Justia U.S. Supreme Court Opinion Summaries

The City and County of San Francisco operates two combined wastewater treatment facilities that process both wastewater and stormwater. During heavy precipitation, these facilities may discharge untreated water into the Pacific Ocean or San Francisco Bay. In 2019, the Environmental Protection Agency (EPA) issued a renewal permit for San Francisco's Oceanside facility, adding two "end-result" requirements. These requirements prohibited discharges that contribute to violations of water quality standards and discharges that create pollution, contamination, or nuisance as defined by California law. San Francisco challenged these provisions, arguing they exceeded the EPA's statutory authority.The California Regional Water Quality Control Board and the EPA approved the final Oceanside NPDES permit. San Francisco appealed to the EPA's Environmental Appeals Board, which rejected the challenge. The City then petitioned for review in the Ninth Circuit, which denied the petition. The Ninth Circuit held that the Clean Water Act (CWA) authorizes the EPA to impose any limitations necessary to ensure water quality standards are met in receiving waters.The Supreme Court of the United States reviewed the case and held that Section 1311(b)(1)(C) of the CWA does not authorize the EPA to include "end-result" provisions in NPDES permits. The Court reasoned that determining the specific steps a permittee must take to meet water quality standards is the EPA's responsibility, and Congress has provided the necessary tools for the EPA to make such determinations. The Court reversed and remanded the Ninth Circuit's decision, emphasizing that the EPA must set specific rules for permittees to follow rather than imposing broad end-result requirements. View "City and County of San Francisco v. EPA" on Justia Law

Jewish survivors of the Hungarian Holocaust and their heirs sued Hungary and its national railway (MÁV) in federal court, seeking damages for property allegedly seized during World War II. They claimed that Hungary and MÁV liquidated the expropriated property, commingled the proceeds with other government funds, and later used funds from those commingled accounts in connection with commercial activities in the United States.The District Court for the District of Columbia determined that the plaintiffs' "commingling theory" satisfied the commercial nexus requirement of the Foreign Sovereign Immunities Act (FSIA) expropriation exception. The D.C. Circuit affirmed, reasoning that requiring plaintiffs to trace the particular funds from the sale of their specific expropriated property to the United States would make the exception a "nullity" in cases involving liquidated property.The Supreme Court of the United States reviewed the case and held that alleging commingling of funds alone cannot satisfy the commercial nexus requirement of the FSIA’s expropriation exception. The Court emphasized that plaintiffs must trace either the specific expropriated property itself or any property exchanged for such property to the United States. The Court vacated the judgment of the D.C. Circuit and remanded the case for further proceedings consistent with this opinion. View "Hungary v. Simon" on Justia Law

Several unemployed workers in Alabama applied for unemployment benefits and claimed that the Alabama Department of Labor unlawfully delayed processing their claims. They sued the Alabama Secretary of Labor in state court under 42 U.S.C. §1983, arguing that the delays violated their due process and federal statutory rights. They sought a court order to expedite the processing of their claims. The Secretary moved to dismiss the complaint, arguing that the claimants had not satisfied the administrative-exhaustion requirement under Alabama law. The state trial court granted the motion and dismissed the complaint.The claimants appealed to the Alabama Supreme Court, which affirmed the dismissal on the grounds of failure to exhaust administrative remedies. The court concluded that §1983 did not preempt the state's administrative-exhaustion requirement, effectively preventing the claimants from suing to expedite the administrative process until they had completed it.The Supreme Court of the United States reviewed the case and held that state courts may not deny §1983 claims on failure-to-exhaust grounds when the application of a state exhaustion requirement effectively immunizes state officials from such claims. The Court reasoned that Alabama's exhaustion requirement, as applied, prevented claimants from challenging delays in the administrative process, thus immunizing state officials from §1983 suits. The Court reversed the Alabama Supreme Court's decision and remanded the case for further proceedings consistent with its opinion. View "Williams v. Reed" on Justia Law

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