Justia U.S. Supreme Court Opinion Summaries
FDA v. Alliance for Hippocratic Medicine
In 2000, the Food and Drug Administration (FDA) approved the use of mifepristone tablets, marketed under the brand name Mifeprex, for terminating pregnancies up to seven weeks. The FDA imposed additional restrictions on the drug's use and distribution, including requiring doctors to prescribe or supervise the prescription of Mifeprex and requiring patients to have three in-person visits with the doctor to receive the drug. In 2016, the FDA relaxed some of these restrictions, and in 2021, it announced that it would no longer enforce the initial in-person visit requirement. Four pro-life medical associations and several individual doctors moved for a preliminary injunction that would require the FDA to either rescind approval of mifepristone or rescind the FDA’s 2016 and 2021 regulatory actions.The District Court agreed with the plaintiffs and effectively enjoined the FDA's approval of mifepristone, ordering it off the market. The FDA and Danco Laboratories, which sponsors Mifeprex, appealed and moved to stay the District Court’s order pending appeal. The Supreme Court ultimately stayed the District Court’s order pending the disposition of proceedings in the Fifth Circuit and the Supreme Court. On the merits, the Fifth Circuit held that plaintiffs had standing and concluded that plaintiffs were unlikely to succeed on their challenge to FDA’s 2000 and 2019 drug approvals, but were likely to succeed in showing that FDA’s 2016 and 2021 actions were unlawful. The Supreme Court granted certiorari with respect to the 2016 and 2021 FDA actions.The Supreme Court of the United States held that the plaintiffs lack Article III standing to challenge the FDA’s actions regarding the regulation of mifepristone. The Court found that the plaintiffs, who are pro-life and oppose elective abortion, have sincere legal, moral, ideological, and policy objections to mifepristone being prescribed and used by others. However, because the plaintiffs do not prescribe or use mifepristone, they are unregulated parties who seek to challenge the FDA’s regulation of others. The Court concluded that the plaintiffs' theories of causation were insufficient to establish Article III standing. The Court reversed the judgment of the Fifth Circuit and remanded the case for further proceedings consistent with its opinion. View "FDA v. Alliance for Hippocratic Medicine" on Justia Law
Vidal v. Elster
Steve Elster sought to register the trademark "Trump too small" for use on shirts and hats, drawing from a 2016 Presidential primary debate exchange. The Patent and Trademark Office (PTO) refused registration based on the "names clause" of the Lanham Act, which prohibits the registration of a mark that identifies a particular living individual without their written consent. Elster argued that this clause violated his First Amendment right to free speech. The Trademark Trial and Appeal Board affirmed the PTO's decision, but the Federal Circuit reversed.The Supreme Court of the United States reversed the Federal Circuit's decision, holding that the Lanham Act's names clause does not violate the First Amendment. The Court found that while the names clause is content-based, it is not viewpoint-based, as it does not discriminate against any particular viewpoint. The Court also noted that the names clause is grounded in a historical tradition of restricting the trademarking of names, which has coexisted with the First Amendment. The Court concluded that this history and tradition are sufficient to demonstrate that the names clause does not violate the First Amendment. The Court emphasized that its decision is narrow and does not set forth a comprehensive framework for judging whether all content-based but viewpoint-neutral trademark restrictions are constitutional. View "Vidal v. Elster" on Justia Law
Becerra v. San Carlos Apache Tribe
The case involves the Indian Self-Determination and Education Assistance Act (ISDA), which allows an Indian tribe to enter into a "self-determination contract" with the Indian Health Service (IHS) to administer healthcare programs that IHS would otherwise operate for the tribe. The San Carlos Apache Tribe and the Northern Arapaho Tribe sued the Government for breach of contract, arguing that although they used the Secretarial amount and program income to operate the healthcare programs they assumed from IHS under their self-determination contracts, IHS failed to pay the contract support costs they incurred by providing healthcare services using program income. The Ninth and Tenth Circuits concluded that each Tribe was entitled to reimbursement for such costs.The Supreme Court of the United States affirmed the decisions of the Ninth and Tenth Circuits. The Court held that