Justia U.S. Supreme Court Opinion Summaries

In 2000, Jones was convicted on two counts of unlawful possession of a firearm by a felon, 18 U.S.C. 922(g)(1). The Eighth Circuit affirmed Jones’ convictions and sentence. Jones’ subsequent 28 U.S.C. 2255 motion resulted in the vacatur of one of his concurrent sentences. Years later, the Supreme Court held (Rehaif) that a defendant’s knowledge of the status that disqualifies him from owning a firearm is an element of a 922(g) conviction, abrogating contrary Eighth Circuit precedent. Jones filed a 28 U.S.C. 2241 motion in the district of his imprisonment.The Eighth Circuit and the Supreme Court affirmed the dismissal of the petition. Section 2255(e) does not allow a prisoner asserting an intervening change in interpretation of a criminal statute to circumvent the Antiterrorism and Effective Death Penalty Act (AEDPA) restrictions on second or successive 2255 motions by filing a 2241 habeas petition.Under section 2255, federal prisoners can collaterally attack their sentences in the sentencing court, rather than by a 2241 habeas corpus petition in the district of confinement. The purpose of 2255 was to address problems created by district courts collaterally reviewing one another’s proceedings and by the concentration of federal prisoners in certain districts. Congress generally barred federal prisoners “authorized” to file a 2255 motion from filing a 2241 petition but preserved access to 2241 in cases where “the remedy by motion is inadequate or ineffective to test the legality" of the detention (Saving Clause). AEDPA subsequently barred second or successive 2255 motions unless based on either newly discovered evidence or “a new rule of constitutional law.” The inability of a prisoner with a statutory claim to satisfy section 2255(h) does not mean that the prisoner may bring a 2241 petition. Section 2255 is not necessarily “inadequate or ineffective” if the 2255 court fails to apply the correct substantive law. The Saving Clause is concerned with the adequacy or effectiveness of the remedial vehicle, not asserted errors of law. Due process does not guarantee the opportunity to have legal issues redetermined in successive collateral attacks. AEDPA embodies a balance between finality and error correction; there is nothing incongruous about a system in which the application of a since-rejected statutory interpretation cannot be remedied after final judgment. View "Jones v. Hendrix" on Justia Law

An 1868 treaty established the Navajo Reservation that today spans some 17 million acres, almost entirely in the Colorado River Basin. While the Tribe has the right to use water from the reservation’s numerous water sources, the Navajos face water scarcity problems. The Navajos sought to compel the United States to take affirmative steps to secure needed water for the Tribe, by assessing the Tribe’s water needs, developing a plan to secure the needed water, and potentially building infrastructure. Three states intervened to protect their interests in Basin's water. The Ninth Circuit reversed the dismissal of the suit.The Supreme Court reversed. The treaty reserved necessary water to accomplish the purpose of the Navajo Reservation but did not require the United States to take affirmative steps to secure water for the Tribe. The federal government owes judicially enforceable duties to a tribe “only to the extent it expressly accepts those responsibilities.” While the treaty “set apart” a reservation for the “use and occupation of the Navajo tribe,” 15 Stat. 668, and did impose several specific duties on the United States, it contains no language imposing a duty on the United States to take affirmative steps to secure water for the Tribe. Indian treaties cannot be rewritten or expanded beyond their clear terms. The United States maintains a general trust relationship with tribes, but unless Congress has created a conventional trust relationship with a tribe as to a particular trust asset, common-law trust principles do not imply duties not found in the text of a treaty, statute, or regulation. It is unsurprising that an 1868 treaty did not provide for all of the Navajos’ current water needs 155 years later; a breach-of-trust claim “cannot be premised on control alone.” View "Arizona v. Navajo Nation" on Justia Law

Smagin won a multimillion-dollar arbitration award against Yegiazaryan stemming from the misappropriation of funds in Moscow. Because Yegiazaryan lives in California, Smagin, who lives in Russia, filed suit to enforce the award in California under the Convention on the Recognition and Enforcement of Foreign Arbitral Awards. The district court froze Yegiazaryan’s California assets before entering judgment. While the action was ongoing, Yegiazaryan himself obtained an unrelated multimillion-dollar arbitration award and sought to avoid the asset freeze by concealing the funds.Smagin filed a civil suit under the Racketeer Influenced and Corrupt Organizations Act (RICO), 18 U.S.C. 1964(c), alleging Yegiazaryan and others worked together to frustrate Smagin’s collection on the judgment through a pattern of RICO predicate racketeering acts, including wire fraud, witness tampering, and obstruction of justice. The district court dismissed the complaint, finding that Smagin failed to plead a “domestic injury.”The Ninth Circuit and the Supreme Court disagreed. The “domestic-injury” requirement for private civil RICO suits is context-specific and turns largely on the facts alleged; it does not mean that foreign plaintiffs may not sue under RICO. The circumstances surrounding Smagin’s injury indicate that the injury arose in the United States. Smagin’s alleged injury is his inability to collect his judgment. Much of the alleged racketeering activity that caused that injury occurred in the United States. While some of Yegiazaryan’s actions to avoid collection occurred abroad, the scheme was directed toward frustrating the California judgment. The injurious effects of the racketeering activity largely manifested in California and undercut the orders of the California court. The Court rejected arguments that fraud is typically deemed felt at the plaintiff’s residence and that intangible property is generally located at the owner’s domicile as not necessarily supporting the presumption against extraterritoriality, with its distinctive concerns for comity and discerning congressional meaning. View "Yegiazaryan v. Smagin" on Justia Law

