Justia U.S. Supreme Court Opinion Summaries

Thomas Keathley and his wife filed for Chapter 13 bankruptcy in December 2019. During the bankruptcy proceedings, they were required to disclose all assets, including any claims against third parties. In August 2021, while the bankruptcy case was still open, Keathley was involved in a car accident with an employee of Buddy Ayers Construction, Inc. He hired a personal injury attorney and told his bankruptcy counsel that he intended to file a lawsuit, but neither he nor his counsel disclosed this potential claim to the Bankruptcy Court. Later, Keathley filed a negligence lawsuit in federal district court without updating his bankruptcy disclosures.Buddy Ayers Construction moved for summary judgment in the U.S. District Court for the Northern District of Mississippi based on judicial estoppel, arguing Keathley was barred from bringing the lawsuit because he had not disclosed the claim to the Bankruptcy Court. When faced with the motion, Keathley amended his bankruptcy filings to include the claim and submitted affidavits asserting the omission was inadvertent. The District Court, following Fifth Circuit precedent, granted summary judgment for Buddy Ayers Construction, finding the omission was not inadvertent because Keathley knew of the facts and had a potential motive to conceal the claim. The United States Court of Appeals for the Fifth Circuit affirmed, though a concurring judge questioned whether this approach furthered the goals of judicial estoppel.The Supreme Court of the United States reviewed the case and held that courts must examine the totality of the circumstances to determine whether a debtor’s omission in bankruptcy was inadvertent or mistaken for purposes of judicial estoppel. The Court found that the Fifth Circuit’s rule—which considered only whether the debtor knew of the claim and had a motive to conceal—was too rigid and overly broad for an equitable doctrine. The Supreme Court vacated the Fifth Circuit’s judgment and remanded the case for further proceedings. View "Keathley v. Buddy Ayers Construction, Inc." on Justia Law

Ahmad Abouammo, while working at Twitter’s San Francisco office, provided a Saudi official with confidential information about dissident users and was paid $300,000. After leaving Twitter, Abouammo moved to Seattle and started a consulting business. FBI agents from San Francisco, investigating these disclosures, interviewed him at his Seattle home. During the interview, Abouammo denied sharing confidential information and claimed the payments were for consulting work. When asked for documentation, he created and emailed a fake invoice to the agents while they waited downstairs. The agents later determined, based on metadata, that the invoice was fabricated during the interview.Abouammo was indicted in the United States District Court for the Northern District of California for violating 18 U.S.C. §1519, which criminalizes falsifying a document with intent to obstruct a federal investigation. He moved to dismiss the charge for improper venue, arguing trial should only occur where the falsification happened—Seattle, in the Western District of Washington. The District Court denied the motion, holding venue was also proper where the investigation was located. A jury convicted him, and the district court reaffirmed its venue ruling after trial. The United States Court of Appeals for the Ninth Circuit affirmed, reasoning that, because §1519 requires intent to obstruct an investigation, the offense’s “essential conduct” included effects in the district where the investigation was based.The Supreme Court of the United States reversed. The Court held that a charge under §1519 must be tried in the district where the falsification occurred, not where the investigation was located. The only conduct constituting the offense is the act of falsification, which was completed in Seattle. The statute’s intent requirement does not expand venue to other districts. Therefore, the trial in California’s Northern District was improper, and the case was remanded for further proceedings. View "Abouammo v. United States" on Justia Law

