Justia U.S. Supreme Court Opinion Summaries

Nigerian nationals, having been granted asylum in the U.S., filed suit under the Alien Tort Statute (ATS), alleging that Dutch, British, and Nigerian corporations aided and abetted the Nigerian Government in committing violations of the law of nations in Nigeria. The complaint alleges that in the 1990s Nigerian government forces attacked villages, beating, raping, killing, and arresting residents and destroying or looting property and that the corporations provided food, transportation, compensation, and a staging ground. The ATS provides that “district courts shall have original jurisdiction of any civil action by an alien for a tort only, committed in violation of the law of nations or a treaty of the United States,” 28 U. S. C. 1350. On interlocutory appeal, the Second Circuit dismissed, holding that the law of nations does not recognize corporate liability. The Supreme Court affirmed. The presumption against extraterritoriality applies to ATS claims. The danger of unwarranted judicial interference in foreign policy is magnified where the question is not what Congress has done but what courts may do. Nothing in the ATS indicates extraterritorial reach. Violations of the law of nations affecting aliens can occur either within or outside the United States. The question is whether the court has authority to recognize a cause of action under U. S. law to enforce a norm of international law. There is no indication that Congress expected causes of action to be brought under the statute for violations of the law of nations occurring abroad. View "Kiobel v. Royal Dutch Petroleum Co." on Justia Law

The Federal Tort Claims Act (FTCA) waives the government’s sovereign immunity from tort suits, but excepts from that waiver certain intentional torts, 28 U. S. C. 2680(h). Section 2680(h) contains a proviso that extends the waiver of immunity to claims for six intentional torts, including assault and battery, that are based on the “acts or omissions” of an “investigative or law enforcement officer” “who is empowered by law to execute searches, to seize evidence, or to make arrests.” A federal prisoner, sued the United States under the FTCA, alleging assault and battery by correctional officers. The district court granted the government summary judgment; the Third Circuit affirmed, reasoning that the “law enforcement proviso” applies only to tortious conduct that occurs during the course of executing a search, seizing evidence, or making an arrest. The Supreme Court reversed. The law enforcement proviso extends to law enforcement officers’ acts or omissions that arise within the scope of employment, regardless of whether the officers are engaged in investigative or law enforcement activity, or are executing a search, seizing evidence, or making an arrest. Congress intended immunity determinations to depend on a federal officer’s legal authority, not on a particular exercise of that authority. Nor does the proviso indicate that a waiver of immunity requires the officer to be engaged in investigative or law enforcement activity. View "Millbrook v. United States" on Justia Law

The Medicaid statute’s anti-lien provision, 42 U. S. C. 1396p(a)(1), pre-empts state efforts to take any portion of a tort judgment or settlement not “designated as payments for medical care.” A North Carolina statute requires that up to one-third of damages recovered by a beneficiary for a tortious injury be paid to the state to reimburse it for payments made for medical treatment on account of the injury. E. M. A. suffered serious birth injuries that require her to receive 12 to 18 hours of skilled nursing care per day and that will prevent her from working or living independently. North Carolina’s Medicaid program pays part of the cost of her ongoing care. E. M. A. and her parents filed a medical malpractice suit against the physician who delivered her and the hospital where she was born and settled for $2.8 million, due to insurance policy limits. The settlement did not allocate money among medical and nonmedical claims. The state court placed one-third of the recovery into escrow pending a judicial determination of the amount owed by E. M. A. to the state. While that litigation was pending, the North Carolina Supreme Court held in another case that the irrebuttable statutory one-third presumption was a reasonable method for determining the amount due the state for medical expenses. The federal district court, in E.M.A.’s case, agreed. The Fourth Circuit vacated. The Supreme Court affirmed. The federal anti-lien provision pre-empts North Carolina’s irrebuttable statutory presumption that one-third of a tort recovery is attributable to medical expenses. North Carolina’s irrebuttable, one-size-fits-all statutory presumption is incompatible with the Medicaid Act’s clear mandate View "Wos v. E. M. A." on Justia Law

The Federal Tort Claims Act waives sovereign immunity from tort suits, 28 U. S. C. 1346(b)(1), except for certain intentional torts, including battery; it originally afforded tort victims a remedy against the government, but did not preclude suit against the alleged tort-feasor. Agency-specific statutes postdating the FTCA immunized certain federal employees from personal liability for torts committed in the course of official duties. The Gonzalez Act makes the FTCA remedy against the U.S. preclusive of suit against armed forces medical personnel, 10 U. S. C. 1089(a), and provides that, “[f]or purposes of this section,” the FTCA intentional tort exception “shall not apply to any cause of action arising out of a negligent or wrongful act or omission in the performance of medical ... functions.” Congress subsequently enacted the Federal Employees Liability Reform and Tort Compensation Act, which makes the FTCA remedy against the government exclusive for torts committed by federal employees acting within the scope of their employment, 28 U. S. C. 2679(b)(1); federal employees are shielded without regard to agency or line of work. Levin, injured as a result of surgery performed at a U. S. Naval Hospital, sued the government and the surgeon, asserting battery, based on his alleged withdrawal of consent shortly before the surgery. Finding that the surgeon had acted within the scope of his employment, the district court released him and dismissed the battery claim. Affirming, the Ninth Circuit concluded that the Gonzalez Act served only to buttress the personal immunity granted military medical personnel and did not negate the FTCA intentional tort exception. The Supreme Court reversed and remanded. The Gonzalez Act section 1089(e) abrogates the FTCA intentional tort exception, allowing Levin’s suit against the U.S. alleging medical battery by a Navy doctor acting within the scope of employment. The operative clause states, “in no uncertain terms,” that the FTCA intentional tort exception “shall not apply,” and confines the abrogation to medical personnel employed by listed agencies. View "Levin v. United States" on Justia Law

