Justia U.S. Supreme Court Opinion Summaries

Ford, incorporated in Delaware and headquartered in Michigan, markets, sells, and services its products across the U.S. and overseas and encourages a resale market for its vehicles. Montana and Minnesota courts exercised jurisdiction over Ford in products-liability suits stemming from car accidents that injured state residents. The vehicles were designed and manufactured elsewhere, and originally were sold outside the forum states.The Supreme Court affirmed the rejection of Ford's jurisdictional arguments. The connection between the claims and Ford’s activities in the forum states is close enough to support specific jurisdiction. A state court may exercise general jurisdiction only when a defendant is “essentially at home” in the state. Specific jurisdiction covers defendants less intimately connected with a state if there was “some act by which [defendant] purposefully avails itself of the privilege of conducting activities within the forum State” and the claims “must arise out of or relate to the defendant’s contacts” with the forum.Ford purposefully availed itself of the privilege of conducting activities in both states. There is no requirement of a causal link locating jurisdiction only in the state where Ford sold the car in question or the states where Ford designed and manufactured the vehicle. Specific jurisdiction attaches in cases in which a company cultivates a market for a product in the forum state and the product malfunctions there. Ford advertises and markets its vehicles in Montana and Minnesota and fosters ongoing connections to Ford owners. Because Ford systematically served a market in Montana and Minnesota for the very vehicles that the plaintiffs allege malfunctioned and injured them in those states, there is a strong “relationship among the defendant, the forum, and the litigation.” View "Ford Motor Co. v. Montana Eighth Judicial District Court" on Justia Law

Uzuegbunam, a Georgia Gwinnett College student, talked with interested students and handed out religious literature on campus until a campus police officer informed him that campus policy prohibited distributing religious materials outside two areas designated for that purpose. Speaking about religion or distributing religious materials in those areas required a permit. Uzuegbunam obtained a permit and tried to speak in a free speech zone. A campus officer again asked him to stop, saying that people had complained. Campus policy prohibited using the free speech zone to say anything that “disturbs the peace and/or comfort of person(s).” Uzuegbunam complied. Another student decided not to speak about religion because of these events. The students sought injunctive relief and nominal damages. College officials discontinued the challenged policies. The Eleventh Circuit held that the students’ plea for nominal damages could not establish standing, absent a request for compensatory damages.The Supreme Court reversed. A request for nominal damages satisfies the redressability element necessary for Article III standing where a plaintiff’s claim is based on a completed violation of a legal right. To establish Article III standing, the Constitution requires a plaintiff to identify an injury in fact that is fairly traceable to the challenged conduct and to seek a remedy likely to redress that injury. Under common law, a party whose rights are invaded can recover nominal damages without furnishing evidence of actual damages, without a plea for compensatory damages. Nominal damages are not purely symbolic. One dollar may not provide full redress, but the partial remedy satisfies the redressability requirement and constitutes relief on the merits. In addition to redressability, the plaintiff must establish the other elements of standing and satisfy other relevant requirements, such as pleading a cognizable cause of action. View "Uzuegbunam v. Preczewski" on Justia Law

The Federal Tort Claims Act (FTCA) allows a plaintiff to bring certain state-law tort claims against the United States for torts committed by federal employees acting within the scope of their employment if the plaintiff alleges six statutory elements of an actionable claim, 28 U.S.C. 1346(b). The judgment in an action under section 1346(b) bars “any action by the claimant” involving the same subject matter against the federal employee whose act gave rise to the claim. King sued the government under the FTCA after a violent encounter with federal task force members and sued the officers individually under “Bivens.” The district court dismissed his FTCA claims, holding that the government was immune because the officers were entitled to qualified immunity under Michigan law, then dismissed King’s Bivens claims. The Sixth Circuit found that the dismissal of King’s FTCA claims did not trigger the judgment bar to block his Bivens claims.A unanimous Supreme Court reversed. The dismissal was a judgment on the merits of the FTCA claims that can trigger the judgment bar, similar to common-law claim preclusion. Whether the undisputed facts established all the elements of King’s FTCA claims is a quintessential merits decision. The court also determined that it lacked subject-matter jurisdiction because, in the unique context of the FTCA, all elements of a meritorious claim are also jurisdictional. Generally, a court may not issue a ruling on the merits when it lacks subject-matter jurisdiction, but when pleading a claim and pleading jurisdiction entirely overlap, a ruling that the court lacks subject-matter jurisdiction may simultaneously be a judgment on the merits. View "Brownback v. King" on Justia Law

