Justia U.S. Supreme Court Opinion Summaries

Pierre Riley, a Jamaican citizen, was ordered removed from the United States by the Department of Homeland Security (DHS) under expedited procedures for aliens convicted of aggravated felonies. Riley sought relief under the Convention Against Torture (CAT), claiming he would be killed by a drug kingpin if returned to Jamaica. An Immigration Judge (IJ) found Riley credible and granted deferral of removal under the CAT. However, the Board of Immigration Appeals (BIA) vacated the IJ’s order, allowing the removal order to be enforced.Riley filed a petition for review in the U.S. Court of Appeals for the Fourth Circuit within 30 days of the BIA’s decision but long after the DHS issued the final administrative review order (FARO). The Fourth Circuit dismissed Riley’s petition for lack of jurisdiction, holding that the 30-day filing deadline for judicial review of a final order of removal is jurisdictional and that the final order of removal was the FARO, not the BIA’s decision.The Supreme Court of the United States reviewed the case and held that BIA orders denying deferral of removal in withholding-only proceedings are not final orders of removal under 8 U.S.C. §1252(b)(1). The Court also held that the 30-day filing deadline under §1252(b)(1) is a claims-processing rule, not a jurisdictional requirement. Consequently, the Court vacated the Fourth Circuit’s judgment and remanded the case for further proceedings consistent with its opinion. View "Riley v. Bondi" on Justia Law

In 2009, Tony Hewitt, Corey Duffey, and Jarvis Ross were convicted of multiple counts of bank robbery and conspiracy, along with corresponding §924(c) offenses for using a firearm during a crime of violence. Each received a mandatory 5-year sentence for the first §924(c) count and 25-year mandatory sentences for each additional count, resulting in sentences exceeding 325 years. After successfully challenging some convictions, the Fifth Circuit vacated their sentences, and they were resentenced to between 285 and 305 years. Following the First Step Act of 2018, which reduced mandatory minimum penalties for first-time §924(c) offenders, the District Court vacated more convictions and resentenced them under the pre-Act scheme, resulting in sentences of 130 years or more.The Fifth Circuit denied the joint request by petitioners and the Government to apply the First Step Act’s more lenient penalties, holding that §403(b) applies only to defendants who had not been sentenced as of the Act’s enactment. Since the petitioners had been sentenced twice before the Act, the court concluded they were ineligible for the Act’s benefits.The Supreme Court of the United States reversed the Fifth Circuit’s decision, holding that under §403(b) of the First Step Act, a sentence “has been imposed” only if it remains valid and has not been vacated. Therefore, the Act’s more lenient penalties apply to defendants whose previous §924(c) sentences have been vacated and who need to be resentenced following the Act’s enactment. The case was remanded for further proceedings consistent with this interpretation. View "Hewitt v. United States" on Justia Law

The Environmental Protection Agency (EPA) approved California regulations under the Clean Air Act that require automakers to produce more electric vehicles and fewer gasoline-powered vehicles to reduce emissions. Several fuel producers, including those of gasoline and ethanol, sued the EPA, arguing that the EPA lacked the authority to approve these regulations as they target global climate change rather than local air quality issues. The fuel producers claimed that the regulations would significantly reduce the demand for liquid fuels, causing them monetary injury.The United States Court of Appeals for the District of Columbia Circuit reviewed the case and held that the fuel producers lacked Article III standing. The court found that the fuel producers failed to demonstrate that automakers would likely respond to the invalidation of the regulations by producing fewer electric vehicles and more gasoline-powered vehicles, thus failing to establish redressability.The Supreme Court of the United States reviewed the case and held that the fuel producers have Article III standing to challenge the EPA’s approval of the California regulations. The Court found that the fuel producers demonstrated injury in fact, causation, and redressability. The Court reasoned that the regulations likely cause monetary injury to the fuel producers by reducing the demand for gasoline and other liquid fuels. The Court also found that invalidating the regulations would likely redress the injury by increasing the sales of gasoline-powered vehicles and, consequently, the demand for liquid fuels. The judgment of the Court of Appeals was reversed and the case was remanded for further proceedings. View "Diamond Alternative Energy, LLC v. Environmental Protection Agency" on Justia Law

