Justia U.S. Supreme Court Opinion Summaries

The Agricultural Marketing Agreement Act of 1937 (AMAA), enacted to stabilize prices for agricultural commodities, regulate “handlers,” defined as “processors, associations of producers, and others engaged in the handling” of covered agricultural commodities, 7 U.S.C. 608c(1). The California Raisin Marketing Order, promulgated under the AMAA, established a Raisin Administrative Committee, which recommends annual reserve pools of raisins not to be sold on the open domestic market and requires handlers to pay assessments to help cover administrative costs. The petitioners, raisin producers, refused to surrender requisite portions of raisins to the reserve. The USDA began administrative proceedings. An ALJ found that petitioners were handlers and had violated the AMAA and the Order, and rejected a takings defense. The district court entered summary judgment for the USDA. The Ninth Circuit affirmed. A unanimous Supreme Court reversed, holding that the Ninth Circuit had jurisdiction to decide the takings claim. Petitioners argued that they were producers, not subject to the AMAA or the Order, but the USDA and the district court concluded that they were handlers. Fines and penalties were levied on them in that capacity. Their takings claim, therefore, was necessarily raised in that capacity. The Ninth Circuit confused a statutory argument that they were producers with a constitutional argument that, if they were handlers, their fine violated the Fifth Amendment. The claim was ripe. The petitioners were subject to a final agency order; because the AMAA provides a comprehensive remedial scheme that withdraws Tucker Act jurisdiction over a handler’s takings claim, there is no alternative remedy. View "Horne v. Department of Agriculture" on Justia Law

The Clean Water Act requires that National Pollutant Discharge Elimination System (NPDES) permits be secured before pollutants are discharged from any point source into navigable waters of the United States, 33 U. S. C. 1311(a), 1362(12). An Environmental Protection Agency implementing regulation, the Silvicultural Rule, specifies which types of logging-related discharges are point sources, requiring NPDES permits unless some other provision exempts them. One exemption covers “discharges composed entirely of stormwater,” 33 U. S. C. 1342(p)(1), unless the discharge is “associated with industrial activity.” Under the EPA’s Industrial Stormwater Rule, the term “associated with industrial activity” covers only discharges “from any conveyance that is used for collecting and conveying storm water and that is directly related to manufacturing, processing or raw materials storage areas at an industrial plant.” A final version of a recent amendment to the Industrial Stormwater Rule clarifies that the NPDES permit requirement applies only to logging operations involving rock crushing, gravel washing, log sorting, and log storage facilities, which are all listed in the Silvicultural Rule. Georgia-Pacific has a contract to harvest timber from an Oregon forest. When it rains, water runs off its logging roads into ditches that discharge the water into rivers and streams, often with sediment, which may be harmful to fish and other aquatic organisms. NEDC sued Georgia-Pacific and state and local governments. The district court dismissed, concluding that NPDES permits were not required because the ditches were not point sources of pollution under the CWA and the Silvicultural Rule. The Ninth Circuit reversed. The Supreme Court reversed, first holding that section1369(b), did not bar the district court from hearing a citizen suit against an alleged violator and seeking to enforce an obligation imposed by the CWA. The recent amendment to the Industrial Stormwater Rule did not make the case moot. Past discharges might be the basis for penalties even if, in the future, those discharges will not require a permit. The pre-amendment Rule, as construed by the EPA, exempted discharges of channeled stormwater runoff from logging roads from the NPDES requirement. The regulation is a reasonable interpretation of the statutory term “associated with industrial activity;” it was reasonable for the EPA to conclude that the conveyances at issue are “directly related” only to harvesting raw materials, rather than to “manufacturing, processing, or raw materials storage areas at an industrial plant.” The EPA has been consistent in its view that the types of discharges at issue do not require NPDES permits. View "Decker v. Nw Envtl Def. Ctr." on Justia Law

