Justia U.S. Supreme Court Opinion Summaries

Amina Bouarfa, a U.S. citizen, filed a visa petition with the U.S. Citizenship and Immigration Services (USCIS) for her noncitizen spouse, Ala’a Hamayel. Initially, USCIS approved the petition. However, two years later, USCIS issued a Notice of Intent to Revoke the approval based on evidence suggesting that Hamayel had previously entered into a sham marriage to evade immigration laws. Despite Bouarfa's denial of the allegations, USCIS revoked the petition approval under the Secretary of Homeland Security's authority to revoke for "good and sufficient cause." The Board of Immigration Appeals affirmed the revocation.Bouarfa challenged the revocation in federal court, arguing that the agency's decision was arbitrary and capricious. The District Court dismissed the suit, holding that 8 U.S.C. §1252(a)(2)(B)(ii) barred judicial review of the agency's discretionary decisions. The Eleventh Circuit Court of Appeals affirmed the District Court's decision, agreeing that the Secretary's revocation authority under 8 U.S.C. §1155 was discretionary and thus not subject to judicial review.The Supreme Court of the United States reviewed the case and held that the revocation of an approved visa petition under §1155, based on a sham-marriage determination, is a discretionary decision falling within the purview of §1252(a)(2)(B)(ii). This statute strips federal courts of jurisdiction to review certain discretionary actions by the agency. The Court affirmed the judgment of the Eleventh Circuit, concluding that the Secretary's decision to revoke the visa petition was indeed discretionary and not subject to judicial review. View "Bouarfa v. Mayorkas" on Justia Law

The case involves Corner Post, a merchant that accepts debit cards as a form of payment. Debit card transactions require merchants to pay an "interchange fee" to the bank that issued the card. The fee amount is set by the payment networks (such as Visa and MasterCard) that process the transaction. In 2010, Congress tasked the Federal Reserve Board with ensuring that interchange fees were "reasonable and proportional to the cost incurred by the issuer with respect to the transaction." In 2011, the Board published Regulation II, which sets a maximum interchange fee of $0.21 per transaction plus .05% of the transaction’s value.In 2021, Corner Post joined a suit against the Board under the Administrative Procedure Act (APA), challenging Regulation II on the ground that it allows higher interchange fees than the statute permits. The District Court dismissed the suit as time-barred under 28 U. S. C. §2401(a), the default six-year statute of limitations applicable to suits against the United States. The Eighth Circuit affirmed the decision.The Supreme Court of the United States reversed the decision of the Eighth Circuit. The Court held that an APA claim does not accrue for purposes of §2401(a)’s 6-year statute of limitations until the plaintiff is injured by final agency action. The Court disagreed with the Board's argument that an APA claim “accrues” under §2401(a) when agency action is “final” for purposes of §704; the claim can accrue for purposes of the statute of limitations even before the plaintiff suffers an injury. The Court held that a right of action “accrues” when the plaintiff has a “complete and present cause of action,” which is when she has the right to “file suit and obtain relief.” Because an APA plaintiff may not file suit and obtain relief until she suffers an injury from final agency action, the statute of limitations does not begin to run until she is injured. View "Corner Post, Inc. v. Board of Governors" on Justia Law

The case involves former President Donald Trump, who was indicted on four counts for conduct that occurred during his presidency following the November 2020 election. The indictment alleged that Trump conspired to overturn the election by spreading knowingly false claims of election fraud. Trump moved to dismiss the indictment based on Presidential immunity, arguing that a President has absolute immunity from criminal prosecution for actions performed within his official responsibilities. The District Court denied Trump’s motion to dismiss, holding that former Presidents do not possess federal criminal immunity for any acts. The D.C. Circuit affirmed this decision.The Supreme Court of the United States held that under the constitutional structure of separated powers, a former President is entitled to absolute immunity from criminal prosecution for actions within his conclusive and preclusive constitutional authority. He is also entitled to at least presumptive immunity from prosecution for all his official acts. However, there is no immunity for unofficial acts. The Court vacated the judgment of the D.C. Circuit and remanded the case for further proceedings consistent with its opinion. The Court emphasized that the President is not above the law, but under the system of separated powers, the President may not be prosecuted for exercising his core constitutional powers. View "Trump v. United States" on Justia Law

