Justia U.S. Supreme Court Opinion Summaries

The named plaintiffs, aliens who were detained under the Immigration and Nationality Act (INA), 8 U.S.C. 1231(a)(6) after reentering the United States illegally, filed a putative class action, alleging that aliens detained under section 1231(a)(6) are entitled to bond hearings after six months’ detention. The district court certified a class of similarly situated plaintiffs and enjoined the government from detaining the class members under section 1231(a)(6) for more than 180 days without providing each a bond hearing. The Ninth Circuit affirmed.The Supreme Court reversed. INA section 1252(f )(1) deprived the district courts of jurisdiction to entertain aliens’ requests for class-wide injunctive relief. Section 1252(f )(1) generally strips lower courts of jurisdiction or authority to “enjoin or restrain the operation of ” certain INA provisions. Section 1252(f )(1)’s one exception allows lower courts to “enjoin or restrain the operation of ” the relevant statutory provisions “with respect to the application of such provisions to an individual alien against whom proceedings under such part have been initiated.” Here, both district courts entered injunctions that “enjoin or restrain the operation” of section 1231(a)(6) because they require officials to take actions that (in the government’s view) are not required by 1231(a)(6) and to refrain from actions that are allowed; the injunctions do not fall within the exception for individualized relief. Section 1252(f )(1) refers to “an individual,” not “individuals.” View "Garland v. Gonzalez" on Justia Law

Arteaga-Martinez, a citizen of Mexico, was removed and reentered the U.S. His earlier removal order was reinstated and he was detained under 8 U.S.C. 1231(a). Arteaga-Martinez applied for withholding of removal and relief under the Convention Against Torture. An asylum officer determined he had established a reasonable fear of persecution or torture if returned to Mexico. DHS referred him for withholding-only proceedings before an immigration judge. After being detained for four months, Arteaga-Martinez filed a habeas corpus petition, challenging his continued detention without a bond hearing. The government conceded that Arteaga-Martinez would be entitled to a bond hearing after six months of detention based on circuit precedent. The district court ordered a bond hearing. The Third Circuit affirmed. At the bond hearing, the Immigration Judge authorized his release pending resolution of his application for withholding of removal.The Supreme Court reversed and remanded. Section 1231(a)(6) does not require the government to provide noncitizens, detained for six months, with bond hearings in which the government bears the burden of proving, by clear and convincing evidence, that a noncitizen poses a flight risk or a danger to the community. Section 1231(a)(6) “does not permit indefinite detention” but “limits an alien’s post-removal-period detention to a period reasonably necessary to bring about that alien’s removal from the United States”; it allows the government to provide bond hearings but does not require them. The Court remanded for consideration of Arteaga-Martinez’s alternative theory. View "Johnson v. Arteaga-Martinez" on Justia Law

Boule’s business, “Smuggler's Inn,” abuts the Canadian border. Boule sometimes helped federal agents identify and apprehend persons engaged in unlawful cross-border activities but also provided transportation and lodging to illegal border crossers. Boule informed U.S. Border Patrol agent Egbert that a Turkish national had scheduled transportation to Smuggler’s Inn. Egbert followed Boule's vehicle to the Inn. Boule claims he asked Egbert to leave, but Egbert refused, threw Boule to the ground, checked the immigration paperwork for Boule’s guest, then left. Boule filed an unsuccessful grievance with Egbert’s supervisors and an unsuccessful administrative claim. Egbert allegedly retaliated by reporting Boule’s license plate to the state for referencing illegal activity, and by prompting an IRS audit. Boule sued Egbert, alleging Fourth Amendment excessive force and First Amendment retaliation.Reversing the Ninth Circuit, The Supreme Court held that "Bivens" does not extend to Boule's claims. In Bivens, the Court created a damages action against federal agents for violating a plaintiff’s Fourth Amendment rights. The Court subsequently fashioned new causes of action under the Fifth and Eighth Amendments.Recognizing a Bivens cause of action is “a disfavored judicial activity." Boule’s Fourth Amendment claim presented a new Bivens context, not akin to a “conventional” excessive-force claim. Concerns about undermining border security foreclose Bivens relief. Congress has provided alternative remedies: Border Patrol must investigate alleged violations and accept grievances. The Court has never held that a Bivens alternative must provide for judicial review. Boule’s First Amendment retaliation claim also presents a new Bivens context. Congress is better suited to authorize a damages remedy. Extending Bivens to alleged First Amendment violations would pose an acute “risk that fear of personal monetary liability and harassing litigation will unduly inhibit officials in the discharge of their duties.” View "Egbert v. Boule" on Justia Law

