Justia U.S. Supreme Court Opinion Summaries

In 2012, Jennifer Zuch and her then-husband Patrick Gennardo filed late 2010 federal tax returns. Gennardo's return showed a significant balance due, which he addressed by submitting an offer in compromise, involving $50,000 in estimated tax payments. The IRS applied these payments to Gennardo's account. Zuch later amended her return, reporting additional income and resulting in $28,000 in taxes due. She argued that the $50,000 should be credited to her account, entitling her to a refund, but the IRS disagreed and placed a levy on her property. Zuch requested a collection due process hearing, which upheld the levy. She appealed to the Tax Court.The Tax Court initially reviewed the case but dismissed it as moot after Zuch's tax liability was reduced to zero through overpayments applied by the IRS. The court ruled it lacked jurisdiction since there was no longer a basis for a levy. Zuch appealed to the Third Circuit, which vacated the dismissal, holding that the IRS's abandonment of the levy did not moot the proceedings, as the Tax Court could still address the underlying tax dispute.The Supreme Court of the United States reviewed the case and held that the Tax Court lacks jurisdiction under 26 U.S.C. §6330 to resolve disputes when the IRS is no longer pursuing a levy. The Court reasoned that the Tax Court's jurisdiction is limited to reviewing the determination of whether a levy may proceed. Once the levy is no longer in question, the Tax Court cannot address the underlying tax liability. The Supreme Court reversed the Third Circuit's decision and remanded the case for further proceedings consistent with this opinion. View "Commissioner v. Zuch" on Justia Law

In October 2017, the FBI mistakenly raided the home of Hilliard Toi Cliatt, Curtrina Martin, and her 7-year-old son in suburban Atlanta, instead of the intended gang hideout. The error occurred due to Special Agent Guerra's reliance on a personal GPS device and the team's failure to notice the correct street sign and house number. The raid resulted in personal injuries and property damage. The plaintiffs sued the United States under the Federal Tort Claims Act (FTCA) for the officers' negligent and intentional actions.The district court granted summary judgment to the government, and the Eleventh Circuit affirmed. The Eleventh Circuit applied a unique approach to FTCA claims, holding that the law enforcement proviso in §2680(h) overrides all exceptions, including the discretionary-function exception, allowing intentional-tort claims to proceed without further analysis. The court also allowed the government to assert a Supremacy Clause defense, which it found valid, leading to summary judgment for the United States.The Supreme Court of the United States reviewed the case and held that the law enforcement proviso in §2680(h) overrides only the intentional-tort exception, not the discretionary-function exception or other exceptions in §2680. The Court also held that the Supremacy Clause does not afford the United States a defense in FTCA suits. The case was vacated and remanded to the Eleventh Circuit to reconsider whether the discretionary-function exception bars the plaintiffs' claims and to assess liability under Georgia state law without reference to a Supremacy Clause defense. View "Martin v. United States" on Justia Law

Simon Soto, a Marine Corps veteran, served from 2000 to 2006 and was medically retired due to post-traumatic stress disorder (PTSD). In 2016, Soto applied for combat-related special compensation (CRSC) and was approved, but his retroactive compensation was limited to six years due to the Barring Act's limitations period. Soto filed a class-action lawsuit arguing that the CRSC statute should displace the Barring Act's limitations period.The United States District Court for the Southern District of Texas granted summary judgment in favor of Soto and the class, holding that the CRSC statute provides its own settlement mechanism, thus displacing the Barring Act. However, the United States Court of Appeals for the Federal Circuit reversed this decision, stating that the CRSC statute does not explicitly grant settlement authority and therefore cannot displace the Barring Act.The Supreme Court of the United States reviewed the case and held that the CRSC statute does confer authority to settle CRSC claims, thereby displacing the Barring Act’s settlement procedures and limitations period. The Court reasoned that the CRSC statute authorizes the Secretary concerned to determine both the validity of CRSC claims and the amount due, creating a comprehensive compensation scheme. Consequently, the Supreme Court reversed the Federal Circuit's decision and remanded the case for further proceedings consistent with this opinion. View "Soto v. United States" on Justia Law

Donte Parrish, a federal inmate, was placed in restrictive segregated confinement for 23 months due to his suspected involvement in another inmate's death. After being cleared of wrongdoing by a hearing officer, Parrish filed a lawsuit in Federal District Court seeking damages for his confinement. The District Court dismissed his case on March 23, 2020, citing some claims as untimely and others as unexhausted. Parrish, who had been transferred to a different facility, received the dismissal order three months later and promptly filed a notice of appeal, explaining the delay.The Fourth Circuit recognized that Parrish's notice of appeal was filed after the 60-day appeal period for suits against the United States. The court construed his filing as a motion to reopen the time to appeal under 28 U.S.C. §2107(c). On remand, the District Court granted a 14-day reopening period, but Parrish did not file a second notice of appeal. Both Parrish and the United States argued that the original notice was sufficient, but the Fourth Circuit held that Parrish's failure to file a new notice within the reopened period deprived the court of jurisdiction.The Supreme Court of the United States reviewed the case and held that a litigant who files a notice of appeal after the original appeal deadline but before the court grants reopening does not need to file a second notice after reopening. The original notice relates forward to the date reopening is granted. The Court reversed the Fourth Circuit's decision, allowing Parrish's appeal to proceed. View "Parrish v. United States" on Justia Law