The Federal Tort Claims Act (FTCA) allows a plaintiff to bring certain state-law tort claims against the United States for torts committed by federal employees acting within the scope of their employment if the plaintiff alleges six statutory elements of an actionable claim, 28 U.S.C. 1346(b). The judgment in an action under section 1346(b) bars “any action by the claimant” involving the same subject matter against the federal employee whose act gave rise to the claim. King sued the government under the FTCA after a violent encounter with federal task force members and sued the officers individually under “Bivens.” The district court dismissed his FTCA claims, holding that the government was immune because the officers were entitled to qualified immunity under Michigan law, then dismissed King’s Bivens claims. The Sixth Circuit found that the dismissal of King’s FTCA claims did not trigger the judgment bar to block his Bivens claims.A unanimous Supreme Court reversed. The dismissal was a judgment on the merits of the FTCA claims that can trigger the judgment bar, similar to common-law claim preclusion. Whether the undisputed facts established all the elements of King’s FTCA claims is a quintessential merits decision. The court also determined that it lacked subject-matter jurisdiction because, in the unique context of the FTCA, all elements of a meritorious claim are also jurisdictional. Generally, a court may not issue a ruling on the merits when it lacks subject-matter jurisdiction, but when pleading a claim and pleading jurisdiction entirely overlap, a ruling that the court lacks subject-matter jurisdiction may simultaneously be a judgment on the merits. View "Brownback v. King" on Justia Law

German Jewish art dealers owned a collection of medieval relics. Their heirs allege that the Nazi government unlawfully coerced the consortium into selling the collection to Prussia for a third of its value. The relics are currently maintained by an instrumentality of the Federal Republic of Germany and displayed at a Berlin museum. After unsuccessfully seeking compensation in Germany, the heirs brought claims in the U.S. Germany argued that the claims did not fall under an exception to the Foreign Sovereign Immunities Act for “property taken in violation of international law,” 28 U.S.C. 1605(a)(3) because a sovereign’s taking of its own nationals’ property is not unlawful under the international law of expropriation. The heirs countered that the purchase was an act of genocide, a violation of international human rights law. The D. C. Circuit affirmed the denial of a motion to dismiss.The Supreme Court vacated. Under the expropriation exception, a foreign sovereign’s taking of its own nationals’ property remains a domestic affair. Historically, a sovereign’s taking of a foreign national’s property implicated international law because it constituted an injury to the state of the alien’s nationality. A domestic taking did not interfere with relations among states. The FSIA’s expropriation exception emphasizes property and property-related rights, while human rights violations are not mentioned. Germany’s interpretation of the exception is more consistent with the FSIA’s goal of codifying the restrictive theory of sovereign immunity, under which immunity extends to a sovereign’s public, but not private, acts. Other FSIA exceptions confirm Germany’s position; those exceptions would be of little consequence if human rights abuses could be packaged as violations of property rights and brought within the expropriation exception. View "Federal Republic of Germany v. Philipp" on Justia Law

In 1992, Salinas began seeking disability benefits under the Railroad Retirement Act (RRA) based on serious injuries he suffered during his 15-year railroad career. He was granted benefits after his fourth application in 2013. He timely sought reconsideration of the amount and start date. After reconsideration was denied, he filed an administrative appeal, arguing that his third application, filed in 2006, should be reopened because the U.S. Railroad Retirement Board had not considered certain medical records. The Board affirmed the denial of the request to reopen because it was not made “[w]ithin four years” of the 2006 decision. The Fifth Circuit dismissed an appeal for lack of jurisdiction.The Supreme Court reversed. The Board’s refusal to reopen a prior benefits determination is subject to judicial review as a "final decision of the Board.” The decision was the “terminal event” in the Board’s administrative review process. Salinas’ only remaining recourse was to seek judicial review. A reopening decision is one “by which rights or obligations have been determined, or from which legal consequences will flow.” Any ambiguity in the meaning of “any final decision” must be resolved in Salinas’ favor under the “strong presumption favoring judicial review of administrative action.” The Board could decline to offer reopening but, having chosen to provide it, the Board may not avoid the plain text of 45 U.S.C. 355(f ). View "Salinas v. Railroad Retirement Board" on Justia Law

Delaware’s Constitution contains a political balance requirement for appointments to the state’s major courts. No more than a bare majority of judges on any of its five major courts “shall be of the same political party.” Art. IV, section 3. On three of those courts, those members not in the bare majority “shall be of the other major political party.” Adams, a Delaware lawyer and political independent, sued, claiming that those requirements violate his First Amendment right to freedom of association by making him ineligible to become a judge unless he joins a major political party.The Supreme Court held that because Adams has not shown that he was “able and ready” to apply for a judicial vacancy in the imminent future, he failed to show a “personal,” “concrete,” and “imminent” injury necessary for Article III standing. A grievance that amounts to nothing more than abstract and generalized harm to a citizen’s interest in the proper application of the law is not an “injury in fact.” Adams must at least show that he is likely to apply to become a judge in the reasonably foreseeable future if not barred because of political affiliation. Adams’ only supporting evidence is his statements that he wanted to be, and would apply to be, a judge on any of Delaware’s courts. The evidence fails to show that, when he filed suit, Adams was “able and ready” to apply for a judgeship in the reasonably foreseeable future. Adams’ statements lack supporting evidence, like efforts to determine possible judicial openings or other preparations. Adams did not apply for numerous existing judicial vacancies while he was a registered Democrat. He then read a law review article arguing that Delaware’s judicial eligibility requirements unconstitutionally excluded independents, changed his political affiliation, and filed suit. View "Carney v. Adams" on Justia Law