ISDA requires IHS to pay the contract support costs that a tribe incurs when it collects and spends program income to further the functions, services, activities, and programs transferred to it from IHS in a self-determination contract. The Court reasoned that the Tribe's self-determination contract incorporated ISDA, which required the Tribe to spend third-party program income on healthcare. Those portions of the Tribe’s healthcare programs funded by third-party income thus constituted “activities which must be carried on by [the Tribe] as a contractor to ensure compliance with the terms of the contract,” and the contract support costs associated with those activities were incurred “in connection with the operation of the Federal program.” The Court concluded that the text of ISDA, therefore, indicated that IHS was required to reimburse the Tribe for those costs. View "Becerra v. San Carlos Apache Tribe" on Justia Law
Posted in:
Contracts, Native American Law
Connelly v. United States
The case revolves around the valuation of shares for estate tax purposes following the death of a shareholder. Michael and Thomas Connelly were the sole shareholders of Crown C Supply, a building supply corporation. They had an agreement that if either brother died, the surviving brother could purchase the deceased's shares. If he declined, the corporation would be required to redeem the shares. To ensure the corporation had enough money for this, it obtained $3.5 million in life insurance on each brother. When Michael died, Thomas chose not to purchase Michael's shares, triggering Crown's obligation to do so. The value of Michael's shares was agreed to be $3 million, which was paid to Michael's estate. The Internal Revenue Service (IRS) audited the return and disagreed with the valuation, insisting that the corporation's redemption obligation did not offset the life-insurance proceeds. The IRS assessed the corporation's total value as $6.86 million and calculated the value of Michael's shares as $5.3 million. Based on this higher valuation, the IRS determined that the estate owed an additional $889,914 in taxes.The District Court granted summary judgment to the Government, holding that the $3 million in life-insurance proceeds must be counted in Crown’s valuation. The Eighth Circuit affirmed this decision.The Supreme Court of the United States affirmed the lower courts' decisions. The Court held that a corporation’s contractual obligation to redeem shares is not necessarily a liability that reduces a corporation’s value for purposes of the federal estate tax. The Court reasoned that a fair-market-value redemption has no effect on any shareholder’s economic interest, and thus, no hypothetical buyer purchasing Michael’s shares would have treated Crown’s obligation to redeem Michael’s shares at fair market value as a factor that reduced the value of those shares. The Court concluded that Crown’s promise to redeem Michael’s shares at fair market value did not reduce the value of those shares. View "Connelly v. United States" on Justia Law
Posted in:
Business Law, Tax Law
Truck Insurance Exchange v. Kaiser Gypsum Co.
The case involves Truck Insurance Exchange (Truck), the primary insurer for companies that manufactured and sold products containing asbestos. Two of these companies, Kaiser Gypsum Co. and Hanson Permanente Cement (Debtors), filed for Chapter 11 bankruptcy after facing thousands of asbestos-related lawsuits. As part of the bankruptcy process, the Debtors proposed a reorganization plan that created an Asbestos Personal Injury Trust (Trust) to handle all present and future asbestos-related claims. Truck, contractually obligated to defend each covered asbestos personal injury claim and to indemnify the Debtors for up to $500,000 per claim, opposed the Plan, arguing that it exposed them to millions of dollars in fraudulent claims due to different disclosure requirements for insured and uninsured claims.The District Court confirmed the Plan, concluding that Truck had limited standing to object to the Plan because it was “insurance neutral,” meaning it did not increase Truck’s prepetition obligations or impair its contractual rights under its insurance policies. The Fourth Circuit affirmed this decision, agreeing that Truck was not a “party in interest” under §1109(b) of the Bankruptcy Code because the plan was “insurance neutral.”The Supreme Court of the United States reversed the Fourth Circuit's decision, holding that an insurer with financial responsibility for bankruptcy claims is a “party in interest” under §1109(b) of the Bankruptcy Code and may raise and appear and be heard on any issue in a Chapter 11 case. The Court reasoned that §1109(b)’s text, context, and history confirm that an insurer such as Truck with financial responsibility for a bankruptcy claim is a “party in interest” because it may be directly and adversely affected by the reorganization plan. The Court also rejected the “insurance neutrality” doctrine, stating that it conflates the merits of an objection with the threshold party in interest inquiry. The case was remanded for further proceedings consistent with the Supreme Court's opinion. View "Truck Insurance Exchange v. Kaiser Gypsum Co." on Justia Law
