Justia U.S. Supreme Court Opinion Summaries

Wooden was convicted as a felon in possession of a firearm, 18 U.S.C. 922(g). The Armed Career Criminal Act (ACCA) mandates a 15-year minimum penalty for section 922(g) offenders with at least three prior convictions for specified felonies “committed on occasions different from one another.” Wooden had 10 burglary convictions arising from a single episode in 1997, during which Wooden unlawfully entered a one-building storage facility and stole items from 10 different storage units. The application of ACCA’s penalty enhancement to Wooden’s 922(g) sentence resulted in a sentence of almost 16 years. The Sixth Circuit affirmed.The Supreme Court reversed. Wooden’s 10 burglary offenses did not occur on different “occasions” and count as only one prior conviction under ACCA. An ordinary person using language in its normal way would describe Wooden’s entries into the storage units as happening on a single occasion. An occasion may encompass multiple, temporally distinct activities. The government’s contrary view could make someone a career offender in the space of a minute. Whether criminal activities occurred on one occasion or different occasions may depend on several circumstances, including timing, location, and the character and relationship of the offenses. Congress’s amendment of ACCA to add the single occasion requirement was based on its belief that a person who robbed a restaurant and did nothing else, is not a career offender. Wooden’s burglary of a single storage facility does not suggest the “special danger” posed by an “armed career criminal.” View "Wooden v. United States" on Justia Law

Members of Muslim communities filed a putative class action, claiming that the government subjected Muslims to illegal surveillance. The Foreign Intelligence Surveillance Act (FISA) provides a procedure for consideration of the legality of electronic surveillance conducted under FISA, 50 U.S.C. 1806(f). The district court dismissed because litigation of the claims “would require or unjustifiably risk disclosure of secret and classified information.” The Ninth Circuit reversed, holding that FISA displaced the state secrets privilege.The Supreme Court reversed. Section 1806(f) does not affect the availability or scope of the privilege for state and military secrets. The absence of any reference to the state secrets privilege in FISA indicates that the availability of the privilege was not altered.Nothing about section 1806(f) is incompatible with the state secrets privilege. The central question under 1806(f) is whether the surveillance was lawfully authorized and conducted. Under 1806, a court cannot award relief if the evidence was lawfully obtained, whereas a court considering the state secrets privilege may order the disclosure of lawfully obtained evidence if it finds that disclosure would not harm national security. Inquiries under 1806(f) allow “review in camera and ex parte” of materials “necessary to determine” whether the surveillance was lawful. Under the state secrets privilege, however, examination of the evidence “even by the judge alone, in chambers,” should not be required if the government shows “a reasonable danger that compulsion of the evidence” will expose information that “should not be divulged” in “the interest of national security.” The Court did not decide which party’s interpretation of 1806(f) is correct, whether the government’s evidence is privileged, or whether the district court was correct to dismiss the claims on the pleadings. View "Federal Bureau of Investigation v. Fazaga" on Justia Law

In 2013, brothers Dzhokhar and Tamerlan planted and detonated homemade bombs near the Boston Marathon’s finish line, killing three and wounding hundreds. The brothers fled, murdering a campus police officer, carjacking a student, and fighting a street battle with police during which Dzhokhar inadvertently killed Tamerlan.Dzhokhar was indicted for 30 crimes, including 17 capital offenses. In a 100-question screening form that included several questions regarding whether media coverage had biased prospective jurors, the district court declined to include a question that asked each prospective juror to list the facts he had learned about the case from the media and other sources. Dzhokhar was convicted on all counts. At sentencing, Dzhokhar argued that Tamerlan had masterminded the bombing and pressured Dzhokhar to participate. The court denied Dzhokhar's request to introduce allegations that, years earlier, Tamerlan had participated in a triple homicide in Waltham. The jury imposed the death penalty. The First Circuit vacated Dzhokhar’s capital sentences.The Supreme Court reversed. The district court did not abuse its broad discretion; the jury question at issue wrongly emphasized what a juror knew before coming to court, rather than potential bias. The court used the 100-question juror form to cull prospective jurors, then subjected those remaining to three weeks of individualized voir dire that probed for bias. The court instructed the jurors that their decisions must be based only on the evidence presented at trial.At the sentencing phase of a capital trial, “information may be presented as to any matter relevant to the sentence, including any mitigating or aggravating factor,” 18 U.S.C. 3593(c). A district court may exclude information “if its probative value is outweighed by the danger of creating unfair prejudice, confusing the issues, or misleading the jury.” The excluded evidence would not have allowed the jury to assess Tamerlan’s alleged role in the Waltham murders and had the potential to confuse the jury. Section 3593(c) does not violate the Eighth Amendment but establishes a regime that affords a capital defendant every reasonable opportunity to present relevant mitigation evidence. The inclusion of the Waltham-murders evidence risked producing a confusing mini-trial in which the only witnesses were dead. View "United States v. Tsarnaev" on Justia Law

