the biological father gave up custody before birth, and because Baby Girl had never been in his legal or physical custody, the ICWA's goal to prevent the breakup of Indian families did not apply. Furthermore, the Court held that the ICWA's preference for placing an Indian child with family, other members of the tribe, or other Indian families did not apply in this case because no other parties beside the adoptive parents had come forward to adopt Baby Girl. The Court feared that applying the lower court's rationale could lead to a scenario where a biological Indian father could play an "ICWA trump card" to override the mother's decision and the child's best interests.
In his concurring opinion, Justice Clarence Thomas stated that the federal government, in passing the ICWA, may have interfered in the area of family law, a topic constitutionally reserved to the states. However, because the majority opinion avoided constitutional problems, he concurred with the decision. Justice Stephen G. Breyer wrote a separate concurrence in which he stated that the majority's decision may adversely affect parents without looking at whether the parent would look out for the child's best interest, and that the ruling still raised the possibility of allowing an absentee father to re-gain custody with the support of his tribe.
Justice Sonia Sotomayor wrote a dissent in which she argued that the majority's opinion distorted the statute and led to a result that was both contrary to Congress' intent and potentially devastating to Baby Girl. Additionally, she argued that the majority completely ignores Congress' policy reasons for passing the ICWA and distorts the clear provisions in the act. Finally, Justice Sotomayor stated that the majority's interpretation of the ICWA applies adversely to all noncustodial Indian parents, regardless of whether those parents actively participated in their child's upbringing. Justice Ruth Bader Ginsburg and Justice Elena Kagan joined in the dissent, and Justice Antonin Scalia joined in part. In his separate dissent, Justice Antonin Scalia argued that the majority's definition of the phrase, "continued custody," should have also included future custody. He also wrote that the majority's decision "needlessly demeans the right of parenthood" by removing a father's right to raise his child.


[Unknown Act > Facts]
The Association for Molecular Pathology along with several other medical associations, doctors and patients sued the United States Patent and Trademark Office (USPTO) and Myriad Genetics to challenge several patents related to human genetics. The patents cover the BRCA1 and BRCA2 genes and certain mutations that indicate a high risk of developing breast cancer. The suit also challenged several method patents covering diagnostic screening for the genes. Myriad argued that once a gene is isolated, and therefore distinguishable from other genes, it could be patented. By patenting the genes, Myriad had exclusive control over diagnostic testing and further scientific research for the BRCA genes. Petitioners argued that patenting those genes violated §101 the Patent Act because they were products of nature. They also argued that the patents limit scientific progress. §101 limits patents to "any new and useful process, machine, manufacture, or composition of matter, or any new and useful improvement thereof."
The district court granted summary judgment in favor of petitioners, holding that isolating a gene does not alter its naturally occurring fundamental qualities. The U.S. Court of Appeals for the Federal Circuit reversed, holding that isolated genes are chemically distinct from their natural state in the human body. In March 2012, Petitioners sought certiorari; the U.S. Supreme Court vacated the Federal Circuit judgment and remanded for further consideration in light of Mayo Collective Services v. Prometheus Laboratories. On remand, the Federal Circuit again upheld the patentability of the BRCA genes.


[Unknown Act > Conclusion]
Yes and no. Justice Clarence Thomas delivered the opinion for the 9-0 majority. The Supreme Court held that naturally occurring gene sequences, and their natural derivative products, are not patent eligible. Under §101 of the Patent Act, the discovery of natural products does not warrant a patent. However, the Court also held that the creation of a new product in a lab exempts that product from being a product of nature. Therefore, gene sequences refined by synthetic processes to create molecules that do not occur naturally are patent eligible.


