Justia U.S. Supreme Court Opinion Summaries

The FTC filed a complaint against Tucker alleging deceptive payday lending practices in violation of the Federal Trade Commission Act Section 5(a). The district court entered a permanent injunction to prevent Tucker from committing future violations and relied on the same authority to direct Tucker to pay $1.27 billion in restitution and disgorgement. The Ninth Circuit rejected Tucker’s argument that section 13(b) does not authorize the award of equitable monetary relief.The Supreme Court reversed. Section 13(b) does not authorize the Commission to seek, or a court to award, equitable monetary relief such as restitution or disgorgement. The Commission has authority to enforce the Act’s prohibitions on “unfair or deceptive acts or practices,” 15 U.S.C. 45(a)(1)–(2), by commencing administrative proceedings under Section 5. Section 5(l) authorizes the Commission, following completion of the administrative process and the issuance of a final cease and desist order, to seek civil penalties, and permits district courts to “grant mandatory injunctions and such other and further equitable relief.” Section 19 authorizes district courts to grant “such relief as the court finds necessary,” in cases where someone has engaged in unfair or deceptive conduct with respect to which the Commission has issued a final cease and desist order.In Tucker's case, the Commission sought equitable monetary relief directly in district court under Section 13(b)’s authorization to seek a “permanent injunction” without having used the Commission’s traditional administrative proceedings. Section 13(b) does not explicitly authorize the Commission to obtain court-ordered monetary relief, and such relief is foreclosed by the structure and history of the Act. It is unlikely that Congress, without mentioning the matter, would grant the Commission authority to circumvent traditional Section 5 administrative proceedings. In enacting Section 19 two years after Section 13(b), Congress did not create an alternative enforcement path with similar remedies. View "AMG Capital Management, LLC v. Federal Trade Commission" on Justia Law

Petitioners, whose applications for disability benefits were denied by the Social Security Administration (SSA) unsuccessfully challenged their adverse determinations before an SSA administrative law judge (ALJ). The SSA Appeals Council denied discretionary review in each case. Thereafter, the Supreme Court decided Lucia v. SEC, holding that the appointment of Securities and Exchange Commission ALJs by lower-level staff violated the Constitution’s Appointments Clause. The SSA ALJs were also appointed by lower-level staff. The Courts of Appeals held that the petitioners could not obtain judicial review of their Appointments Clause claims because they failed to raise those challenges in their administrative proceedings. The Supreme Court reversed. The Courts of Appeals erred in imposing an issue-exhaustion requirement on petitioners’ Appointments Clause claims. Administrative review schemes commonly require parties to give the agency an opportunity to address an issue before seeking judicial review of that question. If no statute or regulation imposes an issue-exhaustion requirement, courts decide whether to require issue exhaustion based on “an analogy to the rule that appellate courts will not consider arguments not raised before trial courts.” In the context of petitioners’ Appointments Clause challenges, two considerations tip the scales against imposing an issue-exhaustion requirement: agency adjudications are generally ill-suited to address structural constitutional challenges, which usually fall outside the adjudicators’ areas of technical expertise, and the Supreme Court has consistently recognized a futility exception to exhaustion requirements. Petitioners assert purely constitutional claims about which SSA ALJs have no special expertise and for which they can provide no relief. View "Carr v. Saul" on Justia Law

A Mississippi jury convicted Jones of murder for killing his grandfather when Jones was 15 years old. Under Mississippi law, murder carried a mandatory sentence of life without parole. That sentence was affirmed on appeal. The Supreme Court subsequently held, in Miller v. Alabama, that the Eighth Amendment permits a life-without-parole sentence for a defendant who committed homicide when he was under 18 only if the sentence is not mandatory and the sentencer has the discretion to impose a lesser punishment. The Mississippi Supreme Court ordered that Jones be resentenced. The judge at resentencing acknowledged that he had discretion under Miller to impose a sentence less than life without parole but determined that life without parole remained the appropriate sentence. The Supreme Court had recently held (Montgomery v. Louisiana) that Miller applied retroactively on collateral review. The Mississippi Court of Appeals rejected Jones’s argument that, under Miller and Montgomery, a sentencer must make a separate factual finding that a murderer under 18 is permanently incorrigible before sentencing the offender to life without parole.The Supreme Court affirmed. In the case of a defendant who committed homicide when he was under 18, Miller and Montgomery do not require the sentencer to make a separate factual finding of permanent incorrigibility before sentencing the defendant to life without parole; a discretionary sentencing system is both constitutionally necessary and constitutionally sufficient. The cases require consideration of an offender’s youth but not any particular factual finding nor an on-the-record sentencing explanation with an “implicit finding” of permanent incorrigibility before sentencing a murderer under 18 to life without parole. Jones's resentencing complied with Miller and Montgomery because the sentencer had discretion to impose a sentence less than life without parole in light of Jones’s youth. View "Jones v. Mississippi" on Justia Law

