Justia U.S. Supreme Court Opinion Summaries

Before the resumption of federal student-loan repayments that had been suspended during the coronavirus pandemic, the Secretary of Education announced a Plan that would discharge $10,000-$20,000 of an eligible borrower’s debt. The Secretary invoked the 2003 Higher Education Relief Opportunities for Students Act (HEROES Act), which authorizes the Secretary “to waive or modify any provision” applicable to federal student financial assistance programs as “necessary” to ensure that recipients of student financial assistance are no worse off “financially in relation to that financial assistance because” of a national emergency or disaster, 20 U.S.C. 1098. The Act exempts rules promulgated under it from otherwise-applicable negotiated rulemaking and notice-and-comment processes. Borrowers who did not qualify for the Plan's maximum relief alleged that the Secretary was required to follow those rulemaking procedures.The Supreme Court held that the borrowers lacked Article III standing, having failed to establish that any injury they suffer from not having their loans forgiven is fairly traceable to the Plan.The Department also claims authority to forgive loans under the Higher Education Act (HEA), 20 U.S.C. 1082(a)(6). The borrowers cannot show that their purported injury of not receiving HEA loan relief is fairly traceable to the Department’s decision to grant relief under the HEROES Act. They are not claiming that they are injured by not being sufficiently included among the Plan’s beneficiaries but argue the Plan is unlawful and instead seek HEA debt forgiveness. The Department’s authority to grant HEA loan relief is not affected by whether the Plan is lawful. Any incidental effect of the Plan on the likelihood that the Department will undertake loan forgiveness under a different statute is too speculative to show that the absence of HEA-based loan forgiveness is fairly traceable to the Plan. View "Department of Education v. Brown" on Justia Law

The Higher Education Act governs federal financial aid, 20 U.S.C. 1070(a), and authorizes the Secretary of Education to cancel or reduce loans held by some public servants and borrowers who have died, become permanently and totally disabled, are bankrupt, or whose schools falsely certify them, close down, or fail to pay lenders. Under the Higher Education Relief Opportunities for Students Act (HEROES Act), the Secretary “may waive or modify" any statutory or regulatory provision applicable to the loan programs as the Secretary deems "necessary in connection with a war or other military operation or national emergency.” As the COVID–19 pandemic was ending, the Secretary invoked the HEROES Act to issue “waivers and modifications” reducing or eliminating most borrowers' federal student debt. States challenged the plan. The Eighth Circuit issued a nationwide preliminary injunction.The Supreme Court found that the plan exceeded the Secretary’s authority, first holding that at least Missouri had standing. The plan would cost the state's nonprofit government corporation about $44 million a year in fees.The HEROES Act allows the Secretary to “waive or modify” existing statutory or regulatory provisions but does not allow the Secretary to rewrite the Education Act to the extent of canceling $430 billion of student loan principal. The Secretary may make modest adjustments to existing provisions, not transform them. The Act includes narrowly-delineated situations that qualify a borrower for loan discharge; the Secretary has extended such discharge to nearly every borrower. The plan constitutes “effectively" a "whole new regime.” The question is not whether something should be done; it is who has the authority to do it. The basic and consequential tradeoffs inherent in mass debt cancellation are ones that Congress would likely have intended for itself. View "Biden v. Nebraska" on Justia Law

