Justia U.S. Supreme Court Opinion Summaries
Southern Union Co. v. United States
The company was convicted of violating the Resource Conservation and Recovery Act for knowingly storing liquid mercury without a permit "on or about September 19, 2002 to October 19, 2004." Violations are punishable by a fine of not more than $50,000 per day, 42 U.S.C. 6928(d). The probation office calculated a maximum fine of $38.1 million, based on 762 days. The company argued that any fine greater than $50,000 would be unconstitutional under Apprendi v. New Jersey, which held that the Sixth Amendment requires that any fact (other than prior conviction) that increases maximum punishment be proved to a jury beyond a reasonable doubt. The district court held that Apprendi applies to criminal fines, but concluded that the jury found a 762-day violation and imposed a fine of $6 million and a community service obligation of $12 million. The First Circuit affirmed on the ground that Apprendi does not apply to criminal fines. The Supreme Court reversed. Apprendi applies to criminal fines. The "core concern, to reserve to the jury determination of facts that warrant punishment for a specific statutory offense, applies whether the sentence is a criminal fine or imprisonment or death. Dissenters argued that facts relevant to a fine’s amount typically quantify the harm and do not define a separate set of acts for punishment. The majority rejected the assumption that, in determining maximum punishment, there is a constitutionally significant difference between a fact that is an "element" and one that is a "sentencing factor." View "Southern Union Co. v. United States" on Justia Law
Williams v. Illinois
In petitioner's bench trial for rape, the prosecution called an expert who testified that a DNA profile produced by an outside lab matched a profile produced by the state police lab using a sample of petitioner's blood. At issue was whether Crawford v. Washington precluded the expert witness from testifying in a manner that had long been allowed under the law of evidence. Specifically, did Crawford bar an expert from expressing an opinion based on facts about a case that have been made known to the expert but about which the expert was not competent to testify. Also at issue was whether Crawford substantially impeded the ability of prosecutors to introduce DNA evidence and thus could effectively relegate the prosecution in some cases to reliance on older, less reliable forms of proof. The Court concluded that this form of expert testimony did not violate the Confrontation Clause because the provision had no application to out-of-court statements that were not offered to prove the truth of the matter asserted. Therefore, the Court concluded that the expert's testimony did not violate the Sixth Amendment. As a second, independent basis for the Court's decision, even if the report produced by the outside lab had been admitted into evidence, there would have been no Confrontation Clause violation. View "Williams v. Illinois" on Justia Law
Match-E-Be-Nash-She-Wish Band of Pottawatomi Indians v. Patchak
Petitioner requested that the Secretary of the Interior take into trust on its behalf a tract of land known as the Bradley Property, which petitioner intended to use "for gaming purposes." The Secretary took title to the property and respondent subsequently filed suit under the Administrative Procedures Act (APA), 5 U.S.C. 500 et seq., asserting that the Indian Reorganization Act (IRA), 25 U.S.C. 465, did not authorize the Secretary to acquire the property because petitioner was not a federally recognized tribe when the IRA was enacted in 1934. At issue was whether the United States had sovereign immunity from the suit by virtue of the Quiet Title Act (QTA), 86 Stat. 1176, and whether respondent had prudential standing to challenge the Secretary's acquisition. The Court held that the United States had waived its sovereign immunity from respondent's action under the QTA. The Court also held that respondent had prudential standing to challenge the Secretary's acquisition where respondent's interests came within section 465's regulatory ambit. View "Match-E-Be-Nash-She-Wish Band of Pottawatomi Indians v. Patchak" on Justia Law
Salazar v. Ramah Navajo Chapter
The Indian Self-Determination and Education Assistance Act (ISDA), 25 U.S.C. 450 et seq., directed the Secretary of the Interior to enter into contracts with willing tribes, pursuant to which those tribes would provide services such as education and law enforcement that otherwise would have been provided by the Federal government. ISDA mandated that the Secretary shall pay the full amount of "contract support costs" incurred by tribes in performing their contracts. At issue was whether the Government must pay those costs when Congress appropriated sufficient funds to pay in full any individual contractor's contract support costs, but not enough funds to cover the aggregate amount due every contractor. The Court held that, consistent with longstanding principles of Government contracting law, the Government must pay each tribe's contract support costs in full. View "Salazar v. Ramah Navajo Chapter" on Justia Law
Christopher v. SmithKline Beecham Corp.