[Unknown Act > Facts]
Tarrant Regional Water District (Tarrant) supplies water to north-central Texas. In 1955, Congress allowed Arkansas, Louisiana, Oklahoma, and Texas to negotiate an agreement allocating the water from the Red River, which forms the boundary between southeastern Oklahoma and northeastern Texas. In 1980, the states signed the Red River Compact and Congress ratified it.
In 2007, Tarrant sought to appropriate water from three locations in Oklahoma for use in Texas and applied to the Oklahoma Water Resources Board (OWRB), which was established to regulate in-state and out-of-state water usage. On November 1, 2007, Tarrant sued the OWRB and sought declaratory and injunctive relief against the Oklahoma statutes on water usage. Tarrant argued that the statutes placed burdens on interstate water commerce that are unconstitutional under the Commerce Clause and overstep the bounds of the Compact that Congress allowed the states to establish. OWRB moved for summary judgment, and the district court granted it. The U.S. Court of Appeals for the Tenth Circuit affirmed.


[Unknown Act > Conclusion]
No, no. Justice Sonia Sotomayor delivered the opinion for the unanimous Court. The Court held that the Compact's silence regarding state lines indicated an understanding that the Compact was meant to respect state lines, so state statutes do not conflict with the Compact's allocation of water. Long-running precedent supports the principle that states do not cede water rights within their own territories. Any other reading of the Compact would create jurisdictional and administrative confusion. The Court also held that the Compact does not violate the Commerce Clause by allowing states to interfere in interstate commerce because the Compact does not leave water unallocated for states statutes to affect.


[Unknown Act > Facts]
Michael Eugene Spears and three other lawyers instituted several "group action" lawsuits against several South Carolina car dealerships for allegedly collecting unlawful fees from car buyers. The lawyers obtained the personal information of thousands of car buyers from the South Carolina Department of Motor Vehicles through a Freedom of Information Act request. The lawyers used this data to identify potential plaintiffs for the group action, and sent mailings to each of those plaintiffs notifying them of the litigation.
Edward F. Maracich and two other car buyers who received mailings, individually and on behalf of all similarly situated individuals, sued the lawyers. The buyers alleged that the lawyers violated the Driver's Privacy Protection Act (DPPA) by obtaining their personal information for purposes of mass solicitation. The lawyers argued that they acted properly under the litigation exception to the DPPA. The DPPA allows disclosure of private information in connection with any state or federal litigation. The district court granted summary judgment in favor of the lawyers, holding that they did not engage in prohibited solicitation. The U.S. Court of Appeals for the Fourth Circuit affirmed, holding that the lawyers did engage in solicitation, but their actions were within the litigation exception to the DPPA.


[Unknown Act > Conclusion]
No, no. Justice Anthony M. Kennedy delivered the opinion for the 5-4 majority. The Supreme Court held that the exceptions to the DPPA's protections do not encompass the use of personal information for solicitation of legal clients. If the exceptions could be interpreted so broadly, the purpose of DPPA—protecting personal information—would be defeated. The Court also held that solicitation was a distinct act separate from litigation and therefore not subject to the litigation exception to the DPPA. Similarly, the DPPA does not allow access to personal information after a lawsuit has been filed. The Court held that a lawyer would only need to file a placeholder lawsuit to gain access to the personal information database, which would prevent the DPPA from providing sufficient protection.
Justice Ruth Bader Ginsburg wrote a dissent in which she argued that the DPPA allows the use of DMV-supplied personal information when connected with a specific, concrete legal proceeding. In such cases, the information adds directly to the development of a case. She also argued that the majority's opinion creates a limitation that has no basis in the text of the DPPA. The majority's reading also confuses the interpretation and implementation of the DPPA as a whole. Justice Antonin Scalia, Justice Sonia Sotomayor, and Justice Elena Kagan joined in the dissent.


[Unknown Act > Facts]
Mark McBurney is a citizen of Rohde Island and a former resident of Virginia where his son lives. When McBurney's wife defaulted on child support obligations, he asked the Virginia Division of Child Support Enforcement (VDCSE) to file a petition for child support on his behalf. After a nine-month delay, the petition was filed and granted. He then filed a Virginia Freedom of Information Act (VFOIA) request with the VDCSE for all records pertaining to his son and ex-wife. The VDCSE denied the request, arguing that the information was confidential and McBurney was not a citizen of the state. While McBurney eventually obtained most of needed the information through other sources, he never got all of the information from his VFOIA request.
McBurney sued in district court arguing that denial of the VFOIA request violated the privileges and immunities clause and the dormant commerce clause of the Constitution. The district court ruled against McBurney. Mc Burney along with two others appealed their VFOIA denials to the U.S. Court of Appeals for the Fourth Circuit, which affirmed the district court. The Court of Appeals held that VFOIA did not hinder a non citizen's right to pursue buisness in the state and did not place a burden on interstate commerce.


