Justia U.S. Supreme Court Opinion Summaries

The case involves Sandra Muñoz, an American citizen, and her husband Luis Asencio-Cordero, a citizen of El Salvador. The couple sought to obtain an immigrant visa for Asencio-Cordero to live in the United States. After several interviews, a consular officer denied Asencio-Cordero's application, citing a provision that renders inadmissible a noncitizen whom the officer believes seeks to engage in unlawful activity. Asencio-Cordero and Muñoz sued the Department of State, claiming that it had abridged Muñoz’s constitutional liberty interest in her husband’s visa application by failing to give a sufficient reason why Asencio-Cordero is inadmissible under the “unlawful activity” bar.The District Court granted summary judgment to the State Department, but the Ninth Circuit vacated the judgment, holding that Muñoz had a constitutionally protected liberty interest in her husband’s visa application and that the State Department was required to give Muñoz a reason for denying her husband’s visa. The court further held that by declining to give Muñoz more information earlier in the process, the State Department had forfeited its entitlement to insulate its decision from judicial review under the doctrine of consular nonreviewability.The Supreme Court of the United States reversed the Ninth Circuit's decision, holding that a citizen does not have a fundamental liberty interest in her noncitizen spouse being admitted to the country. The Court noted that while Congress has extended special treatment to marriage in immigration matters, it has never made spousal immigration a matter of right. The Court also noted that the assertion of a procedural due process right in someone else's legal proceeding would have unsettling collateral consequences. The case was remanded for further proceedings consistent with the Court's opinion. View "Department of State v. Munoz" on Justia Law

The case involves the Sixth Amendment's Confrontation Clause, which guarantees a criminal defendant the right to confront the witnesses against him. The defendant, Jason Smith, was charged with various drug offenses after law enforcement officers found him with a large quantity of what appeared to be drugs and drug-related items. The seized items were sent to a crime lab for scientific analysis. Analyst Elizabeth Rast ran forensic tests on the items and concluded that they contained usable quantities of methamphetamine, marijuana, and cannabis. Rast prepared a set of typed notes and a signed report about the testing. However, Rast stopped working at the lab prior to trial, so the State substituted another analyst, Greggory Longoni, to provide an independent opinion on the drug testing performed by Rast. At trial, Longoni conveyed to the jury what Rast’s records revealed about her testing, before offering his “independent opinion” of each item’s identity. Smith was convicted. On appeal, he argued that the State’s use of a substitute expert to convey the substance of Rast’s materials violated his Confrontation Clause rights. The Arizona Court of Appeals rejected Smith’s challenge.The Supreme Court of the United States held that when an expert conveys an absent analyst’s statements in support of the expert’s opinion, and the statements provide that support only if true, then the statements come into evidence for their truth. The Court vacated the judgment of the Arizona Court of Appeals and remanded the case for further proceedings. The Court clarified that the Confrontation Clause still allows forensic experts to play a useful role in criminal trials. However, a state may not introduce the testimonial out-of-court statements of a forensic analyst at trial, unless she is unavailable and the defendant has had a prior chance to cross-examine her. The Court concluded that the State used Longoni to relay what Rast wrote down about how she identified the seized substances, and thus Longoni effectively became Rast’s mouthpiece. If the out-of-court statements were also testimonial, their admission violated the Confrontation Clause. View "Smith v. Arizona" on Justia Law

