Justia U.S. Supreme Court Opinion Summaries

The E-Rate program, established under the Telecommunications Act of 1996, subsidizes internet and telecommunications services for schools and libraries. The program is funded by contributions from telecommunications carriers, managed by the Universal Service Administrative Company, and regulated by the FCC. The "lowest corresponding price" rule ensures that schools and libraries are not charged more than similarly situated non-residential customers. Todd Heath, an auditor, alleged that Wisconsin Bell overcharged schools, violating this rule and leading to inflated reimbursement requests from the E-Rate program.Wisconsin Bell moved to dismiss Heath's suit, arguing that E-Rate reimbursement requests do not qualify as "claims" under the False Claims Act (FCA) because the funds come from private carriers and are managed by a private corporation, not the government. The District Court and the Seventh Circuit rejected this argument. The Seventh Circuit held that the government "provided" E-Rate funding through its regulatory role and by depositing over $100 million from the U.S. Treasury into the Fund.The Supreme Court of the United States held that E-Rate reimbursement requests are "claims" under the FCA because the government provided a portion of the money by transferring over $100 million from the Treasury into the Fund. This transfer included delinquent contributions collected by the FCC and Treasury, as well as settlements and restitution payments from the Justice Department. The Court affirmed the judgment of the Seventh Circuit and remanded the case for further proceedings. View "Wisconsin Bell, Inc. v. United States ex rel. Heath" on Justia Law

The case involves Corner Post, a merchant that accepts debit cards as a form of payment. Debit card transactions require merchants to pay an "interchange fee" to the bank that issued the card. The fee amount is set by the payment networks (such as Visa and MasterCard) that process the transaction. In 2010, Congress tasked the Federal Reserve Board with ensuring that interchange fees were "reasonable and proportional to the cost incurred by the issuer with respect to the transaction." In 2011, the Board published Regulation II, which sets a maximum interchange fee of $0.21 per transaction plus .05% of the transaction’s value.In 2021, Corner Post joined a suit against the Board under the Administrative Procedure Act (APA), challenging Regulation II on the ground that it allows higher interchange fees than the statute permits. The District Court dismissed the suit as time-barred under 28 U. S. C. §2401(a), the default six-year statute of limitations applicable to suits against the United States. The Eighth Circuit affirmed the decision.The Supreme Court of the United States reversed the decision of the Eighth Circuit. The Court held that an APA claim does not accrue for purposes of §2401(a)’s 6-year statute of limitations until the plaintiff is injured by final agency action. The Court disagreed with the Board's argument that an APA claim “accrues” under §2401(a) when agency action is “final” for purposes of §704; the claim can accrue for purposes of the statute of limitations even before the plaintiff suffers an injury. The Court held that a right of action “accrues” when the plaintiff has a “complete and present cause of action,” which is when she has the right to “file suit and obtain relief.” Because an APA plaintiff may not file suit and obtain relief until she suffers an injury from final agency action, the statute of limitations does not begin to run until she is injured. View "Corner Post, Inc. v. Board of Governors" on Justia Law

In 2021, Florida and Texas enacted statutes regulating large social-media companies and other internet platforms. The laws curtailed the platforms' ability to engage in content moderation and required them to provide reasons to a user if they removed or altered her posts. NetChoice LLC, a trade association whose members include Facebook and YouTube, brought First Amendment challenges against the two laws. District courts in both states entered preliminary injunctions.The Eleventh Circuit upheld the injunction of Florida’s law, holding that the state's restrictions on content moderation trigger First Amendment scrutiny. The court concluded that the content-moderation provisions are unlikely to survive heightened scrutiny. The Fifth Circuit, however, disagreed and reversed the preliminary injunction of the Texas law. The court held that the platforms’ content-moderation activities are “not speech” at all, and so do not implicate the First Amendment.The Supreme Court of the United States vacated the judgments and remanded the cases, stating that neither the Eleventh Circuit nor the Fifth Circuit conducted a proper analysis of the facial First Amendment challenges to Florida and Texas laws regulating large internet platforms. The Court held that the laws interfere with protected speech, as they prevent the platforms from compiling the third-party speech they want in the way they want, thus producing their own distinctive compilations of expression. The Court also held that Texas's asserted interest in correcting the mix of viewpoints that major platforms present is not valid under the First Amendment. View "Moody v. NetChoice, LLC" on Justia Law

The Supreme Court of the United States reviewed two cases involving challenges to a rule promulgated by the National Marine Fisheries Service under the Magnuson-Stevens Act. The rule required certain fishing vessels to carry observers onboard to collect data necessary for fishery conservation and management, with the cost of these observers to be borne by the vessel owners. The petitioners, various fishing businesses, argued that the Act did not authorize the Fisheries Service to impose these costs on them.In the lower courts, the District Court for the District of Columbia Circuit and the First Circuit Court of Appeals both upheld the rule. They applied the Chevron framework, a two-step process used to interpret statutes administered by federal agencies. Under this framework, if a statute is ambiguous, courts defer to the agency's interpretation as long as it is reasonable. Both courts found that the Magnuson-Stevens Act was ambiguous on the issue of observer costs and deferred to the Fisheries Service's interpretation.The Supreme Court, however, overruled the Chevron doctrine, holding that it was inconsistent with the Administrative Procedure Act (APA). The APA requires courts to exercise their independent judgment in deciding whether an agency has acted within its statutory authority. Courts may not defer to an agency interpretation of the law simply because a statute is ambiguous. The Court vacated the judgments of the lower courts and remanded the cases for further proceedings consistent with this opinion. The Court emphasized that while courts may seek guidance from the interpretations of those responsible for implementing particular statutes, they must not defer to these interpretations. Instead, they must independently interpret the statute and ensure that the agency has acted within its statutory authority. View "Loper Bright Enterprises v. Raimondo" on Justia Law

