Justia U.S. Supreme Court Opinion Summaries

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

The Supreme Court of the United States was tasked with interpreting the Armed Career Criminal Act (ACCA) in relation to state drug convictions that occurred before recent amendments to the federal drug schedules. The ACCA imposes a 15-year mandatory minimum sentence on defendants convicted for illegal firearm possession who have a criminal history demonstrating a propensity for violence. A defendant with three previous convictions for a "serious drug offense" qualifies for ACCA's enhanced sentencing.Petitioners Justin Rashaad Brown and Eugene Jackson were separately convicted of the federal crime of possession of a firearm by a convicted felon. In both cases, an ACCA enhancement was recommended based on prior state felony drug convictions. Both defendants argued that their prior convictions did not qualify as "serious drug offenses" due to changes in the federal definition of the drugs involved in their convictions. The District Courts disagreed and sentenced the petitioners to enhanced sentences, and the respective appellate courts affirmed.The Supreme Court held that a state drug conviction counts as an ACCA predicate if it involved a drug on the federal schedules at the time of that conviction. The Court reasoned that the ACCA is a recidivist statute that gauges what a defendant’s “history of criminal activity” says about his or her “culpability and dangerousness.” The Court also noted that the Government’s interpretation best fulfills ACCA’s statutory objectives. The Court affirmed the judgments of the Courts of Appeals. View "Brown v. United States" on Justia Law

The case revolves around Stuart Harrow, a Department of Defense employee who was furloughed for six days. Harrow challenged this decision before the Merit Systems Protection Board. After a five-year delay, the Board ruled against him. Harrow had the right to appeal this decision to the Court of Appeals for the Federal Circuit within 60 days of the Board's final order. However, Harrow did not learn about the Board's decision until after the 60-day period had elapsed, and he filed his appeal late. Harrow requested the Federal Circuit to overlook his untimeliness and equitably toll the filing deadline. The Federal Circuit, however, denied his request, believing that the deadline was an unalterable "jurisdictional requirement."The Supreme Court of the United States reviewed the case. The main issue was whether the 60-day filing deadline under Section 7703(b)(1) was jurisdictional, meaning it marked the bounds of a court's power and could not be waived or subject to exceptions. The Supreme Court held that the 60-day filing deadline was not jurisdictional. The Court reasoned that procedural rules, even when phrased in mandatory terms, are generally subject to exceptions like waiver, forfeiture, and equitable tolling. The Court found no language in Section 7703(b)(1) that suggested it was a jurisdictional requirement. The Court also rejected the Government's argument that the term "pursuant to" in a different statute, 28 U.S.C. §1295(a)(9), made the deadline jurisdictional.The Supreme Court vacated the judgment of the Federal Circuit and remanded the case for further proceedings consistent with its opinion. The Federal Circuit was directed to determine whether equitable tolling was available and, if so, whether Harrow was entitled to that relief given the facts of the case. View "Harrow v. Department of Defense" on Justia Law

The case involves the Consumer Financial Protection Bureau (CFPB) and its funding mechanism. The CFPB, unlike most federal agencies, has a standing source of funding outside the ordinary annual appropriations process. Congress authorized the CFPB to draw from the Federal Reserve System an amount that its Director deems “reasonably necessary to carry out” the Bureau’s duties, subject only to an inflation-adjusted cap. Several trade associations representing payday lenders and credit-access businesses challenged this funding mechanism, arguing that it violates the Appropriations Clause of the Constitution.The Fifth Circuit Court of Appeals agreed with the associations, ruling that the CFPB's funding mechanism violates the Appropriations Clause. The court reasoned that the Appropriations Clause requires both Chambers of Congress to periodically agree on an agency’s funding, which ensures that each Chamber reserves the power to unilaterally block those funding measures through inaction. The CFPB's funding mechanism, the court argued, allows it to draw funds indefinitely unless both Chambers of Congress step in and affirmatively prevent the agency from doing so.The Supreme Court of the United States, however, reversed the Fifth Circuit's decision. The Supreme Court held that Congress’ statutory authorization allowing the Bureau to draw money from the earnings of the Federal Reserve System to carry out the Bureau’s duties satisfies the Appropriations Clause. The Court reasoned that under the Appropriations Clause, an appropriation is a law that authorizes expenditures from a specified source of public money for designated purposes. The statute that provides the Bureau’s funding meets these requirements. Therefore, the Court concluded that the Bureau’s funding mechanism does not violate the Appropriations Clause. The case was remanded for further proceedings consistent with the Supreme Court's opinion. View "Consumer Financial Protection Bureau v. Community Financial Services Assn. of America, Ltd." on Justia Law

