Justia U.S. Supreme Court Opinion Summaries
Truck Insurance Exchange v. Kaiser Gypsum Co.
The case involves Truck Insurance Exchange (Truck), the primary insurer for companies that manufactured and sold products containing asbestos. Two of these companies, Kaiser Gypsum Co. and Hanson Permanente Cement (Debtors), filed for Chapter 11 bankruptcy after facing thousands of asbestos-related lawsuits. As part of the bankruptcy process, the Debtors proposed a reorganization plan that created an Asbestos Personal Injury Trust (Trust) to handle all present and future asbestos-related claims. Truck, contractually obligated to defend each covered asbestos personal injury claim and to indemnify the Debtors for up to $500,000 per claim, opposed the Plan, arguing that it exposed them to millions of dollars in fraudulent claims due to different disclosure requirements for insured and uninsured claims.The District Court confirmed the Plan, concluding that Truck had limited standing to object to the Plan because it was “insurance neutral,” meaning it did not increase Truck’s prepetition obligations or impair its contractual rights under its insurance policies. The Fourth Circuit affirmed this decision, agreeing that Truck was not a “party in interest” under §1109(b) of the Bankruptcy Code because the plan was “insurance neutral.”The Supreme Court of the United States reversed the Fourth Circuit's decision, holding that an insurer with financial responsibility for bankruptcy claims is a “party in interest” under §1109(b) of the Bankruptcy Code and may raise and appear and be heard on any issue in a Chapter 11 case. The Court reasoned that §1109(b)’s text, context, and history confirm that an insurer such as Truck with financial responsibility for a bankruptcy claim is a “party in interest” because it may be directly and adversely affected by the reorganization plan. The Court also rejected the “insurance neutrality” doctrine, stating that it conflates the merits of an objection with the threshold party in interest inquiry. The case was remanded for further proceedings consistent with the Supreme Court's opinion. View "Truck Insurance Exchange v. Kaiser Gypsum Co." on Justia Law
Thornell v. Jones
The case involves Danny Lee Jones, who was convicted of three murders committed with the intent to steal a gun collection. Jones brutally killed a man, his 7-year-old daughter, and his grandmother. After being found guilty, the trial court proceeded to sentencing. Under Arizona law, the court was required to impose a death sentence if it found one or more aggravating circumstances and no mitigating circumstances sufficiently substantial to call for leniency. The court found three aggravating circumstances and sentenced Jones to death. The Arizona Supreme Court affirmed the decision.Jones sought postconviction review, arguing that his attorney was ineffective. He claimed that his attorney should have retained an independent neuropsychologist, rather than relying on a court-appointed psychiatrist. The state court denied this claim. Jones then filed a habeas petition in Federal District Court, reasserting his ineffective-assistance-of-counsel claims. The District Court held an evidentiary hearing but concluded that Jones could not show prejudice because the additional information he presented barely altered the sentencing profile presented to the sentencing judge. The Ninth Circuit reversed, but the Supreme Court vacated that judgment and remanded for the Ninth Circuit to determine whether it had been proper to consider the new evidence presented at the federal evidentiary hearing.On reconsideration, the Ninth Circuit again granted habeas relief. The panel held that it was permissible to consider the new evidence and concluded that there was a reasonable probability that Jones would not have received a death sentence if that evidence had been presented at sentencing. The Supreme Court granted certiorari to review the Ninth Circuit’s interpretation and application of Strickland.The Supreme Court reversed the Ninth Circuit's decision, stating that it had departed from the well-established rules in at least three ways. The Supreme Court found that the Ninth Circuit failed to adequately take into account the weighty aggravating circumstances in this case, applied a strange Circuit rule that prohibits a court in a Strickland case from assessing the relative strength of expert witness testimony, and held that the District Court erred by attaching diminished persuasive value to Jones’s mental health conditions because it saw no link between those conditions and Jones’s conduct when he committed the three murders. The Supreme Court concluded that there was no reasonable probability that the evidence on which Jones relies would have altered the outcome at sentencing. View "Thornell v. Jones" on Justia Law
Posted in:
Criminal Law
National Rifle Association of America v. Vullo
