Justia U.S. Supreme Court Opinion Summaries

Anastasia Wullschleger sued Royal Canin U.S.A., Inc. in state court, alleging deceptive marketing practices. Her original complaint included both federal and state law claims. Royal Canin removed the case to federal court based on the federal claims, which allowed the federal court to exercise supplemental jurisdiction over the state claims. Wullschleger then amended her complaint to remove all federal claims and requested the case be remanded to state court.The District Court denied Wullschleger’s request to remand the case. However, the Eighth Circuit Court of Appeals reversed this decision, concluding that the amended complaint, which no longer contained any federal claims, eliminated the basis for federal-question jurisdiction. Consequently, the federal court also lost its supplemental jurisdiction over the state-law claims.The Supreme Court of the United States reviewed the case and held that when a plaintiff amends her complaint to delete the federal-law claims that enabled removal to federal court, the federal court loses supplemental jurisdiction over the remaining state-law claims. The case must then be remanded to state court. The Court affirmed the Eighth Circuit’s decision, emphasizing that the jurisdictional analysis must be based on the amended complaint, which in this case contained only state-law claims. View "Royal Canin U.S.A. v. Wullschleger" on Justia Law

EMD Sales, Inc. distributes food products in the Washington, D.C. area and employs sales representatives who manage inventory and take orders at grocery stores. Several sales representatives sued EMD, alleging that the company violated the Fair Labor Standards Act (FLSA) by failing to pay them overtime. EMD argued that the sales representatives were outside salesmen and therefore exempt from the FLSA’s overtime-pay requirement.The U.S. District Court for the District of Maryland held a bench trial and found EMD liable for overtime pay because EMD did not prove by clear and convincing evidence that its sales representatives were outside salesmen. The court ordered EMD to pay overtime wages and liquidated damages. EMD appealed, arguing that the District Court should have used the preponderance-of-the-evidence standard instead of the clear-and-convincing-evidence standard. The U.S. Court of Appeals for the Fourth Circuit affirmed the District Court’s judgment, adhering to Circuit precedent that required employers to prove FLSA exemptions by clear and convincing evidence.The Supreme Court of the United States reviewed the case and held that the preponderance-of-the-evidence standard applies when an employer seeks to demonstrate that an employee is exempt from the minimum-wage and overtime-pay provisions of the FLSA. The Court reasoned that the FLSA does not specify a standard of proof for exemptions, and in the absence of such specification, the default preponderance standard should apply. The Court reversed the Fourth Circuit’s judgment and remanded the case for further proceedings consistent with this opinion. View "E.M.D. Sales, Inc. v. Carrera" on Justia Law

The case involves Sandra Muñoz, an American citizen, and her husband Luis Asencio-Cordero, a citizen of El Salvador. The couple sought to obtain an immigrant visa for Asencio-Cordero to live in the United States. After several interviews, a consular officer denied Asencio-Cordero's application, citing a provision that renders inadmissible a noncitizen whom the officer believes seeks to engage in unlawful activity. Asencio-Cordero and Muñoz sued the Department of State, claiming that it had abridged Muñoz’s constitutional liberty interest in her husband’s visa application by failing to give a sufficient reason why Asencio-Cordero is inadmissible under the “unlawful activity” bar.The District Court granted summary judgment to the State Department, but the Ninth Circuit vacated the judgment, holding that Muñoz had a constitutionally protected liberty interest in her husband’s visa application and that the State Department was required to give Muñoz a reason for denying her husband’s visa. The court further held that by declining to give Muñoz more information earlier in the process, the State Department had forfeited its entitlement to insulate its decision from judicial review under the doctrine of consular nonreviewability.The Supreme Court of the United States reversed the Ninth Circuit's decision, holding that a citizen does not have a fundamental liberty interest in her noncitizen spouse being admitted to the country. The Court noted that while Congress has extended special treatment to marriage in immigration matters, it has never made spousal immigration a matter of right. The Court also noted that the assertion of a procedural due process right in someone else's legal proceeding would have unsettling collateral consequences. The case was remanded for further proceedings consistent with the Court's opinion. View "Department of State v. Munoz" on Justia Law