Under the Trustee Program, administrative functions previously handled by bankruptcy judges are handled by U.S. Trustees, within the Department of Justice. Six judicial districts in North Carolina and Alabama opted out of the Trustee Program; those bankruptcy courts continue to appoint bankruptcy administrators. Both programs handle the same administrative functions. The Trustee Program is funded entirely by user fees, largely paid by Chapter 11 debtors, 28 U.S.C. 589a(b)(5). The Administrator Program is funded by the Judiciary’s general budget. Under a Judicial Conference standing order, all districts nationwide charged similarly-situated debtors uniform fees. A 2017 fee increase was made applicable to currently pending and newly-filed cases in the Trustee Program and only to newly-filed cases in Administrator Program districts. Reversing the bankruptcy court, the Fourth Circuit held that the fee increase did not violate the Bankruptcy Clause uniformity requirement.A unanimous Supreme Court reversed, holding that the enactment of a significant fee increase that exempted debtors in two states violated the uniformity requirement. Nothing in the Bankruptcy Clause suggests a distinction between substantive and administrative laws; its language, embracing “laws on the subject of Bankruptcies,” is broad. Congress cannot evade the affirmative limitation of the uniformity requirement by enacting legislation pursuant to other grants of authority such as the Necessary and Proper Clause. The 2017 Act does not confer discretion on bankruptcy districts to set regional policies based on regional needs but exempts debtors in two states from a fee increase that applied to debtors in 48 states, without identifying any material difference between debtors across those states. The Bankruptcy Clause does not permit arbitrary geographically disparate treatment of debtors. View "Siegel v. Fitzgerald" on Justia Law

Saxon, a Southwest Airlines ramp supervisor, frequently loads and unloads cargo alongside the ramp agents. Alleging that Southwest was failing to pay proper overtime wages to ramp supervisors, Saxon brought a putative class action under the Fair Labor Standards Act. Saxon’s employment contract required her to arbitrate wage disputes individually; she claimed that ramp supervisors were a “class of workers engaged in foreign or interstate commerce,” exempt from the Federal Arbitration Act, 9 U.S.C. 1.The Supreme Court affirmed the Seventh Circuit, holding that the act of loading cargo onto a vehicle to be transported interstate is itself commerce according to the “ordinary, contemporary, common meaning” of the word. By referring to “workers” rather than “employees,” the FAA directs attention to “the performance of work” and the word “engaged” similarly emphasizes the actual work that class members typically carry out. Saxon is a member of a “class of workers” based on what she frequently does, physically loading and unloading cargo on and off airplanes, and not on what Southwest does generally. Exempted workers must at least play a direct and “necessary role in the free flow of goods” across borders. Cargo loaders exhibit this central feature of a transportation worker. View "Southwest Airlines Co. v. Saxon" on Justia Law

