Justia U.S. Supreme Court Opinion Summaries

After Mata, an unlawful alien, was convicted of assault in a Texas court, an Immigration Judge ordered him removed to Mexico. Mata’s attorney filed notice of appeal with the Board of Immigration Appeals (BIA), but never filed a brief; the appeal was dismissed. Acting through different counsel, Mata moved to reopen his removal proceedings, 8 U.S.C. 229a(c)(7)(A). Acknowledging that he had missed the 90-day deadline for such motions, Mata argued that his previous counsel’s ineffective assistance was an exceptional circumstance entitling him to equitable tolling. The BIA dismissed the motion as untimely and declined to reopen Mata’s removal proceedings sua sponte based on its separate regulatory authority. The Fifth Circuit construed Mata’s equitable tolling claim as a request that the BIA exercise its regulatory authority to reopen the proceedings sua sponte, and, because its precedent forbids review of BIA decisions not to exercise that authority, dismissed for lack of jurisdiction. The Supreme Court reversed. A court of appeals has jurisdiction to review the BIA’s rejection of an alien’s motion to reopen. Nothing about that jurisdiction changes where the BIA rejects a motion as untimely, or when it rejects a motion requesting equitable tolling of the time limit, or when the denial also contains a separate decision not to exercise its sua sponte authority. If Mata is not entitled to relief on the merits, the correct disposition is to take jurisdiction and affirm the BIA’s denial of his motion. A federal court has a “virtually unflagging obligation” to assert jurisdiction where it has that authority; recharacterizing pleadings cannot be used to sidestep the judicial obligation to assert jurisdiction. View "Mata v. Lynch" on Justia Law

Private parties may file civil qui tam actions to enforce the False Claims Act (FCA), 31 U.S.C. 3729(a)(1). A qui tam action must be brought within six years of a violation, but the Wartime Suspension of Limitations Act (WSLA) suspends the statute of limitations “applicable to any offense” involving fraud against the government, 18 U.S.C. 3287. The FCA’s “first-to-file bar” precludes a qui tam suit “based on the facts underlying [a] pending action.” In 2005, Carter worked for a defense contractor in Iraq. He filed a qui tam complaint, alleging that defense contractors had fraudulently billed the government for water purification services that were not performed or performed improperly. In 2010, the government informed the parties that an earlier-filed qui tam suit (Thorpe) had similar claims. Carter was dismissed without prejudice. While appeal was pending, Thorpe was dismissed for failure to prosecute. Carter filed a new complaint; the court dismissed it because Carter I’s appeal was pending. After dismissing that appeal, more than six years after the alleged fraud, Carter filed a third complaint, which was dismissed with prejudice under the first-to-file rule because of a pending Maryland suit. The court also stated that the actions were untimely. Reversing, the Fourth Circuit concluded that the WSLA applied to civil claims and that the first-to-file bar ceases to apply once a related action is dismissed. A unanimous Supreme Court held that the WSLA applies only to criminal offenses, not to civil claims, so that the claims were untimely. Dismissal with prejudice under the first-to-file bar was improper however. That bar keeps new claims out of court only while related claims are still alive, not in perpetuity. View "Kellogg Brown & Root Servs., Inc. v. United States ex rel. Carter" on Justia Law

Sharif tried to discharge a debt to Wellness in his Chapter 7 bankruptcy. Wellness argued that a trust Sharif claimed to administer was actually Sharif’s alter ego, and that its assets were part of his bankruptcy estate. The Bankruptcy Court entered default judgment against Sharif. While appeal was pending, but before briefing concluded, the Supreme Court held (Stern v. Marshall) that Article III forbids bankruptcy courts to enter final judgment on claims that seek only to “augment” the bankruptcy estate and would otherwise “exis[t] without regard to any bankruptcy proceeding.” The district court denied Sharif permission to file a supplemental brief and affirmed. The Seventh Circuit determined that Sharif’s “Stern” objection could not be waived and reversed, holding that the Bankruptcy Court lacked constitutional authority to enter judgment on the alter ego claim. The Supreme Court reversed. Article III permits bankruptcy judges to adjudicate Stern claims with the parties’ knowing and voluntary consent. The right to adjudication before an Article III court is “personal” and “subject to waiver,” unless Article III’s structural interests as “an inseparable element of the constitutional system of checks and balances” are implicated; parties “cannot by consent cure the constitutional difficulty.” Allowing bankruptcy courts to decide Stern claims by consent does not usurp the constitutional prerogatives of Article III courts. Bankruptcy judges are appointed and may be removed by Article III judges, hear matters solely on a district court’s reference, and possess no free-floating authority to decide claims traditionally heard by Article III courts. Consent to adjudication by a bankruptcy court need not be express, but must be knowing and voluntary. The Seventh Circuit should decide on remand whether Sharif’s actions evinced the requisite knowing and voluntary consent and whether Sharif forfeited his Stern argument. View "Wellness Int’l Network, Ltd. v. Sharif" on Justia Law