Several investment companies managing closed-end mutual funds, incorporated in Maryland, adopted resolutions under the Maryland Control Share Acquisition Act (MCSAA) to limit the voting rights of shareholders who accumulate a large percentage of shares, such as activist investors. Saba Capital, an activist investor, sought to acquire significant stakes in these funds to influence their management. Saba challenged the funds’ resolutions, alleging they violated the Investment Company Act’s (ICA) requirement that every share of stock have equal voting rights. Saba based its legal claim on Section 47(b) of the ICA, which addresses rescission of contracts that violate the Act.The United States District Court ruled in Saba’s favor, holding that Section 47(b) of the ICA creates an implied private right of action that allows private parties to sue for rescission of contracts allegedly violating the ICA. The District Court granted summary judgment to Saba on this basis. The United States Court of Appeals for the Second Circuit summarily affirmed the District Court’s decision.The Supreme Court of the United States reviewed the case to resolve a circuit split regarding whether Section 47(b) of the ICA impliedly authorizes private parties to sue for rescission. The Court held that Section 47(b) does not confer an implied private right of action. The Court reasoned that the provision directs courts on how to exercise remedial authority in cases already before them but does not create a right for private parties to initiate such suits. The statutory text and structure, including the explicit enforcement roles given to the Securities and Exchange Commission and the existence of other express private rights of action in the ICA, further supported this conclusion. The Supreme Court reversed the Second Circuit’s judgment and remanded the case for further proceedings. View "FS Credit Opportunities Corp. v. Saba Capital Master Fund, Ltd." on Justia Law

Ongkaruck Sripetch orchestrated several fraudulent schemes involving over 20 penny-stock companies. These schemes included classic “pump and dump” operations, where Sripetch and his associates would acquire shares, artificially inflate their value through promotion, and then sell at a profit. The Securities and Exchange Commission (SEC) discovered these activities and filed a civil enforcement action, charging Sripetch with six counts of securities fraud and one count of selling unregistered securities. Sripetch consented to judgment and agreed that the court could order disgorgement of ill-gotten gains.The United States District Court for the Southern District of California reviewed the SEC’s request for more than $4.1 million in disgorgement. Sripetch objected, arguing that the SEC had not demonstrated that investors suffered financial losses. The district court rejected this objection, finding that the SEC had made an adequate showing of pecuniary harm suffered by investors, but it did not decide whether such a showing was necessary. Sripetch appealed to the United States Court of Appeals for the Ninth Circuit, which held that a finding of pecuniary harm is not required for a disgorgement order, relying on traditional equitable principles and relevant Restatements. The court’s decision deepened a split among the circuits.The Supreme Court of the United States granted certiorari to resolve whether the SEC must prove that investors suffered financial losses to obtain disgorgement. The Court held that a showing of pecuniary loss is not required before the SEC may secure a disgorgement award. The main holding is that, under traditional equitable principles and the relevant statutes, disgorgement may be ordered based on the defendant’s wrongful gain, regardless of whether the victims suffered financial losses. The Court affirmed the judgment of the Ninth Circuit. View "Sripetch v. SEC" on Justia Law

This case involved two major cellular service providers that were investigated by the Federal Communications Commission (FCC) for allegedly mishandling customer location data, potentially violating laws and regulations concerning confidentiality. Following reports of security breaches, the FCC issued notices of apparent liability to the companies and, after reviewing their responses, assessed monetary penalties—about $57 million against one provider and $47 million against the other. The companies paid these penalties but challenged the process, contending that their Seventh Amendment right to a jury trial was violated because the FCC imposed penalties through an administrative process without the involvement of a jury.One of the companies sought review in the United States Court of Appeals for the Fifth Circuit, which ruled in its favor, holding that the FCC’s process violated the Seventh Amendment since the agency found facts, interpreted the law, and assessed penalties without a jury. The other provider’s case was heard by the United States Court of Appeals for the Second Circuit, which upheld the FCC’s process. The Second Circuit reasoned that the FCC’s forfeiture order did not, by itself, compel payment, and any actual collection would require the Department of Justice to file a civil suit, at which point a jury trial would be available.The Supreme Court of the United States reviewed both cases to resolve the conflict. The Court held that the FCC’s procedures did not violate the Seventh Amendment because the forfeiture orders did not create a binding obligation to pay, nor were the FCC’s factual findings conclusive. Instead, a party could insist on a jury trial in a de novo civil enforcement action brought by the government to collect the penalty. The judgment of the Fifth Circuit was reversed and remanded, while the judgment of the Second Circuit was affirmed. View "FCC v. AT&T" on Justia Law

