Justia U.S. Supreme Court Opinion Summaries

California’s Proposition 12 forbids the in-state sale of whole pork meat that comes from breeding pigs (or their immediate offspring) that are “confined in a cruel manner.” Confinement is “cruel” if it prevents a pig from “lying down, standing up, fully extending [its] limbs, or turning around freely.” Opponents alleged that Proposition 12 violated the Constitution by impermissibly burdening interstate commerce, arguing that the cost of compliance with Proposition 12 will increase production costs and, because California imports almost all the pork it consumes, most of Proposition 12’s compliance costs will be borne by out-of-state firms.The Ninth Circuit and Supreme Court affirmed the dismissal of the case, rejecting arguments under the dormant Commerce Clause. Absent purposeful discrimination, a state may exclude from its territory, or prohibit the sale therein of any articles which, in its judgment, fairly exercised, are prejudicial to the interests of its citizens. Proposition 12 imposes the same burdens on in-state pork producers that it imposes on out-of-state pork producers. Proposition 12 does not implicate the antidiscrimination principle.The Court rejected an argument that its precedents include an “almost per se” rule forbidding enforcement of state laws that have the practical effect of controlling commerce outside the state, even when those laws do not purposely discriminate against out-of-state interests. While leaving the courtroom door open to challenges premised on even nondiscriminatory burdens, the Court noted that “extreme caution is warranted.” View "National Pork Producers Council v. Ross" on Justia Law

Santos-Zacaria, a noncitizen in removal proceedings, was denied protection from removal. The Fifth Circuit dismissed Santos-Zacaria’s petition for review in part, finding that she had not satisfied 8 U.S.C. 1252(d)(1)’s (Judicial Review of Orders of Removal) exhaustion requirement, which it raised sua sponte based on its characterization of 1252(d)(1)’s exhaustion requirement as jurisdictional. Santos-Zacaria did not raise her impermissible fact-finding claim to the Board of Immigration Appeals (BIA) in a motion for reconsideration before filing her petition for judicial review.The Supreme Court vacated in part. Section 1252(d)(1)’s exhaustion requirement is not jurisdictional. To ensure that courts impose the harsh consequences of jurisdictional rules only when Congress unmistakably has so instructed, a rule is treated as jurisdictional “only if Congress ‘clearly states’ that it is.” Section 1252(d)(1) lacks a clear statement. Exhaustion requirements are quintessential claim-processing rules, designed to promote efficiency in litigation. Section 1252(d)(1)’s language differs substantially from the jurisdictional language in related statutory provisions. Section 1252(d)(1) requires exhausting only remedies available “as of right,” meaning review that is guaranteed, not discretionary. Reconsideration by the BIA, however, is discretionary. The right to request discretionary review does not make a remedy available as of right. The Court noted the practical problems that would arise under the government’s interpretation. View "Santos-Zacaria v. Garland" on Justia Law

Then-New York Governor Cuomo’s “Buffalo Billion” initiative administered through Fort Schuyler Management Corporation, a nonprofit affiliated with SUNY, aimed to invest $1 billion in upstate development projects. Investigations later uncovered a scheme that involved Cuomo’s associates--a member of Fort Schuyler’s board of directors and a construction company made payments to a lobbyist with ties to the Cuomo administration. Fort Schuyler’s bid process subsequently allowed the construction company to receive major Buffalo Billion contracts.The participants were charged with wire fraud and conspiracy to commit wire fraud 18 U.S.C. 1343, 1349. Under the Second Circuit’s “right to control” theory, wire fraud can be established by showing that the defendant schemed to deprive a victim of potentially valuable economic information necessary to make discretionary economic decisions. The jury instructions defined “property” as including “intangible interests such as the right to control the use of one’s assets,” and “economically valuable information” as “information that affects the victim’s assessment of the benefits or burdens of a transaction, or relates to the quality of goods or services received or the economic risks.” The Second Circuit affirmed the convictions.The Supreme Court reversed. Under Supreme Court precedents the federal fraud statutes criminalize only schemes to deprive people of traditional property interests. The prosecution must prove that wire fraud defendants “engaged in deception,” and also that money or property was “an object of their fraud.” The "fraud statutes do not vest a general power in the federal government to enforce its view of integrity in broad swaths of state and local policymaking.” The right-to-control theory applies to an almost limitless variety of deceptive actions traditionally left to state contract and tort law. The Court declined to affirm Ciminelli’s convictions on the ground that the evidence was sufficient to establish wire fraud under a traditional property-fraud theory. View "Ciminelli v. United States" on Justia Law