Kentucky’s attorney general and its Secretary of Health and Family Services were defendants in a suit concerning House Bill 454, regulating abortion procedures. Plaintiffs agreed to dismiss the attorney general, stipulating that the attorney general’s office reserved “all rights, claims, and defenses . . . in any appeals” and agreed to be bound by the judgment. The district court enjoined HB 454's enforcement.While an appeal was pending, Kentucky elected a new attorney general, Cameron. Former attorney general Beshear became Governor. Cameron entered an appearance as counsel for the new Secretary. A divided Sixth Circuit panel affirmed. The Secretary opted not to challenge the decision. The attorney general moved to withdraw as counsel for the Secretary and to intervene on the Commonwealth’s behalf, then filed a timely petition for rehearing en banc. The Sixth Circuit denied the motion to intervene.The Supreme Court reversed. Although the attorney general could have filed a notice of appeal, his failure to do so did not mean his motion for intervention should be treated as an untimely notice of appeal. The Sixth Circuit panel failed to account for the strength of the attorney general’s interest in defending HB 454 after the Secretary acquiesced. The attorney general sought to intervene “as soon as it became clear” that the Commonwealth’s interests “would no longer be protected” by the parties. While the rehearing petition pressed an issue (third-party standing) not raised in the Secretary’s appellate briefs, allowing intervention would not have necessitated resolution of that issue. The plaintiffs’ “loss of its claimed expectations around the election of a Governor with a history of declining to defend abortion restrictions is not cognizable as unfair prejudice.” View "Cameron v. EMW Women's Surgical Center, P. S. C." on Justia Law

Unicolors, the owner of fabric design copyrights, successfully sued H&M for copyright infringement, 17 U.S.C. 411(a). H&M argued that Unicolors knowingly included inaccurate information on its registration application, rendering its registration invalid; Unicolors had filed a single application seeking registration for 31 separate works despite a regulation that provides that a single application may cover multiple works only if they were “included in the same unit of publication.” H&M argued that Unicolors had made some of the designs available for sale exclusively to certain customers while offering the rest to the general public.The Ninth Circuit determined that it did not matter whether Unicolors was aware that it had failed to satisfy the single unit of publication requirement because the safe harbor excused only good-faith mistakes of fact, not law; Unicolors knew the relevant facts.The Supreme Court vacated. Section 411(b) does not distinguish between mistakes of law and mistakes of fact. Under the safe harbor, a certificate of registration is valid, even though it contains inaccurate information if the copyright holder lacked “knowledge that it was inaccurate.” If Unicolors was not aware of the legal requirement that rendered its application inaccurate, it could not have included the inaccurate information “with knowledge that it was inaccurate.” Legislative history indicates that Congress enacted section 411(b) to make it easier for nonlawyers to obtain valid copyright registrations by “eliminating loopholes” that allowed infringers to exploit mistakes in the application process. The Court noted that willful blindness may support a finding of actual knowledge and circumstantial evidence may demonstrate that an applicant was aware of, or willfully blind to, legally inaccurate information. View "Unicolors, Inc. v. H&M Hennes & Mauritz, L. P." on Justia Law

