Justia U.S. Supreme Court Opinion Summaries

Atlantic sought to construct a 604-mile natural gas pipeline from West Virginia to North Carolina, crossing 16 miles of land within the George Washington National Forest. Atlantic secured a special use permit from the U.S. Forest Service, obtaining a right-of-way for a 0.1-mile segment of pipe 600 feet below a portion of the Appalachian National Scenic Trail, which also crosses the National Forest. The Fourth Circuit vacated the permit.The Supreme Court reversed. The Department of the Interior’s assignment of responsibility for the Appalachian Trail to the National Park Service did not transform the Trail land into land within the National Park System that is not eligible for a pipeline lease. The Forest Service had the authority to issue the special use permit.Under 16 U.S.C. 521, the Forest Service has jurisdiction over the National Forest. The National Trails System Act, 16 U.S.C. 244(a), applies to the Appalachian Trail; the Secretary of the Interior has delegated to the National Park System the authority to enter into “rights-of-way” agreements for the Trail. The Leasing Act enables any “appropriate agency head” to grant “[r]ights-of-way through any Federal lands . . . for pipeline purposes,” 30 U.S.C. 185(a), except lands in the National Park System. The National Park System is administered by the Secretary of the Interior, through the National Park Service, 54 U.S.C. 100501. The Forest Service “right-of-way” agreements with the National Park Service for the Appalachian Trail did not convert National Forest “Federal lands” under the Leasing Act into “lands” within the “National Park System.” A right-of-way grant only nonpossessory rights of use. Although the federal government owns all lands involved, a right-of-way between two agencies grants only an easement, not jurisdiction over the land itself. View "United States Forest Service v. Cowpasture River Preservation Association" on Justia Law

Three employers each fired a long-time employee for being homosexual or transgender. Each employee sued, alleging sex discrimination under Title VII of the Civil Rights Act of 1964, which makes it “unlawful . . . for an employer to fail or refuse to hire or to discharge any individual, or otherwise to discriminate against any individual . . . because of such individual’s race, color, religion, sex, or national origin,” 42 U.S.C. 2000e–2(a)(1). The Eleventh Circuit held that the suit could be dismissed. The Second and Sixth Circuits allowed the claims to proceed.The Supreme Court ruled in favor of the employees. An employer violates Title VII when it intentionally fires an individual employee based in part on sex regardless of whether other factors besides the plaintiff's sex contributed to the decision or whether the employer treated women as a group the same when compared to men as a group. Discrimination on the basis of homosexuality or transgender status requires an employer to intentionally treat individual employees differently because of their sex. It is irrelevant what an employer or others might call the discriminatory practice; that another factor, such as the plaintiff’s attraction to the same sex or presentation as a different sex from that assigned at birth, might play an important role in the employer’s decision; or that an employer could refuse to hire a gay or transgender individual without learning that person’s sex. The Court rejected arguments that homosexuality and transgender status are distinct concepts from sex and that a stricter causation test should apply because the policies at issue have the same adverse consequences for men and women. Legislative history has no bearing where no ambiguity exists about how Title VII’s terms apply to the facts. View "Bostock v. Clayton County" on Justia Law

The Prison Litigation Reform Act of 1995 (PLRA) established the three-strikes rule, which generally prevents a prisoner from bringing suit in forma pauperis (IFP) if he has had three or more prior suits dismissed on the grounds that they were frivolous, malicious, or failed to state a claim upon which relief may be granted. 28 U.S.C. 1915(g). Colorado inmate Lomax sued prison officials to challenge his expulsion from the facility’s sex-offender treatment program and moved for IFP status. He had already brought three unsuccessful legal actions during his time in prison. The district court and Tenth Circuit rejected Lomax’s argument that two of the dismissals should not count as strikes because they were without prejudice.The Supreme Court affirmed. Section 1915(g)’s three-strikes provision refers to any dismissal for failure to state a claim, whether with prejudice or without. A Section 1915(g) strike-call hinges exclusively on the basis for the dismissal, regardless of the decision’s prejudicial effect. Courts can and sometimes do dismiss frivolous actions without prejudice. View "Lomax v. Ortiz-Marquez" on Justia Law