Percoco served as the Executive Deputy Secretary to New York Governor Cuomo from 2011-2016. During an eight-month hiatus in 2014, Percoco resigned from government service to manage the Governor’s reelection campaign; he accepted payments totaling $35,000 to assist a real-estate development company in dealings with Empire State Development, a state agency. Percoco urged a senior ESD official to drop a requirement of an agreement with local unions as a precondition to receiving state funding. ESD informed the company the following day that the agreement was not necessary.Percoco was convicted of conspiracy to commit honest-services wire fraud, 18 U.S.C. 1343, 1346. The court instructed the jury that Percoco could be found to have had a duty to provide honest services to the public during the time when he was not serving as a public official if the jury concluded that “he dominated and controlled any governmental business” and that “people working in the government actually relied on him because of a special relationship he had with the government.” The Second Circuit affirmed.The Supreme Court reversed, finding the jury instruction erroneous. The instructions did not define “the intangible right of honest services” with sufficient definiteness. The Court cited its 2010 “Skilling” rejection of the prosecution’s argument that section 1346 should apply to cases involving undisclosed self-dealing by a public official or private employee, While a person nominally outside public employment could have the necessary fiduciary duty to the public “the intangible duty of honest services” does not extend a duty to the public to all private persons. View "Percoco v. United States" on Justia Law

Convicted of the 1996 strangulation murder of Stites, Reed was sentenced to death. The Texas Court of Criminal Appeals affirmed. Reed’s state and federal habeas petitions were unsuccessful. In 2014, Reed sought DNA testing of the evidence. The prosecutor refused to test most of the evidence. The court denied Reed’s motion; the Texas Court of Criminal Appeals affirmed, citing chain of custody issues.Reed filed suit, 42 U.S.C. 1983, asserting that Texas’s stringent chain-of-custody requirement was unconstitutional and effectively foreclosed DNA testing for individuals convicted before the promulgation of rules governing the handling and storage of evidence. The Fifth Circuit affirmed the dismissal of the suit, finding that the two-year statute of limitations began to run when the Texas trial court denied Reed’s motion, not when the Texas Court of Criminal Appeals denied rehearing.The Supreme Court reversed. The statute of limitations began to run at the end of the state-court litigation. Establishing a procedural due process violation requires proof of deprivation by state action of a protected interest in life, liberty, or property, and inadequate state process. The claim is not complete when the deprivation occurs but only when the state fails to provide due process. Texas’s alleged failure to provide Reed with a fundamentally fair process was complete when the state litigation ended and deprived Reed of his asserted liberty interest in DNA testing. If the statute of limitations began to run after a state trial court’s denial of the motion, the prisoner would likely continue to pursue state court relief while filing a federal section 1983 suit. That parallel litigation would run counter to principles of federalism, comity, consistency, and judicial economy. If any due process flaws lurk in the DNA testing law, the state appellate process may cure those flaws, rendering a federal suit unnecessary. View "Reed v. Goertz" on Justia Law