The Clean Air Act envisions a collaborative effort between states and the federal government to regulate air quality. When the Environmental Protection Agency (EPA) sets standards for common air pollutants, states must submit a State Implementation Plan (SIP), providing for the implementation, maintenance, and enforcement of those standards in their jurisdictions. In 2015, the EPA revised its air-quality standards for ozone, triggering a requirement for states to submit new SIPs. Years later, the EPA announced its intention to disapprove over 20 SIPs because the agency believed they had failed to address adequately obligations under the Good Neighbor Provision. During the public-comment period for the proposed SIP disapprovals, the EPA issued a single proposed Federal Implementation Plan (FIP) to bind all those states.The D.C. Circuit denied relief to a number of the remaining states and industry groups who challenged the FIP, arguing that the EPA’s decision to apply the FIP after so many other states had dropped out was “arbitrary” or “capricious.” They asked the court to stay any effort to enforce the FIP against them while their appeal unfolded. The parties renewed their request in the Supreme Court of the United States.The Supreme Court granted the applications for a stay, halting enforcement of the EPA’s rule against the applicants pending the disposition of the applicants’ petition for review in the D.C. Circuit and any petition for writ of certiorari, timely sought. The Court found that the applicants were likely to prevail on their claim that the EPA’s action was arbitrary or capricious because the agency failed to offer a satisfactory explanation for its action, including a rational connection between the facts found and the choice made, and ignored an important aspect of the problem. The EPA’s alternative arguments were unavailing. View "Ohio v. Environmental Protection Agency" on Justia Law

The case involves James Snyder, the former mayor of Portage, Indiana, who was convicted of accepting an illegal gratuity in violation of 18 U.S.C. §666(a)(1)(B). In 2013, while Snyder was mayor, Portage awarded two contracts to a local truck company, Great Lakes Peterbilt, and purchased five trash trucks from the company for about $1.1 million. In 2014, Peterbilt paid Snyder $13,000. The FBI and federal prosecutors suspected that the payment was a gratuity for the City’s trash truck contracts, but Snyder claimed that the payment was for his consulting services as a contractor for Peterbilt. A federal jury convicted Snyder, and the District Court sentenced him to 1 year and 9 months in prison. On appeal, Snyder argued that §666 criminalizes only bribes, not gratuities. The Seventh Circuit affirmed Snyder’s conviction.The Supreme Court of the United States reversed the Seventh Circuit's decision. The Court held that 18 U.S.C. §666 proscribes bribes to state and local officials but does not make it a crime for those officials to accept gratuities for their past acts. The Court reasoned that the statutory text, history, structure, punishments, federalism principles, and fair notice considerations all support the conclusion that §666 is a bribery statute and not a gratuities statute. The Court concluded that a state or local official does not violate §666 if the official has taken the official act before any reward is agreed to, much less given. Although a gratuity offered and accepted after the official act may be unethical or illegal under other federal, state, or local laws, the gratuity does not violate §666. The case was remanded for further proceedings consistent with the Court's opinion. View "Snyder v. United States" on Justia Law

The case involves a dispute over the allocation of water from the Rio Grande River among the states of Texas, New Mexico, and Colorado. The Rio Grande Compact, an interstate agreement, governs the equitable distribution of the river's waters among these states. In 2013, Texas sued New Mexico and Colorado, alleging that excessive groundwater pumping in New Mexico was depleting the river's water supply intended for Texas, in violation of the Compact. The United States sought to intervene, asserting its own interests in the Compact's enforcement due to its operation of the Rio Grande Project, an irrigation system in southern New Mexico.In previous proceedings, the Supreme Court allowed the United States to intervene, recognizing its distinct federal interests in the Compact. The Court noted that the Compact was intertwined with the United States' operation of the Rio Grande Project and that the federal government had an interest in ensuring New Mexico complied with its obligations under the Compact.Texas and New Mexico proposed a consent decree to resolve the case, which would establish a methodology for determining each state's allocation of the river's waters. However, the United States opposed the proposed consent decree, arguing that it would dispose of its claims that New Mexico's groundwater pumping was violating the Compact.The Supreme Court of the United States agreed with the United States, holding that parties who choose to resolve litigation through settlement may not dispose of the claims of a third party without that party's agreement. The Court found that the United States still had the same claims it did in 2018, backed by the same unique federal interests. The Court concluded that the proposed consent decree would settle all parties' Compact claims and, in the process, cut off the United States' requested relief as to New Mexican groundwater pumping. As such, the Court denied the motion to enter the consent decree. View "Texas v. New Mexico" on Justia Law

