Justia U.S. Supreme Court Opinion Summaries

Havana Docks Corporation, a U.S.-based entity, obtained a usufructuary concession from the Cuban Government in 1928, granting it the right to develop and operate docks at the Port of Havana until 2004. This concession included a government promise of compensation if expropriation occurred before expiration. In 1960, following Fidel Castro’s rise to power, the Cuban Government seized control of the docks without compensating Havana Docks, prematurely terminating its concession. The Foreign Claims Settlement Commission later certified Havana Docks’ loss as approximately $9 million plus interest. Decades later, from 2016 to 2019, four major cruise lines used the Havana docks to transport passengers to Cuba, paying Cuban government-affiliated entities for access.Havana Docks sued the cruise lines under the Cuban Liberty and Democratic Solidarity Act (LIBERTAD Act) in the United States District Court for the Southern District of Florida. The cruise lines argued they could not be liable because Havana Docks’ concession would have expired in 2004 even without confiscation. The District Court disagreed, found for Havana Docks, and ordered each cruise line to pay over $100 million. The United States Court of Appeals for the Eleventh Circuit reversed this judgment, holding that liability under the Act required the defendant’s conduct to interfere with a property interest the plaintiff would have had absent confiscation, and since Havana Docks’ concession would have expired before the cruise lines’ conduct, no liability attached.The Supreme Court of the United States reviewed the case and disagreed with the Eleventh Circuit’s analysis. The Court held that, under the Act, liability attaches to anyone who traffics in physical property confiscated by the Cuban Government, not just property interests. It concluded that the cruise lines’ use of the docks constituted trafficking in confiscated property to which Havana Docks owns a claim, regardless of when Havana Docks’ concession would have expired. The Supreme Court vacated the Eleventh Circuit’s decision and remanded the case for further proceedings. View "Havana Docks Corp. v. Royal Caribbean Cruises, Ltd." on Justia Law

A state official sought review of a lower court decision concerning an inmate, Joseph Clifton Smith, who was involved in litigation against the Alabama Department of Corrections. The case reached the United States Supreme Court on a writ of certiorari, which is a request for the Supreme Court to review the decision of a lower court.Previously, the United States Court of Appeals for the Eleventh Circuit had reviewed the case and issued a decision regarding Smith’s claims. The party dissatisfied with the Eleventh Circuit’s ruling—the Commissioner of the Alabama Department of Corrections—then sought review in the Supreme Court, prompting the granting of certiorari.Upon consideration, the Supreme Court of the United States dismissed the writ of certiorari as improvidently granted. This means that the Court concluded it should not have agreed to hear the case and, as a result, did not issue a decision on the merits. The effect of this order is that the decision of the Court of Appeals for the Eleventh Circuit remains in place, and the Supreme Court will not provide further review or guidance in this matter. View "Hamm v. Smith" on Justia Law

Four employers participating in an underfunded multiemployer pension plan withdrew from the plan in 2018. The plan’s trustees, using a newly adopted discount rate of 6.50% (previously 7.50%), calculated each employer’s withdrawal liability based on the plan’s unfunded vested benefits as of December 31, 2017. The change in the discount rate, adopted after the measurement date but before the calculation, significantly increased the amounts the employers owed. The employers challenged these assessments in arbitration, arguing that only actuarial assumptions in effect as of the measurement date could be used.Each arbitrator agreed with the employers, concluding that the plan should have used the discount rate in effect on the measurement date and requiring reassessment with the prior, higher rate. The fund’s trustees then sought review in the United States District Court for the District of Columbia, which disagreed with the arbitrators and held that it was permissible for the plan’s actuary to select assumptions after the measurement date. The United States Court of Appeals for the District of Columbia Circuit affirmed, reasoning that the statutory text did not require actuarial assumptions to be fixed as of the measurement date, and that assumptions could be adopted later as long as they reflected the best estimate as of that date. This decision created a conflict with a prior ruling by the United States Court of Appeals for the Second Circuit.The Supreme Court of the United States held that the relevant provisions of ERISA do not require the actuarial assumptions used to calculate withdrawal liability to be selected on or before the statutory measurement date. The Court affirmed the D.C. Circuit, concluding that, while the measurement date fixes the relevant factual data, the timing of selecting actuarial assumptions is not limited by statute. The Court also noted that the statute requires only that the assumptions be reasonable and reflect the actuary’s best estimate. View "M & K Employee Solutions, Inc. v. Trustees of IAM Nat. Pension" on Justia Law

