Justia U.S. Supreme Court Opinion Summaries

Respondent, First Derivative Traders, representing a class of stockholders in petitioner Janus Capital Group, Inc. ("JCG"), filed a private action under the Securities and Exchange Commission ("SEC") Rule 10b-5, alleging that JCG and its wholly owned subsidiary, petitioner Janus Capital Management LLC ("JCM"), made false statements in mutual funds prospectuses filed by Janus Investment Fund, for which JCM was the investment adviser and administrator, and that those statements affected the price of JCG's stock. Although JCG created Janus Investment Fund, it was a separate legal entity owned entirely by mutual fund investors. At issue was whether JCM, a mutual fund investment adviser, could be held liable in a private action under Rule 10b-5 for false statements included in its client mutual funds' prospectuses. The Court held that, because the false statements included in the prospectuses were made by Janus Investment Fund, not by JCM, JCM and JCG could not be held liable in a private action under Rule 10b-5. The Court found that, although JCM could have been significantly involved in preparing the prospectuses, it did not itself "make" the statements at issue for Rule 10b-5 purposes where its assistance in crafting what was said was subject to Janus Investment Fund's ultimate control. Accordingly, respondent had not stated a claim against JCM under Rule 10b-5 and the judgment of the Fourth Circuit was reversed. View "Janus Capital Group, Inc. v. First Derivative Traders" on Justia Law

The Jicarilla Apache Nation's ("Tribe") reservation contained natural resources that were developed pursuant to statutes administered by the Interior Department and proceeds from these resources were held by the United States in trust for the Tribe. The Tribe filed a breach-of-trust action in the Court of Federal Claims ("CFC") seeking monetary damages for the Government's alleged mismanagement of the Tribe's trust funds in violation of 25 U.S.C. 161-162a and other laws. During discovery, the Tribe moved to compel production of certain documents and the Government agreed to the release of some documents but asserted that others were protected by, inter alia, the attorney-client privilege. At issue was whether the fiduciary exception to the attorney-client privilege applied to the general trust relationship between the United States and Indian tribes. The Court held that the fiduciary exception did not apply where the trust obligations of the United States to the Indian tribes were established and governed by statute rather than the common law and, in fulfilling its statutory duties, the Government acted not as a private trustee but pursuant to its sovereign interest in the execution of federal law. The reasons for the fiduciary exception, that the trustee had no independent interest in trust administration, and that the trustee was subject to a general common-law duty of disclosure, did not apply in this context. Accordingly, the Court reversed and remanded for further proceedings. View "United States v. Jicarilla Apache Nation" on Justia Law

Petitioner was convicted for distribution of 50 grams or more of cocaine base under section 841(a)(1) and (b)(1)(A)(iii) of the Anti-Drug Abuse Act of 1986 ("ADAA"), 21 U.S.C. 841(a)(1) and (b)(1)(A)(iii), and sentenced to the 120 months prison term mandated by the statute. At issue was whether the term "cocaine base" as used in the statute referred generally to cocaine in its chemically basic form or exclusively to what was colloquially known as "crack cocaine." The court held that "cocaine base," as used in section 841(b)(1), meant not just "crack cocaine," but cocaine in its chemically basic form where, at the time the statute was enacted, "cocaine" was commonly used to refer to powder cocaine, and the scientific and medical literature often used "cocaine" to refer to all cocaine-related substances, including ones that were not chemically basic; where Congress had good reason to include the term "cocaine" in clause (ii), and the slight inconsistency created by its use of "cocaine base" in clause (iii) was insufficient reason to adopt petitioner's interpretation of the statute; and where petitioner's additional arguments were unpersuasive. Accordingly, the court affirmed the judgment of the First Circuit adhering to its precedent holding that "cocaine base" referred to all forms of cocaine. View "DePierre v. United States" on Justia Law