Halkbank is owned by the Republic of Turkey. The United States indicted Halkbank for conspiracy to evade economic sanctions imposed by the United States on Iran by laundering Iranian oil and gas proceeds and making false statements to the Treasury Department. Two individuals, including a former Halkbank executive, have been convicted for their roles in the conspiracy. The Second Circuit affirmed the denial of Halkbank’s motion to dismiss.The Supreme Court held that the district court has jurisdiction under the general federal criminal jurisdiction statute, 18 U.S.C. 3231; the Foreign Sovereign Immunities Act (FSIA), 28 U.S.C. 1330 does not provide immunity.Section 3231’s text encompasses the charged offenses; the Court declined to limit the broad jurisdictional grant to exclude suits against foreign states and their instrumentalities “simply because" unrelated U.S. Code provisions "happen to expressly reference foreign states and instrumentalities.”FSIA's text exclusively addresses civil suits against foreign states and their instrumentalities. Although most litigation involving foreign states and their instrumentalities at the time of the FSIA’s 1976 enactment was civil, the Executive Branch occasionally attempted to subject foreign-government-owned entities to federal criminal investigations. Given that history, it is unlikely that Congress sought to codify foreign sovereign immunity from criminal proceedings without mentioning such proceedings. Congress housed FSIA within Title 28, which mostly concerns civil procedure, not in Title 18, which addresses crimes and criminal procedure. Under Halkbank’s view, a commercial business that is owned by a foreign state could engage in criminal conduct affecting U.S. citizens and threatening U.S. national security while facing no criminal accountability in U.S. courts. The Court rejected various arguments that U.S. criminal proceedings against instrumentalities of foreign states would negatively affect national security and foreign policy. The Court remanded for consideration of arguments regarding common-law immunity. View "Turkiye Halk Bankasi A.S. v. United States" on Justia Law

In Chapter 11 bankruptcy, Sears, as a debtor in possession, exercised its rights under 11 U.S.C. 363(b)(1) and sold most of its assets to Transform, including the right to designate to whom a lease should be assigned. Section 365 prohibits the assignment of an unexpired lease without “adequate assurance of future performance by the assignee,” and establishes special criteria related to “shopping center[s],” Transform designated the Mall of America lease for assignment. The landlord, MOAC, objected, arguing that Sears had failed to provide adequate assurance. The Bankruptcy Court approved the assignment.Section 363(m) states that the reversal or modification on appeal of a 363(b) authorization of a sale or lease does not affect the validity of a sale or lease to an entity that purchased or leased the property in good faith, even if the entity knew of the pendency of the appeal unless the court entered a stay pending appeal. The Bankruptcy Court denied MOAC’s request for a stay. Sears assigned the lease. The Second Circuit affirmed the dismissal of the appeal, treating 363(m) as jurisdictional.The Supreme Court vacated. Section 363(m) is not jurisdictional and is not, therefore, impervious to excuses like waiver or forfeiture. The Court noted the consequences of deeming the section jurisdictional–even egregious conduct by a litigant could permit the application of judicial estoppel against a jurisdictional rule. Courts should only treat a provision as jurisdictional if Congress “clearly states” as much. Nothing in 363(m) purports to govern a court’s adjudicatory capacity; it plainly contemplates that appellate courts might reverse or modify any covered authorization, with a limitation on the consequences. Congress separated 363(m) from jurisdictional provisions. The Court rejected Transform’s argument that the transfer to a good-faith purchaser removes the property from the bankruptcy estate, and so from the court’s in rem jurisdiction. View "MOAC Mall Holdings LLC v. Transform Holdco LLC" on Justia Law