A federal litigant who is too poor to pay court fees may proceed in forma pauperis and commence a civil action without prepaying fees or paying certain expenses, 28 U.S.C. 1915(a), but a “three strikes” provision prevents a court from granting in forma pauperis status to a prisoner who “has, on 3 or more prior occasions, while incarcerated . . . , brought an action or appeal in a court of the United States that was dismissed on the grounds that it is frivolous, malicious, or fails to state a claim upon which relief may be granted.” A state prisoner filed three federal lawsuits that were dismissed on grounds enumerated in section 1915(g). While the third dismissal was pending on appeal, he filed four additional federal lawsuits, moving to proceed in forma pauperis in each. The district court denied the motion. The Sixth Circuit and a unanimous Supreme Court affirmed. A prior dismissal on statutorily enumerated grounds is a strike, even if the dismissal is the subject of an ongoing appeal. Section 1915 describes dismissal as an action by a single court, not as a sequence of events involving multiple courts. The Court noted that a judgment normally takes effect, and its preclusive effect is immediate, despite a pending appeall. The “three strikes” provision was “designed to filter out the bad claims and facilitate consideration of the good.” To refuse to count a prior dismissal because of a pending appeal would produce a leaky filter. View "Coleman v. Tollefson" on Justia Law

After filing for Chapter 13 bankruptcy, Bullard submitted a proposed repayment plan. Bullard’s mortgage lender objected to the plan’s treatment of its claim. The Bankruptcy Court sustained the Bank’s objection and declined to confirm the plan. Bullard appealed to the First Circuit Bankruptcy Appellate Panel, which concluded that denial of confirmation was not a final, appealable order, 28 U.S.C.158(a)(1), but heard the appeal under a provision permitting interlocutory appeals “with leave of the court,” and agreed that Bullard’s proposed plan was not allowed. The First Circuit dismissed for lack of jurisdiction, finding that the order denying confirmation was not final so long as Bullard remained free to propose another plan. A unanimous Supreme Court affirmed. The relevant proceeding is the entire process of attempting to arrive at an approved plan that would allow the bankruptcy case to move forward. Only plan confirmation, or case dismissal, alters the status quo and fixes the parties’ rights and obligations; denial of confirmation with leave to amend changes little. Additional considerations—that the statute defining core bankruptcy proceedings lists “confirmations of plans,” but omits any reference to denials; that immediate appeals from denials would result in delays and inefficiencies; and that inability to immediately appeal a denial encourages the debtor to work with creditors and the trustee to develop a confirmable plan—bolster this conclusion. View "Bullard v. Blue Hills Bank" on Justia Law

The Federal Tort Claims Act (FTCA) provides that a tort claim against the United States “shall be forever barred” unless presented to the appropriate federal agency for review within two years after the claim accrues,” 28 U.S.C. 2401(b). If the agency denies the claim, the claimant may file suit in federal court within six months of the denial. Wong failed to file her FTCA claim in federal court within six months, but argued that the district court had not permitted her to file until after the period expired. June failed to present her FTCA claim to a federal agency within two years, but argued that her untimely filing should be excused because the government concealed facts vital to her claim. In each case, the district court dismissed the FTCA claim, holding that those time bars are jurisdictional and not subject to equitable tolling. The Ninth Circuit reversed. The Supreme Court affirmed and remanded. Section 2401(b)’s time limits are subject to equitable tolling. Congress must do something special to tag a statute of limitations as jurisdictional and prohibit a court from tolling it, but did no such thing in section 2401(b). Separation of a filing deadline from a jurisdictional grant often indicates that the deadline is not jurisdictional; the FTCA’s jurisdictional grant appears in another section and is not expressly linked to the limitations periods. The phrase “shall be forever barred” was commonplace in statutes of limitations enacted around the time of the FTCA, and does not carry jurisdictional significance. View "United States v. Wong" on Justia Law

Providers of “habilitation services” under Idaho’s Medicaid plan are reimbursed by the state Department of Health and Welfare. Section 30(A) of the Medicaid Act requires Idaho’s plan to “assure that payments are consistent with efficiency, economy, and quality of care” while “safeguard[ing] against unnecessary utilization of . . . care and services,” 42 U.S.C. 1396a(a)(30)(A). Providers of habilitation services claimed that Idaho reimbursed them at rates lower than section 30(A) permits. The district court entered summary judgment for the providers. The Ninth Circuit affirmed, concluding that the Supremacy Clause gave the providers an implied right of action, under which they could seek an injunction requiring compliance. The Supreme Court reversed, concluding that there is no private right of action. The Supremacy Clause instructs courts to give federal law priority when state and federal law clash, but it is not the source of any federal rights and does not create a cause of action. The suit cannot proceed in equity. The power of federal courts of equity to enjoin unlawful executive action is subject to express and implied statutory limitations. The express provision of a single remedy for a state’s failure to comply with Medicaid’s requirements, the withholding of Medicaid funds by the Secretary of Health and Human Services, 42 U.S.C. 1396c, and the complexity associated with enforcing section 30(A) combine to establish Congress’s “intent to foreclose” equitable relief. View "Armstrong v. Exceptional Child Ctr., Inc." on Justia Law