This case arose from a personal injury action brought by petitioner, a professional baseball player in Japan, against respondent, the owner of a resort in the Northern Mariana Islands. The costs that could be awarded to prevailing parties in lawsuits brought in federal court were set forth in 28 U.S.C. 1920. The Court Interpreters Act amended that statute to include "compensation of interpreters." At issue was whether "compensation of interpreters" covered the cost of translating documents. Because the ordinary meaning of the word "interpreter" was a person who translated orally from one language to another, the Court held that "compensation of interpreters" was limited to the cost of oral translation and did not include the cost of document translation. View "Taniguchi v. Kan Pacific Saipan, Ltd." on Justia Law

Petitioners sued the Palestinian Authority and the Palestinian Liberation Organization under the Torture Victim Protection Act of 1991 (TVPA), which authorized a cause of action against "[a]n individual" for acts of torture and extrajudicial killing committed under authority or color of law of any foreign nation. The district court dismissed the suit, concluding that the TVPA's authorization of suit against "[a]n individual" extended liability only to natural persons. The United States Court of Appeals for the District of Columbia affirmed. The Court held that, as used in the TVPA, the term "individual" encompassed only natural persons. Consequently, the TVPA did not impose liability against organizations. Therefore, the Court affirmed the judgment of the lower courts. View "Mohamad v. Palestinian Authority" on Justia Law

Claiming that the FAA, DOT, and SSA violated the Privacy Act of 1974, 5 U.S.C. 552a(g)(4)(A), by sharing his records with one another, respondent filed suit alleging that the unlawful disclosure to the DOT of his confidential medical information, including his HIV status, had caused him "humiliation, embarrassment, mental anguish, fear of social ostracism, and other severe emotional distress." The District Court granted summary judgment against respondent, concluding that respondent could not recover damages because he alleged only mental and emotional harm, not economic loss. Reversing the District Court, the Ninth Circuit concluded that "actual damages" in the Act was not ambiguous and included damages for mental and emotional distress. Applying traditional rules of construction, the Court held that the Act did not unequivocally authorize an award of damages for mental or emotional distress. Accordingly, the Act did not waive the Government's sovereign immunity from liability for such harms. Therefore, the Court reversed the judgment of the Ninth Circuit and remanded for further proceedings. View "FAA v. Cooper" on Justia Law

Petitioner was injured at an Alaska marine terminal while working for respondents and subsequently filed a claim against respondents under the Longshore and Harbor Workers' Compensation Act, 33 U.S.C. 901 et seq. The Act capped benefits for most types of disability at twice the national average weekly wage for the fiscal year in which an injured employee was "newly awarded compensation." The Court held that an employee was "newly awarded compensation" when he first became disabled and thereby became statutorily entitled to benefits, no matter whether, or when, a compensation order issued on his behalf. Therefore, the Court affirmed the judgment of the Ninth Circuit. View "Roberts v. Sea-Land Services, Inc." on Justia Law

George Corson and his wife sued respondents, claiming injury from Corson's exposure to asbestos in locomotives and locomotive parts distributed by respondents. The Corsons alleged state-law claims of defective design and failure to warn of the dangers posed by asbestos. After Corson died, his wife was substituted as a party. Respondents removed the case to the Federal District Court, which granted respondents summary judgment, ruling that the state-law claims were pre-empted by the Locomotive Inspection Act (LIA), 49 U.S.C. 20701, et seq. The Third Circuit affirmed. The Court held that petitioners' state-law design-defect and failure-to-warn claims fell within the field of locomotive equipment regulation pre-empted by the LIA, as that field was defined in Napier v. Atlantic Coast Line. R. Co. Accordingly, the judgment of the Court of Appeals was affirmed. View "Kurns, et al. v. Railroad Friction Products Corp., et al." on Justia Law

Respondent sought damages from employees at a privately run federal prison in California, claiming that they had deprived him of adequate medical care in violation of the Eighth Amendment's prohibition against cruel and unusual punishment. At issue was whether the Court could imply the existence of an Eighth Amendment-based damages action against employees of a privately operated federal prison. Because the Court believed that in the circumstances of this case, state tort law authorized adequate alternative damage actions - actions that provide both significant deterrence and compensation - no Bivens v. Six Unknown Fed. Narcotics Agents remedy could be implied here. View "Minneci v. Pollard" on Justia Law