Justia U.S. Supreme Court Opinion Summaries

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

The Disputed Instruments, prepaid financial instruments used to transfer funds to a named payee, are sold by banks on behalf of MoneyGram and others. When these instruments are not presented for payment within a certain period of time, they are deemed abandoned. MoneyGram applies the common-law escheatment practices outlined in 1965 by the Supreme Court: The proceeds of abandoned financial products should escheat to the state of the creditor’s last known address, or where such records are not kept, to the state in which the company holding the funds is incorporated. MoneyGram does not keep records of creditor addresses but transmits the abandoned proceeds to its state of incorporation. States invoked the Supreme Court’s original jurisdiction to determine whether the abandoned proceeds of the Disputed Instruments are governed by the Disposition of Abandoned Money Orders and Traveler’s Checks Act (FDA), which provides that a money order or “similar written instrument (other than a third-party bank check)” should generally escheat to the state in which the instrument was purchased, 12 U.S.C. 2503.The Court held that the Disputed Instruments are sufficiently similar to money orders to fall within the FDA’s “similar written instrument” category. Being prepaid makes them likely to escheat. The FDA was passed to abrogate common law because, for instruments like money orders, the entities selling such products often did not keep records of creditor addresses, resulting in a “windfall” to the state of incorporation. Bank liability is not a trigger for exclusion, given that banks can be liable on money orders, which are expressly covered. Whatever the intended meaning of “third-party bank check,” it cannot be read broadly to exclude prepaid instruments that escheat inequitably due to the business practices of the company holding the funds. View "Delaware v. Pennsylvania" on Justia Law

The Bank Secrecy Act requires U.S. persons with financial interests in foreign accounts to file an “FBAR” annual Report of Foreign Bank and Financial Accounts; 31 U.S.C. 5314 delineates legal duties while section 5321 outlines the penalties, with a maximum $10,000 penalty for non-willful violations. Bittner—a dual citizen of Romania and the U.S.—learned of his reporting obligations in 2011 and subsequently submitted reports covering 2007-2011. The government deemed Bittner’s late reports deficient because they did not address all accounts as to which Bittner had either signatory authority or a qualifying interest. Bittner filed corrected FBARs providing information for 61 accounts in 2007, 51 in 2008, 53 in 2009 and 2010, and 54 in 2011. The government asserted that non-willful penalties apply to each account not accurately or timely reported. Bittner’s reports collectively involved 272 accounts; the government calculated a $2.72 million penalty. The Fifth Circuit affirmed.The Supreme Court reversed. The $10,000 maximum penalty for non-willful failure to file a compliant report accrues on a per-report, not a per-account, basis. Section 5314 does not address accounts or their number. An individual files a compliant report or does not. For cases involving willful violations, the statute tailors penalties to accounts. When one section of a statute includes language omitted from a neighboring section, the difference normally conveys a different meaning. The Act's implementing regulations require individuals with fewer than 25 accounts to provide details about each account while individuals with 25 or more accounts do not need to list each account or provide account-specific details unless requested by the Secretary. View "Bittner v. United States" on Justia Law

Hewitt filed suit under the Fair Labor Standards Act (FLSA), which guarantees overtime pay to covered employees when they work more than 40 hours a week. From 2014-2017, Hewitt typically worked 84 hours per week on Helix's offshore oil rig, while on the vessel. Helix paid Hewitt a daily rate. Hewitt’s paycheck amounted to his daily rate times the number of days he worked. Hewitt earned over $200,000 annually.Helix argued that Hewitt was exempt from the FLSA as “a bona fide executive,” 29 U.S.C. 213(a)(1). An employee is considered an exempt bona fide executive if the employee meets the “salary basis” test, which requires that an employee receive a predetermined and fixed salary that does not vary with the amount of time worked, the “salary level” test, and the job “duties” test.The Supreme Court affirmed the Fifth Circuit. Hewitt was not exempt from the FLSA’s overtime pay guarantee. A daily-rate employee does not fall within the main salary-basis provision of 29 CFR 541.602(a)--the employee regularly receives each pay period a predetermined amount, “not subject to reduction because of variations in the quality or quantity of the work performed.” A daily-rate worker is paid for each day he works and no others. Daily-rate workers, of whatever income level, qualify as paid on a salary basis under 29 CFR 541.604(b) only if an employer also provides a guarantee of weekly payment approximating what the employee usually earns. Reading 602(a) also to cover daily- and hourly-rate employees would subvert 604(b)’s strict conditions on when their pay counts as a “salary.” There is no simple income level test for the exemption. View "Helix Energy Solutions Group, Inc. v. Hewitt" on Justia Law

Kate and David Bartenwerfer remodeled the house they jointly owned. David oversaw the project. Kate remained largely uninvolved. They sold the house to Buckley, attesting that they had disclosed all material facts. Buckley discovered undisclosed defects and won a California state court judgment, leaving the Bartenwerfers jointly responsible for more than $200,000. The Bartenwerfers filed for Chapter 7 bankruptcy. Buckley filed an adversary complaint, alleging that the state-court judgment debt was non-dischargeable as “any debt . . . for money . . . to the extent obtained by . . . false pretenses, a false representation, or actual fraud,” 11 U.S.C. 523(a)(2)(A).The Bankruptcy Court imputed David's fraudulent intent to Kate, citing their legal partnership to renovate and sell the property. The Bankruptcy Appellate Panel held that section 523(a)(2)(A) barred Kate from discharging the debt only if she knew or had reason to know of David’s fraud. The Ninth Circuit reversed.The Supreme Court affirmed. Section 523(a)(2)(A) precludes Kate from discharging a debt obtained by fraud, regardless of her own culpability. The passive voice in section 523(a)(2)(A) removes the actor; fraud liability is not limited to the wrongdoer. The fraud of one partner should be imputed to other partners, who “received and appropriated the fruits of the fraudulent conduct.” Section 523(a)(2)(A) takes the debt as it finds it, so if California did not extend liability to honest partners, it would have no role. Fraud liability generally requires a special relationship with the wrongdoer and, even then, defenses are available. View "Bartenwerfer v. Buckley" on Justia Law