[Unknown Act > Conclusion]
Yes. Justice Samuel A. Alito delivered a unanimous opinion affirming the Fourth Circuit’s judgment. The Court held that VFOIA does not violate the Privileges and Immunities Clause because VFOIA does not actually violate any fundamental privileges or immunities. Though the Petitioners argued that VFOIA interferes with their fundamental ability to earn a living, own property, and access Virginia courts, the Court rejected these arguments. The Court was also unconvinced that the right to access public information is a fundamental privilege or immunity because neither the Constitution nor the common law guarantees the existence of acts like VFOIA. The Court further held that VFOIA does not violate the dormant Commerce Clause because the law does not interfere with the natural functioning of the interstate market. Since VFOIA neither prohibits access to an interstate market nor imposes burdensome regulation on that market, there is no dormant Commerce Clause issue.


[Unknown Act > Facts]
The Department of the Air Force owns a section of land that Highway 1 crosses, and the Department has granted roadway easements to the State of California and Santa Barbara County. Highway 1 runs next to the main gate of Vandenberg Air Force Base (Vandenberg). Near the gate is a designated area for public protesting that falls under the Highway 1 easement.
John D. Apel was barred from Vandenberg's property in 2007 for trespassing. In 2010, while the order barring him was still in effect, he entered the designated protest area three times and was asked to leave. On all three occasions the respondent failed to leave. In two separate trials, Apel was convicted of three violations of a federal statute prohibiting a person from reentering a military installation after a commanding officer has ordered him not to reenter. Apel appealed, arguing that the federal statute requires that the base has exclusive possession over the area. The district court affirmed the convictions by holding that, under the terms of the easement, the land is subject to base rules and regulations. The U.S. Court of Appeals for the Ninth Circuit reversed and held that, because the area is subject to an easement, the federal government does not have an exclusive right of possession, so the conviction cannot stand.


[Unknown Act > Conclusion]
Yes. Chief Justice John G. Roberts delivered the opinion for the unanimous Court. The Court held that there has historically been a great deal of variation in the ownership status of U.S. military sites around the world, so there is no precedent to support the view that a statute does not apply on a base merely because the base does not have exclusive ownership of the land. Although the base granted the easement, it remained under the jurisdiction of the base commander, who remained in control of all points of access to the base.
In her concurring opinion, Justice Ruth Bader Ginsburg wrote that, when the government creates specific protest places on its property, the First Amendment requires that the government only impose reasonable limitations that are content-neutral and tailored to serve a significant government interest. Although Apel's removal might not stand up to this constitutional review, the Court was correct in not reaching a decision on this issue. Justice Sonia Sotomayor joined in the concurrence. Justice Samuel A. Alito wrote a separate concurring opinion in which he argued that the Supreme Court did not address the constitutional issues in this case because they were not addressed by the Court of Appeals. The failure to address these issues does not indicate agreement or disagreement with the views outlined in Justice Ginsburg's concurrence.


[Unknown Act > Facts]
In November 2006 election, a majority of Michigan voters supported a proposition to amend the state constitution to prohibit "all sex-and race-based preferences in public education, public employment, and public contracting." The day after the proposition passed, a collection of interest groups and individuals formed the Coalition to Defend Affirmative Action, Integration and Immigration Rights and Fight for Equality by Any Means Necessary (Coalition). The Coalition sued the governor and the regents and boards of trustees of three state universities in district court by arguing that the proposition as it related to public education violated the Equal Protection Clause. About a month later, the Michigan Attorney General and Eric Russell, an applicant to the University of Michigan Law School, filed separate motions to intervene as defendants, which were granted. Both sides moved for summary judgment and the plaintiffs moved to have Russell removed from the case as he did not represent interests separate from those of the Michigan Attorney General. The district court granted summary judgment in favor of the defendants and granted the motion to remove Russell as an intervenor. The U.S. Court of Appeals for the Sixth Circuit affirmed in part and reversed in part by holding the proposed amendment unconstitutional and upholding the removal of Russell as a party to the litigation.