Banister was convicted by a Texas court of aggravated assault and sentenced to 30 years’ imprisonment. After exhausting his state remedies, he unsuccessfully sought federal habeas relief. Banister timely filed a motion under Federal Rule of Civil Procedure 59(e), which allows a litigant to file a motion to alter or amend a district court’s judgment within 28 days from the entry of judgment, with no possibility of an extension. That motion was denied. Banister filed a notice of appeal in accordance with the timeline for appealing a judgment after a Rule 59(e) denial. A timely Rule 59 motion suspends the finality of the original judgment for purposes of appeal. The Fifth Circuit construed Banister’s Rule 59(e) motion as a successive habeas petition under the Antiterrorism and Effective Death Penalty Act (AEDPA), 28 U.S.C. 2244(b), and dismissed his appeal as untimely.The Supreme Court reversed Because a Rule 59(e) motion to alter or amend a habeas court’s judgment is not a second or successive habeas petition, Banister’s appeal was timely. The phrase “second or successive application” does not simply refer to all habeas filings made successively in time, following an initial application. Rule 59(e) applies in habeas proceedings, deriving from courts’ common-law power to alter or amend their own judgments before any appeal. The purposes of AEDPA--reducing delay, conserving judicial resources, and promoting finality--are served by Rule 59(e), which offers a narrow window to seek relief; limits requests for reconsideration to matters properly raised in the challenged judgment; and consolidates proceedings into a single final judgment for appeal. View "Banister v. Davis" on Justia Law

Nasrallah pled guilty to receiving stolen property. In removal proceedings, Nasrallah sought relief under the international Convention Against Torture (CAT) to prevent his removal to Lebanon. The Immigration Judge ordered Nasrallah removed but granted CAT relief. The Board of Immigration Appeals ordered Nasrallah removed to Lebanon. The Eleventh Circuit declined to review Nasrallah’s factual challenges to the CAT order because circuit precedent precluded review in cases involving commission of a crime specified in 8 U.S.C. 1252(a)(2)(C).The Supreme Court reversed. Sections 1252(a)(2)(C) and (D) do not preclude judicial review of a noncitizen’s factual challenges to a CAT order but preclude judicial review of factual challenges only to final orders of removal. A CAT order is not a final “order of removal,” nor does a CAT order merge into a final order of removal. A CAT order does not affect the validity of a final order of removal.The Illegal Immigration Reform and Immigrant Responsibility Act authorizes direct “review of a final order of removal” in a court of appeals and requires that all challenges arising from the removal proceeding be consolidated for review,. The Foreign Affairs Reform and Restructuring Act implements Article 3 of CAT and provides for judicial review of CAT claims “as part of the review of a final order of removal.” The REAL ID Act clarifies that final orders of removal and CAT orders may be reviewed only in the courts of appeals. View "Nasrallah v. Barr" on Justia Law