This case involves a dispute between Jascha Chiaverini, a jewelry store owner, and police officers from Napoleon, Ohio. The officers charged Chiaverini with three crimes: receiving stolen property, dealing in precious metals without a license, both misdemeanors, and money laundering, a felony. After obtaining a warrant, the police arrested Chiaverini and detained him for three days. However, county prosecutors later dropped the case. Chiaverini, believing that his arrest and detention were unjustified, sued the officers, alleging a Fourth Amendment malicious-prosecution claim under 42 U.S.C. §1983. To win this claim, he had to show that the officers brought criminal charges against him without probable cause, leading to an unreasonable seizure of his person.The District Court granted summary judgment to the officers, and the Court of Appeals for the Sixth Circuit affirmed. The Court of Appeals held that Chiaverini’s prosecution was supported by probable cause. In its decision, the court did not address whether the officers had probable cause to bring the money-laundering charge. The court believed that there was clearly probable cause to charge Chiaverini with the two misdemeanors. As long as one charge was supported by probable cause, it thought, a malicious-prosecution claim based on any other charge must fail.The Supreme Court of the United States held that the presence of probable cause for one charge in a criminal proceeding does not categorically defeat a Fourth Amendment malicious-prosecution claim relating to another, baseless charge. The parties, and the United States as amicus curiae, all agreed with this conclusion, which follows from both the Fourth Amendment and traditional common-law practice. The Supreme Court vacated the judgment of the Court of Appeals and remanded the case for further proceedings consistent with its opinion. View "Chiaverini v. City of Napoleon" on Justia Law

Delilah Diaz was stopped at a U.S.-Mexico border port of entry, where border patrol officers discovered over 54 pounds of methamphetamine hidden in the car she was driving. Diaz was charged with importing methamphetamine, a charge that required the government to prove that Diaz knowingly transported the drugs. Diaz claimed she was unaware of the drugs in the car. To counter this claim, the government planned to call an expert witness, Homeland Security Investigations Special Agent Andrew Flood, to testify that drug traffickers generally do not entrust large quantities of drugs to people who are unaware they are transporting them. Diaz objected to this testimony under Federal Rule of Evidence 704(b), which prohibits an expert witness from stating an opinion about whether the defendant did or did not have a mental state or condition that constitutes an element of the crime charged or of a defense. The court ruled that Agent Flood could testify that most couriers know they are transporting drugs. Diaz was found guilty and appealed, challenging Agent Flood’s testimony under Rule 704(b).The Court of Appeals held that because Agent Flood did not explicitly opine that Diaz knowingly transported methamphetamine, his testimony did not violate Rule 704(b). Diaz appealed this decision to the Supreme Court of the United States.The Supreme Court affirmed the decision of the Court of Appeals. The Court held that expert testimony that "most people" in a group have a particular mental state is not an opinion about "the defendant" and thus does not violate Rule 704(b). The Court reasoned that Agent Flood did not express an opinion about whether Diaz herself knowingly transported methamphetamine. Instead, he testified about the knowledge of most drug couriers, which does not necessarily describe Diaz’s mental state. The Court concluded that because Agent Flood did not express an opinion about whether Diaz herself knowingly transported methamphetamine, his testimony did not violate Rule 704(b). View "Diaz v. United States" on Justia Law

The case involves Charles and Kathleen Moore, who invested in an American-controlled foreign corporation, KisanKraft. From 2006 to 2017, KisanKraft generated substantial income but did not distribute it to its American shareholders. At the end of the 2017 tax year, the application of the new Mandatory Repatriation Tax (MRT) resulted in a tax bill of $14,729 on the Moores’ pro rata share of KisanKraft’s accumulated income from 2006 to 2017. The Moores paid the tax and then sued for a refund, claiming that the MRT violated the Direct Tax Clause of the Constitution because it was an unapportioned direct tax on their shares of KisanKraft stock. The District Court dismissed the suit, and the Ninth Circuit affirmed.The Supreme Court of the United States affirmed the Ninth Circuit's decision. The Court held that the MRT, which attributes the realized and undistributed income of an American-controlled foreign corporation to the entity’s American shareholders, and then taxes the American shareholders on their portions of that income, does not exceed Congress’s constitutional authority. The Court's decision was based on the broad power of Congress to lay and collect taxes, which includes direct taxes—those imposed on persons or property—and indirect taxes—those imposed on activities or transactions. The Court also noted that taxes on income are indirect taxes, and the Sixteenth Amendment confirms that taxes on income need not be apportioned. The Court's holding is narrow and limited to entities treated as pass-throughs. View "Moore v. United States" on Justia Law