Thornell v. Jones
The case involves Danny Lee Jones, who was convicted of three murders committed with the intent to steal a gun collection. Jones brutally killed a man, his 7-year-old daughter, and his grandmother. After being found guilty, the trial court proceeded to sentencing. Under Arizona law, the court was required to impose a death sentence if it found one or more aggravating circumstances and no mitigating circumstances sufficiently substantial to call for leniency. The court found three aggravating circumstances and sentenced Jones to death. The Arizona Supreme Court affirmed the decision.Jones sought postconviction review, arguing that his attorney was ineffective. He claimed that his attorney should have retained an independent neuropsychologist, rather than relying on a court-appointed psychiatrist. The state court denied this claim. Jones then filed a habeas petition in Federal District Court, reasserting his ineffective-assistance-of-counsel claims. The District Court held an evidentiary hearing but concluded that Jones could not show prejudice because the additional information he presented barely altered the sentencing profile presented to the sentencing judge. The Ninth Circuit reversed, but the Supreme Court vacated that judgment and remanded for the Ninth Circuit to determine whether it had been proper to consider the new evidence presented at the federal evidentiary hearing.On reconsideration, the Ninth Circuit again granted habeas relief. The panel held that it was permissible to consider the new evidence and concluded that there was a reasonable probability that Jones would not have received a death sentence if that evidence had been presented at sentencing. The Supreme Court granted certiorari to review the Ninth Circuit’s interpretation and application of Strickland.The Supreme Court reversed the Ninth Circuit's decision, stating that it had departed from the well-established rules in at least three ways. The Supreme Court found that the Ninth Circuit failed to adequately take into account the weighty aggravating circumstances in this case, applied a strange Circuit rule that prohibits a court in a Strickland case from assessing the relative strength of expert witness testimony, and held that the District Court erred by attaching diminished persuasive value to Jones’s mental health conditions because it saw no link between those conditions and Jones’s conduct when he committed the three murders. The Supreme Court concluded that there was no reasonable probability that the evidence on which Jones relies would have altered the outcome at sentencing. View "Thornell v. Jones" on Justia Law
Posted in:
Criminal Law
National Rifle Association of America v. Vullo
The case involves the National Rifle Association (NRA) and Maria Vullo, the former superintendent of the New York Department of Financial Services (DFS). The NRA alleged that Vullo violated their First Amendment rights by pressuring regulated entities to disassociate from the NRA and other gun-promotion advocacy groups. The NRA claimed that Vullo threatened enforcement actions against those entities that refused to disassociate, thereby stifling the NRA's pro-gun advocacy.The District Court initially denied Vullo's motion to dismiss the NRA's First Amendment damages claims, holding that the NRA plausibly alleged that Vullo's actions could be interpreted as a veiled threat to regulated industries to disassociate with the NRA or risk DFS enforcement action. However, the Second Circuit reversed this decision, concluding that Vullo's alleged actions constituted permissible government speech and legitimate law enforcement, not unconstitutional coercion. The Second Circuit also held that even if the complaint stated a First Amendment violation, the law was not clearly established, and so Vullo was entitled to qualified immunity.The Supreme Court of the United States, however, vacated the judgment of the Second Circuit. The Supreme Court held that the NRA plausibly alleged that Vullo violated the First Amendment by coercing DFS-regulated entities to terminate their business relationships with the NRA in order to punish or suppress the NRA's advocacy. The case was remanded for further proceedings consistent with this opinion. View "National Rifle Association of America v. Vullo" on Justia Law
Cantero v. Bank of America, N. A.
