Justia U.S. Supreme Court Opinion Summaries
Articles Posted in Constitutional Law
Trump v. CASA, Inc.
The case involves three separate lawsuits filed by individuals, organizations, and states to prevent the enforcement of President Trump's Executive Order No. 14160. This order specifies conditions under which a person born in the United States is not considered a citizen. The plaintiffs argue that the order violates the Fourteenth Amendment's Citizenship Clause and the Nationality Act of 1940. District Courts in each case issued universal injunctions, preventing the order's enforcement against anyone, not just the plaintiffs. The Government sought to limit these injunctions to the plaintiffs, arguing that the courts lacked the authority to issue such broad relief.The District Courts concluded that the Executive Order was likely unlawful and issued universal preliminary injunctions. The Courts of Appeals denied the Government's requests to stay these injunctions. The Government then filed emergency applications with the Supreme Court, seeking partial stays to limit the injunctions to the plaintiffs.The Supreme Court of the United States reviewed the case and held that universal injunctions likely exceed the equitable authority granted to federal courts by Congress. The Court granted the Government's applications for partial stays, limiting the injunctions to the extent necessary to provide complete relief to each plaintiff with standing to sue. The Court emphasized that federal courts' equitable authority is confined to traditional remedies available at the time of the Judiciary Act of 1789, and universal injunctions do not have a historical precedent. The Court directed the lower courts to determine whether narrower injunctions would be appropriate. View "Trump v. CASA, Inc." on Justia Law
Posted in:
Civil Procedure, Constitutional Law
FCC v. Consumers’ Research
The case involves the Federal Communications Commission (FCC) and its universal-service contribution scheme, which requires telecommunications carriers to contribute to a fund that subsidizes communications services for underserved communities. The FCC uses a formula to determine the contribution amount, and the Universal Service Administrative Company, a private entity, assists in managing the fund and projecting financial needs.The Fifth Circuit Court of Appeals reviewed the case and found the contribution scheme unconstitutional due to a "double-layered delegation" of authority. The court expressed skepticism about Congress's delegation of power to the FCC and the FCC's delegation to the Administrator, suggesting that the combination of these delegations violated the Constitution's nondelegation doctrine.The Supreme Court of the United States reviewed the case and reversed the Fifth Circuit's decision. The Court held that the universal-service contribution scheme does not violate the nondelegation doctrine. It found that Congress provided sufficient guidance to the FCC through the Communications Act of 1934 and its amendments, which set clear policies and boundaries for the FCC's actions. The Court also determined that the FCC retained decision-making authority and that the Administrator's role was advisory, not a delegation of governmental power. The Court rejected the Fifth Circuit's combination theory, stating that the separate delegations did not compound to create a constitutional violation. View "FCC v. Consumers' Research" on Justia Law
Mahmoud v. Taylor
During the 2022-2023 school year, the Montgomery County Board of Education introduced LGBTQ+-inclusive storybooks into the public school curriculum for kindergarten through fifth grade. Initially, the Board allowed parents to opt their children out of this instruction, consistent with its guidelines for respecting religious diversity. However, the Board later rescinded this opt-out policy, citing disruptions and potential social stigma for students who opted out. A group of parents from diverse religious backgrounds, who believe the curriculum undermines their religious teachings on sexuality and gender, filed a lawsuit seeking to reinstate the opt-out option.The United States District Court for the District of Maryland denied the parents' request for a preliminary injunction, dismissing their reliance on Wisconsin v. Yoder and characterizing their claim as an objection to school indoctrination. The court held that the curriculum did not violate the Free Exercise Clause. A divided panel of the Fourth Circuit affirmed, finding insufficient evidence that the storybooks coerced students to change their views or act contrary to their faith.The Supreme Court of the United States reversed the Fourth Circuit's decision, holding that the parents are entitled to a preliminary injunction. The Court found that the Board's policies substantially interfere with the religious development of the children and impose a burden on religious exercise similar to that in Yoder. The Court concluded that the parents are likely to succeed on the merits of their claim, suffer irreparable harm without relief, and that an injunction is in the public interest. The Board must notify parents in advance when the books will be used and allow their children to be excused from that instruction. View "Mahmoud v. Taylor" on Justia Law
Posted in:
Constitutional Law, Education Law
Free Speech Coalition, Inc. v. Paxton