[Unknown Act > Conclusion]
No. Justice Anthony M. Kennedy delivered the opinion for the three-justice plurality. The plurality held that this case was not about the constitutionality of race-conscious admissions, but rather about whether the voters of a state can choose to prohibit the use of race preferences in the decisions of governmental bodies, specifically with respect to school admissions. The plurality held that the attempt to define and protect interests based on race ran the risk of allowing the government to classify people based on race and therefore perpetuate the same racism such policies were meant to alleviate. While voters may certainly determine that some race-based preferences should be adopted, it is not the role of the courts to disempower the voters from making such a choice. If certain issues were decided to be too sensitive to be addressed by voters, it would be denying the voters their right to debate and act through the lawful democratic process.
Chief Justice John G. Roberts, Jr. wrote a concurring opinion in which he argued that the use of racial preferences might reinforce racial awareness and therefore do more harm than good. In his opinion concurring in the judgment, Justice Antonin Scalia wrote that a state law that provided equal protection by not allowing the use of racial preferences at least facially did not violate the Constitution. Justice Scalia argued that judges should not be in the position of dividing the country into racial blocs and determining what policies are in each one's interests. Additionally, Justice Scalia saw no reason to allow local subordinate authorities to have more power over the use of race-based preferences than the voters of the state. Since the amendment in question prohibits the use of racial preferences, it patently provides equal protection under the law rather than denying it. Justice Clarence Thomas joined in the opinion concurring in the judgment. Justice Stephen G. Breyer wrote a separate opinion concurring in the judgment in which he argued that, while the Constitution allows local, state, and national communities to implement narrowly tailored, race-conscious policies, it is the voters and not the courts who should determine the merits of such strategies. The amendment better allowed for this process to take place because it took the power to decide whether to implement race-conscious policies away from unelected actors and placed it firmly in the hands of the voters.
Justice Sonia Sotomayor wrote a dissenting opinion in which she argued that the democratic process does not in and of itself provide sufficient protection against the oppression of minority groups, which is why the Equal Protection Clause of the Fourteenth Amendment exists. Although equal protection is typically construed as referring to the treatment of different groups under existing laws, it also protects against the implementation of new laws that would oppress certain groups on the basis of race, among other things. Because the amendment in question creates one admission process for those who do think race should be considered and a separate one for those who do not, it places special burdens on minority groups in a manner that violates the Equal Protection Clause. Judicial precedent holds that governmental action violates the Equal Protection Clause when it has a racial focus that places a greater burden on minority. The amendment in question both has a racial focus and places a greater burden on the minority; therefore, it violates the Equal Protection Clause, and the voters of a state cannot democratically ratify an amendment that violates the Constitution. Justice Sotomayor argued that the plurality and concurring opinions allow a majority of voters in Michigan to prevent the elected university boards from implementing constitutional race-sensitive admission policies, and therefore they ignore a key purpose of the Equal Protection Clause. Justice Ruth Bader Ginsburg joined in the dissenting opinion.
Justice Elena Kagan did not participate in the discussion or decision of this case.


[Unknown Act > Facts]
The Indian Gaming Regulatory Act (IGRA) provides that if certain requirements are met, including a compact between the state and the tribe, an Indian tribe can operate a casino on Indian lands. Under the Michigan Indian Land Claims Settlement Act, lands bought with funds from a congressionally established trust are Indian lands. On November 3, 2010, the Bay Mills Indian Community, a federally recognized Indian tribe with a reservation located in northern Michigan, opened a small casino in the town of Vanderbilt, Michigan, on lands purchased with funds from this trust. The state of Michigan sued for closure of the casino by claiming that the Bay Mills casino violated state gaming laws, as well as various provisions of its Tribal-State compact. The district court entered a preliminary injunction ordering Bay Mills to stop the gambling at the Vanderbilt casino. The U.S. Court of Appeals for the Sixth Circuit vacated the injunction and held that the district court lacked jurisdiction over some of the plaintiffs' claims, while Bay Mills' sovereign immunity bars the others.


