Justia U.S. Supreme Court Opinion Summaries

The Employee Retirement Income Security Act (ERISA) requires plaintiffs with “actual knowledge” of an alleged fiduciary breach to file suit within three years of gaining that knowledge, 29 U.S.C. 1113(2), rather than within the six-year period that would otherwise apply. Sulyma worked at Intel, 2010-2012, and participated in retirement plans. In 2015, he sued plan administrators, alleging that they had managed the plans imprudently. Although Sulyma had visited the website that hosted disclosures of investment decisions, he testified that he did not remember reviewing the relevant disclosures and that he had been unaware of the allegedly imprudent investments while working at Intel. Reversing summary judgment, the Ninth Circuit held that Sulyma's testimony created a dispute as to when he gained “actual knowledge.”A unanimous Supreme Court affirmed. A plaintiff does not necessarily have “actual knowledge” of the information contained in disclosures that he receives but does not read or cannot recall reading. To meet the “actual knowledge” requirement, the plaintiff must, in fact, have become aware of that information. The law sometimes imputes “constructive” knowledge to a person who fails to learn something that a reasonably diligent person would have learned but section 1113(2)'s addition of “actual” signals that the plaintiff’s knowledge must be more than hypothetical. While section 1113(2)'s plain meaning substantially diminishes the protection of ERISA fiduciaries, Congress must be the one to make changes. The Court noted the “usual ways” to prove actual knowledge. View "Intel Corp. Investment Policy Committee v. Sulyma" on Justia Law

The Hague Convention on the Civil Aspects of International Child Abduction, 22 U.S.C. 9001, provides that a child wrongfully removed from her country of “habitual residence” ordinarily must be returned to that country. Monasky, a U. S. citizen, asserts that her Italian husband, Taglieri, became abusive after the couple moved to Italy. Two months after the birth of their daughter, in Italy, Monasky fled with the infant to Ohio. Taglieri sought the child’s return to Italy. The Sixth Circuit affirmed a finding that the parents’ shared intent was for their daughter to live in Italy, rejecting Monasky’s arguments in favor of an actual-agreement requirement. The two-year-old was returned to Italy.The Supreme Court affirmed. A child’s habitual residence depends on the totality of the specific circumstances, not on categorical requirements such as an actual agreement between the parents. While an infant’s “mere physical presence” is not dispositive, a wide range of facts other than an actual agreement, including those indicating that the parents have made their home in a particular place, can facilitate a determination of whether an infant’s residence is “habitual.” Imposing a categorical actual-agreement requirement is unlikely to address the serious problem of protecting children born into domestic violence and would leave many infants without a habitual residence. Domestic violence should be fully explored in the custody adjudication upon the child’s return. The Convention allows a court to refrain from ordering a child’s return to her habitual residence if there is a grave risk that return would expose the child to physical or psychological harm or place the child in an intolerable situation. A first-instance habitual-residence determination is subject to deferential appellate review for clear error. View "Monasky v. Taglieri" on Justia Law

The IRS allows affiliated corporations to file a consolidated federal return, 26 U.S.C. 1501, and issues any refund as a single payment to the group’s designated agent. If a dispute arises, federal courts normally turn to state law to resolve the question of distribution of the refund. Some courts follow the “Bob Richards Rule,” which initially provided that, absent an agreement, a refund belongs to the group member responsible for the losses that led to it. The Rule has evolved, in some jurisdictions, into a general rule that is always followed unless an agreement unambiguously specifies a different result. Soon after the bank suffered huge losses, its parent, Bancorp, was forced into bankruptcy. When the IRS issued a $4 million tax refund, the bank’s receiver, the FDIC, and Bancorp’s bankruptcy trustee each claimed it. The Tenth Circuit examined the parties’ allocation agreement, applied the more expansive version of Bob Richards, and ruled for the FDIC.The Supreme Court vacated. The Rule is not a legitimate exercise of federal common lawmaking. Federal judges may appropriately craft the rule of decision in only limited areas; claiming a new area is subject to strict conditions. Federal common lawmaking must be necessary to protect uniquely federal interests. The federal courts applying and extending Bob Richards have not pointed to any significant federal interest sufficient to support the rule, nor have these parties. State law is well-equipped to handle disputes involving corporate property rights, even in cases involving bankruptcy and a tax dispute. Whether this case might yield a different result without Bob Richards is a matter for the court of appeals on remand. View "Rodriguez v. Federal Deposit Insurance Corp." on Justia Law