In 2023, Texas enacted H.B. 1181, which requires commercial websites publishing sexually explicit content to verify that visitors are 18 or older. The law aims to prevent minors from accessing such content, with violations resulting in injunctions and civil penalties. Representatives of the pornography industry challenged the law, claiming it was unconstitutional under the First Amendment as it hindered adults' access to protected speech.The District Court granted a preliminary injunction, finding that the law was subject to strict scrutiny and that Texas had not shown it was narrowly tailored or the least restrictive means to achieve its goal. The court suggested that encouraging parents to use content-filtering software would be a less restrictive alternative.The U.S. Court of Appeals for the Fifth Circuit vacated the injunction, holding that the law was a regulation of the distribution of materials obscene to minors and only incidentally affected adults' privacy. The court applied rational-basis review, concluding that the age-verification requirement was rationally related to the government's interest in preventing minors' access to pornography.The Supreme Court of the United States reviewed the case and held that H.B. 1181 triggers intermediate scrutiny because it only incidentally burdens adults' protected speech. The Court found that the law advances important governmental interests in shielding children from sexual content and is adequately tailored to that interest. The Court affirmed the Fifth Circuit's judgment, concluding that H.B. 1181 is a constitutionally permissible exercise of Texas's authority to prevent minors from accessing sexually explicit content. View "Free Speech Coalition, Inc. v. Paxton" on Justia Law
Posted in:
Constitutional Law, Government & Administrative Law
Fuld v. Palestine Liberation Organization
The case involves two separate lawsuits filed in the United States District Court for the Southern District of New York under the Antiterrorism Act of 1990 (ATA). The plaintiffs, American citizens injured or killed in terror attacks, sued the Palestine Liberation Organization (PLO) and Palestinian Authority (PA). The plaintiffs alleged that the PLO and PA engaged in conduct that triggered jurisdiction under the Promoting Security and Justice for Victims of Terrorism Act (PSJVTA), which deems these entities to have consented to personal jurisdiction in ATA cases under certain conditions.The United States District Court for the Southern District of New York found evidence that the PLO and PA engaged in conduct sufficient to satisfy the PSJVTA's jurisdictional predicates. However, the court ruled that exercising jurisdiction under the PSJVTA was unconstitutional. The Second Circuit Court of Appeals affirmed this decision, holding that the PSJVTA could not establish personal jurisdiction over the PLO or PA consistent with constitutional due process requirements.The Supreme Court of the United States reviewed the case and held that the PSJVTA's personal jurisdiction provision does not violate the Fifth Amendment's Due Process Clause. The Court reasoned that the statute reasonably ties the assertion of jurisdiction over the PLO and PA to conduct involving the United States and implicating sensitive foreign policy matters within the prerogative of the political branches. The Court reversed the Second Circuit's judgment and remanded the case for further proceedings consistent with its opinion. View "Fuld v. Palestine Liberation Organization" on Justia Law
Posted in:
Constitutional Law, International Law
Stanley v. City of Stanford
Karyn Stanley, a firefighter for the City of Sanford, Florida, since 1999, was forced to retire in 2018 due to a disability. When she was hired, the City provided health insurance until age 65 for retirees with 25 years of service or those who retired due to disability. In 2003, the City revised its policy, limiting health insurance to 24 months for those retiring due to disability. Stanley, who retired under the revised policy, received only 24 months of health insurance.Stanley sued the City, alleging that the revised policy violated the Americans with Disabilities Act (ADA) by discriminating against those who retire due to disability. The district court dismissed her ADA claim, stating that the alleged discrimination occurred after her retirement, making her not a "qualified individual" under Title I of the ADA, as she no longer held or sought a job with the City. The Eleventh Circuit affirmed the district court's decision.The Supreme Court of the United States reviewed the case and affirmed the lower courts' decisions. The Court held that to prevail under §12112(a) of the ADA, a plaintiff must prove that they held or desired a job and could perform its essential functions with or without reasonable accommodation at the time of the alleged discrimination. The Court concluded that the ADA's protections do not extend to retirees who neither hold nor seek a job. The judgment of the Eleventh Circuit was affirmed, upholding the dismissal of Stanley's ADA claim. View "Stanley v. City of Stanford" on Justia Law
Posted in:
Civil Rights, Constitutional Law
United States v. Skrmetti
In 2023, Tennessee enacted Senate Bill 1 (SB1), which prohibits healthcare providers from prescribing, administering, or dispensing puberty blockers or hormones to minors for the purpose of enabling them to identify with a gender different from their biological sex or to treat discomfort from such discordance. However, SB1 allows these treatments for minors with congenital defects, precocious puberty, disease, or physical injury. Three transgender minors, their parents, and a doctor challenged SB1 under the Equal Protection Clause of the Fourteenth Amendment.The District Court partially enjoined SB1, finding that transgender individuals constitute a quasi-suspect class, that SB1 discriminates based on sex and transgender status, and that it was unlikely to survive intermediate scrutiny. The Sixth Circuit reversed, holding that SB1 did not trigger heightened scrutiny and satisfied rational basis review. The court found that SB1 did not classify based on sex or transgender status and that Tennessee had provided considerable evidence regarding the risks associated with the banned treatments.The Supreme Court of the United States reviewed the case and held that SB1 is not subject to heightened scrutiny under the Equal Protection Clause and satisfies rational basis review. The Court determined that SB1 does not classify on any bases that warrant heightened review, such as sex or transgender status. Instead, it classifies based on age and medical use, which are subject to rational basis review. The Court found that Tennessee had a rational basis for enacting SB1, citing concerns about the risks and unknown long-term effects of the treatments, the maturity of minors, and the availability of less invasive approaches. The judgment of the Sixth Circuit was affirmed. View "United States v. Skrmetti" on Justia Law
