Justia U.S. Supreme Court Opinion Summaries

Respondents, current or former employees of petitioner Wal-Mart, sought judgment against the company for injunctive and declaratory relief, punitive damages, and backpay, on behalf of themselves and a nationwide class of some 1.5 million female employees because of Wal-Mart's alleged discrimination against women in violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e-1 et seq. At issue was whether the certification of the plaintiff class was consistent with Federal Rules of Civil Procedure 23(a) and (b)(2). The Court held that certification of the plaintiff class was not consistent with Rule 23(a) where proof of commonality necessarily overlapped with respondents' merits contention that Wal-mart engaged in a pattern or practice of discrimination and without some glue holding together the alleged reasons for the employment decisions, it would be impossible to say that examination of all the class members' claims would produce a common answer to the crucial discrimination question. The Court concluded that in a company Wal-Mart's size and geographical scope, it was unlikely that all managers would exercise their discretion in a common way without some common direction and respondents' attempt to show such direction by means of statistical and anecdotal evidence fell well short. The Court also held that respondents' backpay claims were improperly certified under Rule 23(b)(2) where claims for monetary relief could not be certified under the rule. Accordingly, the judgment of the Court of Appeals was reversed. View "Wal-Mart Stores, Inc. v. Dukes, et al." on Justia Law

This case stemmed from petitioner's civil contempt proceedings where South Carolina's Family Court enforced child support orders against him. At issue was whether the Fourteenth Amendment's Due Process Clause required the State to provide counsel at the civil contempt hearing to an indigent person potentially faced with incarceration. The Court held that even though petitioner had completed his 12 month prison sentence, and there were not alleged to be collateral consequences of the contempt determination that might keep the dispute alive, this case was not moot because it was capable of repetition while evading review. The Court held that the Fourteenth Amendment's Due Process Clause did not automatically require the State to provide counsel at civil contempt proceedings to an indigent noncustodial parent who was subject to a child support order, even if that individual faced incarceration. In particular, that Clause did not require that counsel be provided where the opposing parent or other custodian was not represented by counsel and the State provided alternative procedural safeguards equivalent to adequate notice of the importance of the ability to pay, a fair opportunity to present, and to dispute, relevant information, and express court findings as to the supporting parent's ability to comply with the support order. Under the circumstances, petitioner's incarceration violated due process because he received neither counsel nor the benefit of alternative procedures like those the Court described. Accordingly, the Court vacated the judgment and remanded for further proceedings. View "Turner v. Rogers, et al." on Justia Law

This case concerned the extent of the protection, if any, that the Petition Clause granted public employees in routine disputes with government employers where petitioner filed a 42 U.S.C. 1983 suit after respondent's termination of petitioner as police chief and where petitioner was subsequently reinstated, with directives instructing petitioner in the performance of his duties. Petitioner alleged that the directives were issued in retaliation for the filing of his first grievance and violated his First Amendment right to "petition the Government for a redress of grievances." At issue was whether the public concern test applied when the employee invoked the Petition Clause. The Court held that a government employer's allegedly retaliatory actions against an employee did not give rise to liability under the Petition Clause unless the employee's petition related to a matter of public concern. Therefore, the Court held that the Third Circuit's conclusion that the public concern test did not limit public employees' Petition Clause claims was incorrect. Accordingly, the Court concluded that, absent full briefs by the parties, the Court need not consider how the foregoing framework would apply to this case and therefore, vacated the judgment and remanded for further proceedings. View "Borough of Duryea, et al. v. Guarnieri" on Justia Law

Plaintiffs, several states, the city of New York, and three private land trusts, sued defendants, four private power companies and the federal Tennessee Valley Authority, alleging that defendants' emissions substantially and unreasonably interfered with public rights in violation of the federal common law of interstate nuisance, or in the alternative, of state tort law. Plaintiffs sought a decree setting carbon-dioxide emissions for each defendant at an initial cap to be further reduced annually. At issue was whether plaintiffs could maintain federal common law public nuisance claims against carbon-dioxide emitters. As a preliminary matter, the Court affirmed, by an equally divided Court, the Second Circuit's exercise of jurisdiction and proceeded to the merits. The Court held that the Clean Air Act, 42 U.S.C. 7401, and the Environmental Protection Act ("Act"), 42 U.S.C. 7411, action the Act authorized displaced any federal common-law right to seek abatement of carbon-dioxide emissions from fossil-fuel fired power plants. The Court also held that the availability vel non of a state lawsuit depended, inter alia, on the preemptive effect of the federal Act. Because none of the parties have briefed preemption or otherwise addressed the availability of a claim under state nuisance law, the matter was left for consideration on remand. Accordingly, the Court reversed and remanded for further proceedings. View "American Elec. Power Co., et al. v. Connecticut, et al." on Justia Law

In this case, a Federal District Court enjoined a state court from considering a plaintiff's request to approve a class action. The District Court did so because it had earlier denied a motion to certify a class in a related case, brought by a different plaintiff against the same defendant alleging similar claims. The federal court thought its injunction appropriate to prevent relitigation of the issue it had decided. The Court held to the contrary and found that, in issuing the order to a state court, the federal court exceeded its authority under the "relitigation exception" of the Anti-Injunction Act ("Act"), 28 U.S.C. 2283, where the statutory provision permitted a federal court to enjoin a state proceeding only in rare cases, when necessary to "protect or effectuate [the federal court's] judgments." The Court held that the standard was not met in this case for two reasons. First, the issue presented in the state court was not identical to the one decided in the federal tribunal. Second, the plaintiff in the state court did not have the requisite connection to federal suit to be bound by the District Court's judgment. View "Smith v. Bayer Corp." on Justia Law

