Justia U.S. Supreme Court Opinion Summaries

Respondents filed a complaint against AT&T Mobility LLC ("AT&T"), which was later consolidated with a putative class action, alleging that AT&T had engaged in false advertising and fraud by charging sales tax on phones it advertised as free. AT&T moved to compel arbitration under the terms of its contract with respondents and respondents opposed the motion contending that the arbitration agreement was unconscionable and unlawfully exculpatory under California law because it disallowed classwide procedures. The district court denied AT&T's motion in light of Discover Bank v. Superior Court and the Ninth Circuit affirmed. At issue was whether the Federal Arbitration Act ("FAA"), 9 U.S.C. 2, prohibited states from conditioning the enforceability of certain arbitration agreements on the availability of classwide arbitration procedures. The Court held that, because it "stands as an obstacle to the accomplishment and execution of the full purposes and objectives of Congress," quoting Hines v. Davidowitz, California's Discover Bank rule was preempted by the FAA. Therefore, the Court reversed the Ninth Circuit's ruling and remanded for further proceedings consistent with the opinion.

Respondent filed suit in Federal District Court against federal officials who managed tribal assets held in trust by the Federal Government alleging violations of fiduciary duty and requesting equitable relief. The next day after filing the suit, respondent filed this action against the United States in the Court of Federal Claims ("CFC") alleging almost identical violations and requesting money damages. At issue was whether a common factual basis like the one apparent in respondent's suits sufficed to bar jurisdiction under 28 U.S.C. 1500. The Court held that two suits were for or in respect to the same claim, precluding CFC jurisdiction, if they are based on substantially the same operative facts, regardless of the relief sought in each suit. The Court also held that the substantial overlap in operative facts between respondent's District Court and CFC suits precluded jurisdiction in the CFC where both actions alleged that the United States held the same assets in trust for respondent's benefit and they describe almost identical breaches of fiduciary duties.