Justia U.S. Supreme Court Opinion Summaries

The named plaintiffs, aliens who were detained under the Immigration and Nationality Act (INA), 8 U.S.C. 1231(a)(6) after reentering the United States illegally, filed a putative class action, alleging that aliens detained under section 1231(a)(6) are entitled to bond hearings after six months’ detention. The district court certified a class of similarly situated plaintiffs and enjoined the government from detaining the class members under section 1231(a)(6) for more than 180 days without providing each a bond hearing. The Ninth Circuit affirmed.The Supreme Court reversed. INA section 1252(f )(1) deprived the district courts of jurisdiction to entertain aliens’ requests for class-wide injunctive relief. Section 1252(f )(1) generally strips lower courts of jurisdiction or authority to “enjoin or restrain the operation of ” certain INA provisions. Section 1252(f )(1)’s one exception allows lower courts to “enjoin or restrain the operation of ” the relevant statutory provisions “with respect to the application of such provisions to an individual alien against whom proceedings under such part have been initiated.” Here, both district courts entered injunctions that “enjoin or restrain the operation” of section 1231(a)(6) because they require officials to take actions that (in the government’s view) are not required by 1231(a)(6) and to refrain from actions that are allowed; the injunctions do not fall within the exception for individualized relief. Section 1252(f )(1) refers to “an individual,” not “individuals.” View "Garland v. Gonzalez" on Justia Law

Morgan, an hourly employee at Sundance's Taco Bell franchise, had signed an agreement to arbitrate any employment dispute. Morgan later filed a nationwide collective action asserting that Sundance had violated federal law regarding overtime pay. Sundance initially defended as if no arbitration agreement existed, filing an unsuccessful motion to dismiss and engaging in unsuccessful mediation. Months after Morgan filed suit, Sundance unsuccessfully moved to compel arbitration under the Federal Arbitration Act (FAA). Under Eighth Circuit precedent, a party waived its right to arbitration if it knew of the right; “acted inconsistently with that right”; and “prejudiced the other party by its inconsistent actions.”The Supreme Court vacated and remanded. The Eighth Circuit erred in conditioning a waiver of the right to arbitrate on a showing of prejudice. A court must hold a party to its arbitration contract just as the court would to any other kind and may not devise novel rules to favor arbitration over litigation. Federal policy is to treat arbitration contracts like all others, not to foster arbitration. Courts may not create arbitration-specific procedural rules. Because the usual federal rule concerning waiver does not include a prejudice requirement, prejudice is not a condition of finding that a party waived its right to stay litigation or compel arbitration under the FAA. The proper inquiry would focus on Sundance’s conduct. Did Sundance knowingly relinquish the right to arbitrate by acting inconsistently with that right? View "Morgan v. Sundance, Inc." on Justia Law

Patel, who entered the United States illegally in the 1990s, applied for adjustment of status, 8 U.S.C. 1255. Because Patel had previously checked a box on a Georgia driver’s license application falsely stating that he was a U.S. citizen, USCIS denied the application. Section 1182(a)(6)(C)(ii)(I) renders inadmissible a noncitizen who falsely represents himself to be a citizen for any legal benefit. In removal proceedings based on his illegal entry, Patel renewed his adjustment of status request, arguing that he had mistakenly checked the “citizen” box and lacked the subjective intent necessary to violate the federal statute.The BIA dismissed Patel’s appeal from a subsequent removal order. The Eleventh Circuit held that it lacked jurisdiction to consider Patel’s claim. Section 1252(a)(2)(B)(i) prohibits judicial review of “any judgment regarding the granting of relief” under 1255, except “constitutional claims” or “questions of law.” The court concluded that the determinations of whether Patel had testified credibly and of subjective intent each qualified as an unreviewable judgment.The Supreme Court affirmed. Federal courts lack jurisdiction to review facts found as part of discretionary-relief proceedings under section 1255 and the other provisions enumerated in section 1252(a)(2)(B)(i). This case largely turns on the scope of the word “judgment." A “judgment” does not necessarily involve discretion, nor does context indicate that only discretionary judgments are covered by section 1252(a)(2)(B)(i). Using the word "judgment" to describe the fact determinations at issue here "is perfectly natural.” The Court rejected arguments that the statute is ambiguous enough to trigger the presumption that Congress did not intend to foreclose judicial review. View "Patel v. Garland" on Justia Law

