Justia U.S. Supreme Court Opinion Summaries

Mallory worked as a Norfolk mechanic for 20 years in Ohio and Virginia. After leaving the company, Mallory moved to Pennsylvania, then returned to Virginia. He attributed his cancer diagnosis to his work and sued Norfolk under the Federal Employers’ Liability Act, in Pennsylvania state court. Norfolk, incorporated and headquartered in Virginia, challenged the court’s exercise of personal jurisdiction. Mallory noted that Norfolk manages over 2,000 miles of track, operates 11 rail yards, runs locomotive repair shops in Pennsylvania, and has registered to do business in Pennsylvania in light of its "regular, systematic, extensive” operations there. Pennsylvania requires out-of-state companies that register to do business to agree to appear in its courts on “any cause of action” against them. 42 Pa. Cons. Stat. 5301(a)(2)(i), (b). The Pennsylvania Supreme Court held that the Pennsylvania law violated the Due Process Clause.The Supreme Court vacated. Pennsylvania law is explicit that qualification as a foreign corporation shall permit state courts to exercise general personal jurisdiction over a registered foreign corporation. Norfolk has complied with this law since 1998 when it registered to do business in Pennsylvania. Norfolk's “Certificate of Authority” from the Commonwealth conferred both the benefits and burdens shared by domestic corporations, including amenability to suit in state court on any claim. For more than two decades, Norfolk has agreed to be found in Pennsylvania and answer any suit there. Suits premised on these grounds do not deny a defendant due process of law. Regardless of whether any other statutory scheme and set of facts would establish consent to suit, this state law and these facts fall within Supreme Court precedent. View "Mallory v. Norfolk Southern Railway Co." on Justia Law

Samia, Hunter, and Stillwell were tried jointly for the murder-for-hire of Lee, a real estate broker. The prosecution argued that Hunter had hired Samia and Stillwell to pose as buyers and visit properties with Lee. The court admitted Stillwell’s confession that he was in the van in which Lee was killed, but he claimed that Samia had shot Lee. Since Stillwell would not be testifying and the full confession implicated Samia, the prosecution introduced the testimony of a DEA agent, who described Stillwell’s confession in a way that eliminated Samia’s name while avoiding obvious indications of redaction. Before that testimony and again before deliberations, the court instructed the jury that the testimony about Stillwell’s confession was admissible only as to Stillwell and should not be considered as to Samia or Hunter. All three were convicted. The Second Circuit held that the admission of Stillwell’s confession did not violate Samia’s Confrontation Clause rights.The Supreme Court affirmed. The Confrontation Clause was not violated by the admission of a non-testifying codefendant’s confession that did not directly inculpate the defendant and was subject to a proper limiting instruction. The Sixth Amendment’s Confrontation Clause forbids the introduction of out-of-court “testimonial” statements unless the witness is unavailable and the defendant has had the chance to cross-examine the witness previously but applies only to witnesses “against the accused.” Ordinarily, a witness at a joint trial is not considered a witness ‘against’ a defendant if the jury is instructed to consider that testimony only against a codefendant. This rule is consistent with the Clause’s text, historical practice, and the law’s reliance on limiting instructions in other contexts. To mandate severance whenever the prosecution wishes to introduce the confession of a non-testifying codefendant in a joint trial would be “too high” a price to pay. View "Samia v. United States" on Justia Law

Hansen promised hundreds of noncitizens a path to U.S. citizenship through “adult adoption,” earning nearly $2 million from his fraudulent scheme. The government charged Hansen under 8 U.S.C. 1324(a)(1)(A)(iv), which forbids “encourag[ing] or induc[ing] an alien to come to, enter, or reside in the United States, knowing or in reckless disregard of the fact that such [activity] is or will be in violation of law.” The Ninth Circuit found Clause (iv) unconstitutionally overbroad, in violation of the First Amendment.The Supreme Court reversed. Because 1324(a)(1)(A)(iv) forbids only the purposeful solicitation and facilitation of specific acts known to violate federal law, the clause is not unconstitutionally overbroad. A statute is facially invalid under the overbreadth doctrine if it “prohibits a substantial amount of protected speech” relative to its “plainly legitimate sweep.” Here, Congress used “encourage” and “induce” as terms of art referring to criminal solicitation and facilitation (capturing only a narrow band of speech) not as those terms are used in ordinary conversation. Criminal solicitation is the intentional encouragement of an unlawful act, and facilitation—i.e., aiding and abetting—is the provision of assistance to a wrongdoer with the intent to further an offense’s commission. Neither requires lending physical aid; both require an intent to bring about a particular unlawful act. The context of these words and statutory history indicate that Congress intended to refer to their well-established legal meanings. Section 1324(a)(1)(A)(iv) reaches no further than the purposeful solicitation and facilitation of specific acts known to violate federal law and does not “prohibi[t] a substantial amount of protected speech” relative to its “plainly legitimate sweep.” View "United States v. Hansen" on Justia Law