The SEC and FTC initiated enforcement actions. Instead of making a claim within the Commission itself, and then (if needed) in a federal court of appeals, the subjects of the actions filed constitutional claims in federal district courts, arguing that the ALJs are insufficiently accountable to the President, in violation of separation-of-powers principles. One suit also challenged the combination of prosecutorial and adjudicatory functions within the agency. The Ninth Circuit held that the FTC's statutory review scheme precluded district court jurisdiction. The Fifth Circuit disagreed with respect to the SEC.The Supreme Court reversed the Ninth Circuit and affirmed the Fifth Circuit. The review schemes set out in the Securities Exchange Act, 15 U.S.C. 78a, and the FTC Act, 15 U.S.C. 41, do not displace district court jurisdiction over the far-reaching constitutional claims at issue.A statutory review scheme may preclude district courts from exercising “federal question” jurisdiction over challenges to federal agency action but does not necessarily extend to every claim. The relevant question is whether the particular claims brought were “of the type Congress intended to be reviewed within this statutory structure.” The claims here challenge functions at the core of the agencies' existence. They do not challenge any specific substantive decision or commonplace procedures. The alleged harm is “being subjected” to “unconstitutional agency authority.” It is impossible to remedy that harm once the proceeding is over and appellate review becomes available. The claims do not depend on winning or losing before the agency. The separation-of-powers claims are collateral to any Commission orders or rules from which review might be sought. The claims are outside the agencies’ expertise. Agency adjudications are generally ill-suited to address structural constitutional challenges and these constitutional claims are not intertwined with matters on which the Commissions are experts. View "Axon Enterprise, Inc. v. Federal Trade Commission" on Justia Law

Petitioners acquired their properties along the road in 1991 and 2004; in 1962, their predecessors in interest had granted the government an easement for the road. The government moved to dismiss the petitioners' suit under the Quiet Title Act, citing the 12-year limitations period, 28 U.S.C. 2409a(g). The Ninth Circuit affirmed the dismissal for lack of jurisdiction.The Supreme Court reversed, characterizing section 2409a(g) as a non-jurisdictional claim-processing rule, intended to promote the orderly progress of litigation. Limits on subject-matter jurisdiction have a unique potential to disrupt the orderly course of litigation, so courts should not lightly apply that label to procedures Congress enacted to keep things running smoothly unless traditional tools of statutory construction plainly show that Congress imbued a procedural bar with jurisdictional consequences. Congress’s separation of a filing deadline from a jurisdictional grant indicates that the time bar is not jurisdictional. The Quiet Title Act’s jurisdictional grant is in section 1346(f ), far from 2409a(g), with nothing linking those separate provisions. Section 2409a(g) speaks only to a claim’s timeliness.The Court characterized a case cited by the government as a “textbook drive-by jurisdictional” ruling that “should be accorded no precedential effect” as to whether a limit is jurisdictional. Rejecting other cited cases, the Court stated that it has never definitively interpreted section 2409a(g) as jurisdictional. View "Wilkins v. United States" on Justia Law

The Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400, includes administrative procedures for resolving disputes concerning a free and appropriate public education (FAPE) for a child with a disability. “Nothing in [IDEA] shall be construed to restrict” the ability of individuals to seek “remedies” under “other Federal laws protecting the rights of children with disabilities,” section 1415(l), “except that before the filing of a civil action under such [other federal] laws seeking relief that is also available under this subchapter, the procedures under subsections (f) and (g) shall be exhausted.” Those subsections establish the right to a “due process hearing” followed by an “appeal” to the state education agency.Perez, who is deaf, attended Sturgis public schools and was provided with aides to translate classroom instruction into sign language. Perez alleges that the aides were either unqualified or absent from the classroom. Sturgis allegedly promoted Perez regardless of his progress. Perez believed he was on track to graduate from high school. Months before graduation, Sturgis revealed that it would not award him a diploma.Perez filed a complaint with the Michigan Department of Education. Before an administrative hearing, the parties settled. Sturgis promised to provide Perez with forward-looking equitable relief, including additional schooling at the Michigan School for the Deaf. Perez then sought compensatory damages under the Americans with Disabilities Act (ADA), 42 U.S.C. 12101. The district court dismissed the suit based on Sixth Circuit precedent.The Supreme Court reversed, reasoning that compensatory damages are unavailable under IDEA. Although Perez’s suit is premised on the denial of a FAPE, the administrative exhaustion requirement applies only to suits that “see[k] relief … also available under” IDEA. View "Perez v. Sturgis Public Schools" on Justia Law