Justia U.S. Supreme Court Opinion Summaries

Salvatore Delligatti, an associate of the Genovese crime family, was convicted of using or carrying a firearm during a crime of violence under 18 U.S.C. §924(c). He had recruited gang members to kill a suspected police informant and provided them with a loaded revolver. Delligatti was charged with attempted murder under the violent-crimes-in-aid-of-racketeering (VICAR) statute, which required proof of attempted second-degree murder under New York law. He argued that a VICAR offense predicated on New York second-degree murder is not a crime of violence because homicide under New York law can be committed by omission.The District Court denied Delligatti’s motion to dismiss the §924(c) charge, holding that VICAR attempted murder is a crime of violence. A jury convicted Delligatti on all counts, and he was sentenced to 25 years in prison. The U.S. Court of Appeals for the Second Circuit affirmed the District Court’s decision, relying on the precedent set in United States v. Scott, which held that the knowing or intentional causation of bodily injury necessarily involves the use of physical force, even when the harm is caused by omission.The Supreme Court of the United States affirmed the Second Circuit’s decision. The Court held that the knowing or intentional causation of injury or death, whether by act or omission, necessarily involves the use of physical force against another person within the meaning of §924(c)(3)(A). The Court reasoned that it is impossible to deliberately cause physical harm without the use of physical force, extending the logic of United States v. Castleman to §924(c). The Court concluded that New York second-degree murder, including by omission, qualifies as a crime of violence under §924(c)’s elements clause. View "Delligatti v. United States" on Justia Law

Patrick Thompson took out three loans totaling $219,000 from a bank. After the bank failed, the FDIC took over the collection of the loans. Thompson disputed the $269,120.58 balance shown on his invoice, claiming he had only borrowed $110,000. He made similar statements in subsequent calls with FDIC contractors. Thompson was charged with violating 18 U.S.C. §1014, which prohibits making false statements to influence the FDIC’s actions on a loan. A jury found him guilty, and he moved for acquittal, arguing his statements were not false since he had indeed borrowed $110,000, even though he later borrowed more.The District Court denied Thompson’s motion, stating that the Seventh Circuit does not require literal falsity for a §1014 conviction and that misleading statements could suffice. The Seventh Circuit affirmed, citing its precedent that §1014 criminalizes misleading representations. The court found Thompson’s statements misleading because they implied he owed no more than $110,000, despite his total debt being $219,000.The Supreme Court of the United States reviewed the case and held that §1014 does not criminalize statements that are misleading but not false. The Court emphasized that the statute uses the word “false,” which means “not true,” and does not include “misleading.” The Court noted that many other statutes explicitly prohibit both false and misleading statements, indicating that Congress knew how to include misleading statements when it intended to do so. The Court vacated the Seventh Circuit’s judgment and remanded the case to determine whether a reasonable jury could find that Thompson’s statements were false. View "Thompson v. United States" on Justia Law

Petitioners, veterans Joshua Bufkin and Norman Thornton, applied for service-connected PTSD disability benefits from the Department of Veterans Affairs (VA). Bufkin's claim was denied due to insufficient evidence linking his PTSD to his military service. Thornton, who already received benefits, sought an increased disability rating, which the VA denied. Both cases were reviewed de novo by the Board of Veterans’ Appeals, which upheld the VA's decisions. Bufkin and Thornton then appealed to the U.S. Court of Appeals for Veterans Claims, arguing that the evidence was in "approximate balance" and they were entitled to the benefit of the doubt.The Veterans Court affirmed the Board's decisions, finding no clear error in the approximate-balance determinations. Petitioners appealed to the Federal Circuit, challenging the Veterans Court's interpretation of 38 U.S.C. §7261(b)(1). They argued that the Veterans Court should review the entire record de novo to determine if the evidence was in approximate balance. The Federal Circuit rejected this argument and affirmed the Veterans Court's decisions.The Supreme Court of the United States reviewed the case and held that the VA's determination of whether evidence is in "approximate balance" is predominantly a factual determination, subject to clear-error review. The Court clarified that the Veterans Court must review the VA's application of the benefit-of-the-doubt rule using the same standards as other determinations: de novo for legal issues and clear error for factual issues. The judgment of the Federal Circuit was affirmed. View "Bufkin v. Collins" on Justia Law