Congress invoked its Article IV power to enact the Puerto Rico Oversight, Management, and Economic Stability Act (PROMESA). PROMESA created a Financial Oversight and Management Board, whose seven voting members are to be appointed by the President without the Senate’s advice and consent. Congress authorized the Board to file for bankruptcy, to supervise and modify Puerto Rico’s laws and budget, and to conduct related investigations. President Obama selected the Board’s members. The Board filed bankruptcy petitions on behalf of the Commonwealth and five of its entities. Creditors moved to dismiss the proceedings, arguing that the Board members’ selection violated the Constitution’s Appointments Clause, under which the President “shall nominate, and by and with the Advice and Consent of the Senate, shall appoint . . . all . . . Officers of the United States.” The First Circuit held that the Board members’ selection violated the Appointments Clause.The Supreme Court reversed. Congress’ longstanding practice of requiring the Senate’s advice and consent for territorial Governors with important federal duties supports the inference that Congress expected the Appointments Clause to apply to at least some officials with supervisory authority over the Territories. A federal law’s creation of an office, however, does not automatically make its holder an officer of the United States. The Appointments Clause does not restrict the appointment of local officers that Congress vests with primarily local duties. Congress has long legislated for (non-state) entities by making local law directly and creating local government structures, staffed by local officials, who make and enforce local law. The history of Puerto Rico—whose officials with local responsibilities have been selected in ways inconsistent with the Appointments Clause—is consistent with the history of other entities that fall under Article IV and with the District of Columbia's history.The Board members here have primarily local powers and duties. PROMESA says that the Board “shall not be considered a department, agency, establishment, or instrumentality of the Federal Government.” Congress gave the Board a structure, duties, and related powers consistent with this statement. View "Financial Oversight and Management Board for Puerto Rico v. Aurelius Investment, LLC" on Justia Law

Plaintiffs are retired participants a defined-benefit retirement plan, which guarantees them a fixed payment each month regardless of the plan’s value or its fiduciaries’ investment decisions. Both have been paid all of their monthly pension benefits so far and are legally entitled to those payments for the rest of their lives. They filed a putative class-action suit under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001, alleging violations of ERISA’s duties of loyalty and prudence by poorly investing the plan’s assets. They sought the repayment of approximately $750 million to the plan in losses suffered due to mismanagement; injunctive relief, including replacement of the plan’s fiduciaries; and attorney’s fees. The Eighth Circuit and the Supreme Court affirmed the dismissal of the case. Because the plaintiffs have no concrete stake in the lawsuit, they lack Article III standing. Win or lose, they will still receive the exact same monthly benefits they are entitled to receive. Participants in a defined-benefit plan are not similarly situated to the beneficiaries of a private trust or to participants in a defined-contribution plan; they possess no equitable or property interest in the plan. The plaintiffs cannot assert representative standing based on injuries to the plan where they themselves have not “suffered an injury in fact,” or been legally or contractually appointed to represent the plan. The fact that ERISA affords all participants—including defined-benefit plan participants—a cause of action to sue does not satisfy the injury-in-fact requirement. Article III standing requires a concrete injury even in the context of a statutory violation. The Court rejected an argument that meaningful regulation of plan fiduciaries is possible only if they may sue to target perceived fiduciary misconduct; defined-benefit plans are regulated and monitored in multiple ways. View "Thole v. U. S. Bank N. A." on Justia Law

ThyssenKrupp entered into contracts with F. L. for the construction of mills at ThyssenKrupp’s Alabama steel manufacturing plant. Each contract contained an arbitration clause. F. L. entered into a subcontract with GE for the provision of motors. After the motors allegedly failed, Outokumpu (ThyssenKrupp's successor) sued GE, which moved to compel arbitration, relying on the arbitration clauses in the F. L.-ThyssenKrupp contracts. The Eleventh Circuit concluded that the Convention on the Recognition and Enforcement of Foreign Arbitral Awards allows enforcement of an arbitration agreement only by the parties that actually signed the agreement.A unanimous Supreme Court reversed. The Convention does not conflict with domestic equitable estoppel doctrines that permit the enforcement of arbitration agreements by nonsignatories. The Federal Arbitration Act (FAA) grants federal courts jurisdiction over actions governed by the Convention and provides that “Chapter 1 applies to actions and proceedings brought under this chapter to the extent that [Chapter 1] is not in conflict with this chapter or the Convention,” 9 U.S.C. 208. Chapter 1 does not “alter background principles of state contract law regarding the scope of agreements (including the question of who is bound by them).” The state-law equitable estoppel doctrines permitted under Chapter 1 do not “conflict with . . . the Convention,” which is silent on whether nonsignatories may enforce arbitration agreements under domestic doctrines such as equitable estoppel. Nothing in the Convention could be read to conflict with the application of domestic equitable estoppel doctrines. The court, on remand, may address whether GE can enforce the arbitration clauses under equitable estoppel principles and which body of law governs that determination. View "GE Energy Power Conversion France SAS v. Outokumpu Stainless USA, LLC" on Justia Law