Posted in:
Constitutional Law, Health Law
Perttu v. Richards
In this case, inmate Kyle Richards alleged that Thomas Perttu, a prison employee, sexually harassed him and other inmates. Richards also claimed that Perttu destroyed his grievance documents and retaliated against him for attempting to file them. Richards sued Perttu under 42 U.S.C. §1983 for violating his constitutional rights, including his First Amendment right to file grievances. Perttu moved for summary judgment, arguing that Richards had failed to exhaust available grievance procedures as required by the Prison Litigation Reform Act (PLRA).The Magistrate Judge found a genuine issue of fact regarding whether Richards was excused from exhausting his claims due to Perttu's interference and held an evidentiary hearing. The Magistrate Judge concluded that Richards's witnesses lacked credibility and recommended dismissal without prejudice for failure to exhaust. The District Court adopted this recommendation. The Sixth Circuit reversed, holding that the Seventh Amendment requires a jury trial when the resolution of the exhaustion issue under the PLRA would also resolve a genuine dispute of material fact regarding the merits of the plaintiff's substantive case.The Supreme Court of the United States held that parties are entitled to a jury trial on PLRA exhaustion when that issue is intertwined with the merits of a claim that requires a jury trial under the Seventh Amendment. The Court reasoned that the usual practice under the Federal Rules of Civil Procedure is that factual disputes regarding legal claims go to the jury. The PLRA is silent on whether judges or juries should resolve exhaustion disputes, and this silence indicates that the usual practice should be followed. The Court affirmed the judgment of the Sixth Circuit. View "Perttu v. Richards" on Justia Law
Catholic Charities Bureau, Inc. v. Wisconsin Labor and Industry Review Commission
Catholic Charities Bureau, Inc., and its subentities sought an exemption from Wisconsin's unemployment compensation taxes, claiming they were controlled by the Roman Catholic Diocese of Superior and operated primarily for religious purposes. The Wisconsin Supreme Court denied the exemption, ruling that the organizations did not engage in proselytization or limit their services to Catholics, and thus were not operated primarily for religious purposes.The Wisconsin Department of Workforce Development initially denied the exemption request, but an Administrative Law Judge reversed this decision. The Wisconsin Labor and Industry Review Commission then reinstated the denial. The state trial court overruled the commission, granting the exemption, but the Wisconsin Court of Appeals reversed this decision. The Wisconsin Supreme Court affirmed the Court of Appeals, holding that the organizations' activities were secular and not primarily religious, and that the statute did not violate the First Amendment.The United States Supreme Court reviewed the case and held that the Wisconsin Supreme Court's application of the statute violated the First Amendment. The Court found that the statute imposed a denominational preference by differentiating between religions based on theological lines, subjecting it to strict scrutiny. The Court concluded that the statute, as applied, could not survive strict scrutiny because the State failed to show that the law was narrowly tailored to further a compelling government interest. The judgment of the Wisconsin Supreme Court was reversed, and the case was remanded for further proceedings. View "Catholic Charities Bureau, Inc. v. Wisconsin Labor and Industry Review Commission" on Justia Law
Barnes v. Felix
Roberto Felix, Jr., a law enforcement officer, stopped Ashtian Barnes for suspected toll violations. During the stop, Barnes began to drive away, prompting Felix to jump onto the car's doorsill and fire two shots, fatally wounding Barnes. Barnes's mother sued Felix, alleging a violation of Barnes's Fourth Amendment right against excessive force.The District Court granted summary judgment to Felix, applying the Fifth Circuit’s “moment-of-threat” rule, which focuses solely on whether the officer was in danger at the precise moment deadly force was used. The court found that Felix could have reasonably believed he was in danger during the two seconds he was on the doorsill of the moving car. The Court of Appeals affirmed, adhering to the same rule and limiting its analysis to the final moments before the shooting.The Supreme Court of the United States reviewed the case and held that the “moment-of-threat” rule improperly narrows the Fourth Amendment analysis. The Court emphasized that the reasonableness of police force must be assessed based on the “totality of the circumstances,” which includes events leading up to the use of force. The Court vacated the judgment of the Court of Appeals and remanded the case for further proceedings, instructing the lower courts to consider the entire context of the incident, not just the final moments. View "Barnes v. Felix" on Justia Law
Posted in:
Civil Rights, Constitutional Law