Amarin Pharma, Inc. developed and marketed Vascepa, a drug containing icosapent ethyl. Initially, the Food and Drug Administration (FDA) approved Vascepa for treating severe hypertriglyceridemia (the SH indication). Later, the FDA approved a new use: reducing cardiovascular risk in certain patients (the CV indication), for which Amarin held two method-of-use patents. Hikma Pharmaceuticals USA Inc., a generic manufacturer, sought to market a generic icosapent ethyl. After Amarin’s SH-indication patents were invalidated by a district court, Hikma pursued FDA approval for a “skinny label” generic, carving out the patented CV indication. The FDA approved Hikma’s application with the label limited to the SH indication.Amarin sued Hikma in the United States District Court for the District of Delaware, alleging that Hikma actively induced infringement of Amarin’s CV-indication patents. Amarin argued that various statements in Hikma’s skinny label, patient information leaflet, website, and press releases encouraged infringement. The District Court granted Hikma’s motion to dismiss, finding that the statements did not constitute active encouragement of infringement. The United States Court of Appeals for the Federal Circuit reversed, holding it plausible that a physician could read Hikma’s statements as instructions or encouragement to prescribe the drug for the patented use.The Supreme Court of the United States reviewed the case and held that Amarin failed to state a claim for active inducement under 35 U.S.C. §271(b). The Court clarified that liability requires affirmative “active steps” to encourage infringement, not merely statements that could be read as encouragement. The Court found Hikma’s statements either reflected legal compliance or ordinary industry practice, or were too vague or passive to plausibly constitute active inducement. The Supreme Court reversed the Federal Circuit’s judgment and remanded for further proceedings. View "Hikma Pharmaceuticals USA Inc. v. Amarin Pharma, Inc." on Justia Law

In this matter, Alabama enacted a congressional district map in 2023 that included only one district in which Black voters constituted a majority. Plaintiffs challenged the map, arguing that it diluted Black voting strength in violation of Section 2 of the Voting Rights Act and the Fourteenth Amendment. The essential factual dispute centered on whether Alabama’s map failed to provide an additional district offering Black voters an opportunity to elect their preferred candidates, and whether the State had intentionally avoided implementing a remedial map previously ordered by the court.The United States District Court for the Northern District of Alabama first enjoined the use of Alabama’s 2023 congressional map, finding it violated Section 2 because it did not include an additional Black-opportunity district and concluding that the State’s actions also violated the Fourteenth Amendment as a deliberate refusal to comply with prior remedial requirements. After the Supreme Court vacated this injunction in light of its decision in Louisiana v. Callais, the District Court issued a new injunction on similar grounds. State officials then applied to the Supreme Court for a stay of the District Court’s order.The Supreme Court of the United States granted Alabama’s application for a stay, holding that the State is likely to succeed on the merits. The Court concluded that the District Court failed to apply the updated standards for Section 2 liability announced in Callais, particularly the requirement that a plaintiff’s alternative map must perform “just as well” with respect to all constitutionally permissible districting criteria, and erred in its evaluation of alleged discriminatory intent. The Supreme Court stayed the District Court’s order pending further proceedings, emphasizing the importance of not altering election rules close to an election. View "Allen v. Milligan" on Justia Law