The case revolves around a dispute between Alex Cantero, Saul Hymes, Ilana Harwayne-Gidansky, and others (the plaintiffs) and Bank of America. The plaintiffs had obtained home mortgage loans from Bank of America, which required them to make monthly deposits into escrow accounts. These accounts were used by the bank to pay the borrowers' property taxes and insurance premiums. Under New York law, banks are required to pay borrowers interest on the balance of such escrow accounts. However, Bank of America did not pay interest on the money in the plaintiffs' escrow accounts, arguing that the New York law was preempted by the National Bank Act. The plaintiffs filed class-action suits against Bank of America, alleging that the bank violated New York law by failing to pay them interest on the balances in their escrow accounts.The U.S. District Court for the Eastern District of New York ruled in favor of the plaintiffs, agreeing that New York law required Bank of America to pay interest on the escrow account balances. The court concluded that nothing in the National Bank Act or other federal law preempted the New York law. However, the U.S. Court of Appeals for the Second Circuit reversed this decision, holding that the New York interest-on-escrow law was preempted as applied to national banks. The Court of Appeals argued that federal law preempts any state law that attempts to exercise control over a federally granted banking power, regardless of the magnitude of its effects.The Supreme Court of the United States, in reviewing the case, focused on the standard for determining when state laws that regulate national banks are preempted. The Court noted that the Dodd-Frank Act of 2010 expressly incorporated the standard articulated in Barnett Bank of Marion County, N. A. v. Nelson, which asks whether a state law "prevents or significantly interferes with the exercise by the national bank of its powers." The Supreme Court found that the Court of Appeals did not apply this standard in a manner consistent with Dodd-Frank and Barnett Bank. Therefore, the Supreme Court vacated the judgment of the Court of Appeals and remanded the case for further proceedings consistent with its opinion. View "Cantero v. Bank of America, N. A." on Justia Law
Posted in:
Banking, Class Action
Alexander v. South Carolina State Conference of the NAACP
The Supreme Court of the United States reviewed a case involving the redrawing of congressional districts in South Carolina following the 2020 Census. The National Association for the Advancement of Colored People and a voter from District 1 challenged the new map, alleging that it resulted in racial gerrymanders in certain districts and diluted the electoral power of the state's black voters. The District Court held that the state drew District 1 with a 17% black voting-age population target in mind, violating the Equal Protection Clause and unlawfully diluting the black vote.The Supreme Court disagreed with the District Court's findings. The Court found that the District Court erred in its conclusion that race predominated in the design of District 1. The Court noted that the challengers did not provide sufficient evidence to show that the legislature subordinated traditional race-neutral districting principles to racial considerations. The Court also criticized the District Court for not drawing an adverse inference from the challengers' failure to submit an alternative map that would have allowed the state to achieve its districting goals while maintaining a higher black voting-age population in District 1.The Supreme Court reversed the District Court's decision in part and remanded the case for further proceedings. The Court concluded that the same findings of fact and reasoning that guided the court's racial-gerrymandering analysis also guided the analysis of the challengers' independent vote-dilution claim, and that conclusion also could not stand. The Court found that the District Court erred in conflating the two claims. View "Alexander v. South Carolina State Conference of the NAACP" on Justia Law
Posted in:
Civil Rights, Election Law
Coinbase v. Suski
The case involves a dispute between Coinbase, Inc., a cryptocurrency exchange platform, and its users. The users had agreed to two contracts with Coinbase. The first contract, the User Agreement, contained an arbitration provision stating that an arbitrator must decide all disputes, including whether a disagreement is arbitrable. The second contract, the Official Rules for a promotional sweepstakes, contained a forum selection clause stating that California courts have sole jurisdiction over any controversies regarding the promotion. The users filed a class action in the U.S. District Court for the Northern District of California, alleging that the sweepstakes violated various California laws. Coinbase moved to compel arbitration based on the User Agreement’s arbitration provision. The District Court denied the motion, ruling that the Official Rules’ forum selection clause controlled the dispute. The Ninth Circuit affirmed this decision.The Supreme Court of the United States affirmed the Ninth Circuit's decision. The Court held that when parties have agreed to two contracts—one sending arbitrability disputes to arbitration, and the other either explicitly or implicitly sending arbitrability disputes to the courts—a court must decide which contract governs. The Court rejected Coinbase's arguments that the Ninth Circuit should have applied the severability principle and that the Ninth Circuit erroneously held that the Official Rules’ forum selection clause superseded the User Agreement’s arbitration provision. The Court also dismissed Coinbase's concern that its ruling would invite chaos by facilitating challenges to delegation clauses. The Court concluded that a court, not an arbitrator, must decide whether the parties’ first agreement was superseded by their second. View "Coinbase v. Suski" on Justia Law