In 2021, Florida and Texas enacted statutes regulating large social-media companies and other internet platforms. The laws curtailed the platforms' ability to engage in content moderation and required them to provide reasons to a user if they removed or altered her posts. NetChoice LLC, a trade association whose members include Facebook and YouTube, brought First Amendment challenges against the two laws. District courts in both states entered preliminary injunctions.The Eleventh Circuit upheld the injunction of Florida’s law, holding that the state's restrictions on content moderation trigger First Amendment scrutiny. The court concluded that the content-moderation provisions are unlikely to survive heightened scrutiny. The Fifth Circuit, however, disagreed and reversed the preliminary injunction of the Texas law. The court held that the platforms’ content-moderation activities are “not speech” at all, and so do not implicate the First Amendment.The Supreme Court of the United States vacated the judgments and remanded the cases, stating that neither the Eleventh Circuit nor the Fifth Circuit conducted a proper analysis of the facial First Amendment challenges to Florida and Texas laws regulating large internet platforms. The Court held that the laws interfere with protected speech, as they prevent the platforms from compiling the third-party speech they want in the way they want, thus producing their own distinctive compilations of expression. The Court also held that Texas's asserted interest in correcting the mix of viewpoints that major platforms present is not valid under the First Amendment. View "Moody v. NetChoice, LLC" on Justia Law

The Supreme Court of the United States reviewed two cases involving challenges to a rule promulgated by the National Marine Fisheries Service under the Magnuson-Stevens Act. The rule required certain fishing vessels to carry observers onboard to collect data necessary for fishery conservation and management, with the cost of these observers to be borne by the vessel owners. The petitioners, various fishing businesses, argued that the Act did not authorize the Fisheries Service to impose these costs on them.In the lower courts, the District Court for the District of Columbia Circuit and the First Circuit Court of Appeals both upheld the rule. They applied the Chevron framework, a two-step process used to interpret statutes administered by federal agencies. Under this framework, if a statute is ambiguous, courts defer to the agency's interpretation as long as it is reasonable. Both courts found that the Magnuson-Stevens Act was ambiguous on the issue of observer costs and deferred to the Fisheries Service's interpretation.The Supreme Court, however, overruled the Chevron doctrine, holding that it was inconsistent with the Administrative Procedure Act (APA). The APA requires courts to exercise their independent judgment in deciding whether an agency has acted within its statutory authority. Courts may not defer to an agency interpretation of the law simply because a statute is ambiguous. The Court vacated the judgments of the lower courts and remanded the cases for further proceedings consistent with this opinion. The Court emphasized that while courts may seek guidance from the interpretations of those responsible for implementing particular statutes, they must not defer to these interpretations. Instead, they must independently interpret the statute and ensure that the agency has acted within its statutory authority. View "Loper Bright Enterprises v. Raimondo" on Justia Law

The case involves the city of Grants Pass, Oregon, and its laws restricting public camping. The city's laws prohibit activities such as camping on public property or parking overnight in the city’s parks. Violations can result in fines and, in the case of multiple violations, imprisonment. A group of homeless individuals filed a class action lawsuit against the city, arguing that these ordinances violated the Eighth Amendment's prohibition against cruel and unusual punishment. The district court agreed with the plaintiffs, citing a previous Ninth Circuit decision, Martin v. Boise, which held that cities cannot enforce public camping ordinances against homeless individuals when the number of homeless individuals exceeds the number of available shelter beds.The Ninth Circuit affirmed the district court's decision, leading to the city's appeal to the Supreme Court. The Supreme Court reversed the Ninth Circuit's decision, holding that the enforcement of laws regulating camping on public property does not constitute "cruel and unusual punishment" prohibited by the Eighth Amendment. The Court reasoned that the Eighth Amendment focuses on the punishment a government may impose after a criminal conviction, not on whether a government may criminalize particular behavior in the first place. The Court also noted that the punishments imposed by the city of Grants Pass, such as fines and temporary bans from public parks, did not qualify as cruel and unusual under the Eighth Amendment. The case was remanded for further proceedings consistent with the Supreme Court's opinion. View "City of Grants Pass v. Johnson" on Justia Law

The case revolves around the interpretation of the Sarbanes-Oxley Act of 2002, specifically 18 U.S.C. §1512(c)(2), which imposes criminal liability on anyone who corruptly obstructs, influences, or impedes any official proceeding, or attempts to do so. The petitioner, Joseph Fischer, was charged with violating this provision for his actions during the Capitol breach on January 6, 2021. Fischer moved to dismiss the charge, arguing that the provision only criminalizes attempts to impair the availability or integrity of evidence. The District Court granted his motion, but a divided panel of the D.C. Circuit reversed and remanded for further proceedings.The Supreme Court of the United States held that to prove a violation of §1512(c)(2), the Government must establish that the defendant impaired the availability or integrity for use in an official proceeding of records, documents, objects, or other things used in an official proceeding, or attempted to do so. The Court reasoned that the "otherwise" provision of §1512(c)(2) is limited by the list of specific criminal violations that precede it in (c)(1). The Court also considered the broader context of §1512 in the criminal code and found that an unbounded interpretation of subsection (c)(2) would render superfluous the careful delineation of different types of obstructive conduct in §1512 itself. The Court vacated the judgment of the D.C. Circuit and remanded the case for further proceedings consistent with its opinion. View "Fischer v. United States" on Justia Law