Gallardo suffered catastrophic injuries resulting in permanent disability when a truck struck her as she stepped off her Florida school bus. Florida’s Medicaid agency paid $862,688.77 to cover Gallardo’s initial medical expenses and continues to pay her medical expenses. Gallardo’s suit against the truck’s owner and the School Board resulted in an $800,000 settlement, with $35,367.52 designated as compensation for past medical expenses. The settlement did not specifically allocate any amount for future medical expenses.The Medicaid Act requires participating states to pay for certain individuals’ medical costs and to make reasonable efforts to recoup those costs from liable third parties, 42 U.S.C. 1396k(a)(1)(A). Under Florida’s Medicaid Third-Party Liability Act, a beneficiary who accepts medical assistance from Medicaid automatically assigns to the state any right to third-party payments for medical care; Florida was entitled to $300,000--presumptively representing the portion of the recovery that is for past and future medical expenses.The Supreme Court affirmed the Eleventh Circuit. The Medicaid Act permits a state to seek reimbursement from settlement payments allocated for future medical care. The Act’s anti-lien provision, prohibiting states from recovering medical payments from a beneficiary’s “property,” does not foreclose recovery from settlement amounts other than those allocated for past medical care paid for by Medicaid. Florida’s statute is expressly authorized by section 1396k(a) and is within the recognized exception to the anti-lien provision. The relevant distinction is between medical and nonmedical expenses, not between past and future medical expenses. Section 1396k(a)(1)(A) does not authorize a “lifetime assignment” covering any rights acquired in the future but covers only rights the individual possesses while on Medicaid. View "Gallardo v. Marstiller" on Justia Law

Morgan, an hourly employee at Sundance's Taco Bell franchise, had signed an agreement to arbitrate any employment dispute. Morgan later filed a nationwide collective action asserting that Sundance had violated federal law regarding overtime pay. Sundance initially defended as if no arbitration agreement existed, filing an unsuccessful motion to dismiss and engaging in unsuccessful mediation. Months after Morgan filed suit, Sundance unsuccessfully moved to compel arbitration under the Federal Arbitration Act (FAA). Under Eighth Circuit precedent, a party waived its right to arbitration if it knew of the right; “acted inconsistently with that right”; and “prejudiced the other party by its inconsistent actions.”The Supreme Court vacated and remanded. The Eighth Circuit erred in conditioning a waiver of the right to arbitrate on a showing of prejudice. A court must hold a party to its arbitration contract just as the court would to any other kind and may not devise novel rules to favor arbitration over litigation. Federal policy is to treat arbitration contracts like all others, not to foster arbitration. Courts may not create arbitration-specific procedural rules. Because the usual federal rule concerning waiver does not include a prejudice requirement, prejudice is not a condition of finding that a party waived its right to stay litigation or compel arbitration under the FAA. The proper inquiry would focus on Sundance’s conduct. Did Sundance knowingly relinquish the right to arbitrate by acting inconsistently with that right? View "Morgan v. Sundance, Inc." on Justia Law

The Arizona Supreme Court affirmed each prisoner's conviction and death sentence on direct review; each was denied state postconviction relief. Rejecting their petitions for federal habeas relief under 28 U.S.C. 2254, the district court found their ineffective-assistance-of-trial-counsel claims procedurally defaulted as not properly presented in state court. Each unsuccessfully argued that ineffective assistance of postconviction counsel constituted "cause" to excuse the procedural default. The Ninth Circuit reversed and remanded.The Supreme Court reversed. Under section 2254(e)(2), a federal habeas court may not conduct an evidentiary hearing or otherwise consider evidence beyond the state-court record based on the ineffective assistance of state postconviction counsel. The Antiterrorism and Effective Death Penalty Act, section 2254(b)(1)(A), requires state prisoners to “exhaus[t] the remedies available in the courts of the State” before seeking federal habeas relief. The doctrine of procedural default, a “corollary” to the exhaustion requirement, generally prevents federal courts from hearing any federal claim that was not presented to the state courts “consistent with [the State’s] own procedural rules.” Together, exhaustion and procedural default protect against “the significant harm to the States that results from the failure of federal courts to respect” state procedural rules,Federal courts may excuse procedural default only if a prisoner “can demonstrate cause for the default and actual prejudice.” Attorney error cannot provide cause to excuse a default in proceedings for which the Constitution does not guarantee the assistance of counsel except where the state requires prisoners to raise such claims for the first time during state collateral proceedings. Under section 2254(e)(2), when a prisoner is “at fault” for the undeveloped record in state court, a federal court may hold “an evidentiary hearing on the claim” in only two limited scenarios not relevant here and also must show that further fact-finding would demonstrate, by clear and convincing evidence, that he is innocent. State postconviction counsel’s ineffective assistance in developing the state-court record is attributed to the prisoner because there is no constitutional right to counsel in state postconviction proceedings. When a federal habeas court convenes an evidentiary hearing for any purpose or otherwise reviews any evidence for any purpose, it may not consider that evidence on the merits of a negligent prisoner’s defaulted claim unless the exceptions in section 2254(e)(2) are satisfied. View "Shinn v. Martinez Ramirez" on Justia Law