Sylvia Gonzalez, a city council member in Castle Hills, Texas, was involved in a campaign to remove the city manager, Ryan Rapelye. She gathered signatures for a petition, which was introduced at a city council meeting. After the meeting, the mayor, Edward Trevino, II, asked Gonzalez for the petition. Gonzalez found the petition in her binder, which she claimed was unintentional. Trevino reported this to the city police, leading to an investigation. A private attorney concluded that Gonzalez likely violated a Texas anti-tampering statute, leading to her arrest. The charges were later dismissed, but Gonzalez claimed this incident led her to step away from politics.Gonzalez filed a lawsuit under 42 U.S.C. §1983 in Federal District Court against Trevino, the police chief, and the private attorney, alleging that her arrest was in retaliation for her role in the petition and violated her First Amendment rights. The District Court denied the defendants' motion to dismiss the complaint, finding that it fell within an exception to the no-probable-cause rule recognized in Nieves. However, the Fifth Circuit reversed this decision, stating that Gonzalez's claim could only fall within the Nieves exception if she provided "comparative evidence" of similarly situated individuals who engaged in the same criminal conduct but were not arrested.The Supreme Court of the United States disagreed with the Fifth Circuit's interpretation of the Nieves exception. The Court found that the Fifth Circuit's requirement for specific comparator evidence was overly restrictive. The Court clarified that to fall within the Nieves exception, a plaintiff must produce objective evidence to prove that his arrest occurred in circumstances where officers typically exercise their discretion not to make arrests. The Court held that Gonzalez's evidence, showing that no one had ever been arrested for similar conduct, was a permissible type of evidence. The Court vacated the Fifth Circuit's judgment and remanded the case for further proceedings. View "Gonzalez v. Trevino" on Justia Law

The case involves three aliens, Moris Esmelis Campos-Chaves, Varinder Singh, and Raul Daniel Mendez-Colín, who were ordered removed in absentia after failing to appear at their respective removal hearings. The Government had initiated removal proceedings against each of them, serving them with Notices to Appear (NTAs) that did not specify the time and date of the hearings. However, each alien was later provided with a notice specifying the time and place of the removal hearing. After being ordered removed in absentia, each alien sought to rescind the order, arguing that they did not receive a proper NTA.In the lower courts, the Fifth Circuit denied Campos-Chaves's petition for review, while the Ninth Circuit granted the petitions for Singh and Mendez-Colín. The Fifth Circuit based its decision on the fact that Campos-Chaves did not dispute receiving the subsequent notice specifying the time and place of the hearing. The Ninth Circuit, on the other hand, held that the lack of a single-document NTA alone rendered the in absentia removal orders rescindable.The Supreme Court of the United States held that to rescind an in absentia removal order on the ground that the alien did not receive notice in accordance with paragraph (1) or (2), the alien must show that he did not receive notice under either paragraph for the hearing at which the alien was absent and ordered removed. Because each of the aliens in these cases received a proper paragraph (2) notice for the hearings they missed and at which they were ordered removed, they cannot seek rescission of their in absentia removal orders on the basis of defective notice. The Court affirmed the judgment of the Fifth Circuit, reversed the Ninth Circuit’s judgment in Garland v. Mendez-Colín, and vacated and remanded the Ninth Circuit’s judgment in Garland v. Singh for further proceedings consistent with this opinion. View "Campos-Chaves v. Garland" on Justia Law

The case involves the Office of the United States Trustee and a group of Chapter 11 debtors, John Q. Hammons Fall 2006, LLC, et al. The issue at hand is the remedy for a constitutional violation identified in a previous case, Siegel v. Fitzgerald, where a statute was found to violate the Bankruptcy Clause’s uniformity requirement as it allowed different fees for Chapter 11 debtors depending on the district where their case was filed. The government argued for prospective parity as the appropriate remedy, while the debtors argued for a refund.The Bankruptcy Court found no constitutional violation and did not address the remedial question. The Tenth Circuit reversed this decision, finding that the fee statute permitting nonuniform fees violated the Bankruptcy Clause and ordered a refund of the debtors’ quarterly fees. The U.S. Trustee sought certiorari, which was granted by the Supreme Court.The Supreme Court reversed the Tenth Circuit's decision. The Court agreed with the government that the appropriate remedy for the constitutional violation is prospective parity. The Court held that requiring equal fees for otherwise identical Chapter 11 debtors going forward aligns with congressional intent, corrects the constitutional wrong, and complies with due process. The Court rejected the debtors' argument for a refund, stating that such a remedy would require undercutting congressional intent and transforming a program that Congress designed to be self-funding into a significant bill for taxpayers. The Court concluded that neither remedial principles nor due process requires such an outcome. View "United States Trustee v. John Q. Hammons Fall 2006, LLC" on Justia Law

Several Starbucks employees in Memphis, Tennessee, announced plans to unionize and invited a local news crew to their store after hours to promote their efforts. Starbucks fired multiple employees involved in the media event for violating company policy. The National Labor Relations Board (NLRB) filed an administrative complaint against Starbucks, alleging unfair labor practices. The Board's regional Director then filed a petition under §10(j) of the National Labor Relations Act seeking a preliminary injunction that would require Starbucks to reinstate the fired employees during the administrative proceedings. The District Court granted the injunction, applying a two-part test that asks whether there is reasonable cause to believe that unfair labor practices have occurred and whether injunctive relief is just and proper. The Sixth Circuit affirmed the decision.The Supreme Court of the United States vacated the Sixth Circuit's decision. The Supreme Court held that when considering the NLRB’s request for a preliminary injunction under §10(j), district courts must apply the traditional four-factor test articulated in Winter v. Natural Resources Defense Council, Inc. This test requires a plaintiff to make a clear showing that they are likely to succeed on the merits, that they are likely to suffer irreparable harm in the absence of preliminary relief, that the balance of equities tips in their favor, and that an injunction is in the public interest. The Court found that nothing in §10(j) displaces the presumption that these traditional principles govern. The Court rejected the Board's argument that statutory context requires district courts to apply the traditional criteria in a less exacting way. The Court concluded that the reasonable-cause standard substantively lowers the bar for securing a preliminary injunction by requiring courts to yield to the Board’s preliminary view of the facts, law, and equities. The case was remanded for further proceedings consistent with this opinion. View "Starbucks Corp. v. McKinney" on Justia Law