[Unknown Act > Conclusion]
Yes. Justice Elena Kagan delivered the opinion for the 5-4 majority. The Court held that Indian tribes have sovereign immunity that can only be revoked by Congress. Additionally, the Supreme Court's decision in Kiowa Tribe of Okla. v. Manufacturing Technologies extended an Indian tribe's sovereign immunity to lawsuits arising out of the tribe's commercial activity. In this case, Congress, via the Indian Gaming Regulatory Act, only regulated an Indian tribe's sovereignty for suits concerning gambling activity on Indian lands. Because Michigan's suit against the Tribe was based on the claim that the new gambling activity was taking place off of the Tribe's land, Michigan cannot rely on the sovereignty abrogation in the Indian Gaming Regulatory Act. The Court also held that states may still act against tribe's who establish gambling venues outside of Indian lands, either by denying a gambling license if the establishment is not located on Indian land or by waiving the tribe's sovereign immunity when negotiating the agreement required by the Indian Gaming Regulatory Act.
In her concurrence in the judgment, Justice Sonia Sotomayor wrote that the principle of "comity," or mutual respect between sovereigns, supported the majority's opinion because the Court had previously ruled that states have sovereign immunity against suits brought by Indian Tribes. Furthermore, tribal sovereign immunity should not be abrogated simply because the Tribe was participating in commercial activity, as such a precedent would deter Tribes from participating in commercial activity, which is a necessary aspect of the Tribes becoming actually sovereign as opposed to relying on federal funds.
Justice Clarence Thomas wrote a dissent in which he argued that a sovereign's immunity relates to immunity within the sovereign's own court system, not to immunity from the courts of other sovereigns. Therefore, an Indian tribe would only be immune from federal and state courts when federal or state law says that Indian tribes are immune. Justice Thomas also argued that any federal law that granted Indian tribes immunity from state courts for off-reservation acts would infringe upon the sovereignty of the individual states. Congress had previously abrogated foreign sovereign immunity when suits are based on a foreign sovereign's commercial activity in the Foreign Sovereign Immunities Act; similarly, in this case, immunity from commercial suits is not fundamental to protecting a Tribe's interest in controlling its internal affairs. Lastly, Justice Thomas stated he would overrule the Court's previous decision in Kiowa Tribe of Oklahoma v. Manufacturing Technologies, which first extended tribal sovereign immunity to a tribe's commercial activities. Justice Ruth Bader Ginsburg, Justice Samuel Alito and Justice Antonin Scalia joined in the dissent. In his separate dissent, Justice Scalia wrote that, for the reasons stated in Justice Thomas' dissent, he would also overrule the previous decision in Kiowa. Justice Ruth Bader Ginsburg also wrote a separate dissent in which she expressed her general concurrence with Justice Thomas's dissent, but she noted a reservation concerning Justice Thomas's expansive view of state sovereignty.


[Unknown Act > Facts]
On March 25, 2011, the State of Mississippi sued a group of liquid crystal display (LCD) manufacturers and claimed that they harmed consumers by engaging in a conspiracy to fix prices for LCD panels, which artificially inflated prices. On June 9, 2011, the respondents jointly removed the case from the Chancery Court of Hinds County to the federal district court and asserted federal jurisdiction was satisfied under the Class Action Fairness Act (CAFA). Class action and mass action suits can be properly removed to federal court under the CAFA.
The State of Mississippi moved to remand the case to state court because the claims in the suit were asserted on behalf of the general public, which prevented the case from falling under federal jurisdiction. The district court granted the motion. The respondents appealed to the United States Court of Appeals of Fifth Circuit, which reversed the lower court's decision. The appellate court held that the suit qualified as a mass action under the CAFA and that Mississippi brought the case in the interest of individual citizens, so the general public exception was not applicable.


