Justia U.S. Supreme Court Opinion Summaries

Respondents, North Carolina residents whose sons died in a bus accident outside Paris, France, filed a suit for wrongful death damages in North Carolina state court alleging that the accident was caused by tire failure. At issue was whether foreign subsidiaries of a United States parent corporation were amenable to suit in state court on claims unrelated to any activity of the subsidiaries in the forum state. The Court held that, because the episode-in-suit, the bus accident, occurred in France, and the tire alleged to have caused the accident was manufactured and sold abroad, North Carolina courts lacked specific jurisdiction to adjudicate the controversy. The Court also held that a connection so limited between the forum and the foreign corporation was an inadequate basis for the exercise of general jurisdiction where such a connection did not establish the "continuous and systematic" affiliation necessary to empower North Carolina courts to entertain claims unrelated to the foreign corporation's contacts with the State. Therefore, the Court held that petitioners were not amendable to suit in North Carolina and the judgment of the North Carolina Court of Appeals was reversed. View "Goodyear Dunlop Tires Operations, S. A., et al. v. Brown" on Justia Law

In 2005, respondent was charged with delinquency under the Federal Juvenile Delinquency Act, 18 U.S.C. 5031 et seq., for sexually abusing a boy for approximately two years until respondent was 15 years old and his victim was 12 years old. Respondent was sentenced to two years of juvenile detention followed by juvenile supervision until his 21st birthday. In 2006, while respondent remained in juvenile detention, Congress enacted the Sex Offender Registration and Notification Act (SORNA), 42 U.S.C. 16902 et seq. In July 2007, the District Court determined that respondent had failed to comply with the requirements of his prerelease program. On appeal, respondent challenged his "special conditio[n]" of supervision and requested that the Court of Appeals "reverse th[e] portion of his sentence requiring Sex Offender Registration and remand with instructions that the district court ... strik[e] Sex Offender Registration as a condition of juvenile supervision." Over a year after respondent's 21st birthday, the Court of Appeals handed down its decision and held that the SORNA requirements violated the Ex Post Facto Clause of the Constitution, Art. I, section 9, cl. 3, when applied to juveniles adjudicated as delinquent before SORNA's enactment. The Court held that the Court of Appeals had no authority to enter that judgment because it had no live controversy before it where respondent had turned 21 and where the capable-of-repetition exception to mootness did not apply in this case. Accordingly, the judgment of the Ninth Circuit was vacated and the case remanded with instructions to dismiss the appeal. View "United States v. Juvenile Male" on Justia Law

The Arizona Citizens Clean Elections Act (matching funds provision), Ariz. Rev. Stat. Ann. 16-940 et seq., created a voluntary public financing system to fund the primary and general election campaigns of candidates for state office. Petitioners, candidates and independent expenditure groups, filed suit challenging the constitutionality of the matching funds provision. The Court held that the matching funds provision substantially burdened the speech of privately financed candidates and independent expenditure groups without serving a compelling state interest where the professed purpose of the state law was to cause a sufficient number of candidates to sign up for public financing, which subjected them to the various restrictions on speech that went along with that program. Therefore, the Court held that the matching funds scheme violated the First Amendment and reversed the judgment of the Ninth Circuit. View "Arizona Free Enterprise Club's Freedom Club PAC, et al. v. Bennett, et al; McComish, et al. v. Bennett, et al." on Justia Law

Respondents, representing the video game and software industries, filed a preenforcement challenge to California Assembly Bill 1179 (Act), Cal. Civ. Code Ann. 1746-1746.5, which restricted the sale or rental of violent video games to minors. At issue was whether the Act comported with the First Amendment. The Court held that, because the Act imposed a restriction on the content of protected speech, it was invalid unless California could demonstrate that it passed strict scrutiny. The Court held that California had a legitimate interest in addressing a serious social problem and helping concerned parents control their children. The Court held, however, that as a means of protecting children from portrayals of violence, the legislation was seriously underinclusive, not only because it excluded portrayals other than video games, but also because it permitted a parental or avuncular veto. The Court also held that, as a means of assisting concerned parents, it was seriously overinclusive because it abridged the First Amendment rights of young people whose parents think violent video games were a harmless pastime. The Court further held that the overbreadth in achieving one goal was not cured by the overbreadth in achieving the other and therefore, the legislation could not survive strict scrutiny. Accordingly, the court affirmed the judgment of the Ninth Circuit enjoining the Act's enforcement. View "Brown, et al. v. Entertainment Merchants Assn. et al." on Justia Law