The case concerns an employee who worked at a Los Angeles hotel and was terminated in March 2020, allegedly due to COVID-19-related staffing issues. The employee sued the hotel and its affiliates in the United States District Court for the Southern District of New York, alleging federal and state law discrimination claims. However, before starting work, the employee had signed an arbitration agreement covering disputes related to employment or termination. The hotel moved to stay the court proceedings and compel arbitration under the Federal Arbitration Act (FAA), and the District Court stayed the case pending arbitration. Arbitration proceeded, resulting in an award against the employee on all claims, as well as sanctions for misconduct.After the arbitrator’s award, the hotel moved to confirm the award in the District Court under §9 of the FAA, while the employee sought to vacate it under §10. The employee argued that the District Court lacked jurisdiction to confirm or vacate the award because the post-arbitration motions did not independently satisfy the requirements for federal-question or diversity jurisdiction. The District Court disagreed, held that it retained jurisdiction, and confirmed the arbitral award. The United States Court of Appeals for the Second Circuit affirmed, distinguishing the case from Supreme Court precedent involving freestanding FAA motions, and holding that the District Court’s original jurisdiction over the employee’s federal claims extended to the post-arbitration proceedings.The Supreme Court of the United States affirmed the Second Circuit’s judgment. It held that when a federal court has original jurisdiction over claims and stays those claims pending arbitration under §3 of the FAA, the court retains jurisdiction to confirm or vacate the resulting arbitral award under §9 and §10. The Court reasoned that nothing in the FAA divests the court of jurisdiction over the original claims while arbitration is pending, and that post-arbitration motions are integral to the resolution of those stayed claims. View "Jules v. Andre Balazs Properties" on Justia Law

A man suffered severe injuries, including the loss of his leg, when his stopped tractor-trailer was struck by a truck driven by an employee of a motor carrier. The shipment had been coordinated by a broker, and the injured man alleged the broker was liable for negligently hiring the motor carrier and its driver, pointing to the carrier’s poor safety rating and regulatory violations. The claim asserted that the broker knew, or should have known, that hiring this carrier posed a reasonable risk of causing harm.In the United States District Court for the Southern District of Illinois, the broker moved to dismiss the negligent-hiring claim, arguing that it was preempted by the Federal Aviation Administration Authorization Act (FAAAA). That court, following precedent from the United States Court of Appeals for the Seventh Circuit, agreed and dismissed the claim, reasoning that it was expressly preempted by the FAAAA and did not fall within the safety exception. The Seventh Circuit affirmed the district court’s decision, maintaining that the safety exception did not apply to the broker in this context.The Supreme Court of the United States reviewed the case to resolve a division among the circuits. The Court held that the FAAAA’s safety exception does encompass negligent-hiring claims against brokers when those claims concern the use of motor vehicles in transportation. Specifically, the Court determined that state common-law negligent-hiring standards, as applied to brokers who select motor carriers, constitute the exercise of “safety regulatory authority of a State with respect to motor vehicles” and are thus not preempted by the FAAAA. The Supreme Court reversed the judgment of the Seventh Circuit and remanded the case for further proceedings. View "Montgomery v. Caribe Transport II, LLC" on Justia Law