Oracle owns a copyright in Java SE, a computer platform. Google acquired Android and sought to build a new software platform for mobile devices. To allow millions of programmers familiar with Java to work with its new platform, Google copied roughly 11,500 lines of code from Java SE. The copied lines allow programmers to call upon prewritten computing tasks for use in their own programs. The Federal Circuit held that the copied lines were copyrightable and reversed a jury’s finding of fair use.The Supreme Court reversed. Google’s copying of code lines needed to allow programmers to put their talents to work in a transformative program was fair use as a matter of law. Copyright protection cannot extend to “any idea, procedure, process, system, method of operation, concept, principle, or discovery,” 17 U.S.C. 102(b), and a copyright holder may not prevent another from making a “fair use” of a copyrighted work.Assuming that the copied lines can be copyrighted, the Court focused on “fair use.” The “right of trial by jury” does not include the right to have a jury resolve a fair use defense. Unlike other types of code, much of the copied material's value derives from the investment of users (computer programmers) who have learned the system; application of fair use here is unlikely to undermine the general copyright protection for computer programs. The “purpose and character” of this use is transformative. Google copied only about 0.4 percent of the entire program at issue and that was tethered to a valid, transformative, purpose. Google’s new smartphone platform is not a market substitute for Java SE; the copyright holder would benefit from the reimplementation of its interface into a different market. Enforcing the copyright on these facts risks causing creativity-related harms to the public. View "Google LLC v. Oracle America, Inc." on Justia Law

The Telephone Consumer Protection Act of 1991 (TCPA) restricts communications made with an “automatic telephone dialing system,” defined as equipment with the capacity both “to store or produce telephone numbers to be called, using a random or sequential number generator,” and to dial those numbers, 47 U.S.C. 227(a)(1). Facebook’s social media platform allows users to elect to receive text messages when someone attempts to log in to the user’s account from a new device. Facebook sent such texts to Duguid, alerting him to login activity on a Facebook account linked to his telephone number, but Duguid never created any Facebook account. Duguid tried, unsuccessfully, to stop the unwanted messages. He brought a putative class action, alleging that Facebook violated the TCPA by maintaining a database that stored phone numbers and programming its equipment to send automated text messages. The Ninth Circuit ruled in Duguid’s favor.The Supreme Court reversed: To qualify as an “automatic telephone dialing system” under the TCPA, a device must have the capacity either to store a telephone number using a random or sequential number generator or to produce a telephone number using a random or sequential number generator. The statutory context confirms that the TCPA’s autodialer definition excludes equipment that does not use a random or sequential number generator. Congress found autodialer technology harmful because autodialers can dial emergency lines randomly or tie up all of an entity's sequentially numbered phone lines. Duguid’s interpretation would encompass any equipment that stores and dials telephone numbers. View "Facebook, Inc. v. Duguid" on Justia Law

Federal Communications Commission (FCC) ownership rules limit the number of radio stations, television stations, and newspapers that a single entity may own in a given market. Section 202(h) of the Telecommunications Act of 1996 directs the FCC to review its media ownership rules every four years and to repeal or modify rules that no longer serve the public interest. In 2017, the FCC concluded that three ownership rules were no longer necessary to promote competition, localism, or viewpoint diversity and that the record did not suggest that repealing or modifying those rules was likely to harm minority and female ownership. The FCC repealed two ownership rules and modified another. The Third Circuit vacated the order.The Supreme Court reversed. The FCC’s decision to repeal or modify the three ownership rules was not arbitrary and capricious under the Administrative Procedures Act (APA); it considered the record evidence and reasonably concluded that the rules at issue were no longer necessary to serve the agency’s public interest goals of competition, localism, and viewpoint diversity and that the changes were not likely to harm minority and female ownership. The FCC acknowledged the gaps in the data sets it relied on and noted that, despite its repeated requests for additional data, it had received no countervailing evidence suggesting that changing the rules was likely to harm minority and female ownership. The FCC considered two studies that purported to show that past relaxations of the ownership rules had led to decreases in minority and female ownership levels and interpreted them differently. The APA imposes no general obligation on agencies to conduct or commission their own studies. Nothing in the Telecommunications Act requires the FCC to conduct such studies before exercising its discretion under Section 202(h). View "Federal Communications Commission v. Prometheus Radio Project" on Justia Law

In March 1985, Hines, carrying a concealed hunting knife, checked into a motel. The manager had put Jenkins in charge of the motel, providing her with a bag of money. Another visitor, Jones, later found Jenkins’ body in a guest's room, with several knife wounds. Her money, keys, and vehicle were missing. A group of travelers later picked Hines up from beside Jenkins' broken-down car. Hines had dried blood on his shirt and “ke[pt] contradicting himself.” Hines admitted to his sister that he had stabbed somebody at the motel; he had a lot of money and the keys to Jenkins’ car. Hines changed his story when he surrendered to the police but offered to confess if guaranteed the death penalty. A search of Hines' motel room revealed stab marks. Jones testified he knew the motel's owners and had stopped by, taken a key from the office, and entered Hines’ room to use the bathroom. Hines’ counsel stressed to the jury this odd sequence of events. The jury heard discrepancies between his account and the first responders' timeline. When Hines unsuccessfully sought post-conviction review, Jones admitted that he was at the motel with a woman other than his wife and had helped himself to a room key. His story was confirmed by his companion who watched through the room’s window. Hines’ attorney was aware of Jones’ affair but had decided to spare him some embarrassment.The Supreme Court reversed the Sixth Circuit's 2020 grant of habeas relief. A federal court “shall not” grant habeas relief unless the state decision took an “unreasonable” view of the facts or law. Substantial evidence linked Hines to the crime. The theory that a more aggressive attorney could have changed the result by casting doubt on Jones’ credibility or portraying him as a viable suspect ignores that Jones’ testimony about discovering the body did not indicate that Hines was the culprit. Ample other evidence did that. If Jones’ credibility mattered, the jury had good reasons to be skeptical. Had the Sixth Circuit properly considered the entire record, it would have had little trouble deferring to the Tennessee court’s conclusion that Hines suffered no prejudice. View "Mays v. Hines" on Justia Law