When petitioner pleaded guilty to being a felon in possession of a firearm, he had prior convictions for at least three felonies, including the state-law crime of "using a vehicle" to "knowingly or intentionally" "flee from a law enforcement officer" after being ordered to stop pursuant to Ind. Code 35-44-3-3(b)(1)(A). The Federal District Court decided that the prior convictions subjected petitioner to the 15-year mandatory minimum prison term that the Armed Career Criminal Act ("ACCT"), 18 U.S.C. 924(e), provided for an armed defendant who had three prior "violent felony" convictions. Rejecting petitioner's argument that his vehicle flight felony was not "violent" under the ACCA, the Seventh Circuit affirmed. The Court held that felony vehicle flight, as proscribed by Indiana law, was a violent felony for purposes of the ACCA where felony vehicle flight presented a serious potential risk of physical injury to another; where, because felony vehicle flight was not a strict-liability, negligence, or recklessness crime and was, as a categorical matter, similar in risk to the crimes listed in the residual clause, it was a violent felony; where Indiana treated subsection 35-44-3-3(b)(1)(A) and 35-44-3-3(b)(1)(B) as felonies of the same magnitude carrying similar prison terms; and where Congress had power to enact the residual clause to impose enhanced punishment for unlawful firearm possession when the relevant prior offenses involved a potential risk of physical injury similar to that presented by several enumerated offenses. Accordingly, the court affirmed the judgment of the Seventh Circuit. View "Sykes v. United States" on Justia Law

The Telecommunications Act of 1996, 110 Stat. 56, required incumbent local exchange carriers ("LECs"), providers of local telephone service, to share their physical networks with competitive LECs at cost-based rates. This suit arose when, in the wake of the Federal Communication Commission's ("FCC") Triennial Review Remand Order, respondent notified competitive LECs that it would no longer provide entrance facilities at cost-based rates for either backhauling or interconnection, but would instead charge higher rates. At issue was whether an incumbent provider of local telephone services must make certain transmission facilities available to competitors at cost-based rates. The court held that the FCC had advanced a reasonable interpretation of its regulations, i.e., that to satisfy its duty under 47 U.S.C. 251(c)(2), an incumbent LEC must make its existing entrance facilities available to competitors at cost-based rates if the facilities were to be used for interconnection, and the Court deferred to the FCC's views. View "Talk America, Inc. v. Michigan Bell Telephone Co.; Isiogu, et al. v. Michigan Bell Telephone Co." on Justia Law

Respondents (collectively, "i4i"), holding a patent which claimed an improved method for editing computer documents, sued petitioner, Microsoft Corp. ("Microsoft"), for willful infringement of the patent. Microsoft counterclaimed and sought a declaration that the patent was invalid pursuant to the on-sale bar under Section 102(b) of the Patent Act of 1952 ("Act"), 35 U.S.C. 102(b), which precluded patent protection for any "invention" that was "on sale in this country" more than one year prior to the filing of a patent application. At issue was whether Section 282 of the Act required an invalidity defense to be proved by clear and convincing evidence. The Court rejected Microsoft's contention that a defendant need only persuade the jury of a patent invalidity defense by a preponderance of the evidence and also rejected Microsoft's argument that a preponderance standard must at least apply where the evidence before the factfinder was not before the Patent and Trademark Office during the examination process. Accordingly, the Court held that Section 282 required an invalidity defense to be proved by clear and convincing evidence. The Court also added that it was in no position to judge the comparative force of the parties' policy arguments as to the wisdom of the clear and convincing standard that Congress adopted where any recalibration of the standard of proof remained in Congress' hands. View "Microsoft Corp. v. i4i Limited Partnership" on Justia Law

Claiming that he was subjected to dirty tricks during his successful campaign to become the police chief of Vinton, La., plaintiff filed a state court suit against the incumbent chief and the town (collectively, "defendant") asserting both state and federal law claims. Defendant removed the case to federal court based on plaintiff's 42 U.S.C. 1983 claims and after discovery, defendant sought summary judgment on the federal claims, which plaintiff conceded were not valid. The District Court accordingly dismissed the federal claims with prejudice and remanded the remaining claims to state court, noting that defendant's attorneys' work could be useful in the state court proceedings. Defendant then asked the federal court for attorney's fees. At issue was whether a court could grant reasonable fees to defendant when plaintiff's suit involved both frivolous and non-frivolous claims. The Court held that, when a plaintiff's suit involved both frivolous and non-frivolous claims, a court could grant reasonable fees to defendant, but only for costs that defendant would not have incurred but for the frivolous claims. The Court concluded that, although the District Court noted the usefulness of the attorneys' work in defending against the state law claims, it failed to take proper account of the overlap between the frivolous and non-frivolous claims; the District Court's reasoning that the close relationship between the federal and state law claims supported the award could not be squared with the congressional policy of sparing defendant from the costs only of frivolous litigation; and the Fifth Circuit did not uphold the award on proper ground where it seemed to think that defendant could receive fees for any work useful to defendant against a frivolous claim, even if his lawyers would have done that work regardless. Accordingly, the court vacated and remanded for further proceedings. View "Fox v. Vice" on Justia Law