The Clean Air Act envisions a collaborative effort between states and the federal government to regulate air quality. When the Environmental Protection Agency (EPA) sets standards for common air pollutants, states must submit a State Implementation Plan (SIP), providing for the implementation, maintenance, and enforcement of those standards in their jurisdictions. In 2015, the EPA revised its air-quality standards for ozone, triggering a requirement for states to submit new SIPs. Years later, the EPA announced its intention to disapprove over 20 SIPs because the agency believed they had failed to address adequately obligations under the Good Neighbor Provision. During the public-comment period for the proposed SIP disapprovals, the EPA issued a single proposed Federal Implementation Plan (FIP) to bind all those states.The D.C. Circuit denied relief to a number of the remaining states and industry groups who challenged the FIP, arguing that the EPA’s decision to apply the FIP after so many other states had dropped out was “arbitrary” or “capricious.” They asked the court to stay any effort to enforce the FIP against them while their appeal unfolded. The parties renewed their request in the Supreme Court of the United States.The Supreme Court granted the applications for a stay, halting enforcement of the EPA’s rule against the applicants pending the disposition of the applicants’ petition for review in the D.C. Circuit and any petition for writ of certiorari, timely sought. The Court found that the applicants were likely to prevail on their claim that the EPA’s action was arbitrary or capricious because the agency failed to offer a satisfactory explanation for its action, including a rational connection between the facts found and the choice made, and ignored an important aspect of the problem. The EPA’s alternative arguments were unavailing. View "Ohio v. Environmental Protection Agency" on Justia Law

Between 1999 and 2019, Purdue Pharma, owned and controlled by the Sackler family, was at the center of the opioid crisis in the United States. After earning billions from the sale of OxyContin, Purdue faced thousands of lawsuits. In response, the Sacklers withdrew approximately $11 billion from Purdue, leaving the company in a weakened financial state. In 2019, Purdue filed for Chapter 11 bankruptcy. During the bankruptcy process, the Sacklers proposed to return approximately $4.3 billion to Purdue’s bankruptcy estate in exchange for a judicial order releasing the family from all opioid-related claims and preventing victims from bringing such claims against them in the future.The bankruptcy court approved Purdue’s proposed reorganization plan, including its provisions concerning the Sackler discharge. However, the district court vacated that decision, holding that nothing in the law authorizes bankruptcy courts to extinguish claims against third parties like the Sacklers, without the claimants’ consent. A divided panel of the Second Circuit reversed the district court and revived the bankruptcy court’s order approving a modified reorganization plan.The Supreme Court of the United States held that the bankruptcy code does not authorize a release and injunction that, as part of a plan of reorganization under Chapter 11, effectively seek to discharge claims against a nondebtor without the consent of affected claimants. The Court found that the Sacklers sought to pay less than the code ordinarily requires and receive more than it normally permits. The Court reversed the Second Circuit's judgment and remanded the case for further proceedings consistent with its opinion. View "Harrington v. Purdue Pharma L.P." on Justia Law

The case involves the Securities and Exchange Commission (SEC) and investment adviser George Jarkesy, Jr., and his firm, Patriot28, LLC. The SEC initiated an enforcement action for civil penalties against Jarkesy and Patriot28 for alleged violations of the "antifraud provisions" contained in the federal securities laws. The SEC opted to adjudicate the matter in-house. The final order determined that Jarkesy and Patriot28 had committed securities violations and levied a civil penalty of $300,000. Jarkesy and Patriot28 petitioned for judicial review. The Fifth Circuit vacated the order on the ground that adjudicating the matter in-house violated the defendants’ Seventh Amendment right to a jury trial.The Fifth Circuit Court of Appeals ruled that the in-house adjudication by the SEC violated the defendants' Seventh Amendment right to a jury trial. The court applied a two-part test from Granfinanciera, S.A. v. Nordberg, determining that the SEC's antifraud claims were akin to traditional actions at common law, and thus required a jury trial. The court also concluded that the "public rights" exception did not apply, as the claims were not closely intertwined with the bankruptcy process.The Supreme Court of the United States affirmed the Fifth Circuit's decision. The Court held that when the SEC seeks civil penalties against a defendant for securities fraud, the Seventh Amendment entitles the defendant to a jury trial. The Court found that the SEC's antifraud provisions replicate common law fraud, and thus implicate the Seventh Amendment. The Court also concluded that the "public rights" exception to Article III jurisdiction did not apply, as the action did not fall within any of the distinctive areas involving governmental prerogatives where a matter may be resolved outside of an Article III court, without a jury. The Court did not reach the remaining constitutional issues and affirmed the ruling of the Fifth Circuit on the Seventh Amendment ground alone. View "SEC v. Jarkesy" on Justia Law