[Unknown Act > Conclusion]
No. Justice Sonia Sotomayor delivered the opinion for the unanimous Court. The Supreme Court held that, while CAFA allows defendants in mass action civil suits to remove the case to federal district court, this case does not qualify as a mass action under CAFA. The plain text of CAFA states that a mass action refers to any case with 100 or more persons seeking to try a case jointly for monetary compensation. The Court held that the language of the statute reinforces the interpretation that "persons" refers to plaintiffs in the sense of real named parties to the suit. Because Mississippi is the only named plaintiff in this case, it does not fulfill the meaning of a mass action under CAFA, and the case should be considered in state court.


[Unknown Act > Facts]
In the early 1990s, BG Group PLC (BG), a British company, made a major investment in Argentina's natural gas industry. Later, in the midst of an economic crisis, Argentina enacted an emergency law that required investors to collect tariff revenues in Argentinian pesos at a rate of one peso per dollar. Given the weak international peso-to-dollar exchange rate, these changes that made it difficult for BG to see a return on its investment. Simultaneously, Argentina adopted legislation that stayed all lawsuits arising from the emergency measures. . BG sought recourse under a bilateral investment treaty (Treaty) between the United Kingdom and Argentina. The Treaty required that BG first attempt to resolve its dispute before a "competent tribunal" in Argentina for at least eighteen months. Instead, BG bypassed the Argentinian courts and submitted its dispute directly to an arbitral tribunal. The arbitral panel, seated in Washington, D.C., held that Argentina's changes to its judicial system excused the eighteen-month precondition to arbitration and awarded BG over US$185 million in damages. Argentina petitioned the district court to vacate the award under the Federal Arbitration Act by arguing that the arbitral panel exceeded its powers. The court denied the petition. The U.S. Court of Appeals, District of Columbia Circuit reversed and held that the determination of whether BG could submit its dispute directly to arbitration must be made by a court, not the arbitral tribunal.


[Unknown Act > Conclusion]
No. Justice Stephen G. Breyer delivered the opinion for the 7-2 majority. The Court held that the task of interpreting the Treaty's local litigation provision fell to the arbitrator, and courts should give deference to the arbitrator's findings. Whether a party has satisfied a precondition to arbitration is a procedural matter left for arbitrators under ordinary contract law. The fact that the document at issue is a treaty does not make a critical difference because the text contained no evidence that the parties intended to bypass ordinary contract presumptions about who should decide threshold arbitration issues. The Court further held that the arbitrators' determination that the local litigation provision did not act as a bar to arbitration was within their interpretative authority.
Justice Sonia Sotomayor wrote an opinion concurring in part in which she noted that explicitly labeling a local litigation provision as a condition on the parties' consent to arbitrate would change her analysis. Justice Sotomayor argued that such a label signals the parties' intent for courts, not arbitrators, to decide the issue.
Chief Justice John G. Roberts, Jr. wrote a dissenting opinion in which he argued that the local litigation provision is a condition to the formation of an agreement between the investors and host country to eventually submit their dispute to arbitration. As courts usually decide issues concerning conditions on a party's consent to arbitrate, Justice Roberts would have remanded the case for further proceedings. Justice Anthony M. Kennedy joined in the dissent.


[Unknown Act > Facts]
The Green family owns and operates Hobby Lobby Stores, Inc., a national arts and crafts chain with over 500 stores and over 13,000 employees. The Green family has organized the business around the principles of the Christian faith and has explicitly expressed the desire to run the company according to Biblical precepts, one of which is the belief that the use of contraception is immoral. Under the Patient Protection and Affordable Care Act (ACA), employment-based group health care plans must provide certain types of preventative care, such as FDA-approved contraceptive methods. While there are exemptions available for religious employers and non-profit religious institutions, there are no exemptions available for for-profit institutions such as Hobby Lobby Stores, Inc.
On September 12, 2012, the Greens, as representatives of Hobby Lobby Stores, Inc., sued Kathleen Sebelius, the Secretary of the Department of Health and Human Services, and challenged the contraception requirement. The plaintiffs argued that the requirement that the employment-based group health care plan cover contraception violated the Free Exercise Clause of the First Amendment and the Religious Freedom Restoration Act of 1993 (RFRA). The plaintiffs sought a preliminary injunction to prevent the enforcement of tax penalties, which the district court denied and a two-judge panel of the U.S. Court of Appeals for the Tenth Circuit affirmed. The Supreme Court also denied relief, and the plaintiffs filed for an en banc hearing of the Court of Appeals. The en banc panel of the Court of Appeals reversed and held that corporations were "persons" for the purposes of RFRA and had protected rights under the Free Exercise Clause of the First Amendment.