In 2000, Jones was convicted on two counts of unlawful possession of a firearm by a felon, 18 U.S.C. 922(g)(1). The Eighth Circuit affirmed Jones’ convictions and sentence. Jones’ subsequent 28 U.S.C. 2255 motion resulted in the vacatur of one of his concurrent sentences. Years later, the Supreme Court held (Rehaif) that a defendant’s knowledge of the status that disqualifies him from owning a firearm is an element of a 922(g) conviction, abrogating contrary Eighth Circuit precedent. Jones filed a 28 U.S.C. 2241 motion in the district of his imprisonment.The Eighth Circuit and the Supreme Court affirmed the dismissal of the petition. Section 2255(e) does not allow a prisoner asserting an intervening change in interpretation of a criminal statute to circumvent the Antiterrorism and Effective Death Penalty Act (AEDPA) restrictions on second or successive 2255 motions by filing a 2241 habeas petition.Under section 2255, federal prisoners can collaterally attack their sentences in the sentencing court, rather than by a 2241 habeas corpus petition in the district of confinement. The purpose of 2255 was to address problems created by district courts collaterally reviewing one another’s proceedings and by the concentration of federal prisoners in certain districts. Congress generally barred federal prisoners “authorized” to file a 2255 motion from filing a 2241 petition but preserved access to 2241 in cases where “the remedy by motion is inadequate or ineffective to test the legality" of the detention (Saving Clause). AEDPA subsequently barred second or successive 2255 motions unless based on either newly discovered evidence or “a new rule of constitutional law.” The inability of a prisoner with a statutory claim to satisfy section 2255(h) does not mean that the prisoner may bring a 2241 petition. Section 2255 is not necessarily “inadequate or ineffective” if the 2255 court fails to apply the correct substantive law. The Saving Clause is concerned with the adequacy or effectiveness of the remedial vehicle, not asserted errors of law. Due process does not guarantee the opportunity to have legal issues redetermined in successive collateral attacks. AEDPA embodies a balance between finality and error correction; there is nothing incongruous about a system in which the application of a since-rejected statutory interpretation cannot be remedied after final judgment. View "Jones v. Hendrix" on Justia Law

A federal court imposing multiple prison sentences typically has discretion to run the sentences concurrently or consecutively, 18 U.S.C. 3584. Section 924(c)'s exception provides: no term of imprisonment imposed “under this subsection shall run concurrently with any other term of imprisonment.” Lora was convicted of aiding and abetting a violation of section 924(j)(1), which penalizes “a person who, in the course of a violation of subsection (c), causes the death of a person through the use of a firearm,” where “the killing is a murder.” A violation of subsection (c) occurs when a person “uses or carries a firearm” “during and in relation to any crime of violence or drug trafficking crime,” or “possesses a firearm” “in furtherance of any such crime.” Lora was also convicted of conspiring to distribute drugs. The district court concluded that it lacked discretion to run the sentences for Lora’s two convictions concurrently. The Second Circuit affirmed.A unanimous Supreme Court vacated. Section 924(c)(1)(D)(ii)’s bar on concurrent sentences does not govern a 924(j) sentence, which can run either concurrently with or consecutively to another sentence. Subsection (c)’s consecutive-sentence mandate applies only to the terms of imprisonment prescribed within subsection (c). A sentence imposed under subsection (j) does not qualify. Subsection (j) is located outside subsection (c) and does not call for imposing any sentence from subsection (c); while subsection (j) references subsection (c), that reference is limited to offense elements, not penalties. It is not “implausible” for Congress to have imposed the harsh consecutive-sentence mandate under subsection (c) but not subsection (j). That result is consistent with the statute’s design. Unlike subsection (c), subsection (j) generally eschews mandatory penalties in favor of sentencing flexibility. View "Lora v. United States" on Justia Law