The petitioner was convicted of murder in Florida and sentenced to death after a jury trial. A key witness for the prosecution was a jailhouse informant, Jake Ozio, who testified that he heard the petitioner confess while in jail. Ozio also testified, falsely, that he had no prior criminal history, despite juvenile records showing otherwise—records that were in the State’s possession at the time of trial. The petitioner later argued that the use of this false testimony violated his due process rights under Giglio v. United States because the prosecution knew Ozio’s statement was untrue and there was a reasonable likelihood it affected the jury’s verdict.After unsuccessful direct appeals and postconviction relief in state court, the petitioner sought habeas corpus relief in federal court. The United States District Court denied his application, finding any Giglio violation harmless because juvenile records are generally inadmissible under Florida law. The United States Court of Appeals for the Eleventh Circuit disagreed with the District Court’s harmlessness reasoning, noting that such records could have been used to impeach Ozio since he had opened the door by denying any prior history. However, the Court of Appeals affirmed the denial of habeas relief on the alternative ground that, even without Ozio’s testimony, the evidence against the petitioner was overwhelming—a conclusion it based in part on post-trial DNA testing not presented to the jury.The Supreme Court of the United States held that the Eleventh Circuit erred by considering DNA evidence that did not exist at the time of trial when assessing whether the Giglio error was harmless. The proper inquiry is limited to whether the constitutional error had a substantial and injurious effect or influence on the jury’s verdict, considering only evidence available to the jury. The Supreme Court vacated the judgment and remanded the case for further proceedings. View "Whitton v. Dixon" on Justia Law

Angelo Brock operated as a franchisee distributing baked goods for a large national baking company in Colorado. He picked up products from a local warehouse and delivered them to stores within the state, never leaving Colorado or directly interacting with vehicles that crossed state lines. In 2022, Brock and other distributors alleged in federal court that the baking company underpaid them, violating federal and state laws. The company moved to compel arbitration, citing an agreement Brock had signed requiring disputes to be arbitrated, and invoked the Federal Arbitration Act (FAA).The United States District Court denied the company's motion to compel arbitration. On appeal, the United States Court of Appeals for the Tenth Circuit affirmed this denial. The Tenth Circuit focused on Section 1 of the FAA, which exempts “contracts of employment” for workers “engaged in interstate commerce.” The appellate court found that even though Brock’s deliveries were confined to Colorado and he did not interact with interstate vehicles, his role as part of the continuous interstate distribution of goods qualified him for the exemption. The court determined that Brock was part of a class of workers engaged in interstate commerce, placing his contract outside the FAA’s compulsory arbitration requirements.The Supreme Court of the United States reviewed whether the FAA’s exemption for “workers engaged in interstate commerce” applies to workers who do not cross state lines or interact with vehicles that do. The Court held that a worker transporting goods on an intrastate segment of an interstate journey can fall under the FAA’s Section 1 exemption, even without leaving the state or handling vehicles engaged in interstate transit. The judgment of the Tenth Circuit was affirmed. View "Flowers Foods, Inc. v. Brock" on Justia Law

Two individuals were convicted of multiple counts under 18 U.S.C. §924(c) for using and carrying firearms during crimes of violence, resulting in lengthy mandatory minimum sentences due to a “stacking” provision. Years after their convictions, Congress enacted the First Step Act of 2018, which eliminated the stacking requirement for first-time offenders, thereby reducing future sentences for similar offenses. However, the new law did not apply retroactively to individuals already sentenced, including the petitioners.Following the Act’s enactment, both petitioners sought sentence reductions under 18 U.S.C. §3582(c)(1)(A)(i), which allows for “compassionate release” if there are “extraordinary and compelling reasons.” The United States District Court denied their motions, and the United States Court of Appeals for the Third Circuit affirmed those denials, holding that the nonretroactive change in the law could not itself qualify as an “extraordinary and compelling” reason for a sentence reduction. The Third Circuit reasoned that allowing such relief would conflict with Congress’s clear decision not to apply the Act retroactively.The Supreme Court of the United States reviewed the consolidated cases to resolve a circuit split on whether sentencing disparities created by nonretroactive statutory changes can justify compassionate release. The Court held that when Congress chooses not to make a sentencing amendment retroactive, the resulting sentencing disparity does not constitute an “extraordinary and compelling” reason for a reduced sentence under §3582(c)(1)(A)(i). The Court further concluded that the Sentencing Commission’s policy statement to the contrary is invalid to the extent it conflicts with this statutory interpretation. The decision of the Third Circuit was affirmed. View "Rutherford v. United States" on Justia Law