[Unknown Act > Conclusion]
Yes. Justice Samuel A. Alito, Jr. delivered the opinion for the 5-4 majority. The Court held that Congress intended for the RFRA to be read as applying to corporations since they are composed of individuals who use them to achieve desired ends. Because the contraception requirement forces religious corporations to fund what they consider abortion, which goes against their stated religious principles, or face significant fines, it creates a substantial burden that is not the least restrictive method of satisfying the government's interests. In fact, a less restrictive method exists in the form of the Department of Health and Human Services' exemption for non-profit religious organizations, which the Court held can and should be applied to for-profit corporations such as Hobby Lobby. Additionally, the Court held that this ruling only applies to the contraceptive mandate in question rather than to all possible objections to the Affordable Care Act on religious grounds, as the principal dissent fears.
In his concurrence, Justice Anthony M. Kennedy wrote that the government had not met its burden to show that there was a meaningful difference between non-profit religious institutions and for-profit religious corporations under the RFRA. Because the contraception requirement accommodates the former while imposing a more restrictive requirement on the later without showing proper cause, the requirement violates the RFRA.
Justice Ruth Bader Ginsburg wrote a dissent in which she argued that the majority's decision was precluded by the Court's decision in Employment Division, Department of Human Resources of Oregon v. Smith in which the Court held that there is no violation of the freedom of religion when an infringement on that right is merely an incidental consequence of an otherwise valid statute. Additionally, judicial precedent states that religious beliefs or observances must not impinge on the rights of third parties, as the sought-after exemption would do to women seeking contraception in this case. Justice Ginsburg also wrote that the majority opinion misconstrued the RFRA as a bold legislative statement with sweeping consequences. Because for-profit corporations cannot be considered religious entities, the burden the respondents claim is not substantial, and the government has shown a sufficiently compelling interest, Justice Ginsburg argued that the contraception mandate does not violate the RFRA. Justice Sonia Sotomayor, Justice Stephen G. Breyer, and Justice Elena Kagan joined in the dissent. In their separate dissent, Justice Breyer and Justice Kagan wrote that the Court need not decide whether for-profit corporations or their owners may sue under the RFRA.


[Unknown Act > Facts]
The workers and relatives of workers in the Gonzalez-Catan plant of Mercedes Benz Argentina, a wholly owned subsidiary of German-based DaimlerChrysler AG ("the company"), sued the company for violations of the Torture Victims Protection Act of 1991. They argued that, during Argentina's "Dirty War" of 1976-1983, the company sought to punish plant workers suspected of being union agitators and worked with the Argentinean military and police to do so by passing along information and allowing the plant to be raided. The plaintiffs also argued that the company stood to gain from these actions as they ended strikes and allowed the plant to continue operating at maximum production levels.
The plaintiffs sued the company in district court in California, where some of the company's major subsidiaries are located under the Alien Torts Act, and the company moved for dismissal based on a lack of personal jurisdiction. The district court granted the motion for dismissal and held that the company did not have enough contacts in California to warrant a California court exercising jurisdiction. The U.S. Court of Appeals for the Ninth Circuit reversed the decision and held that it is reasonable for a California court to have jurisdiction over a multinational company that is capable of litigating the case regardless of the location and has pervasive business contacts in the state.