The case involves the National Rifle Association (NRA) and Maria Vullo, the former superintendent of the New York Department of Financial Services (DFS). The NRA alleged that Vullo violated their First Amendment rights by pressuring regulated entities to disassociate from the NRA and other gun-promotion advocacy groups. The NRA claimed that Vullo threatened enforcement actions against those entities that refused to disassociate, thereby stifling the NRA's pro-gun advocacy.The District Court initially denied Vullo's motion to dismiss the NRA's First Amendment damages claims, holding that the NRA plausibly alleged that Vullo's actions could be interpreted as a veiled threat to regulated industries to disassociate with the NRA or risk DFS enforcement action. However, the Second Circuit reversed this decision, concluding that Vullo's alleged actions constituted permissible government speech and legitimate law enforcement, not unconstitutional coercion. The Second Circuit also held that even if the complaint stated a First Amendment violation, the law was not clearly established, and so Vullo was entitled to qualified immunity.The Supreme Court of the United States, however, vacated the judgment of the Second Circuit. The Supreme Court held that the NRA plausibly alleged that Vullo violated the First Amendment by coercing DFS-regulated entities to terminate their business relationships with the NRA in order to punish or suppress the NRA's advocacy. The case was remanded for further proceedings consistent with this opinion. View "National Rifle Association of America v. Vullo" on Justia Law
Cantero v. Bank of America, N. A.
The case revolves around a dispute between Alex Cantero, Saul Hymes, Ilana Harwayne-Gidansky, and others (the plaintiffs) and Bank of America. The plaintiffs had obtained home mortgage loans from Bank of America, which required them to make monthly deposits into escrow accounts. These accounts were used by the bank to pay the borrowers' property taxes and insurance premiums. Under New York law, banks are required to pay borrowers interest on the balance of such escrow accounts. However, Bank of America did not pay interest on the money in the plaintiffs' escrow accounts, arguing that the New York law was preempted by the National Bank Act. The plaintiffs filed class-action suits against Bank of America, alleging that the bank violated New York law by failing to pay them interest on the balances in their escrow accounts.The U.S. District Court for the Eastern District of New York ruled in favor of the plaintiffs, agreeing that New York law required Bank of America to pay interest on the escrow account balances. The court concluded that nothing in the National Bank Act or other federal law preempted the New York law. However, the U.S. Court of Appeals for the Second Circuit reversed this decision, holding that the New York interest-on-escrow law was preempted as applied to national banks. The Court of Appeals argued that federal law preempts any state law that attempts to exercise control over a federally granted banking power, regardless of the magnitude of its effects.The Supreme Court of the United States, in reviewing the case, focused on the standard for determining when state laws that regulate national banks are preempted. The Court noted that the Dodd-Frank Act of 2010 expressly incorporated the standard articulated in Barnett Bank of Marion County, N. A. v. Nelson, which asks whether a state law "prevents or significantly interferes with the exercise by the national bank of its powers." The Supreme Court found that the Court of Appeals did not apply this standard in a manner consistent with Dodd-Frank and Barnett Bank. Therefore, the Supreme Court vacated the judgment of the Court of Appeals and remanded the case for further proceedings consistent with its opinion. View "Cantero v. Bank of America, N. A." on Justia Law
Posted in:
Banking, Class Action
Alexander v. South Carolina State Conference of the NAACP
The Supreme Court of the United States reviewed a case involving the redrawing of congressional districts in South Carolina following the 2020 Census. The National Association for the Advancement of Colored People and a voter from District 1 challenged the new map, alleging that it resulted in racial gerrymanders in certain districts and diluted the electoral power of the state's black voters. The District Court held that the state drew District 1 with a 17% black voting-age population target in mind, violating the Equal Protection Clause and unlawfully diluting the black vote.The Supreme Court disagreed with the District Court's findings. The Court found that the District Court erred in its conclusion that race predominated in the design of District 1. The Court noted that the challengers did not provide sufficient evidence to show that the legislature subordinated traditional race-neutral districting principles to racial considerations. The Court also criticized the District Court for not drawing an adverse inference from the challengers' failure to submit an alternative map that would have allowed the state to achieve its districting goals while maintaining a higher black voting-age population in District 1.The Supreme Court reversed the District Court's decision in part and remanded the case for further proceedings. The Court concluded that the same findings of fact and reasoning that guided the court's racial-gerrymandering analysis also guided the analysis of the challengers' independent vote-dilution claim, and that conclusion also could not stand. The Court found that the District Court erred in conflating the two claims. View "Alexander v. South Carolina State Conference of the NAACP" on Justia Law
Posted in:
Civil Rights, Election Law
Coinbase v. Suski