Northwestern’s defined contribution retirement plans, governed by the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001, allowed participants to choose an individual investment mix from a menu of options selected by plan administrators. Participants claimed those administrators violated their duty of prudence by offering needlessly expensive investment options and paying excessive record-keeping fees. The Seventh Circuit affirmed the dismissal of those claims, finding that the plaintiffs’ preferred type of low-cost investments were available as plan options.The Supreme Court vacated. A categorical rule is inconsistent with the context-specific inquiry that ERISA requires and fails to take into account the duty of plan fiduciaries to monitor all plan investments and remove any imprudent ones. The Seventh Circuit erroneously focused on another component of the duty of prudence: the obligation to assemble a diverse menu of options. Provision of an adequate array of investment choices, including the lower cost investments plaintiffs wanted, does not excuse the allegedly imprudent decisions. Even if participants choose their investments, plan fiduciaries must conduct their own independent evaluation to determine which investments may be prudently included in the plan’s menu of options. If the fiduciaries fail to remove an imprudent investment from the plan within a reasonable time, they breach their duty. The Court remanded, “so that the Seventh Circuit may reevaluate the allegations as a whole, considering whether petitioners have plausibly alleged a violation of the duty of prudence,” which turns on the circumstances prevailing when the fiduciary acts. View "Hughes v. Northwestern University" on Justia Law

A stray 9-millimeter bullet killed a child after a Bronx street fight. Eyewitnesses described the shooter as wearing a blue shirt or sweater. Police officers determined Gilliam was involved and that Morris was at the scene. A search of Morris’ apartment revealed a 9-millimeter cartridge and .357-caliber bullets. Gilliam initially identified Morris as the shooter but subsequently said that Hemphill was the shooter. Morris was charged with murder and possession of a 9-millimeter handgun. The prosecution agreed to dismiss the murder charges if Morris pleaded guilty to possession of a .357 revolver. Years later, Hemphill was indicted for the murder; his DNA matched a blue sweater found in Morris’ apartment shortly after the murder. Hemphill elicited testimony that police had recovered 9-millimeter ammunition from Morris’ apartment, pointing to Morris as the culprit. Morris was not available to testify. The court allowed the prosecution to introduce parts of Morris’ plea allocation transcript to rebut Hemphill’s theory, reasoning that although Morris’ out-of-court statements had not been subjected to cross-examination, Hemphill’s arguments had “opened the door” and admission of the statements was reasonably necessary to correct a misleading impression. Hemphill was convicted. The Supreme Court reversed. Admission of the plea allocution transcript violated Hemphill’s Sixth Amendment right to confront the witnesses against him. While the Sixth Amendment permits reasonable procedural rules concerning the exercise of a defendant’s confrontation right, the “door-opening principle” is a substantive principle that dictates what material is relevant and admissible. It was not for the trial judge to determine whether Hemphill’s theory that Morris was the shooter was unreliable, incredible, or otherwise misleading in light of the state’s proffered, unconfronted plea evidence, nor whether this evidence was reasonably necessary to correct that misleading impression. View "Hemphill v. New York" on Justia Law