Petitioner, the lead plaintiff in a putative securities fraud class action, filed suit against respondent alleging violations under section 10(b) of the Securities and Exchange Act of 1934, 15 U.S.C. 78a et seq., and Securities and Exchange Commission Rule 10b-5, and sought to have its proposed class certified pursuant to Federal Rule of Civil Procedure 23. The Court of Appeals affirmed the District Court's conclusion that the "loss causation" element of class certification was not satisfied and denied class certification. At issue was whether securities fraud plaintiffs must also prove loss causation in order to obtain class certification. The Court held that securities fraud plaintiffs need not prove loss causation in order to obtain class certification and that the Court of Appeals' rule contravened Basic Inc. v. Levinson's fundamental premise that an investor presumptively relied on a misrepresentation so long as it was reflected in the market price at the time of his transaction. The Court also distinguished that, where loss causation was a familiar and distinct concept in securities law, it was not price impact. Accordingly, the Court vacated the judgment and remanded for further proceedings. View "Erica P. John Fund, Inc. v. Halliburton Co., et al." on Justia Law

The Board of Trustees of Stanford University filed suit against Roche Molecular Systems ("Roche") claiming that their HIV test kits infringed upon Stanford's patents. The suit stemmed from Stanford's employment of a research fellow who was arranged by his supervisor to work at Cetus, a research company developing methods to quantify blood-borne levels of HIV. The research fellow subsequently devised a PCR-based procedure for measuring the amount of HIV in a patient's blood while working with Cetus employees. The research fellow had entered into an agreement to assign to Stanford his "right, title and interest in" inventions resulting from his employment there and subsequently signed a similar agreement at Cetus. Stanford secured three patents to the measurement process. Roche acquired Cetus's PCR-related assets and commercialized the procedure into HIV test kits. At issue was whether the University and Small Business Patent Procedures Act of 1980, 35 U.S.C. 200 et seq., commonly referred to as the Bayh-Dole Act ("Act"), displaced the basic principle that rights in an invention belonged to the inventor and automatically vested title to federally funded inventions in federal contractors. The Court held that the Act did not automatically vest title to federally funded inventions in federal contractors or authorize contractors to unilaterally take title to such inventions and therefore, affirmed the judgment of the Court of Appeals for the Federal Circuit, which held that the research fellow's agreement with Cetus assigned his rights to Cetus, and subsequently to Roche; that the Act did not automatically void an inventor's rights in federally funded inventions; and thus, the Act did not extinguish Roche's ownership interest in the invention and Stanford was deprived of standing. View "Board of Trustees of the Leland Stanford Junior Univ. v. Roche Molecular Systems, Inc." on Justia Law

Defendant pleaded guilty to unlawful possession of a firearm by a felon, 18 U.S.C. 922(g)(1), and possession with intent to distribute cocaine base, 21 U.S.C. 841(a)(1). At sentencing, the district court determined that defendant qualified for the Armed Career Criminal Act's ("ACCA") sentencing enhancement and defendant conceded that two of his prior convictions were for "violent felonies." Defendant argued, however, that none of his six state drug trafficking convictions were for "serious drug offenses" because those crimes no longer carried a "maximum term of imprisonment of ten years or more" pursuant to 18 U.S.C. 924(e)(1). At issue was how a federal court should determine the maximum sentence for a prior state drug offense for ACCA purposes. The Court held that the "maximum term of imprisonment" for a defendant's prior state drug offense was the maximum sentence applicable to his offense when he was convicted of it where the ACCA's plain text required this result by mandating that the court determine whether a "previous conviction" was for a serious drug offense and where the ACCA's broader context confirmed this interpretation. Accordingly, the district court properly applied ACCA's sentencing enhancement to defendant because all of his six prior drug convictions were for "serious drug offenses." View "McNeill v. United States" on Justia Law