Smith, wanting to expand her graphic design business to include wedding websites, worried that the Colorado Anti-Discrimination Act would require her to create websites celebrating marriages that defy her belief that marriage should be between one man and one woman. Smith intends to produce a story for each couple using her own words and original artwork, combined with the couple’s messages. The Tenth Circuit affirmed the denial of Smith’s request for an injunction.The Supreme Court reversed. The First Amendment prohibits Colorado from forcing a website designer to create expressive designs conveying messages with which the designer disagrees. The First Amendment protects an individual’s right to speak his mind regardless of whether the government considers his speech “misguided.” Generally, the government may not compel a person to speak preferred messages. The wedding websites Smith seeks to create involve her speech and are pure speech protected by the First Amendment. Colorado seeks to put Smith to a choice prohibited by precedent. If she wishes to speak, she must either speak as Colorado demands or face sanctions for expressing her own beliefs.Public accommodations laws are vital to realizing the civil rights of all Americans; governments have a “compelling interest” in eliminating discrimination in places of public accommodation. States may protect gay persons, just as they protect other classes of individuals. However, public accommodations laws are not immune from the demands of the Constitution. Smith does not seek to sell an ordinary commercial good but intends to create “customized and tailored” expressive speech “to celebrate and promote the couple’s wedding.” Speakers do not shed their First Amendment protections by accepting compensation or employing the corporate form to disseminate their speech. Smith will gladly conduct business with those having protected characteristics when the product she is creating does not violate her beliefs. View "303 Creative LLC v. Elenis" on Justia Law

Groff, an Evangelical Christian who believes that Sunday should be devoted to worship and rest, took a mail delivery job with the Postal Service (USPS). USPS subsequently began facilitating Amazon’s Sunday deliveries. To avoid working Sundays on a rotating basis, Groff transferred to a rural USPS station. After Amazon deliveries began at that station, Groff received progressive discipline for failing to work on Sundays. He eventually resigned. Groff sued under Title VII of the Civil Rights Act, asserting that USPS could accommodate his Sunday Sabbath practice “without undue hardship" to its business, 42 U.S.C. 2000e(j). The Third Circuit affirmed summary judgment in favor of USPS, reasoning that under Supreme Court precedent, “requiring an employer ‘to bear more than a de minimis cost’ to provide a religious accommodation is an undue hardship.”The Supreme Court vacated. Title VII requires an employer that denies a religious accommodation to show that the burden of granting an accommodation would result in substantially increased costs in relation to the conduct of its particular business. After tracing Establishment Clause and Title VII jurisprudence, the Court concluded that showing “more than a de minimis cost,” as that phrase is used in common parlance, does not establish “undue hardship” under Title VII. Undue hardship is shown when a burden is substantial in the overall context of the business–a fact-specific inquiry. Courts must consider all relevant factors, including the accommodations at issue and their practical impact, given the nature, size, and operating cost of an employer. Impacts on coworkers are relevant only to the extent those impacts affect the conduct of the business. Title VII requires that an employer “reasonably accommodate” an employee’s practice of religion, not merely assess the reasonableness of a particular possible accommodation. An employer must do more than conclude that forcing other employees to work overtime would constitute an undue hardship; other options must be considered. View "Groff v. DeJoy" on Justia Law

Hetronic (a U.S. company) manufactures remote controls for construction equipment. Abitron Austria, once a licensed Hetronic distributor, claimed ownership of the rights to much of Hetronic’s intellectual property and began employing Hetronic’s marks on products it sold. Hetronic sued Abitron in the Western District of Oklahoma under the Lanham Act, 15 U.S.C. 1114(1)(a), 1125(a)(1). A jury awarded Hetronic approximately $96 million. The Tenth Circuit affirmed, concluding that the Lanham Act extended to “all of [Abitron’s] foreign infringing conduct.”The Supreme Court vacated. Applying the presumption against extraterritoriality, the relevant sections of the Lanham Act are not extraterritorial and extend only to claims where the infringing use in commerce is domestic. Neither provision provides an express statement of extraterritorial application or any other clear indication that it is one of the “rare” provisions that nonetheless applies abroad. Both simply prohibit the use “in commerce” of protected trademarks when that use “is likely to cause confusion.” Because sections 1114(1)(a) and 1125(a)(1) are not extraterritorial, the Court considered the location of the conduct relevant to the focus of the statutory provisions: the unauthorized “use in commerce” of a protected trademark under certain conditions. “Use in commerce” provides the dividing line between foreign and domestic applications of these provisions. View "Abitron Austria GmbH v. Hetronic International, Inc." on Justia Law

