Justia U.S. Supreme Court Opinion Summaries

Petitioner filed suit, alleging that his employer, the Maryland Court of Appeals, an instrumentality of the State, violated the Family and Medical Leave Act of 1993 (FMLA), 29 U.S.C. 2612(a)(1). The provision at issue required employers, including state employers, to grant unpaid leave for self care for a serious medical condition, provided other statutory requisites were met, particularly requirements that the total amount of annual leave taken under all the FMLA's provisions did not exceed a stated maximum. The Court held that suits against States under the self-care provision, section 2612(a)(1), were barred by the States' immunity as sovereigns in the federal system. Therefore, the Court affirmed the judgment of the Fourth Circuit. View "Coleman v. Court of Appeals of Md." on Justia Law

The patent claims at issue covered processes that help doctors who use thiopurine drugs to treat patients with autoimmune diseases determine whether a given dosage level was too low or too high. The claims purported to apply natural laws describing the relationships between the concentration in the blood of certain thiopurine metabolites and the likelihood that the drug dosage would be ineffective or induce harmful side-effects. At issue was whether the claimed processes have transformed these unpatentable natural laws into patent-eligible applications of those laws. The Court concluded that they have not done so and that therefore the processes were not patentable. The steps in the claimed processes involved well-understood, routine, conventional activity previously engaged in by researchers in the field. At the same time, upholding the patents would risk disproportionately tying up the use of the underlying natural laws, inhibiting their use in the making of further discoveries. Therefore, the Court reversed the judgment of the Federal Circuit. View "Mayo Collaborative Services v. Prometheus Laboratories, Inc." 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

Respondent was convicted of capital murder and subsequently commenced federal habeas proceedings by filing a request for appointment of counsel under 18 U.S.C. 3599. Section 3599(e) contemplated that appointed counsel could be "replaced . . . upon motion of the defendant," but did not specify the standard that district courts should use in evaluating those motions. The Court held that courts should employ the same "interests of justice" standard that they apply in non-capital cases under a related statute, 18 U.S.C. 3006A. The Court also held that the district court here did not abuse its discretion in denying respondent's motion to change counsel. View "Martel v. Clair" 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

The Court granted certiorari in these cases to decide whether Medicaid providers and recipients could maintain a cause of action under the Supremacy Clause to enforce a federal Medicaid law. Since the Court granted certiorari, however, the relevant circumstances have changed. The federal agency in charge of administering Medicaid, CMS, approved the state statutes as consistent with the federal law. In light of the changed circumstances, the Court believed that the question before it was whether, once the agency approved the state statutes, groups of Medicaid providers and beneficiaries could still maintain a Supremacy Clause action asserting that the state statutes were inconsistent with the federal Medicaid law. Given the present posture of the cases, the Court did not address whether the Ninth Circuit properly recognized a Supremacy Clause action to enforce the federal law before the agency took final action. To decide whether these cases could proceed under the Supremacy Clause now that the agency has acted, it would be necessary on remand to consider at least the matters addressed by the Court. Accordingly, the Court vacated the judgment and remanded for further proceedings. View "Douglas v. Independent Living Center of Southern Cal., Inc." on Justia Law

Respondents filed an action under 42 U.S.C. 1983 against petitioners, police officers, alleging that the officers had subjected them to an unreasonable search in violation of the Fourth Amendment. The district court granted summary judgment to respondents and the Ninth Circuit affirmed the denial of qualified immunity. The Court held, however, that the officers were entitled to qualified immunity. The Court concluded that the case did not fall within the narrow exception to allowing suit where it would not be entirely unreasonable for an officer to believe that there was probable cause to search for all firearms and firearm-related materials. Regarding the warrant's authorization to search for gang-related materials, a reasonable officer could view Jerry Ray Bowen's attack as motivated not by the souring of his romantic relationship with Shelly Kelly but by a desire to prevent her from disclosing details of his gang activity to the police. The fact that the officers sought and obtained approval of the warrant application from a superior and a deputy district attorney before submitting it to the magistrate provided further support for the conclusion than an officer could reasonably have believed that the scope of the warrant was supported by probable cause. In holding that the warrant in this case was so obviously defective that no reasonable officer could have believed it to be valid, the court below erred in relying on Groh v. Ramirez. Accordingly, the judgment was reversed. View "Messerschmidt, et al. v. Millender, et al." 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

Respondent, a prison inmate, sought to suppress his confession under Miranda v. Arizona after he was subjected to custodial interrogation when he was escorted from his prison cell by a corrections officer to a conference room where he was questioned by two sheriff's deputies about criminal activity he had allegedly engaged in before coming to prison. The Sixth Circuit subsequently held that precedent clearly established that a prisoner was in custody within the meaning of Miranda if the prisoner was taken aside and questioned about events that occurred outside the prison walls. The Court's decision, however, did not clearly establish such a rule, and therefore the Court of Appeals erred in holding that this rule provided a permissible basis for federal habeas relief under the relevant provision of the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA), 28 U.S.C. 2254(d)(1). The rule applied by the lower court did not represent a correct interpretation of the Court's Miranda law. Therefore, taking into account all of the circumstances of the questioning - including especially the undisputed fact that respondent was told he was free to end the questioning and to return to his cell - the Court held that respondent was not in custody within the meaning of Miranda. View "Howes v. Fields" on Justia Law

Petitioners, natives and citizens of Japan who have been lawful permanent residents of the United States since 1984, appealed a removal order after husband pleaded guilty to one count of willfully making and subscribing a false tax return in violation of 26 U.S.C. 7206(1) and wife pleaded guilty to one count of aiding and assisting in the preparation of a false tax return in violation of 26 U.S.C. 7206(2). At issue was whether aliens who commit certain federal tax crimes were subject to deportation as aliens who have been convicted of an aggravated felony. The Court held that violations of section 7206(1) and (2) were crimes "involv[ing] fraud or deceit" under 8 U.S.C. 1101(a)(43)(M)(i) and were therefore aggravated felonies as that term was defined in the Immigration and Nationality Act, 8 U.S.C. 1101 et seq., when the loss to the Government exceeded $10,000. Because petitioners were subject to deportation as aliens who have been convicted of aggravated felonies, the Court affirmed the judgment of the Court of Appeals. View "Kawashima v. Holder" on Justia Law