The case involves a dispute between Coinbase, Inc., a cryptocurrency exchange platform, and its users. The users had agreed to two contracts with Coinbase. The first contract, the User Agreement, contained an arbitration provision stating that an arbitrator must decide all disputes, including whether a disagreement is arbitrable. The second contract, the Official Rules for a promotional sweepstakes, contained a forum selection clause stating that California courts have sole jurisdiction over any controversies regarding the promotion. The users filed a class action in the U.S. District Court for the Northern District of California, alleging that the sweepstakes violated various California laws. Coinbase moved to compel arbitration based on the User Agreement’s arbitration provision. The District Court denied the motion, ruling that the Official Rules’ forum selection clause controlled the dispute. The Ninth Circuit affirmed this decision.The Supreme Court of the United States affirmed the Ninth Circuit's decision. The Court held that when parties have agreed to two contracts—one sending arbitrability disputes to arbitration, and the other either explicitly or implicitly sending arbitrability disputes to the courts—a court must decide which contract governs. The Court rejected Coinbase's arguments that the Ninth Circuit should have applied the severability principle and that the Ninth Circuit erroneously held that the Official Rules’ forum selection clause superseded the User Agreement’s arbitration provision. The Court also dismissed Coinbase's concern that its ruling would invite chaos by facilitating challenges to delegation clauses. The Court concluded that a court, not an arbitrator, must decide whether the parties’ first agreement was superseded by their second. View "Coinbase v. Suski" on Justia Law
Brown v. United States
The Supreme Court of the United States was tasked with interpreting the Armed Career Criminal Act (ACCA) in relation to state drug convictions that occurred before recent amendments to the federal drug schedules. The ACCA imposes a 15-year mandatory minimum sentence on defendants convicted for illegal firearm possession who have a criminal history demonstrating a propensity for violence. A defendant with three previous convictions for a "serious drug offense" qualifies for ACCA's enhanced sentencing.Petitioners Justin Rashaad Brown and Eugene Jackson were separately convicted of the federal crime of possession of a firearm by a convicted felon. In both cases, an ACCA enhancement was recommended based on prior state felony drug convictions. Both defendants argued that their prior convictions did not qualify as "serious drug offenses" due to changes in the federal definition of the drugs involved in their convictions. The District Courts disagreed and sentenced the petitioners to enhanced sentences, and the respective appellate courts affirmed.The Supreme Court held that a state drug conviction counts as an ACCA predicate if it involved a drug on the federal schedules at the time of that conviction. The Court reasoned that the ACCA is a recidivist statute that gauges what a defendant’s “history of criminal activity” says about his or her “culpability and dangerousness.” The Court also noted that the Government’s interpretation best fulfills ACCA’s statutory objectives. The Court affirmed the judgments of the Courts of Appeals. View "Brown v. United States" on Justia Law
Posted in:
Criminal Law, Government & Administrative Law
Harrow v. Department of Defense
The case revolves around Stuart Harrow, a Department of Defense employee who was furloughed for six days. Harrow challenged this decision before the Merit Systems Protection Board. After a five-year delay, the Board ruled against him. Harrow had the right to appeal this decision to the Court of Appeals for the Federal Circuit within 60 days of the Board's final order. However, Harrow did not learn about the Board's decision until after the 60-day period had elapsed, and he filed his appeal late. Harrow requested the Federal Circuit to overlook his untimeliness and equitably toll the filing deadline. The Federal Circuit, however, denied his request, believing that the deadline was an unalterable "jurisdictional requirement."The Supreme Court of the United States reviewed the case. The main issue was whether the 60-day filing deadline under Section 7703(b)(1) was jurisdictional, meaning it marked the bounds of a court's power and could not be waived or subject to exceptions. The Supreme Court held that the 60-day filing deadline was not jurisdictional. The Court reasoned that procedural rules, even when phrased in mandatory terms, are generally subject to exceptions like waiver, forfeiture, and equitable tolling. The Court found no language in Section 7703(b)(1) that suggested it was a jurisdictional requirement. The Court also rejected the Government's argument that the term "pursuant to" in a different statute, 28 U.S.C. §1295(a)(9), made the deadline jurisdictional.The Supreme Court vacated the judgment of the Federal Circuit and remanded the case for further proceedings consistent with its opinion. The Federal Circuit was directed to determine whether equitable tolling was available and, if so, whether Harrow was entitled to that relief given the facts of the case. View "Harrow v. Department of Defense" on Justia Law
Posted in:
Civil Procedure, Government & Administrative Law
Consumer Financial Protection Bureau v. Community Financial Services Assn. of America, Ltd.