The Secretary of Labor, through OSHA, enacted a vaccine mandate, to be enforced by employers. The mandate preempted contrary state laws and covered virtually all employers with at least 100 employees, with exemptions for employees who exclusively work remotely or outdoors. It required that covered workers receive a COVID–19 vaccine or obtain a medical test each week at their own expense, on their own time, and also wear a mask at work. Challenges were consolidated before the Sixth Circuit, which allowed OSHA’s rule to take effect.The Supreme Court stayed the rule. Applicants are likely to succeed on the merits of their claim that the Secretary lacked the authority to impose the mandate. The rule is “a significant encroachment into the lives—and health—of a vast number of employees,” not plainly authorized by statute; 29 U.S.C. 655(b) empowers the Secretary to set workplace safety standards, not broad public health measures. Although COVID–19 is a risk in many workplaces, it is not an occupational hazard in most. COVID–19 spreads everywhere that people gather. Permitting OSHA to regulate the hazards of daily life would significantly expand OSHA’s regulatory authority without clear congressional authorization. The vaccine mandate is unlike typical OSHA workplace regulations. A vaccination “cannot be undone.” Where the virus poses a special danger because of the particular features of an employee’s job or workplace, targeted regulations are permissible but OSHA’s indiscriminate approach fails to distinguish between occupational risk and general risk. The equities do not justify withholding interim relief. States and employers allege that OSHA’s mandate will force them to incur billions of dollars in unrecoverable compliance costs and will cause hundreds of thousands of employees to leave their jobs. View "National Federation of Independent Business v. Department of Labor, Occupational Safety & Health Administration" on Justia Law

In November 2021, the Secretary of HHS announced that, in order to receive Medicare and Medicaid funding, participating facilities must ensure that their staff—unless exempt for medical or religious reasons or teleworking full-time—are vaccinated against COVID–19. Two district courts enjoined enforcement of the rule. The Supreme Court stayed the injunctions pending appeals in the Fifth and Eighth Circuits. The rule falls within the Secretary’s statutory authority to promulgate regulations “necessary to the efficient administration of the functions with which [he] is charged,” 42 U.S.C. 1302(a), including ensuring that the healthcare providers who care for Medicare and Medicaid patients protect their patients’ health and safety. Conditions with which facilities must comply to be eligible to receive Medicare and Medicaid funds have long included a requirement that certain providers maintain and enforce an “infection prevention and control program.” Vaccination requirements are a common feature of the provision of healthcare in America. The rule is not arbitrary. The Court noted the Secretary’s findings that in addition to the threat posed by in- facility transmission itself, “fear of exposure” to the virus “from unvaccinated health care staff can lead patients to themselves forgo seeking medically necessary care.” Nor did the Secretary fail to consider that the rule might cause staffing shortages. The Secretary’s finding of good cause to delay notice and comment was based on a finding that accelerated promulgation of the rule in advance of the winter flu season would significantly reduce COVID–19 infections, hospitalizations, and deaths. View "Biden v. Missouri" on Justia Law

Social Security retirement benefits are calculated using a formula based on past earnings, 42 U.S.C. 415(a)(1)(A). Under the “windfall elimination” provision, benefits are reduced when a retiree receives a separate pension payment based on employment not subject to Social Security taxes. Pension payments exempt from the windfall reduction include those "based wholly on service as a member of a uniformed service.”A “military technician (dual status),” 10 U.S.C. 10216, is a “civilian employee” assisting the National Guard. Such technicians are required to maintain National Guard membership and must wear uniforms while working. For their work as full-time civilian technicians, they receive civil-service pay. If hired before 1984, they receive Civil Service Retirement System pension payments. As part-time National Guard members, they receive military pay and pension payments from a different arm of the government.The SSA applied the windfall elimination provision to the benefits calculation for Babcock, a dual-status technician. The district court and Sixth Circuit upheld that decision, declining to apply the uniformed-services exception.The Supreme Court affirmed. Civil Service Retirement System pensions generally trigger the windfall provision. Babcock’s technician work was not service “as” a National Guard member. A condition of employment is not the same as the capacity in which one serves. The statute states: “For purposes of this section and any other provision of law,” a technician “is” a “civilian employee,” “authorized and accounted for as” a “civilian.” While working in a civilian capacity, technicians are not subject to the Uniform Code of Military Justice. They possess characteristically civilian rights concerning employment discrimination, workers’ compensation, disability benefits, and overtime work; technicians hired before 1984 are “civil service” members, entitled to pensions as civil servants. Babcock’s civil-service pension payments are not based on his National Guard service, for which he received separate military pension payments. View "Babcock v. Kijakazi" on Justia Law