Petitioner was indicted for violating 18 U.S.C. 229, which forbid knowing possession or use, for nonpeaceful purposes, of a chemical that "can cause death, temporary incapacitation or permanent harm to humans," and which was part of a federal act implementing a chemical weapons treaty ratified by the United States. At issue was whether a person indicted for violating a federal statute had standing to challenge its validity on grounds that, by enacting it, Congress exceeded its powers under the Constitution, thus intruding upon the sovereignty and authority of the States. The Court held that petitioner had standing to challenge the federal statute where there was no basis in precedent or principle to deny petitioner's standing to raise her claims. The ultimate issue of the statute's validity turned in part on whether the law could be deemed "necessary and proper for carrying into Execution" the President's Article II, section 2 Treaty Power. Accordingly, the Court expressed no view on the merits of the argument and noted that it could be addressed by the Court of Appeals on remand. Therefore, the judgment of the Court of Appeals was reversed and the case remanded for further proceedings. View "Bond v. United States" on Justia Law

While conducting a routine vehicle stop, police arrested petitioner, a passenger of the vehicle, for giving a false name. After handcuffing him and securing the scene, the police searched the vehicle and found petitioner's revolver. Petitioner was subsequently indicted on charges of being a felon in possession of a firearm. In a suppression motion, petitioner acknowledged that the search of the vehicle complied with existing Eleventh Circuit precedent interpreting New York v. Belton, but he raised a Fourth Amendment challenge to preserve the issue on appeal. The District Court denied the motion and petitioner was convicted. While his appeal was pending, the Court announced, in Arizona v. Gant, a new rule governing automobile searches incident to arrests of recent occupants. At issue was whether to apply the exclusionary rule when the police conducted a search in compliance with binding precedent that was later overruled. Because the suppression would do nothing to deter police misconduct in these circumstances, and because it would come at a high cost to both the truth and the public safety, the Court held that the searches conducted in objectionable reliance on binding appellate precedent were not subject to the exclusionary rule. Accordingly, the Court affirmed the suppression of the revolver and petitioner's conviction. View "Davis v. United States" on Justia Law

J.D.B., a thirteen-year-old seventh-grade student, was taken from his classroom to a closed-door conference room where uniformed police and school administrators questioned him for at least 30 minutes regarding two home break-ins nearby. Before beginning, they did not give J.D.B. Miranda warnings, the opportunity to call his legal guardian, or tell him he was free to leave the room. After J.D.B. subsequently confessed to the break-ins and wrote a statement at the request of police, two juvenile petitions were filed against him. J.D.B.'s public defender moved to suppress his statements and the evidence derived therefrom, arguing that he had been interrogated in a custodial setting without being afforded Miranda warnings and that his statements were involuntary. At issue was whether the age of a child subjected to police questioning was relevant to the custody analysis of Miranda v. Arizona. The Court held that it was beyond dispute that children would often feel bound to submit to police questioning when an adult in the same circumstances would feel free to leave. Seeing no reason for police officers or courts to blind themselves to that commonsense reality, the Court held that a child's age group properly informed the Miranda custody analysis. Accordingly, the Court reversed and remanded to the state courts to address whether J.D.B. was in custody when he was interrogated, taking account of all of the relevant circumstances of the interrogation, including his age at the time. View "J. D. B. v. North Carolina" on Justia Law

Petitioner was convicted of, inter alia, smuggling unauthorized aliens into the United States. The District Court imposed a 51 month prison sentence, reasoning that petitioner should serve that long in order to qualify for and complete the Bureau of Prisons' Residential Drug Abuse Program ("RDAP"). At issue was whether the Sentencing Reform Act ("SRA"), 18 U.S.C. 3582(a), precluded federal courts from imposing or lengthening a prison term in order to promote a criminal defendant's rehabilitation. The Court held that the text, context, and history of section 3582(a) precluded sentencing courts from imposing or lengthening a prison term to promote an offender's rehabilitation. The Court also held that Amicus' attempts to recast what the SRA said about rehabilitation were unavailing. The court further held that the record indicated that the District Court may have increased the length of petitioner's sentence to ensure her completion of RDAP, something a court could not do. Accordingly, the Court reversed and remanded for further proceedings and held that the Ninth Circuit was left to consider on remand the effect of petitioner's failure to object to the sentence when imposed. View "Tapia v. United States" on Justia Law

Petitioner administered and enforced Nevada's Ethics in Government Law, Nev. Rev. Stat. 281A.420, and investigated respondent, an elected official who voted to approve a hotel/casino project proposed by a company that used respondent's long-time friend and campaign manager as a paid consultant. Petitioner concluded that respondent had a disqualifying conflict of interest under section 281A.420(8)(e)'s catch-all provision and censured him for failing to abstain from voting on the project. At issue was whether legislators have a personal, First Amendment right to vote on any given matter. The Court held that the Nevada Ethics in Government Law was not unconstitutionally overbroad where the law prohibited a legislator who had a conflict both from voting on a proposal and from advocating its passage or failure; where a universal and long-established tradition of prohibiting certain conduct created a strong presumption that the prohibition was constitutional; and where restrictions on legislators' voting were not restrictions on legislators' protected speech because the legislator's vote was the commitment of his apportioned share of the legislature's power to the passage or defeat of a particular proposal and the legislative power thus committed was not personal to the legislator but belonged to the people. The Court also concluded that additional arguments raised in respondent's brief were not decided or raised in his brief in opposition and were thus considered waived. Accordingly, the Court reversed the judgment of the Nevada Supreme Court and remanded the case for further proceedings. View "Nevada Commission on Ethics v. Carrigan" on Justia Law