A.J.T., a teenage girl with a rare form of epilepsy, moved to Minnesota in 2015. Her new school district, Osseo Area Public Schools, denied her parents' requests to include evening instruction in her Individualized Educational Program (IEP), despite her inability to attend school before noon due to frequent morning seizures. Consequently, A.J.T. received only 4.25 hours of instruction daily, compared to the typical 6.5-hour school day for nondisabled students. After further cuts to her school day were proposed, her parents filed an IDEA complaint, alleging that the refusal to provide afterhours instruction denied A.J.T. a free appropriate public education.An Administrative Law Judge ruled in favor of A.J.T., finding that the school district violated the IDEA and ordered compensatory education and evening instruction. The Federal District Court and the Eighth Circuit Court of Appeals affirmed this decision. However, when A.J.T. and her parents sued under the ADA and the Rehabilitation Act, the District Court granted summary judgment for the school, and the Eighth Circuit affirmed, stating that a plaintiff must prove bad faith or gross misjudgment by school officials to establish a prima facie case of discrimination.The Supreme Court of the United States reviewed the case and held that schoolchildren bringing ADA and Rehabilitation Act claims related to their education are not required to make a heightened showing of bad faith or gross misjudgment. Instead, they are subject to the same standards that apply in other disability discrimination contexts. The Court vacated the Eighth Circuit's judgment and remanded the case for further proceedings consistent with this opinion. View "A. J. T. v. Osseo Area Schools, Independent School Dist. No. 279" on Justia Law

Danny Rivers was convicted in Texas state court of continuous sexual abuse of a child and related charges. After failing to obtain relief through direct appeal and state habeas proceedings, Rivers filed his first federal habeas petition in August 2017, which was denied by the District Court in September 2018. The Fifth Circuit granted a certificate of appealability on his ineffective assistance of counsel claim in July 2020. While his appeal was pending, Rivers discovered new evidence in his trial counsel’s client file and filed a second federal habeas petition based on this evidence.The District Court classified Rivers's second petition as a "second or successive" habeas application under 28 U.S.C. §2244(b) and transferred it to the Fifth Circuit for authorization. Rivers appealed the transfer order, arguing that his second petition should not be considered "second or successive" because his first petition was still on appeal. The Fifth Circuit affirmed the District Court's decision, holding that the pending appeal did not exempt Rivers from the requirements for successive petitions under §2244.The Supreme Court of the United States reviewed the case and held that once a district court enters its judgment on a first-filed habeas petition, any subsequent filing qualifies as a "second or successive" application subject to the requirements of §2244(b). The Court emphasized that the existence of a final judgment, not the status of an appeal, determines whether a filing is considered second or successive. The Court affirmed the Fifth Circuit's decision, rejecting Rivers's argument that his second filing should be treated as an amendment to his initial petition. View "Rivers v. Guerrero" on Justia Law

Catholic Charities Bureau, Inc., and its subentities sought an exemption from Wisconsin's unemployment compensation taxes, claiming they were controlled by the Roman Catholic Diocese of Superior and operated primarily for religious purposes. The Wisconsin Supreme Court denied the exemption, ruling that the organizations did not engage in proselytization or limit their services to Catholics, and thus were not operated primarily for religious purposes.The Wisconsin Department of Workforce Development initially denied the exemption request, but an Administrative Law Judge reversed this decision. The Wisconsin Labor and Industry Review Commission then reinstated the denial. The state trial court overruled the commission, granting the exemption, but the Wisconsin Court of Appeals reversed this decision. The Wisconsin Supreme Court affirmed the Court of Appeals, holding that the organizations' activities were secular and not primarily religious, and that the statute did not violate the First Amendment.The United States Supreme Court reviewed the case and held that the Wisconsin Supreme Court's application of the statute violated the First Amendment. The Court found that the statute imposed a denominational preference by differentiating between religions based on theological lines, subjecting it to strict scrutiny. The Court concluded that the statute, as applied, could not survive strict scrutiny because the State failed to show that the law was narrowly tailored to further a compelling government interest. The judgment of the Wisconsin Supreme Court was reversed, and the case was remanded for further proceedings. View "Catholic Charities Bureau, Inc. v. Wisconsin Labor and Industry Review Commission" on Justia Law