Arkansas Game and Fish Commission owns and manages the Donaldson Black River Wildlife Management Area, 23,000 acres with multiple hardwood species and used for recreation and hunting. In 1948, the U.S. Army Corps of Engineers constructed Clearwater Dam upstream from the Area and adopted the Water Control Manual, setting seasonally varying rates for release of water from the Dam. From 1993-2000, the Corps, at the request of farmers, authorized deviations from the Manual that extended flooding into peak timber growing season. The Commission objected that deviations adversely impacted the Area, and opposed a proposal to make deviations part of the permanent water-release plan. After testing, the Corps abandoned the proposed Manual revision and ceased temporary deviations. The Commission sued, alleging that the deviations caused sustained flooding during growing season and that the cumulative impact of the flooding caused destruction of Area timber and substantial change in the terrain, necessitating costly reclamation. The Claims Court judgment ($5,778,757) in favor of the Commission was reversed by the Federal Circuit, which held that government-induced flooding can support a taking claim only if “permanent or inevitably recurring.” The Supreme Court reversed and remanded. Government-induced flooding of limited duration may be compensable. There is no blanket temporary-flooding exception to Takings Clause jurisprudence and no reason to treat flooding differently than other government intrusions. While the public interests are important, they are not categorically different from interests at stake in other takings cases. When regulation or temporary physical invasion by government interferes with private property, time is a factor in determining the existence of a compensable taking, as are the degree to which the invasion is intended or the foreseeable result of authorized government action, the character of the land, the owner’s “reasonable investment-backed expectations,” and the severity of the interference. View "AR Game & Fish Comm'n v. United States" on Justia Law

Petitioner requested that the Secretary of the Interior take into trust on its behalf a tract of land known as the Bradley Property, which petitioner intended to use "for gaming purposes." The Secretary took title to the property and respondent subsequently filed suit under the Administrative Procedures Act (APA), 5 U.S.C. 500 et seq., asserting that the Indian Reorganization Act (IRA), 25 U.S.C. 465, did not authorize the Secretary to acquire the property because petitioner was not a federally recognized tribe when the IRA was enacted in 1934. At issue was whether the United States had sovereign immunity from the suit by virtue of the Quiet Title Act (QTA), 86 Stat. 1176, and whether respondent had prudential standing to challenge the Secretary's acquisition. The Court held that the United States had waived its sovereign immunity from respondent's action under the QTA. The Court also held that respondent had prudential standing to challenge the Secretary's acquisition where respondent's interests came within section 465's regulatory ambit. View "Match-E-Be-Nash-She-Wish Band of Pottawatomi Indians v. Patchak" on Justia Law

An Indiana statute, the "Barrett Law," Ind. Code 36-9-15(b)(3), authorized Indiana's cities to impose upon benefited owners the cost of sewer improvement projects. The Law also permitted those lot owners to pay either immediately in the form of a lump sum or over time in installments. In 2005, the city of Indianapolis adopted a new assessment and payment method, the "STEP" plan, and it forgave any Barrett Law installments that lot owners had not yet paid. A group of lot owners who had already paid their entire Barrett Law assessment in a lump sum believed that the City should have provided them with equivalent refunds. At issue was whether the City's refusal to do so unconstitutionally discriminated against them in violation of the Equal Protection Clause, Amdt. 14, section 1. The Court held that the City had a rational basis for distinguishing between those lot owners who had already paid their share of project costs and those who had not. Therefore, the Court concluded that there was no equal protection violation. View "Armour v. Indianapolis" on Justia Law

A provision of the Real Estate Settlement Procedures Act (RESPA), 12 U.S.C. 2607(b), prohibited giving and accepting "any portion, split, or percentage of any charge made or received for the rendering of a real estate settlement service... other than for services actually performed." Petitioners, three couples who obtained mortgage loans from respondent, filed separate state-court actions, alleging that respondent had violated section 2607(b) by charging them fees for which no services were provided in return. At issue was whether, to establish a violation of section 2607(b), a plaintiff must demonstrate that a charge was divided between two or more persons. The Court held that, in order to establish a violation of section 2607(b), a plaintiff must demonstrate that a charge for settlement services was divided between two or more persons. Because petitioners did not contend that respondent split the challenged charges with anyone else, summary judgment was properly granted in favor of respondent. Therefore, the Court affirmed the judgment of the Court of Appeals. View "Freeman, et al. v. Quicken Loans, Inc." on Justia Law

