Justia U.S. Supreme Court Opinion Summaries

An immigration statute, 8 U.S.C. 1229b(a), authorized the Attorney General to cancel the removal of an alien from the United States who, among other things, has held the status of a lawful permanent resident (LPR) for at least five years, and has lived in the United States for at least seven continuous years after a lawful admission. Respondents both sought to impute their parents' years of continuous residence or LPR status to themselves. At issue was whether the Board of Immigration Appeals (BIA) could reasonably conclude that an alien living in this country as a child must meet those requirements on his own, without counting a parent's years of residence or immigration status. The Court held that the BIA's approach was based on a permissible construction of the statute under Chevron U.S.A. Inc. v. Natural Resources Defense Council, Inc. View "Holder v. Gutierrez; Holder v. Sawyers" on Justia Law

Respondent gave birth to twins conceived through in vitro fertilization using her deceased husband's frozen sperm. Respondent applied for Social Security survivors benefits for the twins, relying on 42 U.S.C. 416(e) of the Social Security Act, which defined child to mean, inter alia, "the child or legally adopted child of an [insured] individual." The Social Security Administration (SSA), however, identified subsequent provisions of the Act, sections 416(h)(2) and (h)(3)(C), as critical, and read them to entitle biological children to benefits only if they qualified for inheritance from the decedent under state intestacy law, or satisfied one of the statutory alternatives to that requirement. The Court concluded that the SSA's reading was better attuned to the statute's text and its design to benefit primarily those supported by the deceased wage earner in his or her lifetime. And even if the SSA's longstanding interpretation was not the only reasonable one, it was at least a permissible construction that garnered the Court's respect under Chevron U.S.A. Inc. v. Natural Resources Defense Council, Inc. View "Astrue v. Capato" 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

In 1987, petitioner was convicted of murder and other crimes by a Colorado court and sentenced to life imprisonment. Petitioner filed a federal habeas petition in 2008. After receiving the petition, the district court asked the State if it planned to argue that the petition was untimely. In response, the State twice informed the district court that it would "not challenge, but [was] not conceding," the timeliness of the petition. Thereafter, the district court ordered the parties to brief both the merits and the timeliness of the petition. At issue was the authority of a federal court to raise, on its own motion, a statute of limitations defense to a habeas corpus petition. The Court held that courts of appeal, like district courts, have the authority - though not the obligation - to raise a forfeited timeliness defense on their own initiative in exceptional cases. The Tenth Circuit abused its discretion when it dismissed the petition as untimely. In the district court, the State was well aware of the statute of limitations defense available to it, and of the arguments that could be made in support of that defense. Yet, the State twice informed the district court that it would "challenge" the timeliness of the petition. In doing so, the State deliberately waived the statute of limitations defense. In light of that waiver, the Tenth Circuit should have followed the district court's lead and decided the merits of the petition. Accordingly, the Court reversed and remanded. View "Wood v. Milyard" on Justia Law

In 1995, respondent filed a patent application covering 117 claims under the Patent Act of 1952, 35 U.S.C. 112. The patent examiner denied all of the claims for lack of an adequate written description. Respondent appealed to the Board of Patent Appeals and Interferences, pursuant to section 134 of the Act, which approved some claims but denied others. Pursuant to section 145 of the Act, respondent filed a civil action against the Director, but the district court declined to consider respondent's newly proffered written declaration in support of the adequacy of his description, thus limiting its review to the administrative record. On appeal, the Federal Circuit vacated the judgment. The Court held that there are no limitations on a patent applicant's ability to introduce new evidence in a section 145 proceeding beyond those already present in the Federal Rules of Evidence and the Federal Rules of Civil Procedure. If new evidence was presented on a disputed question of fact, the district court must make de novo factual findings that take account of both the new evidence and the administrative record before the Patent and Trade Office. Therefore, the Court affirmed the judgment of the Federal Circuit. View "Kappos v. Hyatt" 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

Once the FDA has approved a brand manufacturer's drug, another company could seek permission to market a generic version pursuant to legislation known as the Hatch-Waxman Amendments. See Drug Price Competition and Patent Term Restoration Act of 1984, 98 Stat. 1585. The relevant statute at issue in this case provided that a generic company "may assert a counterclaim seeking an order requiring the [brand manufacturer] to correct or delete the patent information [it] submitted... under [two statutory subsections] on the ground that the patent does not claim... an approved method of using the drug." 117 Stat. 2452, 21 U.S.C. 355(j)(5)(C)(ii)(I). At issue in this case was whether Congress had authorized a generic company to challenge a use code's accuracy by bringing a counterclaim against the brand manufacturer in a patent infringement suit. The Court held that a generic manufacturer could employ this provision to force correction of a use code that inaccurately described the brand's patent as covering a particular method of using the drug in question. Therefore, the Court reversed the judgment of the Federal Circuit. View "Caraco Pharmaceutical Laboratories, Ltd. v. Novo Nordisk A/S" on Justia Law

Respondent, a firefighter employed by the City of Rialto, brought an action under 42 U.S.C. 1983 against the City, the Fire Department, the private attorney hired by the City, and other individuals. The district court granted summary judgment to the individual defendants based on qualified immunity. The Ninth Circuit concluded that the attorney the City hired was not entitled to seek qualified immunity because he was a private attorney, not a City employee. At issue before the Court was whether an individual hired by the government to do its work was prohibited from seeking qualified immunity, solely because he worked for the government on something other than a permanent full-time basis. The Court held that a private individual temporarily retained by the government to carry out its work was entitled to seek qualified immunity from suit under section 1983. Therefore, the Court reversed the judgment of the Ninth Circuit. View "Filarsky v. Delia" on Justia Law

Respondent, the chief investigator for a district attorney's office, testified at grand jury proceedings that resulted in petitioner's indictment. After the indictments were dismissed, petitioner brought an action under 42 U.S.C. 1983, alleging that respondent had conspired to present and did present false testimony to the grand jury. The district court denied respondent's motion to dismiss on immunity grounds, but the Eleventh Circuit reversed, holding that respondent had absolute immunity from a section 1983 claim based on his grand jury testimony. The Court affirmed and held that a witness in a grand jury proceeding was entitled to the same absolute immunity from suit under section 1983 as a witness who testified at trial. View "Rehberg v. Paulk" on Justia Law