Justia U.S. Supreme Court Opinion Summaries

The Comprehensive Environmental Response, Compensation, and Liability Act of 1980, 42 U.S.C. 960, contains a provision (section 9658) that preempts statutes of limitations applicable to state-law actions for personal injury or property damage arising from the release of a hazardous substance, pollutant, or contaminant into the environment. Section 9658 adopts the discovery rule, so that statutes of limitations begin to run when a plaintiff discovers, or reasonably should have discovered, that the harm was caused by the contaminant because person who is exposed to a toxic contaminant may not develop or show signs of resulting injury for many years. CTS sold property on which it had stored chemicals as part its operations as an electronics plant; 24 years later, owners of parts of that property and adjacent landowners, sued, alleging damages from the stored contaminants. CTS moved to dismiss, citing a state statute of repose that prevented subjecting a defendant to a tort suit brought more than 10 years after the defendant’s last culpable act. Because CTS’s last act occurred when it sold the property, the district court granted the motion. The Fourth Circuit reversed, holding that the statute’s remedial purpose favored preemption. The Supreme Court reversed in part, concluding that section 9658 does not pre-empt state statutes of repose. Statutes of limitations promote justice by encouraging plaintiffs to pursue claims diligently and begin to run when a claim accrues. Statutes of repose effect a legislative judgment that a defendant should be free from liability after a legislatively determined amount of time and are measured from the date of the defendant’s last culpable actor omission. Under the language of the statute, pre-emption is characterized as an exception to the regular rule that the “the statute of limitations established under State law” applies; it is proper to conclude that Congress did not intend to preempt statutes of repose. View "CTS Corp. v. Waldburger" on Justia Law

BIA filed a voluntary chapter 7 bankruptcy petition. The bankruptcy trustee filed a complaint alleging fraudulent conveyance of assets. The bankruptcy court granted the trustee summary judgment. The district court affirmed. While appeal was pending, the Supreme Court held, in Stern v. Marshall, that Article III did not permit a bankruptcy court to enter final judgment on a counterclaim for tortious interference, even though final adjudication of that claim by the bankruptcy court was authorized by statute. The Ninth Circuit affirmed, acknowledging the trustee’s claims as “Stern claims,” i.e., claims designated for final adjudication in the bankruptcy court as a statutory matter, but prohibited from proceeding in that way under Article III, but concluding that defendants had impliedly consented to jurisdiction. The court stated that the bankruptcy court’s judgment could be treated as proposed findings of fact and conclusions of law, subject to de novo review by the district court. A unanimous Supreme Court affirmed. Under 28 U.S.C. 157, federal district courts have original jurisdiction in bankruptcy cases and may refer to bankruptcy judges “core” proceedings and “non-core” proceedings. In core proceedings, a bankruptcy judge “may hear and determine . . . and enter appropriate orders and judgments,” subject to the district court’s traditional appellate review. In non-core proceedings—those that are “otherwise related to a case under title 11,” final judgment must be entered by the district court after de novo review of the bankruptcy judge’s proposed findings of fact and conclusions of law, except that the bankruptcy judge may enter final judgment if the parties consent. Lower courts have described Stern claims as creating a statutory gap, since bankruptcy judges are not explicitly authorized to propose findings of fact and conclusions of law in a core proceeding. However, the gap is closed by the Act’s severability provision; when a court identifies a Stern claim, the bankruptcy court should simply treat that claim as non-core. The fraudulent conveyance claims, which Article III does not permit to be treated as “core” claims are “related to a case under title 11” and fit comfortably within the category of claims governed by section 157(c)(1). View "Exec. Benefits Ins. Agency v. Arkison" on Justia Law

The Copyright Act protects works published before 1978 for 28 years, renewable for up to 67 years, 17 U.S.C. 304(a). An author’s heirs inherit renewal rights. If an author who has assigned rights dies before the renewal period the assignee may continue to use the work only if the author’s successor transfers renewal rights to the assignee. The Act provides for injunctive relief and damages. Civil actions must be commenced within three years after the claim accrued-ordinarily when an infringing act occurred. Under the separate-accrual rule, each successive violation starts a new limitations period, but is actionable only within three years of its occurrence. The movie, Raging Bull, is based on the life of boxer Jake LaMotta, who, with Petrella, told his story in a screenplay copyrighted in 1963. In 1976 they assigned their rights and renewal rights to MGM. In 1980 MGM released, and registered a copyright in, Raging Bull. Petrella died during the initial copyright term, so renewal rights reverted to his daughter, who renewed the 1963 copyright in 1991. Seven years later, she advised MGM that it was violating her copyright. Nine years later she filed suit, seeking damages and injunctive relief for violations occurring after January 5, 2006. The district court dismissed, citing laches. The Ninth Circuit affirmed. The Supreme Court reversed. Laches cannot bar a claim for damages brought within the three-year window. By permitting retrospective relief only three years back, the limitations period takes account of delay. Noting the “essentially gap-filling, not legislation-overriding,” nature of laches, the Court stated that it has never applied laches to entirely bar claims for discrete wrongs occurring within a federally prescribed limitations period. It is not incumbent on copyright owners to challenge every actionable infringement; there is nothing untoward about waiting to see whether a violation undercuts the value of the copyrighted work, has no effect, or even complements the work. The limitations period, with the separate-accrual rule, allows an owner to defer suit until she can estimate whether litigation is worth the effort. Because a plaintiff bears the burden of proof, evidence unavailability is as likely to affect plaintiffs as defendants. The Court noted that in some circumstances, the equitable defense of estoppel might limit remedies. Allowing this suit to proceed will put at risk only a fraction of what MGM has earned from Raging Bull and will work no unjust hardship on innocent third parties. Should Petrella prevail on the merits, the court may fashion a remedy taking account of the delay and MGM’s alleged reliance on that delay. View "Petrella v. Metro-Goldwyn-Mayer, Inc." on Justia Law

Walden, a Georgia police officer working as a DEA agent at a Georgia airport, searched plaintiffs and seized a large amount of cash. Plaintiffs claim that after they returned to their Nevada residence, Walden helped draft a false probable cause affidavit in support of forfeiture and forwarded it to a Georgia office of the U.S. Attorney. No forfeiture complaint was filed and the funds were returned. Plaintiffs filed a tort suit in a Nevada District Court. The district court dismissed, finding that the Georgia search and seizure did not establish a basis for personal jurisdiction in Nevada. The Ninth Circuit reversed, reasoning that Walden submitted the affidavit with the knowledge that it would affect persons with significant Nevada connections. The Supreme Court reversed, holding that the district court lacked personal jurisdiction over Walden. The Due Process Clause limits state authority to bind a nonresident defendant to a judgment of its courts, requiring that the nonresident have “certain minimum contacts” with the forum state. For a state to exercise jurisdiction consistent with due process, a relationship must arise out of contacts that the defendant himself created with the forum itself, not with persons residing there. The plaintiff cannot be the only link between the defendant and the forum. Walden lacks those “minimal contacts” with Nevada. None of his conduct occurred in Nevada, and he formed no jurisdictionally relevant contacts with that forum. Mere injury to a forum resident is not a sufficient connection to the forum. The injury occurred in Nevada simply because that is where plaintiffs chose to be when they desired to use the seized funds. The Court also rejected an argument based on the origin of the funds. View "Walden v. Fiore" on Justia Law