Sylvia Gonzalez, a city council member in Castle Hills, Texas, was involved in a campaign to remove the city manager, Ryan Rapelye. She gathered signatures for a petition, which was introduced at a city council meeting. After the meeting, the mayor, Edward Trevino, II, asked Gonzalez for the petition. Gonzalez found the petition in her binder, which she claimed was unintentional. Trevino reported this to the city police, leading to an investigation. A private attorney concluded that Gonzalez likely violated a Texas anti-tampering statute, leading to her arrest. The charges were later dismissed, but Gonzalez claimed this incident led her to step away from politics.Gonzalez filed a lawsuit under 42 U.S.C. §1983 in Federal District Court against Trevino, the police chief, and the private attorney, alleging that her arrest was in retaliation for her role in the petition and violated her First Amendment rights. The District Court denied the defendants' motion to dismiss the complaint, finding that it fell within an exception to the no-probable-cause rule recognized in Nieves. However, the Fifth Circuit reversed this decision, stating that Gonzalez's claim could only fall within the Nieves exception if she provided "comparative evidence" of similarly situated individuals who engaged in the same criminal conduct but were not arrested.The Supreme Court of the United States disagreed with the Fifth Circuit's interpretation of the Nieves exception. The Court found that the Fifth Circuit's requirement for specific comparator evidence was overly restrictive. The Court clarified that to fall within the Nieves exception, a plaintiff must produce objective evidence to prove that his arrest occurred in circumstances where officers typically exercise their discretion not to make arrests. The Court held that Gonzalez's evidence, showing that no one had ever been arrested for similar conduct, was a permissible type of evidence. The Court vacated the Fifth Circuit's judgment and remanded the case for further proceedings. View "Gonzalez v. Trevino" on Justia Law

The case revolves around the legality of bump stocks, accessories that allow semi-automatic rifles to fire at a rate similar to machine guns. The Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) had long held that semi-automatic rifles equipped with bump stocks were not machine guns under the statute. However, following a mass shooting in Las Vegas, Nevada, where the shooter used bump stocks, the ATF reversed its position and issued a rule classifying bump stocks as machine guns.The case was first heard in the District Court, where Michael Cargill, who had surrendered two bump stocks to the ATF under protest, challenged the rule. Cargill argued that the ATF lacked statutory authority to classify bump stocks as machine guns because they did not meet the definition of a machine gun under §5845(b). The District Court ruled in favor of the ATF, concluding that a bump stock fits the statutory definition of a machine gun.The case was then taken to the Court of Appeals, which initially affirmed the District Court's decision but later reversed it after rehearing en banc. The majority of the Court of Appeals agreed that §5845(b) was ambiguous as to whether a semi-automatic rifle equipped with a bump stock fits the statutory definition of a machine gun. They concluded that the rule of lenity required resolving that ambiguity in Cargill's favor.The Supreme Court of the United States affirmed the decision of the Court of Appeals. The Court held that a semi-automatic rifle equipped with a bump stock is not a machine gun because it cannot fire more than one shot by a single function of the trigger. Furthermore, even if it could, it would not do so automatically. Therefore, the ATF exceeded its statutory authority by issuing a rule that classifies bump stocks as machine guns. View "Garland v. Cargill" on Justia Law