The case involves the Consumer Financial Protection Bureau (CFPB) and its funding mechanism. The CFPB, unlike most federal agencies, has a standing source of funding outside the ordinary annual appropriations process. Congress authorized the CFPB to draw from the Federal Reserve System an amount that its Director deems “reasonably necessary to carry out” the Bureau’s duties, subject only to an inflation-adjusted cap. Several trade associations representing payday lenders and credit-access businesses challenged this funding mechanism, arguing that it violates the Appropriations Clause of the Constitution.The Fifth Circuit Court of Appeals agreed with the associations, ruling that the CFPB's funding mechanism violates the Appropriations Clause. The court reasoned that the Appropriations Clause requires both Chambers of Congress to periodically agree on an agency’s funding, which ensures that each Chamber reserves the power to unilaterally block those funding measures through inaction. The CFPB's funding mechanism, the court argued, allows it to draw funds indefinitely unless both Chambers of Congress step in and affirmatively prevent the agency from doing so.The Supreme Court of the United States, however, reversed the Fifth Circuit's decision. The Supreme Court held that Congress’ statutory authorization allowing the Bureau to draw money from the earnings of the Federal Reserve System to carry out the Bureau’s duties satisfies the Appropriations Clause. The Court reasoned that under the Appropriations Clause, an appropriation is a law that authorizes expenditures from a specified source of public money for designated purposes. The statute that provides the Bureau’s funding meets these requirements. Therefore, the Court concluded that the Bureau’s funding mechanism does not violate the Appropriations Clause. The case was remanded for further proceedings consistent with the Supreme Court's opinion. View "Consumer Financial Protection Bureau v. Community Financial Services Assn. of America, Ltd." on Justia Law
Posted in:
Constitutional Law, Government & Administrative Law
Smith v. Spizzirri
The case involves the interpretation of Section 3 of the Federal Arbitration Act (FAA), which outlines procedures for enforcing arbitration agreements in federal court. The petitioners, current and former delivery drivers for an on-demand delivery service operated by the respondents, filed a lawsuit alleging violations of federal and state employment laws. The respondents moved to compel arbitration and dismiss the suit. The petitioners agreed that their claims were arbitrable but argued that Section 3 of the FAA required the District Court to stay the action pending arbitration rather than dismissing it entirely. The District Court issued an order compelling arbitration and dismissed the case without prejudice. The Ninth Circuit affirmed the decision.The Supreme Court of the United States reversed the Ninth Circuit's decision. The Supreme Court held that when a district court finds that a lawsuit involves an arbitrable dispute and a party has requested a stay of the court proceeding pending arbitration, Section 3 of the FAA compels the court to issue a stay, and the court lacks discretion to dismiss the suit. The Court reasoned that the statutory text, structure, and purpose all point to this conclusion. The Court further explained that the FAA's structure and purpose confirm that a stay is required. The Court concluded that staying rather than dismissing a suit comports with the supervisory role that the FAA envisions for the courts. The case was remanded for further proceedings consistent with the Supreme Court's opinion. View "Smith v. Spizzirri" on Justia Law
Posted in:
Arbitration & Mediation, Labor & Employment Law