Justia U.S. Supreme Court Opinion Summaries

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

During the Second World War, Chevron’s corporate predecessor operated oil fields in Plaquemines Parish, Louisiana, producing crude oil that was refined into aviation gasoline (avgas) for the United States military under federal contracts. Decades later, following the enactment of Louisiana’s State and Local Coastal Resources Management Act of 1978, which imposed permit requirements on certain uses of the coastal zone but exempted uses lawfully commenced before 1980, Plaquemines Parish and other parishes brought suit in state court. They alleged that Chevron and other oil companies had failed to obtain required permits and that some pre-1980 activities, including those during the war, were illegally commenced and not exempt.The parish’s expert report specifically challenged Chevron’s wartime crude-oil production methods, including its use of vertical drilling, canals, and earthen pits, as harmful to the environment and not in compliance with the Act. Chevron sought removal to federal court under the federal officer removal statute, 28 U.S.C. §1442(a)(1), arguing that the suit was “for or relating to” acts under color of its duties as a federal contractor refining avgas. The United States District Court granted the parish’s motion to remand to state court. The United States Court of Appeals for the Fifth Circuit affirmed, reasoning that although Chevron acted under a federal officer as a military contractor, the suit did not “relate to” those acts because the federal refining contract did not govern how Chevron obtained or produced crude oil.The Supreme Court of the United States held that Chevron plausibly alleged a close, not tenuous or remote, relationship between the challenged crude-oil production and its federal avgas refining duties. The Court concluded that the suit satisfied the “relating to” requirement for removal under §1442(a)(1), vacated the Fifth Circuit’s judgment, and remanded the case for further proceedings. View "Chevron USA Inc. v. Plaquemines Parish" on Justia Law

A licensed mental health counselor in Colorado, who provides talk therapy to clients—including minors—challenged a state law that prohibits licensed counselors from engaging in “conversion therapy” with minors. The law defines conversion therapy broadly to include any practice or treatment that attempts to change an individual’s sexual orientation or gender identity, including efforts to alter behaviors, expressions, or attractions. However, the law permits counselors to support clients exploring their identity or undergoing gender transition. The counselor’s practice involves helping clients pursue their own stated goals, which may include support for changes in sexual orientation or gender identity, but she only utilizes talk therapy and does not engage in any physical interventions.The United States District Court for the District of Colorado first reviewed the case. That court, and later the United States Court of Appeals for the Tenth Circuit, concluded that the counselor had standing to bring a pre-enforcement, as-applied First Amendment challenge to the law. Both courts interpreted the law as prohibiting her from using speech to help clients change their sexual orientation or gender identity. Nevertheless, both courts denied her request for a preliminary injunction, reasoning that the law regulates professional conduct, not speech, and any effect on speech is merely incidental. Applying rational-basis review, they found the law constitutionally permissible.The Supreme Court of the United States granted review to resolve a circuit split. The Supreme Court held that, as applied to the counselor’s talk therapy, the Colorado law regulates speech based on viewpoint, not merely conduct, and that the lower courts erred by applying only rational-basis scrutiny. The Supreme Court ruled that the law is subject to strict scrutiny under the First Amendment and reversed the Tenth Circuit’s decision, remanding the case for further proceedings consistent with its opinion. View "Chiles v. Salazar" on Justia Law

Several major music copyright owners, including a leading entertainment company, sought to hold an Internet service provider responsible for copyright infringement committed by its subscribers. The service provider, which serves millions of customers, was notified by a monitoring company of over 160,000 instances where its subscribers’ IP addresses were linked to alleged copyright violations such as illegal music file sharing. Although the provider had policies prohibiting infringement and took steps such as issuing warnings and suspending service, the copyright holders argued these measures were inadequate and brought suit seeking to impose liability on the provider for continuing to serve known infringers.The case was tried in the United States District Court for the Eastern District of Virginia. There, the jury found in favor of the copyright owners on both contributory and vicarious liability, and determined the provider’s infringement was willful, awarding $1 billion in statutory damages. After the District Court denied the provider’s post-trial motion, the United States Court of Appeals for the Fourth Circuit affirmed the finding of contributory liability, reasoning that supplying a service with knowledge it would be used for infringement was sufficient. The Fourth Circuit, however, reversed as to vicarious liability and remanded for a new determination of damages.The Supreme Court of the United States reviewed the case concerning contributory liability. The Court held that a service provider is contributorily liable for a user’s infringement only if it either induced the infringement or provided a service tailored for infringement. Because the provider neither encouraged infringement nor offered a service primarily designed for infringement—since Internet access has substantial lawful uses—the provider was not contributorily liable. The Supreme Court reversed the Fourth Circuit’s judgment on contributory liability and remanded the case for further proceedings. View "Cox Communications, Inc. v. Sony Music Entertainment" on Justia Law