The case involves three aliens, Moris Esmelis Campos-Chaves, Varinder Singh, and Raul Daniel Mendez-Colín, who were ordered removed in absentia after failing to appear at their respective removal hearings. The Government had initiated removal proceedings against each of them, serving them with Notices to Appear (NTAs) that did not specify the time and date of the hearings. However, each alien was later provided with a notice specifying the time and place of the removal hearing. After being ordered removed in absentia, each alien sought to rescind the order, arguing that they did not receive a proper NTA.In the lower courts, the Fifth Circuit denied Campos-Chaves's petition for review, while the Ninth Circuit granted the petitions for Singh and Mendez-Colín. The Fifth Circuit based its decision on the fact that Campos-Chaves did not dispute receiving the subsequent notice specifying the time and place of the hearing. The Ninth Circuit, on the other hand, held that the lack of a single-document NTA alone rendered the in absentia removal orders rescindable.The Supreme Court of the United States held that to rescind an in absentia removal order on the ground that the alien did not receive notice in accordance with paragraph (1) or (2), the alien must show that he did not receive notice under either paragraph for the hearing at which the alien was absent and ordered removed. Because each of the aliens in these cases received a proper paragraph (2) notice for the hearings they missed and at which they were ordered removed, they cannot seek rescission of their in absentia removal orders on the basis of defective notice. The Court affirmed the judgment of the Fifth Circuit, reversed the Ninth Circuit’s judgment in Garland v. Mendez-Colín, and vacated and remanded the Ninth Circuit’s judgment in Garland v. Singh for further proceedings consistent with this opinion. View "Campos-Chaves v. Garland" on Justia Law

The case involves the Office of the United States Trustee and a group of Chapter 11 debtors, John Q. Hammons Fall 2006, LLC, et al. The issue at hand is the remedy for a constitutional violation identified in a previous case, Siegel v. Fitzgerald, where a statute was found to violate the Bankruptcy Clause’s uniformity requirement as it allowed different fees for Chapter 11 debtors depending on the district where their case was filed. The government argued for prospective parity as the appropriate remedy, while the debtors argued for a refund.The Bankruptcy Court found no constitutional violation and did not address the remedial question. The Tenth Circuit reversed this decision, finding that the fee statute permitting nonuniform fees violated the Bankruptcy Clause and ordered a refund of the debtors’ quarterly fees. The U.S. Trustee sought certiorari, which was granted by the Supreme Court.The Supreme Court reversed the Tenth Circuit's decision. The Court agreed with the government that the appropriate remedy for the constitutional violation is prospective parity. The Court held that requiring equal fees for otherwise identical Chapter 11 debtors going forward aligns with congressional intent, corrects the constitutional wrong, and complies with due process. The Court rejected the debtors' argument for a refund, stating that such a remedy would require undercutting congressional intent and transforming a program that Congress designed to be self-funding into a significant bill for taxpayers. The Court concluded that neither remedial principles nor due process requires such an outcome. View "United States Trustee v. John Q. Hammons Fall 2006, LLC" on Justia Law

Several Starbucks employees in Memphis, Tennessee, announced plans to unionize and invited a local news crew to their store after hours to promote their efforts. Starbucks fired multiple employees involved in the media event for violating company policy. The National Labor Relations Board (NLRB) filed an administrative complaint against Starbucks, alleging unfair labor practices. The Board's regional Director then filed a petition under §10(j) of the National Labor Relations Act seeking a preliminary injunction that would require Starbucks to reinstate the fired employees during the administrative proceedings. The District Court granted the injunction, applying a two-part test that asks whether there is reasonable cause to believe that unfair labor practices have occurred and whether injunctive relief is just and proper. The Sixth Circuit affirmed the decision.The Supreme Court of the United States vacated the Sixth Circuit's decision. The Supreme Court held that when considering the NLRB’s request for a preliminary injunction under §10(j), district courts must apply the traditional four-factor test articulated in Winter v. Natural Resources Defense Council, Inc. This test requires a plaintiff to make a clear showing that they are likely to succeed on the merits, that they are likely to suffer irreparable harm in the absence of preliminary relief, that the balance of equities tips in their favor, and that an injunction is in the public interest. The Court found that nothing in §10(j) displaces the presumption that these traditional principles govern. The Court rejected the Board's argument that statutory context requires district courts to apply the traditional criteria in a less exacting way. The Court concluded that the reasonable-cause standard substantively lowers the bar for securing a preliminary injunction by requiring courts to yield to the Board’s preliminary view of the facts, law, and equities. The case was remanded for further proceedings consistent with this opinion. View "Starbucks Corp. v. McKinney" on Justia Law