The case revolves around the legality of bump stocks, accessories that allow semi-automatic rifles to fire at a rate similar to machine guns. The Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) had long held that semi-automatic rifles equipped with bump stocks were not machine guns under the statute. However, following a mass shooting in Las Vegas, Nevada, where the shooter used bump stocks, the ATF reversed its position and issued a rule classifying bump stocks as machine guns.The case was first heard in the District Court, where Michael Cargill, who had surrendered two bump stocks to the ATF under protest, challenged the rule. Cargill argued that the ATF lacked statutory authority to classify bump stocks as machine guns because they did not meet the definition of a machine gun under §5845(b). The District Court ruled in favor of the ATF, concluding that a bump stock fits the statutory definition of a machine gun.The case was then taken to the Court of Appeals, which initially affirmed the District Court's decision but later reversed it after rehearing en banc. The majority of the Court of Appeals agreed that §5845(b) was ambiguous as to whether a semi-automatic rifle equipped with a bump stock fits the statutory definition of a machine gun. They concluded that the rule of lenity required resolving that ambiguity in Cargill's favor.The Supreme Court of the United States affirmed the decision of the Court of Appeals. The Court held that a semi-automatic rifle equipped with a bump stock is not a machine gun because it cannot fire more than one shot by a single function of the trigger. Furthermore, even if it could, it would not do so automatically. Therefore, the ATF exceeded its statutory authority by issuing a rule that classifies bump stocks as machine guns. View "Garland v. Cargill" on Justia Law

In 2000, the Food and Drug Administration (FDA) approved the use of mifepristone tablets, marketed under the brand name Mifeprex, for terminating pregnancies up to seven weeks. The FDA imposed additional restrictions on the drug's use and distribution, including requiring doctors to prescribe or supervise the prescription of Mifeprex and requiring patients to have three in-person visits with the doctor to receive the drug. In 2016, the FDA relaxed some of these restrictions, and in 2021, it announced that it would no longer enforce the initial in-person visit requirement. Four pro-life medical associations and several individual doctors moved for a preliminary injunction that would require the FDA to either rescind approval of mifepristone or rescind the FDA’s 2016 and 2021 regulatory actions.The District Court agreed with the plaintiffs and effectively enjoined the FDA's approval of mifepristone, ordering it off the market. The FDA and Danco Laboratories, which sponsors Mifeprex, appealed and moved to stay the District Court’s order pending appeal. The Supreme Court ultimately stayed the District Court’s order pending the disposition of proceedings in the Fifth Circuit and the Supreme Court. On the merits, the Fifth Circuit held that plaintiffs had standing and concluded that plaintiffs were unlikely to succeed on their challenge to FDA’s 2000 and 2019 drug approvals, but were likely to succeed in showing that FDA’s 2016 and 2021 actions were unlawful. The Supreme Court granted certiorari with respect to the 2016 and 2021 FDA actions.The Supreme Court of the United States held that the plaintiffs lack Article III standing to challenge the FDA’s actions regarding the regulation of mifepristone. The Court found that the plaintiffs, who are pro-life and oppose elective abortion, have sincere legal, moral, ideological, and policy objections to mifepristone being prescribed and used by others. However, because the plaintiffs do not prescribe or use mifepristone, they are unregulated parties who seek to challenge the FDA’s regulation of others. The Court concluded that the plaintiffs' theories of causation were insufficient to establish Article III standing. The Court reversed the judgment of the Fifth Circuit and remanded the case for further proceedings consistent with its opinion. View "FDA v. Alliance for Hippocratic Medicine" on Justia Law

The case involves the National Rifle Association (NRA) and Maria Vullo, the former superintendent of the New York Department of Financial Services (DFS). The NRA alleged that Vullo violated their First Amendment rights by pressuring regulated entities to disassociate from the NRA and other gun-promotion advocacy groups. The NRA claimed that Vullo threatened enforcement actions against those entities that refused to disassociate, thereby stifling the NRA's pro-gun advocacy.The District Court initially denied Vullo's motion to dismiss the NRA's First Amendment damages claims, holding that the NRA plausibly alleged that Vullo's actions could be interpreted as a veiled threat to regulated industries to disassociate with the NRA or risk DFS enforcement action. However, the Second Circuit reversed this decision, concluding that Vullo's alleged actions constituted permissible government speech and legitimate law enforcement, not unconstitutional coercion. The Second Circuit also held that even if the complaint stated a First Amendment violation, the law was not clearly established, and so Vullo was entitled to qualified immunity.The Supreme Court of the United States, however, vacated the judgment of the Second Circuit. The Supreme Court held that the NRA plausibly alleged that Vullo violated the First Amendment by coercing DFS-regulated entities to terminate their business relationships with the NRA in order to punish or suppress the NRA's advocacy. The case was remanded for further proceedings consistent with this opinion. View "National Rifle Association of America v. Vullo" on Justia Law