Cummings, who is deaf and blind, sought physical therapy services from Premier, requesting an American Sign Language interpreter at her sessions. Premier declined. Cummings sought damages, alleging discrimination on the basis of disability under the Rehabilitation Act and the Affordable Care Act. Premier is subject to those statutes because it receives reimbursement through Medicare and Medicaid. The district court determined that the only compensable injuries allegedly caused by Premier were emotional in nature.The Fifth Circuit and Supreme Court affirmed the dismissal of the complaint. Spending Clause legislation, including the statutes at issue, operates based on consent; a particular remedy is available in a private Spending Clause action only if the funding recipient is on notice that, by accepting federal funding, it exposes itself to liability of that nature. Because the statutes at issue are silent as to available remedies, the Court followed the contract analogy. A federal funding recipient is on notice that it is subject to the “usual” remedies traditionally available in breach of contract suits; emotional distress is generally not compensable in contract.The Court rejected an argument that such damages may be awarded where a contractual breach is particularly likely to result in emotional disturbance. Even if it were appropriate to treat funding recipients as aware that they may be subject to rare contract-law rules, they would lack the requisite notice that emotional distress damages are available under these statutes. There is no majority rule on what circumstances may trigger the allowance of such damages. View "Cummings v. Premier Rehab Keller, P.L.L.C." on Justia Law

Cassirer inherited a Pissaro Impressionist painting. After the Nazis came to power in Germany, she surrendered the painting to obtain an exit visa. She and her grandson, Claude, eventually settled in the United States. The family’s post-war search for the painting was unsuccessful. In the 1990s, the painting was purchased by the Foundation, an entity created and controlled by the Kingdom of Spain.Claude sued the Foundation, invoking the Foreign Sovereign Immunities Act (FSIA), 28 U.S.C. 1602, to establish jurisdiction. FSIA provides foreign states and their instrumentalities with immunity from suit unless the claim falls within a specified exception. The court held that the Nazi confiscation of the painting brought Claude’s suit within the FSIA exception for expropriated property. To determine what property law governed the dispute, the court had to apply a choice-of-law rule. The plaintiffs urged the use of California’s choice-of-law rule; the Foundation advocated federal common law. The Ninth Circuit affirmed the choice of the federal option, which commanded the use of the law of Spain, under which the Foundation was the rightful owner.The Supreme Court vacated. In an FSIA suit raising non-federal claims against a foreign state or instrumentality, a court should determine the substantive law by using the same choice-of-law rule applicable in a similar suit against a private party. When a foreign state is not immune from suit under FSIA, it is subject to the same rules of liability as a private party. Only the same choice-of-law rule can guarantee the use of the same substantive law and guarantee the same liability. Judicial creation of federal common law to displace state-created rules must be “necessary to protect uniquely federal interests.” Even the federal government disclaims any necessity for a federal choice-of-law rule in FSIA suits raising non-federal claims. View "Cassirer v. Thyssen-Bornemisza Collection Foundation" on Justia Law

The IRS notified Boechler, a North Dakota law firm, of a discrepancy in its tax filings. When Boechler did not respond, the IRS assessed an “intentional disregard” penalty and notified Boechler of its intent to levy Boechler’s property to satisfy the penalty, 26 U.S.C. 6330(a), 6721(a)(2), (e)(2)(A). The IRS’s Independent Office of Appeals sustained the proposed levy. Under section 6330(d)(1), Boechler had 30 days to petition the Tax Court for review. Boechler filed its petition one day late. The Tax Court dismissed the petition. The Eighth Circuit affirmed, finding the 30-day filing deadline jurisdictional.The Supreme Court reversed. Section 6330(d)(1)’s 30-day time limit to file a petition for review of a collection due process determination is a non-jurisdictional deadline subject to equitable tolling. Whether Boechler is entitled to equitable tolling should be determined on remand. Jurisdictional requirements cannot be waived or forfeited, must be raised by courts “sua sponte,” and do not allow for equitable exceptions. A procedural requirement is jurisdictional only if Congress “clearly states” that it is. Section 6330(d)(1) provides that a “person may, within 30 days of a determination under this section, petition the Tax Court for review of such determination (and the Tax Court shall have jurisdiction with respect to such matter).” The text does not clearly mandate the jurisdictional reading; multiple plausible, non-jurisdictional interpretations exist. Non-jurisdictional limitations periods are presumptively subject to equitable tolling and nothing rebuts the presumption here. View "Boechler v. Commissioner of Internal Revenue" on Justia Law

Badgerow initiated an arbitration proceeding, alleging that her employment was unlawfully terminated. After arbitrators dismissed Badgerow’s claims, she filed suit in Louisiana state court to vacate the arbitral award. Walters removed the case and applied to confirm the award. Badgerow then moved to remand the case to state court, arguing that the federal court lacked jurisdiction to resolve the parties’ requests to vacate or confirm the award under Federal Arbitration Act (FAA) Sections 10 and 9. Normally, a court has federal-question jurisdiction whenever federal law authorizes an action but the FAA does not itself support federal jurisdiction. A federal court must find an independent basis for jurisdiction to resolve an arbitral dispute. In this case, neither application revealed a jurisdictional basis on its face. The district court applied the “look-through” approach, finding jurisdiction in the federal-law claims contained in Badgerow’s underlying employment action. The Fifth Circuit affirmed.The Supreme Court reversed and remanded. The “look-through” approach to determining federal jurisdiction does not apply to requests to confirm or vacate arbitral awards under Sections 9 and 10 of the FAA. The Court distinguished precedent that interpreted other FAA sections. Sections 9 and 10 lack specific statutory language that instructs a federal court to “look through” the petition to the “underlying substantive controversy.” When Congress includes particular language in one section of a statute but omits it in another section of the same Act, the choice is considered deliberate. View "Badgerow v. Walters" on Justia Law