The case involves two separate lawsuits filed in the United States District Court for the Southern District of New York under the Antiterrorism Act of 1990 (ATA). The plaintiffs, American citizens injured or killed in terror attacks, sued the Palestine Liberation Organization (PLO) and Palestinian Authority (PA). The plaintiffs alleged that the PLO and PA engaged in conduct that triggered jurisdiction under the Promoting Security and Justice for Victims of Terrorism Act (PSJVTA), which deems these entities to have consented to personal jurisdiction in ATA cases under certain conditions.The United States District Court for the Southern District of New York found evidence that the PLO and PA engaged in conduct sufficient to satisfy the PSJVTA's jurisdictional predicates. However, the court ruled that exercising jurisdiction under the PSJVTA was unconstitutional. The Second Circuit Court of Appeals affirmed this decision, holding that the PSJVTA could not establish personal jurisdiction over the PLO or PA consistent with constitutional due process requirements.The Supreme Court of the United States reviewed the case and held that the PSJVTA's personal jurisdiction provision does not violate the Fifth Amendment's Due Process Clause. The Court reasoned that the statute reasonably ties the assertion of jurisdiction over the PLO and PA to conduct involving the United States and implicating sensitive foreign policy matters within the prerogative of the political branches. The Court reversed the Second Circuit's judgment and remanded the case for further proceedings consistent with its opinion. View "Fuld v. Palestine Liberation Organization" on Justia Law

Karyn Stanley, a firefighter for the City of Sanford, Florida, since 1999, was forced to retire in 2018 due to a disability. When she was hired, the City provided health insurance until age 65 for retirees with 25 years of service or those who retired due to disability. In 2003, the City revised its policy, limiting health insurance to 24 months for those retiring due to disability. Stanley, who retired under the revised policy, received only 24 months of health insurance.Stanley sued the City, alleging that the revised policy violated the Americans with Disabilities Act (ADA) by discriminating against those who retire due to disability. The district court dismissed her ADA claim, stating that the alleged discrimination occurred after her retirement, making her not a "qualified individual" under Title I of the ADA, as she no longer held or sought a job with the City. The Eleventh Circuit affirmed the district court's decision.The Supreme Court of the United States reviewed the case and affirmed the lower courts' decisions. The Court held that to prevail under §12112(a) of the ADA, a plaintiff must prove that they held or desired a job and could perform its essential functions with or without reasonable accommodation at the time of the alleged discrimination. The Court concluded that the ADA's protections do not extend to retirees who neither hold nor seek a job. The judgment of the Eleventh Circuit was affirmed, upholding the dismissal of Stanley's ADA claim. View "Stanley v. City of Stanford" on Justia Law

Edgardo Esteras pleaded guilty to conspiring to distribute heroin and was sentenced to 12 months in prison followed by a 6-year term of supervised release. After completing his prison term, Esteras was arrested for allegedly threatening to kill the mother of his children and firing shots into her vehicle. Although the charges were dismissed, the District Court held a revocation hearing and found that Esteras had violated the conditions of his supervised release. The court revoked his supervised release, ordered 24 months of reimprisonment, and imposed an additional three years of supervised release.Esteras's counsel objected, arguing that the District Court had impermissibly considered the factor in Section 3553(a)(2)(A). The District Court acknowledged that part of its decision was based on the need to promote respect for the law. The Sixth Circuit affirmed the District Court's decision, reasoning that Section 3583(e) does not explicitly prohibit considering Section 3553(a)(2)(A) and that excluding it would be unworkable.The Supreme Court of the United States reviewed the case and disagreed with the Sixth Circuit. The Court held that Congress's decision to exclude Section 3553(a)(2)(A) from the list of factors in Section 3583(e) implies that courts may not consider it when deciding whether to revoke a term of supervised release. The Court emphasized that supervised release is intended to fulfill rehabilitative ends and provide postconfinement assistance, not to serve as additional punishment for the original offense. Consequently, the Supreme Court vacated the judgments of the Sixth Circuit and remanded the cases for further proceedings consistent with this opinion. View "Esteras v. United States" on Justia Law

McKesson Corporation sent unsolicited fax advertisements to medical practices, including McLaughlin Chiropractic Associates, in 2009 and 2010. McLaughlin sued McKesson in 2014 in the U.S. District Court for the Northern District of California, alleging violations of the Telephone Consumer Protection Act (TCPA) for sending unsolicited faxes without the required opt-out notices. McLaughlin sought damages and an injunction and aimed to represent a class of fax recipients who received the advertisements on traditional fax machines or through online fax services. The District Court certified the class without distinguishing between the two methods of receipt.During the lawsuit, the Federal Communications Commission (FCC) issued the Amerifactors order, which interpreted "telephone facsimile machine" in the TCPA to exclude online fax services. The District Court, following Ninth Circuit precedent, deemed the Amerifactors order binding and granted summary judgment to McKesson for claims involving online fax services. The court then decertified the class, leaving McLaughlin with claims for only 12 faxes received on a traditional machine and damages of $6,000. The Ninth Circuit affirmed the District Court's decision.The Supreme Court of the United States reviewed the case and held that the Hobbs Act does not bind district courts in civil enforcement proceedings to an agency’s interpretation of a statute. District courts must independently determine the law’s meaning under ordinary principles of statutory interpretation while affording appropriate respect to the agency’s interpretation. The Court reversed the Ninth Circuit's decision and remanded the case for further proceedings consistent with this opinion. View "McLaughlin Chiropractic Associates, Inc. v. McKesson Corp." on Justia Law