The Sentencing Reform Act of 1984 ("Act"), 18 U.S.C. 3551 et seq., called for the creation of Sentencing Guidelines to inform judicial discretion in order to reduce unwarranted disparities in federal sentencing. The Act allowed retroactive amendments to the Guidelines for cases where the Guidelines became a cause of inequality. When a retroactive Guideline amendment was adopted, section 3682(c)(2) permitted defendants sentenced based on a sentencing range that had been modified to move for a reduced sentence. In this case, petitioner was indicted for various crimes, including possessing with intent to distribute cocaine base, and entered into a Federal Rule of Criminal Procedure 11(c)(1)(C) agreement to plead guilty to all charges where the Government, in return, agreed to a 106 month sentence. At issue was whether defendants who enter into plea agreements that recommended a particular sentence as a condition of the guilty plea could be eligible for relief under section 3682(c)(2). The Court held that the text and purpose of the statute, Rule 11(c)(1)(C), and the governing Guidelines policy statements compelled the conclusion that the district court had authority to entertain section 3582(c)(2) motions when sentences were imposed in light of the Guidelines, even if the defendant entered into an Rule 11(c)(1)(C) agreement. The Court also held that petitioner's sentencing hearing transcript revealed that the District Court expressed its independent judgment that the sentence was appropriate in light of the applicable Guidelines range. Therefore, the District Court's decisions was "based on" that range within section 3682(c)(2)'s meaning. Accordingly, the judgment of the Court of Appeals was reversed and the case remanded for further proceedings. View "Freeman v. United States" on Justia Law

This case concerned the standard of causation applicable in cases arising under the Federal Employers' Liability Act ("FELA"), 45 U.S.C. 51 et seq., which rendered railroads liable for employees' injuries or deaths "resulting in whole or in part from [carrier] negligence." Respondent, a locomotive engineer with petitioner, an interstate railroad, sustained a debilitating hand injury and subsequently filed suit under the FELA. At issue was whether the causation instruction endorsed by the Seventh Circuit was proper in FELA cases where that instruction did not include the term "proximate cause," but did tell the jury defendant's negligence must "pla[y] a part-no matter how small-in bringing about the [plaintiff's] injury." In accord with the text and purpose of the Act, the Court's decision in Rogers v. Missouri Pacific R. Co., and the uniform view of federal appellate courts, the Court held that the Act did not incorporate "proximate cause" standards developed in nonstatutory common law tort actions. The Court held that the charge proper in FELA cases simply tracked the language Congress employed, informing juries that a defendant railroad caused or contributed to a plaintiff employee's injury if the railroad's negligence played any part in bringing about the injury. Accordingly, the judgment of the Seventh Circuit was affirmed. View "CSX Transp., Inc. v. McBride" on Justia Law

Petitioner was arrested on charges of driving while intoxicated ("DWI") and the principal evidence against him was a forensic laboratory report certifying that his blood alcohol concentration was well above the threshold for aggravated DWI. At trial, the prosecution did not call as a witness the analyst who signed the certification and, instead, called another analyst who was familiar with the laboratory's testing procedures but had neither participated in nor observed the test on petitioner's blood sample. At issue was whether the Confrontation Clause permitted the prosecution to introduce a forensic laboratory report containing a testimonial certification, made for the purpose of proving a particular fact, through the in-court testimony of a scientist who did not sign the certification or perform or observe the test reported in the certification. The Court held that surrogate testimony of that order did not meet the constitutional requirement where the accused's right was to be confronted with the analyst who made the certification, unless that analyst was unavailable at trial and the accused had an opportunity, pretrial, to cross-examine that particular scientist. Accordingly, the judgment of the New Mexico Supreme Court was reversed and the case remanded for further proceedings. View "Bullcoming v. New Mexico" on Justia Law