Members of Muslim communities filed a putative class action, claiming that the government subjected Muslims to illegal surveillance. The Foreign Intelligence Surveillance Act (FISA) provides a procedure for consideration of the legality of electronic surveillance conducted under FISA, 50 U.S.C. 1806(f). The district court dismissed because litigation of the claims “would require or unjustifiably risk disclosure of secret and classified information.” The Ninth Circuit reversed, holding that FISA displaced the state secrets privilege.The Supreme Court reversed. Section 1806(f) does not affect the availability or scope of the privilege for state and military secrets. The absence of any reference to the state secrets privilege in FISA indicates that the availability of the privilege was not altered.Nothing about section 1806(f) is incompatible with the state secrets privilege. The central question under 1806(f) is whether the surveillance was lawfully authorized and conducted. Under 1806, a court cannot award relief if the evidence was lawfully obtained, whereas a court considering the state secrets privilege may order the disclosure of lawfully obtained evidence if it finds that disclosure would not harm national security. Inquiries under 1806(f) allow “review in camera and ex parte” of materials “necessary to determine” whether the surveillance was lawful. Under the state secrets privilege, however, examination of the evidence “even by the judge alone, in chambers,” should not be required if the government shows “a reasonable danger that compulsion of the evidence” will expose information that “should not be divulged” in “the interest of national security.” The Court did not decide which party’s interpretation of 1806(f) is correct, whether the government’s evidence is privileged, or whether the district court was correct to dismiss the claims on the pleadings. View "Federal Bureau of Investigation v. Fazaga" on Justia Law

Kentucky’s attorney general and its Secretary of Health and Family Services were defendants in a suit concerning House Bill 454, regulating abortion procedures. Plaintiffs agreed to dismiss the attorney general, stipulating that the attorney general’s office reserved “all rights, claims, and defenses . . . in any appeals” and agreed to be bound by the judgment. The district court enjoined HB 454's enforcement.While an appeal was pending, Kentucky elected a new attorney general, Cameron. Former attorney general Beshear became Governor. Cameron entered an appearance as counsel for the new Secretary. A divided Sixth Circuit panel affirmed. The Secretary opted not to challenge the decision. The attorney general moved to withdraw as counsel for the Secretary and to intervene on the Commonwealth’s behalf, then filed a timely petition for rehearing en banc. The Sixth Circuit denied the motion to intervene.The Supreme Court reversed. Although the attorney general could have filed a notice of appeal, his failure to do so did not mean his motion for intervention should be treated as an untimely notice of appeal. The Sixth Circuit panel failed to account for the strength of the attorney general’s interest in defending HB 454 after the Secretary acquiesced. The attorney general sought to intervene “as soon as it became clear” that the Commonwealth’s interests “would no longer be protected” by the parties. While the rehearing petition pressed an issue (third-party standing) not raised in the Secretary’s appellate briefs, allowing intervention would not have necessitated resolution of that issue. The plaintiffs’ “loss of its claimed expectations around the election of a Governor with a history of declining to defend abortion restrictions is not cognizable as unfair prejudice.” View "Cameron v. EMW Women's Surgical Center, P. S. C." on Justia Law

When a business opted into its Name Screen Alert service, TransUnion would conduct its ordinary credit check of the consumer and would also use third-party software to compare the consumer’s name against the Treasury Department’s Office of Foreign Assets Control's list of terrorists, drug traffickers, and other serious criminals. If the consumer’s first and last name matched the first and last name of an individual on that list, TransUnion would note on the credit report that the consumer’s name was a “potential match.”A class of 8,185 individuals with such alerts in their credit files sued TransUnion under the Fair Credit Reporting Act, 15 U.S.C. 1681. for failing to use reasonable procedures to ensure the accuracy of their credit files. The parties stipulated that only 1,853 class members had their misleading credit reports containing alerts provided to third parties during the seven-month period specified in the class definition. The Ninth Circuit affirmed a jury verdict, awarding each class member statutory and punitive damages.The Supreme Court reversed. Only plaintiffs concretely harmed by a defendant’s statutory violation have Article III standing to seek damages in federal court. An injury-in-law is not an injury-in-fact. The asserted harm must have a close relationship to harm traditionally recognized as providing a basis for a lawsuit. Physical or monetary harms and various intangible harms—like reputational harms--qualify as concrete injuries under Article III; 1,853 class members suffered harm with a “close relationship” to the harm associated with the tort of defamation. The credit files of the remaining 6,332 class members contained misleading alerts, but TransUnion did not provide that information to potential creditors. The mere existence of inaccurate information, absent dissemination, traditionally has not provided the basis for a lawsuit. Exposure to the risk that the misleading information would be disseminated in the future, without more, cannot qualify as concrete harm in a suit for damages. View "TransUnion LLC v. Ramirez" on Justia Law