A religious nonprofit organization in New Jersey, active since 1985, provides counseling and resources to pregnant women but does not offer or refer for abortions due to its belief that life begins at conception. In 2022, the state’s Attorney General created a task force that accused groups like this one of spreading misleading information about abortion. Subsequently, the Attorney General issued a subpoena demanding the group turn over documents identifying many of its donors, except those who donated through one specific webpage. The subpoena warned that noncompliance could lead to contempt charges and other penalties.The organization responded by filing a lawsuit in the United States District Court, seeking to block enforcement of the subpoena and arguing that the compelled disclosure of its donor information would chill its First Amendment rights by deterring donors. The district court denied the group’s request for a preliminary injunction and dismissed the complaint, holding there was no justiciable claim because no court had yet ordered the group to comply with the subpoena, so no injury had occurred. The United States Court of Appeals for the Third Circuit affirmed, finding that the group lacked standing since any potential harm was not sufficiently concrete or imminent.The Supreme Court of the United States reversed the Third Circuit’s decision. The Court held that the subpoena itself, even before enforcement, constitutes an ongoing injury to the organization’s First Amendment associational rights by deterring donors and burdening protected association. The Court clarified that the injury arises when the government issues such a demand—not only if and when a court enforces it. The Court further held that the possibility of later confidentiality protections or limited exceptions in the subpoena did not eliminate the injury. The case was remanded for further proceedings. View "First Choice Women's Resource Centers, Inc. v. Davenport" on Justia Law

After the 2020 census, Louisiana redrew its congressional districts, enacting a map (HB1) with only one majority-black district. Plaintiffs challenged this map in the United States District Court for the Middle District of Louisiana, arguing that it diluted black voting power in violation of Section 2 of the Voting Rights Act. The court agreed, finding a likely Section 2 violation and ordering the state to add a second majority-black district. To avoid a court-imposed map, the legislature enacted a new map (SB8) with a second majority-black district, which connected distant black populations across the state.The new SB8 map was then challenged as an unconstitutional racial gerrymander in the United States District Court for the Western District of Louisiana (a three-judge court). The court found that race predominated in the drawing of SB8’s District 6 and that the state could not justify its actions under the Equal Protection Clause. The court concluded that the state had failed to show that Section 2 of the Voting Rights Act required the creation of an additional majority-black district or that compliance with the Act was a compelling interest. The court therefore held SB8 unconstitutional.On direct appeal, the Supreme Court of the United States addressed whether compliance with Section 2 of the Voting Rights Act can ever justify intentional race-based districting. The Court held that Section 2, properly interpreted, requires liability only when there is a strong inference of intentional discrimination, not merely disparate impact. The Court also clarified that a plaintiff’s illustrative maps must satisfy all the state’s legitimate districting goals without using race as a predominant factor and that evidence of racially polarized voting must be disentangled from partisan affiliation. The Supreme Court affirmed the district court’s ruling, holding that Louisiana’s SB8 map was an unconstitutional racial gerrymander because Section 2 did not require a second majority-black district, and no compelling interest justified the use of race. The case was remanded for further proceedings. View "Louisiana v. Callais" on Justia Law

A former Army specialist was seriously injured in a suicide bombing at a U.S. military base in Afghanistan. The attack was carried out by Ahmad Nayeb, a Taliban operative hired by Fluor Corporation, a military contractor, as part of a program encouraging the hiring of Afghan nationals. The Army’s investigation concluded that Fluor was primarily responsible due to negligent supervision and failure to enforce proper security procedures, including allowing Nayeb to check out tools used in the bombing and to move about the base unsupervised. The plaintiff sued Fluor in federal court in South Carolina, seeking damages under state law for negligent supervision, negligent entrustment, and negligent retention of Nayeb.The United States District Court for the District of South Carolina granted summary judgment to Fluor, holding that state-law tort claims were preempted under Fourth Circuit precedent whenever they arose out of combatant activities in a wartime setting. The United States Court of Appeals for the Fourth Circuit affirmed, adopting a broad “battlefield preemption” doctrine. It reasoned that the Federal Tort Claims Act’s (FTCA) combatant-activities exception, which preserves government immunity for claims arising out of military combatant activities, reflected an intent to bar all tort suits against contractors connected with those activities, regardless of whether the contractor followed or violated military instructions.The Supreme Court of the United States vacated the Fourth Circuit’s judgment and remanded the case. The Court held that the Fourth Circuit erred in finding the state-law tort claims preempted where the federal government neither ordered nor authorized the challenged conduct. The Supreme Court clarified that neither the Constitution, federal statutes, nor its precedents support such broad preemption. Preemption applies only if the contractor was following government directives or if there is a significant conflict between federal interests and state law, which was not the case here. View "Hencely v. Fluor Corp." on Justia Law