During his 2018 Senate reelection campaign, Cruz loaned his campaign committee $260,000. Section 304 of the 2002 Bipartisan Campaign Reform Act restricts the use of post-election campaign contributions, 52 U.S.C. 30116(j). Federal Election Commission regulations establish that a campaign may repay up to $250,000 in candidate loans using contributions made at any time and may use pre-election contributions to repay any portion exceeding $250,000 only within 20 days of the election; after that deadline, any portion above $250,000 is treated as a campaign contribution, precluding repayment. The Committee began repaying Cruz’s loans after the 20-day post-election window, leaving $10,000 unpaid. Cruz and the Committee challenged Section 304.The Supreme Court affirmed summary judgment for the plaintiffs. The plaintiffs had standing. An injury resulting from the application or threatened application of an unlawful enactment remains fairly traceable to such application, even if the injury was "willingly incurred." The present inability of the Committee to repay and Cruz to recover the final $10,000 is traceable to Section 304.The loan-repayment limitation abridges First Amendment rights by burdening candidates who wish to make expenditures on behalf of their own candidacy through personal loans. It increases the risk that such loans will not be repaid in full, which deters candidates from making loans. Debt is a ubiquitous tool for financing electoral campaigns, especially for new candidates and challengers. Section 304 raises a barrier to entry. The only permissible ground for restricting political speech is the prevention of “quid pro quo” corruption or its appearance. The government failed to identify a single case of quid pro quo corruption in this context, even though most states do not impose any similar limitations. View "Federal Election Commission v. Cruz" on Justia Law

Patel, who entered the United States illegally in the 1990s, applied for adjustment of status, 8 U.S.C. 1255. Because Patel had previously checked a box on a Georgia driver’s license application falsely stating that he was a U.S. citizen, USCIS denied the application. Section 1182(a)(6)(C)(ii)(I) renders inadmissible a noncitizen who falsely represents himself to be a citizen for any legal benefit. In removal proceedings based on his illegal entry, Patel renewed his adjustment of status request, arguing that he had mistakenly checked the “citizen” box and lacked the subjective intent necessary to violate the federal statute.The BIA dismissed Patel’s appeal from a subsequent removal order. The Eleventh Circuit held that it lacked jurisdiction to consider Patel’s claim. Section 1252(a)(2)(B)(i) prohibits judicial review of “any judgment regarding the granting of relief” under 1255, except “constitutional claims” or “questions of law.” The court concluded that the determinations of whether Patel had testified credibly and of subjective intent each qualified as an unreviewable judgment.The Supreme Court affirmed. Federal courts lack jurisdiction to review facts found as part of discretionary-relief proceedings under section 1255 and the other provisions enumerated in section 1252(a)(2)(B)(i). This case largely turns on the scope of the word “judgment." A “judgment” does not necessarily involve discretion, nor does context indicate that only discretionary judgments are covered by section 1252(a)(2)(B)(i). Using the word "judgment" to describe the fact determinations at issue here "is perfectly natural.” The Court rejected arguments that the statute is ambiguous enough to trigger the presumption that Congress did not intend to foreclose judicial review. View "Patel v. Garland" on Justia Law