[Unknown Act > Conclusion]
No. Justice Ruth Bader Ginsburg delivered the opinion for the 9-0 majority. The Court held that the company's slim contacts in California, relative to its other national and international contacts, are not sufficient to render it "at home" in the state for the purpose of general jurisdiction. Because the company had so little connection to California and this suit had nothing to do with the company's conduct in the state, to allow the district court to adjudicate such a case would grant the courts essentially global reach as long as the foreign company in question did any business with the state. The Court also held that subjecting the company to this suit would not be in line with the "fair play and substantial justice" standard the Due Process Clause of the Fourteenth Amendment demands.
In her opinion concurring in the judgment, Justice Sonia Sotomayor wrote that the majority opinion ignored due process and jurisdiction precedent by basing the decision on the company's contacts outside the state rather than inside. She argued that such a case should be decided based solely on whether a company has sufficient contacts within the state to establish jurisdiction, without considering those contacts in relation to a larger company presence. Because this case dealt with foreign plaintiffs suing a foreign company for actions committed abroad, California jurisdiction should be considered unreasonable without the analysis of the majority opinion.


[Unknown Act > Facts]
On August 23, 2008, the Mendocino County dispatch center received a call from a Humboldt County dispatcher with the information that a silver Ford F150 pickup truck had run an unidentified vehicle off the road at mile marker 88 on southbound Highway 1. The original caller had also provided the license plate number of the pickup truck in question. The dispatch center broadcast that information to officers in the area, and two separate officers soon reported seeing the vehicle and began following it. The officers pulled the vehicle over, and while requesting information from the driver, smelled marijuana. During a search of the vehicle, the officers found four large bags of marijuana in the truck bed. The occupants of the vehicle, Lorenzo Prado Navarette and Jose Prado Navarette, were arrested for transportation of marijuana and possession of marijuana for sale.
At trial, the defendants moved to suppress the evidence obtained from the traffic stop and argued that the evidence did not establish a reasonable suspicion of wrongdoing to justify the stop. The state argued that the anonymous tip combined with the officers' observations of details that matched the tip constituted reasonable suspicion of the alleged reckless driving. The magistrate judge denied the motion. After the defendants petitioned for a review of this decision and were denied by both the California Court of Appeals for the First District, Division Five and the California Supreme Court, the defendants pled guilty. The California Court of Appeals for the First District, Division Five affirmed.


[Unknown Act > Conclusion]
No. Justice Clarence Thomas delivered the opinion for the 5-4 majority. The Court held that, under the totality of the circumstances, the officer had a reasonable suspicion that the driver was intoxicated, which justified the traffic stop. Because the reasonable suspicion standard allows an officer to rely on information beyond what that officer personally observed, a stop based on an anonymous tip does not violate the Fourth Amendment as long as the officer had reason to believe the information contained in the tip was reliable. In this case, the information came in the form of a call from the driver who had been run off the road, which means that the caller claimed eyewitness knowledge of the incident. Additionally, the timeline of the events suggest that the call was made almost immediately after the incident, so the caller presumably would not have had sufficient time to concoct a story. The Court held that, because the anonymous tip had these indicators of reliability and reported driving behavior consistent with reports of drunk driving that resulted in a car being run off the road, the officer had sufficient reasonable suspicion and did not need to observe the alleged behavior at length.
In his dissenting opinion, Justice Antonin Scalia wrote that the aspects of the anonymous tip that the majority opinion argues make it reliable do not in fact make the information trustworthy enough to stand uncorroborated. Justice Scalia argued that the supposed eyewitness status of the caller could be afforded to anyone who saw the truck and wanted the driver to be pulled over and that any time at all between the alleged incident and the phone call allowed the caller to create a false story. Since the caller only reported a specific instance of unsafe driving—forcing another car off the road—there was no reason for the police officer to suspect ongoing drunk driving. When the officers observed the car and still did not see any indication of impaired driving, the reliability of the anonymous tip was further undermined, and there was no reasonable suspicion for the officer to conduct a traffic stop. Justice Ruth Bader Ginsburg, Justice Sonia Sotomayor, and Justice Elena Kagan joined in the dissent.