Ford, incorporated in Delaware and headquartered in Michigan, markets, sells, and services its products across the U.S. and overseas and encourages a resale market for its vehicles. Montana and Minnesota courts exercised jurisdiction over Ford in products-liability suits stemming from car accidents that injured state residents. The vehicles were designed and manufactured elsewhere, and originally were sold outside the forum states.The Supreme Court affirmed the rejection of Ford's jurisdictional arguments. The connection between the claims and Ford’s activities in the forum states is close enough to support specific jurisdiction. A state court may exercise general jurisdiction only when a defendant is “essentially at home” in the state. Specific jurisdiction covers defendants less intimately connected with a state if there was “some act by which [defendant] purposefully avails itself of the privilege of conducting activities within the forum State” and the claims “must arise out of or relate to the defendant’s contacts” with the forum.Ford purposefully availed itself of the privilege of conducting activities in both states. There is no requirement of a causal link locating jurisdiction only in the state where Ford sold the car in question or the states where Ford designed and manufactured the vehicle. Specific jurisdiction attaches in cases in which a company cultivates a market for a product in the forum state and the product malfunctions there. Ford advertises and markets its vehicles in Montana and Minnesota and fosters ongoing connections to Ford owners. Because Ford systematically served a market in Montana and Minnesota for the very vehicles that the plaintiffs allege malfunctioned and injured them in those states, there is a strong “relationship among the defendant, the forum, and the litigation.” View "Ford Motor Co. v. Montana Eighth Judicial District Court" on Justia Law

New Mexico State Police officers arrived at an apartment complex to execute an arrest warrant and approached Torres, then standing near a car, and attempted to speak with her as she got into the driver’s seat. Believing the officers to be carjackers, Torres hit the gas to escape. The officers fired their service pistols 13 times to stop Torres, striking her twice. Torres escaped and drove to a hospital 75 miles away. Torres was airlifted back to an Albuquerque hospital, where she was arrested. Her suit for damages under 42 U.S.C. 1983 was rejected on summary judgment. The Tenth Circuit held that “a suspect’s continued flight after being shot by police negates a Fourth Amendment excessive-force claim.”.The Supreme Court vacated. The application of physical force to the body of a person with the intent to restrain is a seizure even if the person does not submit and is not subdued. The required corporal seizing or touching can be as readily accomplished by a bullet as by a finger. The focus of the Fourth Amendment is “the privacy and security of individuals,” not the particular form of governmental intrusion. A seizure requires the use of force with intent to restrain, as opposed to force applied by accident or for some other purpose. The inquiry is whether the challenged conduct objectively manifests an intent to restrain. The officers seized Torres by shooting her with the intent to restrain her movement. The Court did not address the reasonableness of the seizure, damages, or the officers’ entitlement to qualified immunity. View "Torres v. Madrid" on Justia Law

Uzuegbunam, a Georgia Gwinnett College student, talked with interested students and handed out religious literature on campus until a campus police officer informed him that campus policy prohibited distributing religious materials outside two areas designated for that purpose. Speaking about religion or distributing religious materials in those areas required a permit. Uzuegbunam obtained a permit and tried to speak in a free speech zone. A campus officer again asked him to stop, saying that people had complained. Campus policy prohibited using the free speech zone to say anything that “disturbs the peace and/or comfort of person(s).” Uzuegbunam complied. Another student decided not to speak about religion because of these events. The students sought injunctive relief and nominal damages. College officials discontinued the challenged policies. The Eleventh Circuit held that the students’ plea for nominal damages could not establish standing, absent a request for compensatory damages.The Supreme Court reversed. A request for nominal damages satisfies the redressability element necessary for Article III standing where a plaintiff’s claim is based on a completed violation of a legal right. To establish Article III standing, the Constitution requires a plaintiff to identify an injury in fact that is fairly traceable to the challenged conduct and to seek a remedy likely to redress that injury. Under common law, a party whose rights are invaded can recover nominal damages without furnishing evidence of actual damages, without a plea for compensatory damages. Nominal damages are not purely symbolic. One dollar may not provide full redress, but the partial remedy satisfies the redressability requirement and constitutes relief on the merits. In addition to redressability, the plaintiff must establish the other elements of standing and satisfy other relevant requirements, such as pleading a cognizable cause of action. View "Uzuegbunam v. Preczewski" on Justia Law