This case arose when petitioners filed for Chapter 12 bankruptcy and then sold their farm. Under Chapter 12 of the Bankruptcy Code, farmer debtors could treat certain claims owed to a governmental unit resulting from the disposition of farm assets as dischargeable, unsecured liabilities. 11 U.S.C. 1222(a). The Court held that federal income tax liability resulting from petitioners' post-petition farm sale was not "incurred by the estate" under 11 U.S.C. 503(b) of the Bankruptcy Code and thus was neither collectible nor dischargeable in the Chapter 12 plan. Therefore, the Court affirmed the judgment of the Ninth Circuit. View "Hall v. United States" on Justia Law

Ordinarily, the Government must assess a deficiency against a taxpayer within "3 years after the return was filed." 26 U.S.C. 6501(a). The 3-year period was extended to 6 years, however, when a taxpayer "omits from gross income an amount properly includible therein which is in excess of 25 percent of the amount of gross income stated in the return." Section 6501(e)(1)(A). At issue was whether this latter provision applied when the taxpayer overstated his basis in property that he has sold, thereby understating the gain that he received from the sale. Following Colony, Inc. v. Commissioner, the Court held that the provision did not apply to an overstatement of basis. Therefore, the 6-year period did not apply. Accordingly, the Court affirmed the judgment of the Fourth Circuit. View "United States v. Home Concrete & Supply, LLC" on Justia Law

This case concerned three rivers which flow through Montana and then beyond its borders. At issue was whether discrete, identifiable segments of these rivers in Montana were nonnavigable, as federal law defined that concept for purposes of determining whether the State acquired title to the riverbeds underlying those segments, when the State entered the Union in 1989. Montana contended that the rivers must be found navigable at the disputed locations. The Court held that the Montana Supreme Court's ruling that Montana owned and could charge for use of the riverbeds at issue was based on an infirm legal understanding of the Court's rules of navigability for title under the equal-footing doctrine. The Montana Supreme Court erred in its treatment of the question of river segments and portage and erred as a matter of law in relying on evidence of present-day primarily recreational use of the Madison River. Because this analysis was sufficient to require reversal, the Court declined to decide whether the State Supreme Court also erred as to the burden of proof regarding navigability. Montana's suggestion that denying the State title to the disputed riverbeds would undermine the public trust doctrine underscored its misapprehension of the equal-footing and public trust doctrines. Finally, the reliance by petitioner and its predecessors in title on the State's long failure to assert title to the riverbeds was some evidence supporting the conclusion that the river segments over those beds were nonnavigable for purposes of the equal-footing doctrine. Accordingly, the judgment was reversed. View "PPL Montana, LLC v. Montana" on Justia Law

The Jicarilla Apache Nation's ("Tribe") reservation contained natural resources that were developed pursuant to statutes administered by the Interior Department and proceeds from these resources were held by the United States in trust for the Tribe. The Tribe filed a breach-of-trust action in the Court of Federal Claims ("CFC") seeking monetary damages for the Government's alleged mismanagement of the Tribe's trust funds in violation of 25 U.S.C. 161-162a and other laws. During discovery, the Tribe moved to compel production of certain documents and the Government agreed to the release of some documents but asserted that others were protected by, inter alia, the attorney-client privilege. At issue was whether the fiduciary exception to the attorney-client privilege applied to the general trust relationship between the United States and Indian tribes. The Court held that the fiduciary exception did not apply where the trust obligations of the United States to the Indian tribes were established and governed by statute rather than the common law and, in fulfilling its statutory duties, the Government acted not as a private trustee but pursuant to its sovereign interest in the execution of federal law. The reasons for the fiduciary exception, that the trustee had no independent interest in trust administration, and that the trustee was subject to a general common-law duty of disclosure, did not apply in this context. Accordingly, the Court reversed and remanded for further proceedings. View "United States v. Jicarilla Apache Nation" on Justia Law