Petitioners, employed by respondent as pharmaceutical sales representatives, filed suit alleging that respondent violated the Fair Labor Standards Act (FLSA), 29 U.S.C. 206-207, by failing to compensate them for overtime. At issue was whether the term "outside salesman," as defined by the Department of Labor regulations, encompassed pharmaceutical sales representatives whose primary duty was to obtain nonbinding commitments from physicians to prescribe their employer's prescription drugs in appropriate cases. The Court concluded that these employees qualified as outside salesmen under the most reasonable interpretations of the Department's regulations. View "Christopher v. SmithKline Beecham Corp." on Justia Law
Posted in:
Labor & Employment Law, U.S. Supreme Court
Elgin v. Dept. of Treasury
Under the Civil Service Reform Act of 1978 (CSRA), 5 U.S.C. 1101 et seq., certain federal employees could obtain administrative and judicial review of specified adverse employment actions. At issue was whether the CSRA provided the exclusive avenue to judicial review when a qualifying employee challenged an adverse employment action by arguing that a federal statute was unconstitutional. The Court held that it did. The CSRA precluded district court jurisdiction over petitioners' claims because it was fairly discernible that Congress intended the statute's review scheme to provide the exclusive avenue to judicial review for covered employees who challenged covered adverse employment actions, even when those employees argued that a federal statute was unconstitutional. View "Elgin v. Dept. of Treasury" on Justia Law
Reichle v. Howards
This case arose when respondent brought an action against petitioners, two Secret Service agents, and others, under 42 U.S.C. 1983 and Bivens v. Six Unknown Fed. Narcotics Agents, claiming that he was arrested and searched without probable cause, in violation of the Fourth Amendment, and that the arrest violated the First Amendment because it was made in retaliation for respondent's criticism of Vice President Cheney. At issue was whether two federal law enforcement agents were immune from suit for allegedly arresting a suspect in retaliation for his political speech, when the agents had probable cause to arrest the suspect for committing a federal crime. The Court held that petitioners were entitled to qualified immunity because, at the time of respondent's arrest, it was not clearly established that an arrest supported by probable cause could give rise to a First Amendment violation. View "Reichle v. Howards" on Justia Law
Armour v. Indianapolis
An Indiana statute, the "Barrett Law," Ind. Code 36-9-15(b)(3), authorized Indiana's cities to impose upon benefited owners the cost of sewer improvement projects. The Law also permitted those lot owners to pay either immediately in the form of a lump sum or over time in installments. In 2005, the city of Indianapolis adopted a new assessment and payment method, the "STEP" plan, and it forgave any Barrett Law installments that lot owners had not yet paid. A group of lot owners who had already paid their entire Barrett Law assessment in a lump sum believed that the City should have provided them with equivalent refunds. At issue was whether the City's refusal to do so unconstitutionally discriminated against them in violation of the Equal Protection Clause, Amdt. 14, section 1. The Court held that the City had a rational basis for distinguishing between those lot owners who had already paid their share of project costs and those who had not. Therefore, the Court concluded that there was no equal protection violation. View "Armour v. Indianapolis" on Justia Law
RadLAX Gateway Hotel, LLC v. Amalgamated Bank
Debtors obtained a secured loan from an investment fund, for which the Bank served as trustee. Debtors ultimately became insolvent, seeking relief under 11 U.S.C. 1129(b)(2)(A), where debtors sought to confirm a "cramdown" bankruptcy plan over the Bank's objection. The Bankruptcy Court denied debtors' request, concluding that the auction procedures did not comply with section 1129(b)(2)(A)'s requirements for cramdown plans and the Seventh Circuit affirmed. The Court held that debtors could not obtain confirmation of a Chapter 11 cramdown plan that provided for the sale of collateral free and clear of the Bank's lien, but did not permit the Bank to credit-bid at the sale. Accordingly, the Court affirmed the judgment of the Court of Appeals. View "RadLAX Gateway Hotel, LLC v. Amalgamated Bank" on Justia Law
Freeman, et al. v. Quicken Loans, Inc.
A provision of the Real Estate Settlement Procedures Act (RESPA), 12 U.S.C. 2607(b), prohibited giving and accepting "any portion, split, or percentage of any charge made or received for the rendering of a real estate settlement service... other than for services actually performed." Petitioners, three couples who obtained mortgage loans from respondent, filed separate state-court actions, alleging that respondent had violated section 2607(b) by charging them fees for which no services were provided in return. At issue was whether, to establish a violation of section 2607(b), a plaintiff must demonstrate that a charge was divided between two or more persons. The Court held that, in order to establish a violation of section 2607(b), a plaintiff must demonstrate that a charge for settlement services was divided between two or more persons. Because petitioners did not contend that respondent split the challenged charges with anyone else, summary judgment was properly granted in favor of respondent. Therefore, the Court affirmed the judgment of the Court of Appeals. View "Freeman, et al. v. Quicken Loans, Inc." on Justia Law
Posted in:
Real Estate & Property Law, U.S. Supreme Court