The case concerns a dispute over the operation of Line 5, a petroleum pipeline owned and operated by Enbridge, which traverses the Straits of Mackinac in Michigan under a 1953 easement granted by the State. In June 2019, the Michigan Attorney General filed a lawsuit in state court seeking to stop Enbridge from operating the pipeline, arguing that the easement was void and that continued operation violated state law due to environmental risks. Enbridge was served with the complaint in July 2019 but did not remove the case to federal court within the statutory 30-day deadline. Instead, Enbridge litigated in state court for over a year.Subsequently, in November 2020, the Michigan Governor revoked the easement and initiated a separate state lawsuit with similar claims. Enbridge timely removed the Governor’s case to federal court, where the parties agreed to pause the Attorney General’s case pending resolution. After the District Court in the Governor’s case denied remand, finding federal-question jurisdiction, the Governor dismissed her suit. Thereafter, 887 days after the Attorney General’s complaint was served, Enbridge removed the original state lawsuit to federal court. The Attorney General moved to remand, arguing removal was untimely. The U.S. District Court denied the motion, excusing Enbridge’s late removal on equitable grounds and certified the issue for interlocutory appeal.The United States Court of Appeals for the Sixth Circuit reversed, holding that although the 30-day removal deadline in 28 U.S.C. §1446(b)(1) is nonjurisdictional, it is not subject to equitable tolling due to the statute’s text, structure, and context. The Supreme Court of the United States affirmed the Sixth Circuit’s decision, holding that §1446(b)(1)’s 30-day removal deadline cannot be equitably tolled. As a result, Enbridge’s removal was untimely, and the case must be remanded to Michigan state court. View "Enbridge Energy, LP v. Nessel" on Justia Law

In the early morning hours, a Metropolitan Police officer in Washington, D.C., responded to a radio dispatch about a suspicious vehicle at a specific location. Upon arrival, the officer observed two individuals fleeing from the car without any apparent provocation, leaving at least one car door open. The driver, R.W., then began to back the car out of its parking space with the rear door still open. The officer ordered R.W. to put his hands up and subsequently recovered evidence leading to charges including unauthorized use of a motor vehicle and felony receipt of stolen property.The Superior Court of the District of Columbia conducted a suppression hearing and denied R.W.’s motion to suppress, finding that the officer had reasonable suspicion based on the dispatch, the passengers’ flight, the late hour, and the car’s movement. After a bench trial, the court adjudicated R.W. delinquent on all counts. On appeal, the District of Columbia Court of Appeals reversed the suppression ruling and vacated the adjudication. It held that the officer lacked reasonable suspicion, after discounting the dispatch and the companions’ flight as relevant factors.The Supreme Court of the United States reviewed the case and held that the officer did have reasonable suspicion to stop R.W. The Court emphasized that the totality-of-the-circumstances test must be used, and that the Court of Appeals erred by disregarding key facts, such as the dispatch and the passengers’ flight, from its analysis. The Supreme Court reversed the judgment of the District of Columbia Court of Appeals and remanded the case for further proceedings consistent with its opinion. The holding is that, under the totality of the circumstances, the officer’s stop was supported by reasonable suspicion as required by the Fourth Amendment. View "District of Columbia v. R.W." on Justia Law