In 1998, al Qaeda operatives detonated truck bombs outside the U.S. Embassies in Kenya and Tanzania. Victims sued the Republic of Sudan under the state-sponsored terrorism exception to the Foreign Sovereign Immunities Act (FSIA, 28 U.S.C. 1605(a)(7)), which included a bar on punitive damages for suits under any of the sovereign immunity exceptions. In 2008, Congress amended the FSIA in the National Defense Authorization Act (NDAA). NDAA section 1083(c)(2) creates a cause of action for acts of terror that provides for punitive damages; it gave effect to existing lawsuits that had been “adversely affected” by prior law “as if” they had been originally filed under the new section 1605A(c). Section 1083(c)(3) provided a time-limited opportunity for plaintiffs to file new actions “arising out of the same act or incident” as an earlier action and claim those benefits. The plaintiffs amended their complaint to include section 1605A(c) claims. The district court awarded the plaintiffs approximately $10.2 billion, including roughly $4.3 billion in punitive damages. The D.C. Circuit held that the plaintiffs were not entitled to punitive damages because Congress had included no statement in NDAA section 1083 clearly authorizing punitive damages for pre-enactment conduct.The Supreme Court vacated and remanded. Even assuming that Sudan may claim the benefit of the presumption of prospective effect, Congress was as clear as it could have been when it expressly authorized punitive damages under section 1605A(c) and explicitly made that new cause of action available to remedy certain past acts of terrorism. The court of appeals must also reconsider its decision concerning the availability of punitive damages for state law claims. View "Opati v. Republic of Sudan" on Justia Law

Lucky Brand and Marcel market clothing. Marcel registered the trademark “Get Lucky.” Lucky Brand registered the trademark “Lucky Brand” and other marks with the word “Lucky.” In a 2003 settlement agreement, Lucky Brand agreed to stop using the phrase “Get Lucky.” Marcel released its claims regarding Lucky Brand’s use of its other trademarks.In 2005, Lucky Brand sued Marcel for violating its trademarks. Marcel filed counterclaims turning on Lucky Brand’s continued use of “Get Lucky,” but did not claim that Lucky Brand’s use of its other marks alone infringed that mark. The court enjoined Lucky Brand from copying or imitating Marcel’s “Get Lucky” mark.In 2011, Marcel sued Lucky Brand, arguing only that Lucky Brand’s post-2010 use of Lucky Brand’s other marks infringed Marcel’s “Get Lucky” mark. Marcel did not allege that Lucky Brand continued to use "Get Lucky." Lucky Brand argued, for the first time since early in the 2005 Action, that Marcel had released those claims in the settlement agreement. The Second Circuit vacated the dismissal of the action, concluding that “defense preclusion” prohibited Lucky Brand from raising that unlitigated defense.A unanimous Supreme Court reversed. Any preclusion of defenses must, at a minimum, satisfy the strictures of issue preclusion or claim preclusion. Here, issue preclusion does not apply, so the causes of action must share a “common nucleus of operative fact[s]” for claim preclusion to apply. The 2005 claims depended on Lucky Brand’s alleged use of “Get Lucky.” In the 2011 suit, Marcel alleged that the infringement was Lucky Brand’s use of its other marks containing the word “Lucky,” not any use of “Get Lucky” itself. The conduct in the 2011 suit occurred after the conclusion of the 2005 suit. View "Lucky Brand Dungarees, Inc. v. Marcel Fashions Group, Inc." on Justia Law