Justia U.S. Supreme Court Opinion Summaries

The Navy contracted with Campbell to develop a recruiting campaign that included text messages to young adults who had “opted in” to receipt of solicitations on topics that included Navy service. Campbell’s subcontractor generated a list of cellular phone numbers for consenting 18- to 24-year-olds and transmitted the Navy’s message to more than 100,000 recipients, including Gomez, age 40, who claims that he did not "opt in" and was not in the targeted age group. Gomez filed a class action under the Telephone Consumer Protection Act (TCPA), 47 U.S.C. 227(b)(1)(A)(iii), which prohibits “using any automatic dialing system” to send text messages to cellular telephones, absent prior express consent, and seeking treble statutory damages for a willful violation. Before the deadline for a motion for class certification, Campbell proposed to settle Gomez’s individual claim and filed an FRCP 68 offer of judgment, which Gomez did not accept. The district court granted Campbell summary judgment, finding that Campbell acquired the Navy’s sovereign immunity from suit. The Ninth Circuit reversed, holding that Gomez’s case remained live but that Campbell was not entitled to derivative sovereign immunity. The Supreme Court affirmed. An unaccepted offer of judgment does not moot a case. Campbell’s settlement bid and offer of judgment, once rejected, had no continuing efficacy; the parties remained adverse. A federal contractor may be shielded from liability unless it exceeded its authority or authority was not validly conferred; the Navy authorized Campbell to send text messages only to individuals who had “opted in.” View "Campbell-Ewald v. Gomez" on Justia Law

The 1995 Prison Litigation Reform Act provides that prisoners qualified to proceed in forma pauperis must pay an initial partial filing fee of “20 percent of the greater of ” the average monthly deposits in the prisoner’s account or the average monthly balance of the account over the preceding six months, 28 U.S.C. 1915(b)(1). They must pay the remainder in monthly installments of “20 percent of the preceding month’s income credited to the prisoner’s account.” The initial fee is assessed on a per-case basis and may not be exacted if the prisoner has no means to pay it; no monthly installments are required unless the prisoner has more than $10 in his account. Bruce, a federal inmate and a frequent litigant, argued that monthly payments do not become due until obligations previously incurred in other cases were satisfied. The D.C. Circuit disagreed, holding that Bruce’s monthly payments were due simultaneously with monthly payments for earlier cases. A unanimous Supreme Court affirmed. Section 1915(b)(2) calls for simultaneous, not sequential, recoupment of multiple monthly installment payments. The Court rejected Bruce’s reliance on the contrast between the singular “clerk” and the plural “fees” as those nouns appear in the statute, which requires payments to be forwarded “to the clerk of the court . . . until the filing fees are paid.” Section 1915’s text and context support the per-case approach. View "Bruce v. Samuels" on Justia Law

Petitioners, a bipartisan group of citizens, requested that a three-judge court be convened to consider their claim that Maryland’s 2011 congressional redistricting plan burdens their First Amendment right of political association. The district court dismissed the action, concluding that no relief could be granted. The Fourth Circuit affirmed. The Court held that 28 U.S.C. 2284 entitles petitioners to make their case before a three-judge court because, under section 2284(a), the present suit is indisputably an action challenging the constitutionality of the apportionment of congressional districts. The Court further held that the subsequent provision of section 2284(b)(1), that the district judge shall commence the process for appointment of a three-judge panel “unless he determines that three judges are not required,” should be read not as a grant of discretion to the district judge to ignore section 2284(a), but as a compatible administrative detail. The Court went on to say that this conclusion is bolstered by section 2284(b)(3)’s explicit command that “[a] single judge shall not . . . enter judgment on the merits.” Finally, the Court held that respondents' alternative argument, that the District Judge should have dismissed petitioners' claim as "constitutionally insubstantial" under Goosby v. Osser, is unpersuasive. Accordingly, the Court reversed and remanded. View "Shapiro v. McManus" on Justia Law

The Agricultural Marketing Agreement Act authorizes the Secretary of Agriculture to promulgate orders to maintain stable markets for agricultural products. The marketing order for raisins established a Raisin Administrative Committee, which requires that growers set aside a percentage of their crop, free of charge. The government sells the reserve raisins in noncompetitive markets, donates them, or disposes of them by any means consistent with the purposes of the program. If any profits are left over after subtracting administration expenses, the net proceeds are distributed back to the growers. In 2002–2003, growers were required to set aside 47 percent of their raisin crop; in 2003–2004, 30 percent. The Hornes refused to set aside any raisins on the ground that the reserve requirement was an unconstitutional taking of their property for public use without just compensation. The government fined them the fair market value of the raisins, with additional civil penalties. On remand from the Supreme Court, the Ninth Circuit held that the requirement was not a Fifth Amendment taking. The Supreme Court reversed. The Fifth Amendment requires that the government pay just compensation when it takes personal property, just as when it takes real property. The reserve requirement is a clear physical taking. Actual raisins are transferred. Any net proceeds the growers receive from the sale of the reserve raisins goes to the amount of compensation, but does not mean the raisins have not been taken. This taking cannot be characterized as part of a voluntary exchange for a valuable government benefit. The ability to sell produce in interstate commerce, while subject to reasonable government regulation, is not a “benefit” that the government may withhold unless growers waive constitutional protections. The Court noted that just compensation can be measured by the market value the government already calculated when it fined the Hornes. View "Horne v. Dep't of Agriculture" on Justia Law

ASARCO hired the law firms to assist it in carrying out its duties as a Chapter 11 debtor in possession, 11 U.S.C. 327(a). When ASARCO emerged from bankruptcy, the law firms filed fee applications requesting fees under section 330(a)(1), which permits bankruptcy courts to “award . . . reasonable compensation for actual, necessary services rendered by” professionals. The Bankruptcy Court rejected ASARCO’s objections and awarded fees for time spent defending the applications. The district court held that the firms could be awarded fees for defending their fee applications. The Fifth Circuit reversed. The Supreme Court affirmed. Section330(a)(1) does not permit bankruptcy courts to award fees to section 327(a) professionals for defending fee applications. The American Rule provides the basic point of reference for attorney’s fees: Each litigant pays his own attorney’s fees, win or lose, unless a statute or contract provides otherwise. Congress did not depart from the American Rule in section 330(a)(1) for fee-defense litigation. The phrase “reasonable compensation for services rendered” necessarily implies “loyal and disinterested service in the interest of” a client, Time spent litigating a fee application against the bankruptcy estate’s administrator cannot be fairly described as “labor performed for”—let alone “disinterested service to”—that administrator. Requiring bankruptcy attorneys to bear the costs of their fee-defense litigation under section 330(a)(1) creates no disincentive to bankruptcy practice. View "Baker Botts L.L.P. v. ASARCO LLC" on Justia Law

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