In the Harvard College admissions process, “race is a determinative tip for” a significant percentage “of all admitted African American and Hispanic applicants.” University of North Carolina (UNC) also considers the applicant’s race. SFFA challenged both systems.The Supreme Court held that both programs violate the Equal Protection Clause of the Fourteenth Amendment. The Court first held that SFFA complies with the standing requirements for organizational plaintiffs as a voluntary membership organization with identifiable members who support its mission and whom SFFA represents in good faith.Tracing the history of Fourteenth Amendment precedent, the Court acknowledged its "role in that ignoble history,” and subsequent efforts to eliminate racial discrimination. The core purpose of the Equal Protection Clause is to eliminate all governmentally-imposed discrimination based on race. Any exceptions must survive strict scrutiny. which asks whether the racial classification is used to advance compelling governmental interests and whether the use of race is narrowly tailored--necessary to achieve that interest. Previous holdings permitted race-based college admissions only in compliance with strict scrutiny and acknowledged that, eventually, they must end.The admissions programs at issue are not sufficiently measurable to permit strict scrutiny. The identified "compelling" interests include training future leaders, acquiring new knowledge based on diverse outlooks, promoting a robust marketplace of ideas, and preparing engaged and productive citizens. The question of whether a particular mix of minority students produces those results is standardless. The systems fail to articulate a meaningful connection between the means they employ and those goals; they use racial categories that are overbroad, arbitrary or undefined, or underinclusive.The systems also use race as a “negative” and employ stereotypes. College admissions are zero-sum. A benefit provided to some applicants is necessarily at the expense of others. The systems employ “the offensive and demeaning assumption" that students of a particular race think alike. The systems lack a “logical endpoint. View "Students for Fair Admissions, Inc. v. President and Fellows of Harvard College" on Justia Law

From 2014-2016, Counterman sent hundreds of Facebook messages to C.W., a local musician. Each time C.W. tried to block him, Counterman created a new Facebook account and resumed contacting C.W. Several of his messages envisaged violent harm. C.W. stopped walking alone, declined social engagements, canceled performances, and eventually contacted the authorities. Counterman was charged under a Colorado statute making it unlawful to repeatedly make any form of communication with another person in a manner that would cause a reasonable person to suffer serious emotional distress, that does cause that person to suffer serious emotional distress. Colorado courts rejected Counterman’s First Amendment argument.The Supreme Court vacated. In true-threat cases, the prosecution must prove that the defendant had some subjective understanding of his statements’ threatening nature.The First Amendment permits restrictions upon the content of speech in a few areas, including true threats--serious expressions conveying that a speaker means to commit an act of unlawful violence. The existence of a threat depends on what the statement conveys to the person receiving it but the First Amendment may demand a subjective mental-state requirement shielding some true threats because bans on speech have the potential to deter speech outside their boundaries. In this context, a recklessness standard, a showing that a person consciously disregarded a substantial and unjustifiable risk that his conduct will cause harm to another, is the appropriate mental state. Requiring purpose or knowledge would make it harder for states to counter true threats, with diminished returns for protected expression. View "Counterman v. Colorado" on Justia Law