The case involves a dispute over the interpretation of the Montgomery GI Bill and the Post-9/11 GI Bill, both of which provide educational benefits to veterans. The petitioner, James Rudisill, served in the U.S. Army for nearly eight years over three separate periods, earning entitlements under both bills. He used a portion of his Montgomery benefits for his undergraduate degree and sought to use his Post-9/11 benefits for divinity school. However, the Department of Veterans Affairs (VA) limited his Post-9/11 benefits to the duration of his unused Montgomery benefits, arguing that by requesting Post-9/11 benefits before exhausting all of his Montgomery benefits, Rudisill could receive only 36 months of benefits in total, not the 48 months to which he would otherwise be entitled.The Board of Veterans’ Appeals affirmed the VA’s decision, but the Court of Appeals for Veterans Claims reversed. The Federal Circuit, however, reversed the Court of Appeals for Veterans Claims, holding that veterans with multiple periods of qualifying service are subject to a limit on the duration of their benefits.The Supreme Court of the United States reversed the judgment of the Federal Circuit. The Court held that veterans who separately accrue benefits under both the Montgomery and Post-9/11 GI Bills are entitled to both benefits. Neither the Montgomery GI Bill nor the Post-9/11 GI Bill restricts veterans with two separate entitlements who simply seek to use either one. Thus, Rudisill may use his benefits, in any order, up to a 48-month aggregate-benefits cap. The case was remanded for further proceedings consistent with this opinion. View "Rudisill v. McDonough" on Justia Law

The Supreme Court of the United States decided in the case of Mark Pulsifer, who was convicted for distributing methamphetamine and sought to minimize his sentence using the "safety valve" provision of federal sentencing law. This provision allows a sentencing court to disregard the statutory minimum if a defendant meets five criteria, one of which is related to the defendant's criminal history. The government argued that Pulsifer did not meet this requirement due to his previous three-point offenses, disqualifying him under the safety valve provision. Pulsifer, however, contended that he should be considered eligible as he did not have a two-point violent offense, arguing that only the combination of all three elements of the provision could prevent him from receiving safety-valve relief.The court held that a defendant is eligible for safety-valve relief only if he or she satisfies each of the provision’s three conditions. More specifically, a defendant is eligible only if they do not have more than four criminal-history points, do not have a prior three-point offense, and do not have a prior two-point violent offense. This interpretation aligns with the text and context of the law and the Sentencing Guidelines. The court rejected Pulsifer’s attempts to invoke the rule of lenity, as the court found no ambiguity in the statute and, therefore, no room for lenity to play a role. The court affirmed the judgment of the Court of Appeals for the Eighth Circuit. View "Pulsifer v. United States" on Justia Law

A consumer, Reginald Kirtz, secured a loan from the Rural Housing Service, part of the U.S. Department of Agriculture. Although Kirtz repaid his loan by mid-2018, the USDA continued to tell credit report company TransUnion that his account was past due, harming his credit score. The USDA failed to correct its records after being notified of the error, and Kirtz sued the agency under the Fair Credit Reporting Act.The USDA argued that the case should be dismissed based on sovereign immunity, since the Supreme Court has held that the federal government is immune from suits for damages unless Congress waives that immunity. The agency claimed that the FCRA does not make the federal government amenable to suit for a violation. The district court agreed, but the Third Circuit Court of Appeals reversed, finding that the FCRA authorizes suits for damages against any person who violates the Act, and “person” is defined to include any government agency.The U.S. Supreme Court affirmed the decision of the Third Circuit, finding that sovereign immunity did not bar Kirtz’s claim. The Court held that the federal government is susceptible to suit when it provides false information to credit reporting agencies. It noted that dismissing a suit like Kirtz’s case would effectively negate a claim that Congress has clearly authorized. The Court’s ruling resolved a circuit split between the Third, Seventh, and D.C. Circuits, with which the Court agreed, and the Fourth and Ninth Circuits, with which it disagreed. View "Department of Agriculture Rural Development Rural Housing Service v. Kirtz" on Justia Law

Before the resumption of federal student-loan repayments that had been suspended during the coronavirus pandemic, the Secretary of Education announced a Plan that would discharge $10,000-$20,000 of an eligible borrower’s debt. The Secretary invoked the 2003 Higher Education Relief Opportunities for Students Act (HEROES Act), which authorizes the Secretary “to waive or modify any provision” applicable to federal student financial assistance programs as “necessary” to ensure that recipients of student financial assistance are no worse off “financially in relation to that financial assistance because” of a national emergency or disaster, 20 U.S.C. 1098. The Act exempts rules promulgated under it from otherwise-applicable negotiated rulemaking and notice-and-comment processes. Borrowers who did not qualify for the Plan's maximum relief alleged that the Secretary was required to follow those rulemaking procedures.The Supreme Court held that the borrowers lacked Article III standing, having failed to establish that any injury they suffer from not having their loans forgiven is fairly traceable to the Plan.The Department also claims authority to forgive loans under the Higher Education Act (HEA), 20 U.S.C. 1082(a)(6). The borrowers cannot show that their purported injury of not receiving HEA loan relief is fairly traceable to the Department’s decision to grant relief under the HEROES Act. They are not claiming that they are injured by not being sufficiently included among the Plan’s beneficiaries but argue the Plan is unlawful and instead seek HEA debt forgiveness. The Department’s authority to grant HEA loan relief is not affected by whether the Plan is lawful. Any incidental effect of the Plan on the likelihood that the Department will undertake loan forgiveness under a different statute is too speculative to show that the absence of HEA-based loan forgiveness is fairly traceable to the Plan. View "Department of Education v. Brown" on Justia Law