Plaintiffs, victims and families of victims of terrorist attacks carried out by Hamas between 2001 and 2003, sued BLOM Bank SAL under the Anti-Terrorism Act, alleging that the bank aided and abetted the attacks by providing financial services to Hamas-affiliated customers. BLOM argued that the complaint failed to state a claim, and plaintiffs affirmed they would not seek to amend their complaint if dismissed. The District Court dismissed the complaint with prejudice, finding that plaintiffs had not adequately alleged BLOM's general awareness for aiding-and-abetting liability and denied leave to amend due to plaintiffs' refusal to amend earlier.The Second Circuit affirmed the dismissal, noting that the District Court applied too stringent a standard for general awareness but concluded that plaintiffs' claims still failed under the correct standard. Plaintiffs then moved under Federal Rule of Civil Procedure 60(b)(6) to vacate the final judgment to file an amended complaint. The District Court denied the motion, ruling that the Second Circuit’s clarification did not constitute "extraordinary circumstances" required for Rule 60(b)(6) relief and that plaintiffs' prior choices not to amend counseled against relief. The Second Circuit reversed, holding that district courts must balance Rule 60(b)’s finality principles with Rule 15(a)’s liberal amendment policy.The Supreme Court of the United States held that relief under Rule 60(b)(6) requires extraordinary circumstances, and this standard does not become less demanding when the movant seeks to reopen a case to amend a complaint. A party must first satisfy Rule 60(b) before Rule 15(a)’s liberal amendment standard can apply. The Court reversed the Second Circuit’s decision, emphasizing that the District Court correctly applied the Rule 60(b)(6) standard and provided substantial justification for its conclusion. The case was remanded for further proceedings consistent with this opinion. View "BLOM Bank SAL v. Honickman" on Justia Law

Devas Multimedia Private Ltd. entered into a satellite-leasing agreement with Antrix Corporation Ltd., a company owned by the Republic of India. The agreement was terminated by Antrix under a force majeure clause when the Indian Government decided it needed more satellite capacity for itself. Devas initiated arbitration, and the arbitral panel awarded Devas $562.5 million in damages plus interest. Devas sought to confirm the award in the United States District Court for the Western District of Washington, which confirmed the award and entered a $1.29 billion judgment against Antrix.The United States Court of Appeals for the Ninth Circuit reversed the District Court's decision, finding that personal jurisdiction was lacking. The Ninth Circuit held that under the Foreign Sovereign Immunities Act of 1976 (FSIA), personal jurisdiction over a foreign state requires not only an immunity exception and proper service but also a traditional minimum contacts analysis as set forth in International Shoe Co. v. Washington. The court concluded that Antrix did not have sufficient suit-related contacts with the United States to establish personal jurisdiction.The Supreme Court of the United States reviewed the case and held that personal jurisdiction under the FSIA exists when an immunity exception applies and service is proper. The Court determined that the FSIA does not require proof of minimum contacts beyond the contacts already required by the Act’s enumerated exceptions to foreign sovereign immunity. The Court reversed the Ninth Circuit's decision and remanded the case for further proceedings consistent with its opinion. View "CC/Devas (Mauritius) Ltd. v. Antrix Corp." on Justia Law

The Government of Mexico filed a lawsuit against seven American gun manufacturers, alleging that the companies aided and abetted unlawful gun sales that routed firearms to Mexican drug cartels. Mexico claimed that the manufacturers failed to exercise reasonable care to prevent trafficking of their guns into Mexico, resulting in harm from the weapons' misuse. The complaint included allegations that the manufacturers knowingly supplied firearms to retail dealers who sold them illegally to Mexican traffickers, failed to impose controls on their distribution networks, and made design and marketing decisions to stimulate demand among cartel members.The U.S. District Court dismissed the complaint, but the Court of Appeals for the First Circuit reversed the decision. The First Circuit found that Mexico had plausibly alleged that the defendants aided and abetted illegal firearms sales, thus satisfying the predicate exception under the Protection of Lawful Commerce in Arms Act (PLCAA).The Supreme Court of the United States reviewed the case and held that Mexico's complaint did not plausibly allege that the defendant gun manufacturers aided and abetted gun dealers' unlawful sales of firearms to Mexican traffickers. The Court concluded that the allegations did not meet the requirements for aiding and abetting liability, as they did not show that the manufacturers took affirmative acts to facilitate the illegal sales or intended to promote the criminal activities. Consequently, PLCAA barred the lawsuit, and the Supreme Court reversed the judgment of the Court of Appeals and remanded the case for further proceedings consistent with its opinion. View "Smith & Wesson Brands, Inc. v. Estados Unidos Mexicanos" on Justia Law