Petitioners solicited foreign nationals to invest in a cancer-treatment center. A Securities and Exchange Commission investigation revealed they misappropriated the funds. The SEC may seek “equitable relief” in civil proceedings, 15 U.S.C. 78u(d)(5). The SEC brought a civil action for disgorgement equal to the amount raised from investors. Petitioners argued that the remedy failed to account for their legitimate business expenses. The Ninth Circuit affirmed an order holding Petitioners jointly and severally liable for the full amount.The Supreme Court vacated A disgorgement award that does not exceed a wrongdoer’s net profits and is awarded for victims is equitable relief authorized under section 78u(d)(5). Equity practice has long authorized courts to strip wrongdoers of their ill-gotten gains; to avoid transforming that remedy into a punitive sanction, courts restrict it to an individual wrongdoer’s net profits to be awarded for victims. These long-standing equitable principles were incorporated into section 78u(d)(5).If on remand the court orders the deposit of the profits with the Treasury, the court should evaluate whether that order would be for the benefit of investors, consistent with equitable principles. Imposing disgorgement liability on a wrongdoer for benefits that accrue to his affiliates through joint-and-several liability runs against the rule in favor of holding defendants individually liable but the common law permitted liability for partners engaged in concerted wrongdoing. On remand, the court may determine whether Petitioners can, consistent with equitable principles, be found liable for profits as partners in wrongdoing or whether individual liability is required. The court must deduct legitimate expenses before awarding disgorgement. View "Liu v. Securities and Exchange Commission" on Justia Law

The Prison Litigation Reform Act of 1995 (PLRA) established the three-strikes rule, which generally prevents a prisoner from bringing suit in forma pauperis (IFP) if he has had three or more prior suits dismissed on the grounds that they were frivolous, malicious, or failed to state a claim upon which relief may be granted. 28 U.S.C. 1915(g). Colorado inmate Lomax sued prison officials to challenge his expulsion from the facility’s sex-offender treatment program and moved for IFP status. He had already brought three unsuccessful legal actions during his time in prison. The district court and Tenth Circuit rejected Lomax’s argument that two of the dismissals should not count as strikes because they were without prejudice.The Supreme Court affirmed. Section 1915(g)’s three-strikes provision refers to any dismissal for failure to state a claim, whether with prejudice or without. A Section 1915(g) strike-call hinges exclusively on the basis for the dismissal, regardless of the decision’s prejudicial effect. Courts can and sometimes do dismiss frivolous actions without prejudice. View "Lomax v. Ortiz-Marquez" on Justia Law

ThyssenKrupp entered into contracts with F. L. for the construction of mills at ThyssenKrupp’s Alabama steel manufacturing plant. Each contract contained an arbitration clause. F. L. entered into a subcontract with GE for the provision of motors. After the motors allegedly failed, Outokumpu (ThyssenKrupp's successor) sued GE, which moved to compel arbitration, relying on the arbitration clauses in the F. L.-ThyssenKrupp contracts. The Eleventh Circuit concluded that the Convention on the Recognition and Enforcement of Foreign Arbitral Awards allows enforcement of an arbitration agreement only by the parties that actually signed the agreement.A unanimous Supreme Court reversed. The Convention does not conflict with domestic equitable estoppel doctrines that permit the enforcement of arbitration agreements by nonsignatories. The Federal Arbitration Act (FAA) grants federal courts jurisdiction over actions governed by the Convention and provides that “Chapter 1 applies to actions and proceedings brought under this chapter to the extent that [Chapter 1] is not in conflict with this chapter or the Convention,” 9 U.S.C. 208. Chapter 1 does not “alter background principles of state contract law regarding the scope of agreements (including the question of who is bound by them).” The state-law equitable estoppel doctrines permitted under Chapter 1 do not “conflict with . . . the Convention,” which is silent on whether nonsignatories may enforce arbitration agreements under domestic doctrines such as equitable estoppel. Nothing in the Convention could be read to conflict with the application of domestic equitable estoppel doctrines. The court, on remand, may address whether GE can enforce the arbitration clauses under equitable estoppel principles and which body of law governs that determination. View "GE Energy Power Conversion France SAS v. Outokumpu Stainless USA, LLC" on Justia Law