Smith was indicted in the Northern District of Florida for theft of trade secrets from StrikeLines’ website. Smith moved to dismiss the indictment, citing the Constitution’s Venue Clause and the Vicinage Clause. Smith argued that he had accessed the website from his Alabama home and that the servers storing StrikeLines’ data were in Orlando, Florida. The Eleventh Circuit determined that venue was improper and vacated Smith’s conviction, but held that a trial in an improper venue did not bar reprosecution.The Supreme Court affirmed. The Constitution permits the retrial of a defendant following a trial in an improper venue conducted before a jury drawn from the wrong district. Except as prohibited by the Double Jeopardy Clause, when a defendant obtains a reversal of a prior, unsatisfied conviction, he may be retried. Nothing in the Venue Clause suggests that a new trial in the proper venue is not an adequate remedy for its violation. The Vicinage Clause—which guarantees the right to “an impartial jury of the State and district wherein the crime shall have been committed,” concerns jury composition, not the place where a trial may be held, and concerns the district where the crime was committed, rather than the state. The vicinage right is one aspect of the Sixth Amendment’s jury-trial rights and retrials are the appropriate remedy for violations of other jury-trial rights.The Double Jeopardy Clause is not implicated by retrial in a proper venue. A judicial decision on venue is fundamentally different from a jury’s verdict of acquittal. Culpability is the touchstone; when a trial terminates with a finding that the defendant’s criminal culpability had not been established, retrial is prohibited. Retrial is permissible when a trial terminates on a basis unrelated to factual guilt. The reversal of a conviction based on a violation of the Venue or Vicinage Clauses, even when called a “judgment of acquittal,” does not resolve the question of criminal culpability. View "Smith v. United States" on Justia Law

In 1992, Voting Rights Act (52 U.S.C. 10301) Section 2 litigation challenging Alabama’s districting map resulted in Alabama’s first majority-black district and its first black Representative since 1877. Alabama’s congressional map has remained similar since then. Following the 2020 census, the state enacted a new districting map (HB1), which produced only one district in which black voters constituted a majority.The Supreme Court affirmed a preliminary injunction, prohibiting the use of HB 1.Section 2 provides that the right to vote “shall not be denied or abridged ... on account of race, color, or previous condition of servitude.” A 1982 amendment incorporated an effects test and a disclaimer that “nothing” in Section 2 “establishes a right to have members of a protected class elected in numbers equal to their proportion in the population.” The Supreme Court subsequently employed the “Gingles framework,” under which Section 2 plaintiffs must satisfy three preconditions and then show that, under the “totality of circumstances,” the challenged process is not “equally open” to minority voters.The district court correctly found that black voters could constitute a majority in a second district that was “reasonably configured” and that there was no serious dispute that Black voters are politically cohesive, nor that the challenged districts’ white majority votes sufficiently as a bloc to usually defeat Black voters’ preferred candidate. The court’s findings that “Black Alabamians enjoy virtually zero success in statewide elections” and concerning “Alabama’s extensive history of repugnant racial and voting-related discrimination” were unchallenged.The Court rejected Alabama’s arguments that a state’s map cannot abridge a person’s right to vote “on account of race” if the map resembles a sufficient number of race-neutral alternatives and that the plaintiffs must prove discriminatory intent. Section 2, as applied to redistricting, is not unconstitutional under the Fifteenth Amendment. View "Allen v. Milligan" on Justia Law