The City and County of San Francisco operates two combined wastewater treatment facilities that process both wastewater and stormwater. During heavy precipitation, these facilities may discharge untreated water into the Pacific Ocean or San Francisco Bay. In 2019, the Environmental Protection Agency (EPA) issued a renewal permit for San Francisco's Oceanside facility, adding two "end-result" requirements. These requirements prohibited discharges that contribute to violations of water quality standards and discharges that create pollution, contamination, or nuisance as defined by California law. San Francisco challenged these provisions, arguing they exceeded the EPA's statutory authority.The California Regional Water Quality Control Board and the EPA approved the final Oceanside NPDES permit. San Francisco appealed to the EPA's Environmental Appeals Board, which rejected the challenge. The City then petitioned for review in the Ninth Circuit, which denied the petition. The Ninth Circuit held that the Clean Water Act (CWA) authorizes the EPA to impose any limitations necessary to ensure water quality standards are met in receiving waters.The Supreme Court of the United States reviewed the case and held that Section 1311(b)(1)(C) of the CWA does not authorize the EPA to include "end-result" provisions in NPDES permits. The Court reasoned that determining the specific steps a permittee must take to meet water quality standards is the EPA's responsibility, and Congress has provided the necessary tools for the EPA to make such determinations. The Court reversed and remanded the Ninth Circuit's decision, emphasizing that the EPA must set specific rules for permittees to follow rather than imposing broad end-result requirements. View "City and County of San Francisco v. EPA" on Justia Law

Gary Waetzig, a former employee of Halliburton Energy Services, Inc., filed a federal age-discrimination lawsuit against the company. He later submitted his claims for arbitration and voluntarily dismissed his federal lawsuit without prejudice under Federal Rule of Civil Procedure 41(a). After losing in arbitration, Waetzig sought to reopen his dismissed lawsuit and vacate the arbitration award, citing Federal Rule of Civil Procedure 60(b) as the basis for reopening the case.The U.S. District Court for the District of Colorado reopened the case, ruling that a voluntary dismissal without prejudice counts as a "final proceeding" under Rule 60(b) and that Waetzig made a mistake by dismissing his case rather than seeking a stay. The District Court also granted Waetzig's motion to vacate the arbitration award. Halliburton appealed, and the Tenth Circuit reversed the District Court's decision, holding that a voluntary dismissal without prejudice does not count as a "final judgment, order, or proceeding" under Rule 60(b).The Supreme Court of the United States reviewed the case and held that a case voluntarily dismissed without prejudice under Rule 41(a) counts as a "final proceeding" under Rule 60(b). The Court reasoned that a voluntary dismissal is "final" because it terminates the case and aligns with the definitions and historical context of the term "final." The Court also concluded that a voluntary dismissal qualifies as a "proceeding" under Rule 60(b), encompassing all steps in an action's progression. The judgment of the Tenth Circuit was reversed, and the case was remanded for further proceedings consistent with the Supreme Court's opinion. View "Waetzig v. Halliburton Energy Services, Inc." on Justia Law

Dewberry Engineers sued Dewberry Group for trademark infringement under the Lanham Act, alleging that Dewberry Group's use of the "Dewberry" name violated their trademark rights. Dewberry Group, a real-estate development company, provides services to separately incorporated affiliates, which own commercial properties. The affiliates generate rental income, while Dewberry Group operates at a loss, surviving through cash infusions from its owner, John Dewberry.The District Court found Dewberry Group liable for trademark infringement and awarded Dewberry Engineers nearly $43 million in profits. The court treated Dewberry Group and its affiliates as a single corporate entity, totaling the affiliates' real-estate profits to calculate the award. The Fourth Circuit Court of Appeals affirmed this decision, agreeing with the District Court's approach to treat the companies as a single entity due to their economic reality.The Supreme Court of the United States reviewed the case and held that the District Court erred in treating Dewberry Group and its affiliates as a single corporate entity for calculating profits. The Court ruled that under the Lanham Act, only the profits of the named defendant, Dewberry Group, could be awarded. The affiliates' profits could not be considered as the defendant's profits since they were not named as defendants in the lawsuit. The Supreme Court vacated the Fourth Circuit's decision and remanded the case for a new award proceeding consistent with its opinion. View "Dewberry Group, Inc. v. Dewberry Engineers Inc." on Justia Law