The U.S. Constitution's Election Clause requires the legislature of each state to prescribe rules governing federal elections. Following the 2020 decennial census, North Carolina’s General Assembly drafted a new federal congressional map. The map was challenged under the North Carolina Constitution as impermissible partisan gerrymandering. The North Carolina Supreme Court acknowledged that gerrymandering claims are outside the reach of federal courts but held that such questions were not beyond the reach of North Carolina courts. The court enjoined the use of the maps but subsequently addressed a remedial map adopted by the trial court, repudiated its holding that gerrymandering claims are justiciable under the state constitution, and dismissed the suits without reinstating the 2021 maps.The Supreme Court first held that it had jurisdiction to review the Elections Clause holding. The court’s decision to withdraw its second decision and overrule the first did not moot the case; it did not amend the judgment concerning the 2021 maps nor alter the first decision’s analysis of the federal issue.The Elections Clause does not vest exclusive and independent authority in state legislatures to set the rules regarding federal elections. In prescribing such rules, they remain subject to state judicial review and to state constitutional constraints. When legislatures make laws, they are bound by the documents that give them life. When a state legislature carries out its federal constitutional power to prescribe rules regulating federal elections, it acts both as a lawmaking body created and bound by its state constitution and as the entity assigned particular authority by the U.S. Constitution. Both constitutions restrain that exercise of power. Federal courts must not abandon their duty to exercise judicial review. The Court declined to decide whether the North Carolina Supreme Court strayed beyond the limits derived from the Elections Clause. View "Moore v. Harper" on Justia Law

Mallory worked as a Norfolk mechanic for 20 years in Ohio and Virginia. After leaving the company, Mallory moved to Pennsylvania, then returned to Virginia. He attributed his cancer diagnosis to his work and sued Norfolk under the Federal Employers’ Liability Act, in Pennsylvania state court. Norfolk, incorporated and headquartered in Virginia, challenged the court’s exercise of personal jurisdiction. Mallory noted that Norfolk manages over 2,000 miles of track, operates 11 rail yards, runs locomotive repair shops in Pennsylvania, and has registered to do business in Pennsylvania in light of its "regular, systematic, extensive” operations there. Pennsylvania requires out-of-state companies that register to do business to agree to appear in its courts on “any cause of action” against them. 42 Pa. Cons. Stat. 5301(a)(2)(i), (b). The Pennsylvania Supreme Court held that the Pennsylvania law violated the Due Process Clause.The Supreme Court vacated. Pennsylvania law is explicit that qualification as a foreign corporation shall permit state courts to exercise general personal jurisdiction over a registered foreign corporation. Norfolk has complied with this law since 1998 when it registered to do business in Pennsylvania. Norfolk's “Certificate of Authority” from the Commonwealth conferred both the benefits and burdens shared by domestic corporations, including amenability to suit in state court on any claim. For more than two decades, Norfolk has agreed to be found in Pennsylvania and answer any suit there. Suits premised on these grounds do not deny a defendant due process of law. Regardless of whether any other statutory scheme and set of facts would establish consent to suit, this state law and these facts fall within Supreme Court precedent. View "Mallory v. Norfolk Southern Railway Co." on Justia Law

In 2021, the Secretary of Homeland Security promulgated Guidelines for the Enforcement of Civil Immigration Law that prioritize the arrest and removal from the U.S. of noncitizens who are suspected terrorists or dangerous criminals or who have unlawfully entered the country only recently. Texas and Louisiana claimed that the Guidelines contravened federal statutes that require the arrest of certain noncitizens upon their release from prison (8 U.S.C. 1226(c)) or entry of a final order of removal (1231(a)(2)). The district court found that the states had standing, citing costs they would incur, then found the Guidelines unlawful. The Fifth Circuit declined to stay the judgment.The Supreme Court reversed. Texas and Louisiana lack Article III standing to challenge the Guidelines. To establish standing, a plaintiff must show an injury in fact caused by the defendant and redressable by a court order. The alleged injury must “be legally and judicially cognizable.” There is no precedent, history, or tradition of federal courts entertaining lawsuits of this kind; a plaintiff lacks standing to bring such a suit “when he himself is neither prosecuted nor threatened with prosecution.” Such lawsuits implicate the Executive’s Article II authority to decide how to prioritize and how aggressively to pursue legal actions against defendants who violate the law, which extends to the immigration context. The Court stated that the standing calculus might change if the Executive Branch wholly abandoned its statutory responsibilities to make arrests or bring prosecutions and that policies governing the continued detention of noncitizens who have been arrested arguably might raise different standing questions. View "United States v. Texas" on Justia Law