Tyler's Hennepin County, Minnesota condominium accumulated about $15,000 in unpaid real estate taxes plus interest and penalties. The County seized the condo and sold it for $40,000, keeping the $25,000 excess over Tyler’s tax debt for itself, Minn. Stat. 281.18, 282.07, 282.08. The Eighth Circuit affirmed the dismissal of Tyler’s suit.The Supreme Court reversed. Tyler plausibly alleges that Hennepin County’s retention of the excess value of her home above her debt violated the Takings Clause. Whether the remaining value from a tax sale is property protected under the Takings Clause depends on state law, “traditional property law principles,” historical practice, and Supreme Court precedents. Though state law is an important source of property rights, it cannot “sidestep the Takings Clause by disavowing traditional property interests” in assets it wishes to appropriate. The County's use of its power to sell Tyler’s home to recover the unpaid property taxes to confiscate more property than was due effected a “classic taking in which the government directly appropriates private property for its own use.” Supreme Court precedent recognizes that a taxpayer is entitled to any surplus in excess of the debt owed. Minnesota law itself recognizes in other contexts that a property owner is entitled to any surplus in excess of her debt. The Court rejected an argument that Tyler had no property interest in the surplus because she constructively abandoned her home by failing to pay her taxes. View "Tyler v. Hennepin County" on Justia Law

The Puerto Rico Oversight, Management, and Economic Stability Act (PROMESA), 48 U.S.C. 2101, creates the Financial Oversight and Management Board, an “entity within the territorial government” of Puerto Rico. The Board approves and enforces the Commonwealth’s fiscal plans, supervises its borrowing, and represents Puerto Rico in Title III cases, modeled on federal bankruptcy proceedings. PROMESA does not explicitly abrogate sovereign immunity but incorporates, as part of its mechanism for restructuring debt, the Bankruptcy Code’s express abrogation of sovereign immunity. PROMESA contemplates other legal claims and sets limits on litigation targeting the Board, its members, and its employees for “actions taken to carry out” PROMESA. It provides that no district court will have jurisdiction over challenges to the Board’s “certification determinations.”CPI, a media organization, requested materials, including communications between Board members and Puerto Rican and U.S. officials. The request went unanswered. CPI sued the Board, citing the Puerto Rican Constitution as guaranteeing a right of access to public records. The district court concluded that PROMESA abrogated the Board’s immunity. The First Circuit affirmed.The Supreme Court reversed. PROMESA does not abrogate the Board’s immunity. Congress must make its intent to abrogate sovereign immunity “unmistakably clear.” PROMESA does not do so. Except in Title III debt-restructuring proceedings, the statute does not provide that the Board or Puerto Rico is subject to suit. PROMESA’s judicial review provisions are not incompatible with sovereign immunity but serve a function without an abrogation of immunity. Litigation against the Board can arise even though the Board enjoys sovereign immunity generally. Statutes other than PROMESA abrogate its immunity from particular claims; the Board could decide to waive its immunity from particular claims. Providing for a judicial forum and shielding the Board, its members, and employees from liability do not make the requisite clear statement. View "Financial Oversight and Management Board for Puerto Rico v. Centro De Periodismo Investigativo, Inc." on Justia Law

California’s Proposition 12 forbids the in-state sale of whole pork meat that comes from breeding pigs (or their immediate offspring) that are “confined in a cruel manner.” Confinement is “cruel” if it prevents a pig from “lying down, standing up, fully extending [its] limbs, or turning around freely.” Opponents alleged that Proposition 12 violated the Constitution by impermissibly burdening interstate commerce, arguing that the cost of compliance with Proposition 12 will increase production costs and, because California imports almost all the pork it consumes, most of Proposition 12’s compliance costs will be borne by out-of-state firms.The Ninth Circuit and Supreme Court affirmed the dismissal of the case, rejecting arguments under the dormant Commerce Clause. Absent purposeful discrimination, a state may exclude from its territory, or prohibit the sale therein of any articles which, in its judgment, fairly exercised, are prejudicial to the interests of its citizens. Proposition 12 imposes the same burdens on in-state pork producers that it imposes on out-of-state pork producers. Proposition 12 does not implicate the antidiscrimination principle.The Court rejected an argument that its precedents include an “almost per se” rule forbidding enforcement of state laws that have the practical effect of controlling commerce outside the state, even when those laws do not purposely discriminate against out-of-state interests. While leaving the courtroom door open to challenges premised on even nondiscriminatory burdens, the Court noted that “extreme caution is warranted.” View "National Pork Producers Council v. Ross" on Justia Law