A jury found McKinney guilty of two counts of first-degree murder. The judge weighed the aggravating and mitigating circumstances and sentenced McKinney to death. Nearly 20 years later, the Ninth Circuit held on habeas review that the Arizona courts violated Supreme Court precedent (Eddings), by failing to properly consider as relevant mitigating evidence McKinney’s posttraumatic stress disorder. On return to the Arizona Supreme Court, McKinney argued that he was entitled to a jury resentencing, but the court reweighed the aggravating and mitigating circumstances, as permitted by “Clemons,” and upheld both death sentences.The Supreme Court affirmed. A Clemons reweighing is a permissible remedy for an Eddings error; when an Eddings error is found on collateral review, a state appellate court may conduct a Clemons reweighing on collateral review. Clemons did not depend on any unique effect of aggravators as distinct from mitigators. The Court’s holdings in Ring v. Arizona and Hurst v. Florida, that a jury must find the aggravating circumstance that makes the defendant death-eligible, do not mean that a jury is constitutionally required to weigh the aggravating and mitigating circumstances or to make the ultimate sentencing decision. While an Arizona trial court, not the jury, made the initial aggravating circumstance finding that made McKinney eligible for the death penalty, his case became final on direct review long before Ring and Hurst, which do not apply retroactively on collateral review, The Arizona Supreme Court’s 2018 decision reweighing the factors did not constitute a reopening of direct review. View "McKinney v. Arizona" on Justia Law

U.S. Border Patrol Agent Mesa, standing on U.S. soil shot and killed Hernández, a 15-year-old Mexican national, who was on Mexican soil, after having run back across the border after entry onto U.S. territory. Mesa contends that Hernández was part of an illegal border crossing attempt. Hernández’s parents claim he was playing a game with his friends that involved running across the culvert. The Department of Justice concluded that Mesa had not violated Customs and Border Patrol policy or training, and declined to bring charges. The government denied Mexico’s request for Mesa to be extradited. Hernández’s parents sought damages under "Bivens," alleging that Mesa violated Hernández’s Fourth and Fifth Amendment rights. The Fifth Circuit affirmed the dismissal of the suit. On remand from the Supreme Court for reconsideration in light of "Ziglar," the Fifth Circuit again affirmed.The Supreme Court affirmed. Bivens does not extend to claims based on a cross-border shooting. Its expansion to recognize causes of action not expressly created by Congress is “a disfavored’ judicial activity.” While Hernández’s Bivens claims are based on the same constitutional provisions as claims in cases in which damages remedies have been recognized, the context—a cross-border shooting—is significantly different and involves a “risk of disruptive intrusion by the Judiciary into the functioning of other branches.” The Court noted that foreign relations are “so exclusively entrusted to the political branches . . . as to be largely immune from judicial inquiry” and noted the risk of undermining border security. Congress has repeatedly declined to authorize the award of damages against federal officials for injury inflicted outside U. S. borders. When Congress has provided compensation for such injuries, it has done so by empowering Executive Branch officials to make payments under appropriate circumstances. View "Hernandez v. Mesa" on Justia Law

Ritzen sued Jackson in Tennessee state court for breach of contract. Jackson filed for Chapter 11 bankruptcy. Under 11 U.S.C. 362(a), filing a bankruptcy petition automatically “operates as a stay” of creditors’ debt-collection efforts outside the bankruptcy case. The Bankruptcy Court denied Ritzen’s motion for relief from the automatic stay. Ritzen did not appeal but filed a proof of claim, which was disallowed. Ritzen then challenged the denial of relief from the automatic stay. The district court rejected Ritzen’s appeal as untimely under 28 U.S.C. 158(c)(2) and Federal Rule of Bankruptcy Procedure 8002(a), which require appeals from a bankruptcy court order to be filed “within 14 days after entry of [that] order.”The Sixth Circuit and a unanimous Supreme Court affirmed. A bankruptcy court’s order unreservedly denying relief from the automatic stay constitutes a final, immediately appealable order under section 158(a). Adjudication of a creditor’s motion for relief from the stay is a discrete “proceeding” that disposes of a procedural unit anterior to, and separate from, claim-resolution proceedings. The order can have large practical consequences, including whether a creditor can isolate its claim from those of other creditors and proceed outside bankruptcy. Rather than disrupting the efficiency of the bankruptcy process, an immediate appeal may permit creditors to establish their rights expeditiously outside the bankruptcy process, affecting the relief awarded later in the bankruptcy case. View "Ritzen Group, Inc. v. Jackson Masonry, LLC" on Justia Law

