Justia U.S. Supreme Court Opinion Summaries

Respondent's trial on federal drug and gun charges began 287 days after his arraignment. The Sixth Circuit agreed with the District Court that many of the 287 days were excludable under the lists of exclusions from the 70 day speedy trial period set forth in the Speedy Trial Act of 1974 ("Act"), 18 U.S.C. 3161(c)(1). However, the Sixth Circuit concluded that 9 days, during which three pretrial motions were pending, were not excludable because the motions did not actually cause a delay, or the expectation of delay, at trial. Since these 9 days were sufficient to bring the number of nonexcludable days above 70, the court found a violation of the Act. And given respondent had already served his prison sentence, the Sixth Circuit ordered the indictment dismissed with prejudice. The Court granted certiorari at the Government's request in order to review the Sixth Circuit's motion-by-motion causation test. The Court reversed the Sixth Circuit's determination and held that the Act contained no requirements that the filing of a pretrial motion actually caused, or was expected to cause, delay of a trial. Rather, section 3161(h)(1)(D) stopped the Speedy Trial clock from running automatically upon the filing of a pretrial motion irrespective of whether the motion had any impact on when the trial began. The Sixth Circuit also misinterpreted section 3161(h)(1)(F), which excluded from the 70 day calculation "delay resulting from transportation of any defendant... to and from places of examination... except that any time consumed in excess of ten days... shall be presumed to be unreasonable." Although the Sixth Circuit's interpretations of subparagraphs (D) and (F) were both mistaken, the conclusions the Court drew from its interpretations in relevant part canceled each other out, such that the Court's ultimate conclusion that respondent's trial failed to comply with the Act's deadline was correct.

While preparing to rob a bank, petitioner and others were discovered by a local police officer, whom petitioner killed. Petitioner was convicted of violating the federal witness tampering statute, 18 U.S.C. 1512(a)(1)(C). At issue was how the language of the statute applied when a defendant killed a victim, with an intent to prevent a communication about the commission or possible commission of a federal offense, but to law enforcement officers in general rather than to some specific law enforcement officer or set of officers which defendant had in mind. The Court held that in such circumstances, the Government must establish a section 1512(a)(1)(C) violation by showing there was a reasonable likelihood that a relevant communication would have been made to a federal officer. The Court also held that, because petitioner's argument that the evidence was insufficient to satisfy a "reasonable likelihood" standard was not raised at trial, the lower courts must determine whether, and how, the standard applied in this case.

The Chamber of Commerce of the United States of America and various business and civil rights organizations (collectively, "Chamber") filed a federal preenforcement suit against those charged with administering the Legal Arizona Workers Act, Ariz. Rev. Stat. Ann. 23-211, 212, 212.01, which provided that the licenses of state employers that knowingly or intentionally employed unauthorized aliens could be, and in certain circumstances, must be, suspended or revoked. The law also required that all Arizona employers use E-Verify, an internet-based system employers could use to check the work authorization status of employees. At issue was whether federal immigration law preempted those provisions of Arizona law. The Court held that Arizona's licensing law fell within the confines of the authority Congress chose to leave to the states and therefore, was not expressly preempted where the Immigration Reform and Control Act ("IRCA"), 8 U.S.C. 1324a(h)(2), prohibited states from imposing civil or criminal sanctions on those who employed unauthorized aliens but preserved state authority to impose sanctions through licensing and similar laws. The court also held that Arizona's requirement that employers use E-Verify did not conflict with the federal scheme and in no way obstructed achieving the aims of the federal program.

Nearly a decade ago, petitioners, a state child protective services worker and a county deputy sheriff, interviewed then 9-year-old S.G. at her Oregon elementary school about allegations that her father had sexually abused her. Her father stood trial for that abuse but the jury failed to reach a verdict and the charges were later dismissed. S.G.'s mother subsequently sued petitioners on S.G.'s behalf for damages under 42 U.S.C. 1983, alleging that the in-school interview breached the Fourth Amendment's proscription on unreasonable seizures. The Ninth Circuit held that petitioners' conduct violated the Fourth Amendment but that they were entitled to qualified immunity from damages liability because no clearly established law had warned them of the illegality of the conduct. Although judgment was entered in petitioners' favor, they petitioned the Court to review the Ninth Circuit's ruling that their conduct violated the Fourth Amendment. At issue was whether government officials who prevailed on grounds of qualified immunity could obtain the Court's review of a court of appeals' decision that their conduct violated the Constitution. Also at issue was, if the Court could consider cases in this procedural posture, did the Ninth Circuit correctly determine that this interview breached the Fourth Amendment. The Court held that it could generally review a lower court's constitutional ruling at the behest of a government official granted immunity but could not do so in this case for reasons peculiar to it. The case had become moot because the child had grown up and moved across the country and so would never again be subject to the Oregon in-school interviewing practices whose constitutionality was at issue. Therefore, the Court did not reach the Fourth Amendment question in this case and vacated the part of the Ninth Circuit's opinion that decided the Fourth Amendment issue.