Hana Financial and Hana Bank both provide financial services to individuals in the U.S. When Hana Financial sued Hana Bank for trademark infringement, Hana Bank invoked the tacking doctrine, under which lower courts have provided that a trademark user may make certain modifications to its mark over time while, in limited circumstances, retaining its priority position. The district court adopted in substantial part the jury instruction on tacking proposed by Hana Bank. The jury returned a verdict in Hana Bank’s favor. Affirming, the Ninth Circuit explained that the tacking inquiry was an exceptionally limited and highly fact-sensitive matter reserved for juries, not judges. A unanimous Supreme Court affirmed. Whether two trademarks may be tacked for purposes of determining priority is a jury question. Lower courts have held that two marks may be tacked when they are considered to be “legal equivalents,” i.e., they “create the same, continuing commercial impression,” which “must be viewed through the eyes of a consumer.” When the relevant question is how an ordinary person or community would make an assessment, the jury is generally the decision-maker that ought to provide the fact-intensive answer. The “legal equivalents” test may involve a legal standard, but such mixed questions of law and fact have typically been resolved by juries. Any concern that a jury may improperly apply the relevant legal standard can be remedied by crafting careful jury instructions. View "Hana Financial, Inc. v. Hana Bank" on Justia Law

The London InterBank Offered Rate (LIBOR) is a reference point in determining interest rates for financial instruments in the U.S. and globally. The Judicial Panel on Multidistrict Litigation (JPML) established a multidistrict litigation for cases alleging that banks understated their borrowing costs, depressing LIBOR and enabling the banks to pay lower interest rates on financial instruments sold to investors. Over 60 actions were consolidated, including the Gelboim class action, which raised a single claim that banks, acting in concert, had violated federal antitrust law. The district court dismissed all antitrust claims and granted certifications under Rule 54(b), which authorizes parties with multiple-claim complaints to immediately appeal dismissal of discrete claims. The Second Circuit dismissed the Gelboim appeal because the order appealed from did not dispose of all of the claims in the consolidated action. A unanimous Supreme Court reversed. The order dismissing their case in its entirety removed Gelboim from the consolidated proceeding, triggering their right to appeal under 28 U.S.C. 1291, which gives the courts of appeals jurisdiction over appeals from “all final decisions of the district courts.” Because cases consolidated for MDL pretrial proceedings ordinarily retain their separate identities, an order disposing of one of the discrete cases in its entirety qualifies under section 1291 as an appealable final decision. The JPML’s authority to transfer civil actions for consolidated pretrial proceedings, 28 U.S.C. 1407, refers to individual “actions,” not to a monolithic multidistrict “action” and indicates Congress’ anticipation that, during pretrial proceedings, final decisions might be rendered in one or more of the consolidated actions. The Gelboim plaintiffs are no longer participants in the consolidated proceedings. View "Gelboim v. Bank of Am. Corp." on Justia Law

In 1999, Christeson was convicted of three counts of capital murder and sentenced to death. The Missouri Supreme Court affirmed Christeson’s conviction and sentence and denial of his post-conviction motion for relief. Under the one-year limitations period imposed by the Antiterrorism and Effective Death Penalty Act, 28 U. S. C. 244(d)(1), Christeson’s federal habeas petition was due on April 10, 2005. Nine months before that deadline, the court appointed attorneys Horwitz and Butts to represent Christeson, 18 U. S. C. 599(a)(2). The attorneys subsequently acknowledged that they failed to meet with Christeson until six weeks after his petition was due. There is no evidence that they communicated with him at all. They finally filed the petition 117 days late. The district court dismissed; the Eighth Circuit denied a certificate of appealability. Christeson, who has severe cognitive disabilities, relied entirely on his attorneys, and may not have known of the dismissal. About seven years later, the attorneys contacted attorneys Merrigan and Perkovich to discuss Christeson’s case. Christeson’s only hope for merits review was to move under FRCP60(b) to reopen final judgment on the ground that AEDPA’s statute of limitations should have been equitably tolled. Horwitz and Butts would not file that motion, premised on their own malfeasance. In 2014, Merrigan and Perkovich unsuccessfully moved to substitute counsel. The Eighth Circuit dismissed, reasoning that they were not authorized to file on Christeson’s behalf. The Missouri Supreme Court set an October 29, 2014 execution date. The district court denied a second motion as untimely, stating that Horwitz and Butts had not “abandoned” Christeson, and reasoning that allowing the motion would permit “‘abusive’” delays in capital cases. The Eighth Circuit affirmed. The Supreme Court stayed execution and reversed, stating that the denials contravened its 2012 decision, Martel v. Clair, concerning the “interests of justice” standard, and noting the obvious conflict of interest with respect to the original attorneys. View "Christeson v. Roper" on Justia Law