The case concerns a federal defendant who, after serving a prison sentence for drug trafficking, began a term of supervised release. Following her initial release, she violated the conditions of supervised release, resulting in revocation and a new term of supervised release. During her second supervised release period, she again violated the conditions by changing her address without notifying her probation officer. A warrant was issued, but authorities did not apprehend her until over a year after her supervised release term was scheduled to expire. While absconding, she committed a separate state drug offense and was convicted in state court.The United States District Court concluded that her state drug offense, committed after her supervised release term had expired by the original schedule, constituted a violation of supervised release because her period was tolled (paused) while she was absconding. The court treated the drug offense as a Grade A violation and imposed another prison sentence followed by a new term of supervised release. The United States Court of Appeals for the Ninth Circuit affirmed, adopting the view that abscondment automatically tolled the supervised release period, allowing post-expiration violations to be treated as if they occurred during the term.The Supreme Court of the United States reversed the Ninth Circuit’s decision. The Court held that the Sentencing Reform Act does not authorize an automatic extension of a supervised release term when a defendant absconds. The Act specifies when supervised release begins and ends, provides mechanisms for revocation and extension under defined circumstances, and allows delayed adjudication of violations only for conduct occurring before expiration if a warrant or summons issues before the term ends. The Court concluded that abscondment does not automatically extend or toll the supervised release term beyond its judicially prescribed limit. The case was remanded for further proceedings. View "Rico v. United States" on Justia Law

During the inauguration of Vermont’s governor, a group of protesters, including Shela Linton, staged a sit-in at the state capitol to advocate for universal healthcare. When the building closed, police instructed the protesters to leave or face arrest for trespassing. Some complied, while others, including Linton, refused. Sergeant Jacob Zorn approached Linton, who remained seated and passively resisted. After multiple warnings, Zorn used a rear wristlock to lift Linton to her feet, causing her to exclaim in pain. Linton alleged that this action resulted in physical and psychological injuries.Linton filed a lawsuit under 42 U.S.C. §1983, claiming Zorn’s use of force violated her Fourth Amendment rights. The United States District Court for the District of Vermont granted summary judgment to Zorn, holding he was entitled to qualified immunity because it was not clearly established that his actions constituted excessive force in these circumstances. The United States Court of Appeals for the Second Circuit reversed, relying on its earlier decision in Amnesty America v. West Hartford, reasoning that the use of a rear wristlock on a passively resisting protester was clearly established as excessive force. The Second Circuit remanded the case for a jury trial.The Supreme Court of the United States reviewed the case and held that Zorn was entitled to qualified immunity. The Court determined that Amnesty America did not clearly establish, with the requisite specificity, that Zorn’s conduct—using a wristlock after repeated warnings—violated the Fourth Amendment. The Court emphasized that qualified immunity protects officials unless prior precedent places the constitutional question beyond debate and found that no case had clearly held such conduct unlawful in similar circumstances. Accordingly, the Supreme Court granted certiorari and reversed the judgment of the Second Circuit. View "Zorn v. Linton" on Justia Law

Gabriel Olivier, a street preacher in Mississippi, was convicted in 2021 for violating a city ordinance that restricted expressive activities near a public amphitheater. The ordinance required individuals engaging in protests or demonstrations during event times to remain within a designated protest area. Olivier found the area too remote to reach his audience and, after returning to a more visible location, was arrested. He later pleaded no contest in municipal court, received a fine, probation, and a suspended jail sentence, and did not appeal his conviction.Following his conviction, Olivier filed a lawsuit in the United States District Court for the Southern District of Mississippi under 42 U.S.C. §1983 against the City and its police chief, claiming the ordinance violated the First Amendment. He sought declaratory and injunctive relief to prevent future enforcement of the ordinance, but not to overturn his prior conviction or seek damages. The City argued, based on Heck v. Humphrey, that his suit was barred because success would imply the invalidity of his conviction. The District Court agreed, and the United States Court of Appeals for the Fifth Circuit affirmed, holding that a §1983 suit implying a prior conviction’s invalidity is not allowed, regardless of the relief sought.The Supreme Court of the United States reviewed the case and unanimously held that Heck v. Humphrey does not bar a §1983 suit seeking only prospective relief, such as an injunction against future enforcement of a law, even if the plaintiff was previously convicted under that law. The Court reasoned that Olivier’s suit did not challenge his prior conviction or seek damages for it, but merely sought to avoid future prosecutions. The Supreme Court reversed the judgment of the Fifth Circuit and remanded the case for further proceedings. View "Olivier v. City of Brandon" on Justia Law

The petitioners, a family from El Salvador, entered the United States without authorization in 2021 and were placed in removal proceedings. Seeking asylum, they claimed that they had been targeted by a hitman in their home country. The testimony of Douglas Humberto Urias-Orellana, the principal applicant, was found credible by the Immigration Judge (IJ). However, the IJ determined that the evidence presented did not establish past persecution or a well-founded fear of future persecution as defined under the Immigration and Nationality Act (INA). The IJ denied their asylum applications and ordered their removal, with the claims of the wife and minor child treated as derivative of Urias-Orellana’s.Upon appeal to the Board of Immigration Appeals (BIA), the Board affirmed the IJ’s findings, concluding that the harm described did not rise to the statutory level of persecution and that Urias-Orellana did not demonstrate a well-founded fear of future persecution. The petitioners then sought review from the United States Court of Appeals for the First Circuit. The First Circuit applied the substantial-evidence standard, holding that the agency's conclusion was supported by the record and that a reasonable adjudicator would not be compelled to reach a contrary conclusion.The Supreme Court of the United States reviewed whether the First Circuit applied the correct standard of review. The Court held that the INA requires courts of appeals to apply the substantial-evidence standard to the entire agency determination of persecution, including both factual findings and the application of the statutory standard to those facts. Substantial-evidence review is required unless any reasonable adjudicator would be compelled to conclude otherwise. The Court affirmed the judgment of the First Circuit. View "Urias-Orellana v. Bondi" on Justia Law