After petitioners fell behind schedule in developing a stealth aircraft (A-12) for the Navy, the contracting officer terminated their $4.8 billion fixed-price contract for default and ordered petitioners to repay approximately $1.35 billion in progress payments for work the Government never accepted. Petitioners filed suit in the Court of Federal Claims ("CFC"), challenging the termination decision under the Contract Disputes Act of 1978, 41 U.S.C. 609(a)(1). The CFC held that, since invocation of the state-secrets privilege obscured too many of the facts relevant to the superior-knowledge defense, the issue of that defense was nonjusticiable, even though petitioners had brought forward enough unprivileged evidence for a prima facie showing. Accordingly, at issue was what remedy was proper when, to protect state secrets, a court dismissed a Government contractor's prima facie valid affirmative defense to the Government's allegations of contractual breach. The Court concluded that it must exercise its common-law authority in this situation to fashion contractual remedies in Government-contracting disputes and held that the proper remedy was to leave the parties where they were on the day they filed suit.

The State appealed a three-judge district court order directing California to remedy two ongoing violations of the Cruel and Unusual Punishments Clause, a guarantee binding on the States by the Due Process Clause of the Fourteenth Amendment, by reducing the prison system population where the violations were the subject of two class actions involving a class of prisoners with serious mental disorders and a class of prisoners with serious medical conditions. At issue was whether the remedial order issued by the three-judge court was consistent with requirements and procedures set forth in a congressional statute, the Prison Litigation Reform Act of 1995 ("PLRA"), 18 U.S.C. 3626. The Court held that the court-mandated population limit was necessary to remedy the violation of prisoners' constitutional rights and was authorized by the PLRA.

Respondent filed an action under the False Claims Act ("FCA"), 31 U.S.C. 3730(e)(4)(A), alleging that his former employer had submitted hundreds of false claims for payment under its federal contracts. At issue was whether a federal agency's written response to a request for records under the Freedom of Information Act ("FOIA"), 5 U.S.C. 552, constituted a "report" within the meaning of the public disclosure bar. The Court held that a federal agency's written response to a FOIA request for records constituted a "report" within the meaning of the FCA's public disclosure bar where a "report," in this context, carried its ordinary meaning; where the Labor Department's three written responses in this case, along with the accompanying records produced to respondent's wife, were "reports" within the public disclosure bar's ordinary meaning; where the Court was not persuaded by assertions that it would be anomalous to read the public disclosure bar to encompass written FOIA responses; and whether respondent's suit was "based upon... allegations or transactions" disclosed in the reports at issue was a question to be resolved on remand.

Respondent entered a conditional guilty plea to charges of trafficking in marijuana, first-degree trafficking in a controlled substance, and second-degree persistent felony offender status and appealed the denial of his motion to suppress evidence from a warrantless search. At issue was whether the exigent circumstances rule applied when police officers, by knocking on the door of a residence and announcing their presence, caused the occupants to attempt to destroy evidence. The Court held that the exigent circumstances rule applied when the police did not create the exigency by engaging or threatening to engage in conduct that violated the Fourth Amendment. The Court also held that, assuming than an exigency existed in this case, there was no evidence that the officers either violated the Fourth Amendment or threatened to do so prior to the point when they entered the apartment. Therefore, the Court reversed and remanded for further proceedings.

Respondents, on behalf of beneficiaries of the CIGNA Corporation's ("CIGNA") Pension Plan, challenged the new plan's adoption, claiming that CIGNA's notice of the changes was improper, particularly because the new plan in certain respects provided them with less generous benefits. At issue was whether the district court applied the correct legal standard, namely, a "likely harm" standard, in determining that CIGNA's notice violations caused its employees sufficient injury to warrant legal relief. The Court held that although section 502(a)(1)(B) of the Employee Retirement Income Security Act of 1974 ("ERISA"), 29 U.S.C. 1022(a), 1024(b), 1054(h), did not give the district court authority to reform CIGNA's plan, relief was authorized by section 502(a)(3), which allowed a participant, beneficiary, or fiduciary "to obtain other appropriate relief" to redress violations of ERISA "or the [plan's] terms." The Court also held that, because section 502(a)(3) authorized "appropriate equitable relief" for violations of ERISA, the relevant standard of harm would depend on the equitable theory by which the district court provided relief. Therefore, the Court vacated and remanded for further proceedings.

Montana alleged that Wyoming breached Article V(A) of the Yellowstone River Compact ("Compact"), 65 Stat. 666, by allowing its pre-1950 water appropriators to increase their net water consumption by improving the efficiency of their irrigation systems where the new systems employed sprinklers that reduced the amount of wastewater returned to the river, thus depriving Montana's downstream pre-1950 appropriators of water to which they were entitled. At issue was whether Article V(A) allowed Wyoming's pre-1950's water users, diverting the same quantity of water for the same irrigation purpose and acreage as before 1950, to increase their consumption of water by improving their irrigation systems even if it reduced the flow of water to Montana's pre-1950 users. The Court held that Montana's increased-efficiency allegation failed to state a claim for breach of the Compact under Article V(A) where Article V(A) incorporated the ordinary doctrine of appropriation without significant qualification and where, in Wyoming and Montana, that doctrine allowed appropriators to improve their irrigation systems, even to the detriment of downstream appropriators.