The case revolves around Stuart Harrow, a Department of Defense employee who was furloughed for six days. Harrow challenged this decision before the Merit Systems Protection Board. After a five-year delay, the Board ruled against him. Harrow had the right to appeal this decision to the Court of Appeals for the Federal Circuit within 60 days of the Board's final order. However, Harrow did not learn about the Board's decision until after the 60-day period had elapsed, and he filed his appeal late. Harrow requested the Federal Circuit to overlook his untimeliness and equitably toll the filing deadline. The Federal Circuit, however, denied his request, believing that the deadline was an unalterable "jurisdictional requirement."The Supreme Court of the United States reviewed the case. The main issue was whether the 60-day filing deadline under Section 7703(b)(1) was jurisdictional, meaning it marked the bounds of a court's power and could not be waived or subject to exceptions. The Supreme Court held that the 60-day filing deadline was not jurisdictional. The Court reasoned that procedural rules, even when phrased in mandatory terms, are generally subject to exceptions like waiver, forfeiture, and equitable tolling. The Court found no language in Section 7703(b)(1) that suggested it was a jurisdictional requirement. The Court also rejected the Government's argument that the term "pursuant to" in a different statute, 28 U.S.C. §1295(a)(9), made the deadline jurisdictional.The Supreme Court vacated the judgment of the Federal Circuit and remanded the case for further proceedings consistent with its opinion. The Federal Circuit was directed to determine whether equitable tolling was available and, if so, whether Harrow was entitled to that relief given the facts of the case. View "Harrow v. Department of Defense" on Justia Law

The case involves two petitioners, Halima Culley and Lena Sutton, who loaned their cars to others who were subsequently arrested for drug-related offenses. The cars were seized under Alabama's civil forfeiture law, which allowed for the seizure of a car "incident to an arrest" as long as the state promptly initiated a forfeiture case. The State of Alabama filed forfeiture complaints against the cars 10 and 13 days after their seizure, respectively. While the forfeiture proceedings were pending, Culley and Sutton each filed purported class-action complaints in federal court, claiming that state officials violated their due process rights by retaining their cars during the forfeiture process without holding preliminary hearings.The Eleventh Circuit affirmed the dismissal of the petitioners' claims, holding that a timely forfeiture hearing affords claimants due process and that no separate preliminary hearing is constitutionally required. The petitioners argued that the Due Process Clause requires a separate preliminary hearing before the forfeiture hearing.The Supreme Court of the United States affirmed the Eleventh Circuit's decision. The Court held that in civil forfeiture cases involving personal property, the Due Process Clause requires a timely forfeiture hearing but does not require a separate preliminary hearing. The Court's decision was based on its precedents, which established that a timely forfeiture hearing satisfies due process in civil forfeiture cases. The Court also noted that historical practice reinforces its conclusion that due process does not require preliminary hearings in civil forfeiture cases. View "Culley v. Marshall" on Justia Law

Sergeant Jatonya Clayborn Muldrow, a police officer in the St. Louis Police Department, alleged that she was transferred from her position in the Intelligence Division to a uniformed job in another department because of her gender. Despite maintaining her rank and pay, Muldrow's responsibilities, perks, and schedule were significantly altered. She filed a Title VII suit against the City of St. Louis, claiming that the transfer constituted sex discrimination with respect to her employment terms and conditions.The District Court granted the City summary judgment, and the Eighth Circuit affirmed, holding that Muldrow had to show that the transfer caused her a "materially significant disadvantage." The courts ruled that since the transfer did not result in a reduction to her title, salary, or benefits and only caused minor changes in working conditions, Muldrow's lawsuit could not proceed.The Supreme Court of the United States disagreed with the lower courts' interpretation of Title VII. The Court held that an employee challenging a job transfer under Title VII must show that the transfer brought about some harm with respect to an identifiable term or condition of employment, but that harm need not be significant. The Court rejected the City's arguments based on statutory text, precedent, and policy, and vacated the judgment of the Eighth Circuit, remanding the case for further proceedings under the correct Title VII standard. The Court clarified that Muldrow only needed to show some injury respecting her employment terms or conditions, not that the harm was significant. View "Muldrow v. City of St. Louis" on Justia Law