In 2014, the Supreme Court held that a claim for breach of the duty of prudence imposed on plan fiduciaries by the Employee Retirement Income Security Act (ERISA) on the basis of inside information, must plausibly allege an alternative action that would have been consistent with securities laws and that a prudent fiduciary would not have viewed as more likely to harm the fund than to help it. The ERISA duty of prudence does not require a fiduciary to break the law and cannot require the fiduciary of an Employee Stock Ownership Plan (ESOP) “to perform an action—such as divesting the fund’s holdings of the employer’s stock on the basis of inside information—that would violate the securities laws.”In 2018, the Second Circuit reinstated a claim for breach of fiduciary duty under ERISA brought by participants in IBM’s 401(k) plan who suffered losses from their investment in IBM stock. The Supreme Court vacated and remanded, characterizing the question as what it takes to plausibly allege an alternative action “that a prudent fiduciary in the same circumstances would not have viewed as more likely to harm the fund than to help it” and whether that pleading standard can be satisfied by generalized allegations that the harm of an inevitable disclosure of an alleged fraud generally increases over time.” The Court concluded that the Second Circuit did not address those questions and noted that the views of the Securities and Exchange Commission might “well be relevant” to discerning the content of ERISA’s duty of prudence in this context. View "Retirement Plans Committee of IBM v. Jander" on Justia Law

The Patent Act provides two methods for challenging an adverse decision by the Patent and Trademark Office (PTO): direct appeal to the Federal Circuit, 35 U.S.C. 141, or a new civil action against the PTO Director in the Eastern District of Virginia, section 145. Under section 145, the applicant must pay “[a]ll the expenses of the proceedings.” NantKwest filed a section 145 civil action after its patent application was denied. The Federal Circuit affirmed summary judgment in favor of the PTO, which moved for reimbursement of expenses, including the pro-rata salaries of PTO attorneys and a paralegal who worked on the case. The Federal Circuit and the Supreme Court affirmed the denial of the motion, concluding that the statutory language referencing expenses was not sufficient to rebut the “American Rule” presumption that parties are responsible for their own attorney’s fees. Reading section 145 to permit an unsuccessful government agency to recover attorney’s fees from a prevailing party “would be a radical departure from longstanding fee-shifting principles adhered to in a wide range of contexts.” The phrase “expenses of the proceeding” would not have been commonly understood to include attorney’s fees at the time section 145 was enacted. The appearance of “expenses” and “attorney’s fees” together across various statutes indicates that Congress understands the terms as distinct and not inclusive of each other. View "Peter v. NantKwest, Inc." on Justia Law

The Fair Debt Collection Practices Act (FDCPA) authorizes private civil actions against debt collectors “within one year from the date on which the violation occurs,” 15 U.S.C. 1692k(d). Klemm sued Rotkiske to collect an unpaid debt and attempted service at an address where Rotkiske no longer lived. An individual other than Rotkiske accepted service. Rotkiske failed to respond to the summons; Klemm obtained a default judgment in 2009. Rotkiske claims that he first learned of this judgment in 2014 when his mortgage application was denied. He filed suit, alleging that Klemm violated the FDCPA by contacting him without lawful ability to collect. Rotkiske argued for the application of a “discovery rule” to delay the beginning of the limitations period until the date that he knew or should have known of the alleged FDCPA violation. The Third Circuit and Supreme Court affirmed the dismissal of the suit. Absent the application of an equitable doctrine, section 1692k(d)’s limitations period begins to run when the alleged FDCPA violation occurs, not when the violation is discovered. Rotkiske cannot rely on the application of an equitable, fraud-specific discovery rule to excuse his otherwise untimely filing, having neither preserved that issue before the Third Circuit nor raised it in his certiorari petition. View "Rotkiske v. Klemm" on Justia Law

Alaska law limits the amount an individual can contribute to a candidate for political office, or to an election-oriented group other than a political party, to $500 per year. Alaska Stat. 15.13.070(b)(1). Plaintiffs contributed the maximum amounts permitted but wanted to contribute more. They challenged the limits under the First Amendment. The district court and Ninth Circuit upheld the statute as furthering a “sufficiently important state interest” and “closely drawn” to that end. The Supreme Court vacated and remanded, citing its precedent in Randall v. Sorrell (2006), which invalidated a Vermont law that limited individual contributions on a per-election basis to $400 to a candidate for Governor, Lieutenant Governor, or other statewide office, $300 to a candidate for state senator, and $200 to a candidate for state representative. A contribution limit that is too low can “prove an obstacle to the very electoral fairness it seeks to promote.” Alaska’s $500 individual-to-candidate contribution limit is substantially lower than limits that have previously been upheld; the individual-to-candidate contribution limit is substantially lower than comparable limits in other states. Alaska’s $500 contribution limit applies uniformly to all offices while other states have limits above $500 for candidates for Governor and Lieutenant Governor. Alaska’s contribution limit is not adjusted for inflation and is the same as it was 23 years ago. View "Thompson v. Hebdon" on Justia Law