These consolidated lawsuits involved state tort law claims based on certain drug manufacturers' alleged failure to provide adequate warning labels for the generic drug metoclopramide. State tort law required a manufacturer that was, or should be, aware of its drug's danger to label it in a way that rendered it reasonably safe. On the other hand, federal drug regulations, as interpreted by the FDA, prevented the manufacturers from independently changing their generic drug safety labels. At issue was whether such federal drug regulations applicable to generic drug manufacturers directly conflicted with, and thus preempted, the state law claims. The Court concluded that the federal drug regulations preempted the state law claims because, if manufacturers had independently changed their labels to satisfy their state law duty to attach a safer label to their generic metoclopramide, they would have violated the federal requirement that generic drug labels be the same as the corresponding brand-name drug labels. Thus, it was impossible for the manufacturers to comply with federal and state law. Even if the manufacturers had fulfilled their federal duty to ask for FDA help in strengthening the corresponding brand-name labels, assuming such a duty existed, they would not have satisfied their state tort law duty. State law demanded a safer label, it did not require communication with the FDA about the possibility of a safer label. Therefore, the Court held that when a party could not satisfy its state duties without the Federal Government's special permission and assistance, which was dependent on the exercise of judgment by a federal agency, that party could not independently satisfy those state duties for preemption purposes. The Court also noted that Congress and the FDA retained authority to change the law and regulations if they so desired. Accordingly, the case was reversed and remanded for further proceedings. View "PLIVA, Inc., et al. v. Mensing; Actavis Elizabeth, LLC v. Mensing; Actavis, Inc., v. Demahy" on Justia Law

This case stemmed from the long-running dispute between Vickie Lynn Marshall and E. Pierce Marshall over the fortune of J. Howard Marshall II, a man believed to have been one of the richest people in Texas. Vickie married J. Howard, Pierce's father, approximately a year before his death. Shortly before J. Howard died, Vickie filed a suit against Pierce in Texas state court asserting that J. Howard meant to provide for Vickie through a trust, and Pierce tortiously interfered with that gift. The litigation worked its way through state and federal courts in Louisiana, Texas, and California, and two of those courts, a Texas state probate court and the Bankruptcy Court for the Central District of California, reached contrary decisions on its merits. The Court of Appeals subsequently held that the Texas state decision controlled after concluding that the Bankruptcy Court lacked the authority to enter final judgment on a counterclaim that Vickie brought against Pierce in her bankruptcy proceeding. At issue was whether the Bankruptcy Court Judge, who did not enjoy tenure and salary protections pursuant to Article III of the Constitution, had the statutory authority under 28 U.S.C. 157(b) to issue a final judgment on Vickie's counterclaims and, if so, whether conferring that authority on the Bankruptcy Court was constitutional. The Court held that the Bankruptcy Court had the statutory authority to enter judgment on Vickie's counterclaim as a core proceeding under section 157(b)(2)(C). The Court held, however, that the Bankruptcy Court lacked the constitutional authority under Article III to enter final judgment on a state law counterclaim that was not resolved in the process of ruling on a creditor's proof claim. Accordingly, the judgment of the Court of Appeals was affirmed. View "Stern v. Marshall" on Justia Law

Vermont's Prescription Confidentiality Law, Vt. Stat. Ann., Tit. 18, 4631(d), restricted the sale, disclosure, and use of pharmacy records that revealed the prescribing practices of individual doctors. Respondents, Vermont data miners and an association of brand-name drug manufacturers, sought declaratory and injunctive relief against state officials, contending that section 4631(d) violated their rights under the Free Speech Clause of the First Amendment. At issue was whether section 4631(d) must be tested by heightened judicial scrutiny and, if so, whether Vermont could justify the law. The Court held that the Vermont Statute, which imposed content-based and speaker-based burdens on protected expression, was subject to heightened judicial scrutiny. The Court also held that Vermont's justifications for section 4631(d) did not withstand such heightened scrutiny and therefore, affirmed the Second Circuit's judgment that section 4631(d) unconstitutionally burdened the speech of pharmaceutical marketers and data miners without adequate justification. View "Sorrell, et al. v. IMS Health Inc., et al." on Justia Law