The Family Smoking Prevention and Tobacco Control Act (TCA) mandates that manufacturers must obtain approval from the Food and Drug Administration (FDA) before marketing any new tobacco product. In 2016, the FDA classified e-cigarettes as new tobacco products under the TCA. R. J. Reynolds Vapor Co. (RJR Vapor) applied for FDA approval to market its Vuse Alto e-cigarettes, but the FDA denied the application, stating that RJR Vapor failed to prove that marketing the products would protect public health. RJR Vapor, along with a Texas-based retailer and a Mississippi-based trade association, challenged the FDA's denial in the Fifth Circuit.The FDA requested the Fifth Circuit to dismiss or transfer the petition, arguing that only the applicant (RJR Vapor) was "adversely affected" by the denial and thus eligible to seek judicial review. The Fifth Circuit, however, ruled that the venue was proper and denied the FDA's motion.The Supreme Court of the United States reviewed the case and held that retailers who would sell a new tobacco product if not for the FDA’s denial order are "adversely affected" and may seek judicial review under the TCA. The Court interpreted "adversely affected" broadly, consistent with its use in other statutes, and concluded that the retailers' interests were within the zone of interests protected by the TCA. The Court affirmed the Fifth Circuit's decision and remanded the case for further proceedings. View "Food and Drug Administration v. R.J. Reynolds Vapor Co." on Justia Law

In 2023, Tennessee enacted Senate Bill 1 (SB1), which prohibits healthcare providers from prescribing, administering, or dispensing puberty blockers or hormones to minors for the purpose of enabling them to identify with a gender different from their biological sex or to treat discomfort from such discordance. However, SB1 allows these treatments for minors with congenital defects, precocious puberty, disease, or physical injury. Three transgender minors, their parents, and a doctor challenged SB1 under the Equal Protection Clause of the Fourteenth Amendment.The District Court partially enjoined SB1, finding that transgender individuals constitute a quasi-suspect class, that SB1 discriminates based on sex and transgender status, and that it was unlikely to survive intermediate scrutiny. The Sixth Circuit reversed, holding that SB1 did not trigger heightened scrutiny and satisfied rational basis review. The court found that SB1 did not classify based on sex or transgender status and that Tennessee had provided considerable evidence regarding the risks associated with the banned treatments.The Supreme Court of the United States reviewed the case and held that SB1 is not subject to heightened scrutiny under the Equal Protection Clause and satisfies rational basis review. The Court determined that SB1 does not classify on any bases that warrant heightened review, such as sex or transgender status. Instead, it classifies based on age and medical use, which are subject to rational basis review. The Court found that Tennessee had a rational basis for enacting SB1, citing concerns about the risks and unknown long-term effects of the treatments, the maturity of minors, and the availability of less invasive approaches. The judgment of the Sixth Circuit was affirmed. View "United States v. Skrmetti" on Justia Law

In this case, inmate Kyle Richards alleged that Thomas Perttu, a prison employee, sexually harassed him and other inmates. Richards also claimed that Perttu destroyed his grievance documents and retaliated against him for attempting to file them. Richards sued Perttu under 42 U.S.C. §1983 for violating his constitutional rights, including his First Amendment right to file grievances. Perttu moved for summary judgment, arguing that Richards had failed to exhaust available grievance procedures as required by the Prison Litigation Reform Act (PLRA).The Magistrate Judge found a genuine issue of fact regarding whether Richards was excused from exhausting his claims due to Perttu's interference and held an evidentiary hearing. The Magistrate Judge concluded that Richards's witnesses lacked credibility and recommended dismissal without prejudice for failure to exhaust. The District Court adopted this recommendation. The Sixth Circuit reversed, holding that the Seventh Amendment requires a jury trial when the resolution of the exhaustion issue under the PLRA would also resolve a genuine dispute of material fact regarding the merits of the plaintiff's substantive case.The Supreme Court of the United States held that parties are entitled to a jury trial on PLRA exhaustion when that issue is intertwined with the merits of a claim that requires a jury trial under the Seventh Amendment. The Court reasoned that the usual practice under the Federal Rules of Civil Procedure is that factual disputes regarding legal claims go to the jury. The PLRA is silent on whether judges or juries should resolve exhaustion disputes, and this silence indicates that the usual practice should be followed. The Court affirmed the judgment of the Sixth Circuit. View "Perttu v. Richards" on Justia Law