Virginia drivers whose licenses were suspended for failing to pay court fines challenged the constitutionality of the statute under 42 U.S.C. §1983. The District Court granted a preliminary injunction preventing enforcement of the statute. Before the case reached final judgment, the Virginia General Assembly repealed the statute, requiring reinstatement of the suspended licenses. The parties agreed to dismiss the case as moot.The District Court declined to award attorney’s fees to the drivers under §1988(b), reasoning that obtaining a preliminary injunction did not qualify them as “prevailing parties.” A Fourth Circuit panel affirmed this decision, but the Fourth Circuit en banc reversed, holding that some preliminary injunctions can provide lasting, merits-based relief, qualifying plaintiffs as prevailing parties even if the case becomes moot before final judgment.The Supreme Court of the United States reviewed the case and held that the drivers, who only obtained preliminary injunctive relief before the action became moot, do not qualify as “prevailing parties” eligible for attorney’s fees under §1988(b). The Court reasoned that no court conclusively resolved their claims by granting enduring judicial relief on the merits that materially altered the legal relationship between the parties. The judgment of the Fourth Circuit was reversed, and the case was remanded for further proceedings consistent with this opinion. View "Lackey v. Stinnie" on Justia Law

In 1997, Justin Sneed murdered Barry Van Treese at an Oklahoma hotel managed by Richard Glossip. Sneed claimed Glossip orchestrated the murder to steal Van Treese's money. Glossip denied involvement but was convicted and sentenced to death based on Sneed's testimony. The Oklahoma Court of Criminal Appeals (OCCA) overturned the initial conviction due to ineffective defense counsel but upheld a second conviction despite inconsistencies in Sneed's testimony and new evidence suggesting prosecutorial misconduct.The OCCA initially reversed Glossip's conviction due to ineffective assistance of counsel but affirmed his second conviction, finding sufficient circumstantial evidence to support Sneed's testimony. Glossip's subsequent habeas petitions were unsuccessful. An independent investigation commissioned by Oklahoma legislators raised doubts about the conviction, revealing prosecutorial misconduct, including the destruction of evidence and false portrayal of Sneed. The State disclosed previously withheld documents, including evidence of Sneed's bipolar disorder and false testimony about his lithium prescription.The Supreme Court of the United States reviewed the case, focusing on whether the prosecution violated its constitutional obligation to correct false testimony under Napue v. Illinois. The Court found that the prosecution knowingly allowed Sneed to falsely testify about his lithium prescription and failed to correct it. This false testimony was material, as Sneed's credibility was crucial to Glossip's conviction. The Court held that the prosecution's failure to correct the false testimony violated Glossip's due process rights, warranting a new trial. The judgment of the OCCA was reversed, and the case was remanded for further proceedings consistent with this opinion. View "Glossip v. Oklahoma" on Justia Law

Jewish survivors of the Hungarian Holocaust and their heirs sued Hungary and its national railway (MÁV) in federal court, seeking damages for property allegedly seized during World War II. They claimed that Hungary and MÁV liquidated the expropriated property, commingled the proceeds with other government funds, and later used funds from those commingled accounts in connection with commercial activities in the United States.The District Court for the District of Columbia determined that the plaintiffs' "commingling theory" satisfied the commercial nexus requirement of the Foreign Sovereign Immunities Act (FSIA) expropriation exception. The D.C. Circuit affirmed, reasoning that requiring plaintiffs to trace the particular funds from the sale of their specific expropriated property to the United States would make the exception a "nullity" in cases involving liquidated property.The Supreme Court of the United States reviewed the case and held that alleging commingling of funds alone cannot satisfy the commercial nexus requirement of the FSIA’s expropriation exception. The Court emphasized that plaintiffs must trace either the specific expropriated property itself or any property exchanged for such property to the United States. The Court vacated the judgment of the D.C. Circuit and remanded the case for further proceedings consistent with this opinion. View "Hungary v. Simon" on Justia Law

Several unemployed workers in Alabama applied for unemployment benefits and claimed that the Alabama Department of Labor unlawfully delayed processing their claims. They sued the Alabama Secretary of Labor in state court under 42 U.S.C. §1983, arguing that the delays violated their due process and federal statutory rights. They sought a court order to expedite the processing of their claims. The Secretary moved to dismiss the complaint, arguing that the claimants had not satisfied the administrative-exhaustion requirement under Alabama law. The state trial court granted the motion and dismissed the complaint.The claimants appealed to the Alabama Supreme Court, which affirmed the dismissal on the grounds of failure to exhaust administrative remedies. The court concluded that §1983 did not preempt the state's administrative-exhaustion requirement, effectively preventing the claimants from suing to expedite the administrative process until they had completed it.The Supreme Court of the United States reviewed the case and held that state courts may not deny §1983 claims on failure-to-exhaust grounds when the application of a state exhaustion requirement effectively immunizes state officials from such claims. The Court reasoned that Alabama's exhaustion requirement, as applied, prevented claimants from challenging delays in the administrative process, thus immunizing state officials from §1983 suits. The Court reversed the Alabama Supreme Court's decision and remanded the case for further proceedings consistent with its opinion. View "Williams v. Reed" on Justia Law