Two noncitizens were determined removable because they had convictions for aggravated felonies, offenses “relating to obstruction of justice,” 8 U.S.C. 1101(a)(43)(S), 1227(a)(2)(A)(iii). The Ninth Circuit concluded that Cordero-Garcia’s state conviction for dissuading a witness from reporting a crime did not constitute an offense “relating to obstruction of justice” because the state offense did not require that an investigation or proceeding be pending. The Fourth Circuit concluded that Pugin’s state conviction for accessory after the fact constituted an offense “relating to obstruction of justice” even if the state offense did not require that an investigation or proceeding be pending.The Supreme Court held that an offense may “relat[e] to obstruction of justice” under section 1101(a)(43)(S) even if the offense does not require that an investigation or proceeding be pending. The definition of “aggravated felony,” for purposes of removal, was expanded in 1996 to include offenses “relating to obstruction of justice.” Obstruction of justice is often “most effective” when it prevents an investigation or proceeding from commencing. The phrase “relating to” indicates that the statute covers offenses having a connection with obstruction of justice—which surely covers common obstruction offenses that can occur when an investigation or proceeding is not pending. Even if a specific prohibition in 18 U.S.C. 1503(a) requires that an investigation or proceeding be pending, Congress defined offenses under 1101(a)(43)(S) more broadly. View "Pugin v. Garland" on Justia Law

The False Claims Act (FCA) imposes civil liability on those who present false or fraudulent claims for payment to the federal government, 31 U.S.C. 3729–3733, and authorizes private parties (relators) to bring “qui tam actions” in the name of the government. A relator may receive up to 30% of any recovery. The relator must file his complaint under seal and serve a copy and supporting evidence on the government, which has 60 days to decide whether to intervene. As a “real party in interest,” the government can intervene after the seal period ends, if it shows good cause.Polansky filed an FCA action alleging Medicare fraud. The government declined to intervene during the seal period. After years of discovery, the government decided that the burdens of the suit outweighed its potential value, and moved under section 3730(c)(2)(A) (Subparagraph (2)(A)), which provides that the government may dismiss the action notwithstanding the objections of the relator if the relator received notice and an opportunity for a hearing.The Third Circuit and Supreme Court affirmed the dismissal of the suit. The government may move to dismiss an FCA action whenever it has intervened, whether during the seal period or later. It may not move to dismiss if it has never intervened. A successful motion to intervene turns the movant into a party; it can assume primary responsibility for the case’s prosecution, which triggers the Subparagraph (2)(A) right to dismiss, consistent with the FCA’s government-centered purposes. The government’s motion to dismiss will satisfy FRCP 41 in all but exceptional cases. The government gave good grounds for believing that this suit would not vindicate its interests. Absent extraordinary circumstances, that showing suffices for the government to prevail. View "United States ex rel. Polansky v. Executive Health Resources, Inc." on Justia Law

A federal court imposing multiple prison sentences typically has discretion to run the sentences concurrently or consecutively, 18 U.S.C. 3584. Section 924(c)'s exception provides: no term of imprisonment imposed “under this subsection shall run concurrently with any other term of imprisonment.” Lora was convicted of aiding and abetting a violation of section 924(j)(1), which penalizes “a person who, in the course of a violation of subsection (c), causes the death of a person through the use of a firearm,” where “the killing is a murder.” A violation of subsection (c) occurs when a person “uses or carries a firearm” “during and in relation to any crime of violence or drug trafficking crime,” or “possesses a firearm” “in furtherance of any such crime.” Lora was also convicted of conspiring to distribute drugs. The district court concluded that it lacked discretion to run the sentences for Lora’s two convictions concurrently. The Second Circuit affirmed.A unanimous Supreme Court vacated. Section 924(c)(1)(D)(ii)’s bar on concurrent sentences does not govern a 924(j) sentence, which can run either concurrently with or consecutively to another sentence. Subsection (c)’s consecutive-sentence mandate applies only to the terms of imprisonment prescribed within subsection (c). A sentence imposed under subsection (j) does not qualify. Subsection (j) is located outside subsection (c) and does not call for imposing any sentence from subsection (c); while subsection (j) references subsection (c), that reference is limited to offense elements, not penalties. It is not “implausible” for Congress to have imposed the harsh consecutive-sentence mandate under subsection (c) but not subsection (j). That result is consistent with the statute’s design. Unlike subsection (c), subsection (j) generally eschews mandatory penalties in favor of sentencing flexibility. View "Lora v. United States" on Justia Law

The Lac du Flambeau Band of Lake Superior Chippewa Indians is a federally recognized Indian tribe. One of its businesses extended Coughlin a payday loan. After receiving the loan, Coughlin filed for Chapter 13 bankruptcy, triggering an automatic stay under the Bankruptcy Code against further collection efforts by creditors. The lender allegedly continued attempting to collect Coughlin’s debt. The First Circuit reversed the Bankruptcy Court's dismissal of Coughlin’s subsequent suit on tribal sovereign immunity grounds.The Supreme Court affirmed. The Bankruptcy Code unambiguously abrogates the sovereign immunity of all governments, including federally recognized Indian tribes; 11 U.S.C. 106(a), expressly abrogates the sovereign immunity of “governmental unit[s]” for enumerated purposes. Section 101(27) defines “governmental unit” as “United States; State; Commonwealth; District; Territory; municipality; foreign state; department, agency, or instrumentality of the United States.... a State, a Commonwealth, a District, a Territory, a municipality, or a foreign state; or other foreign or domestic government.” The sections cannot plausibly be read to preserve sovereign immunity. The definition of “governmental unit” exudes comprehensiveness and includes a broad catchall phrase, sweeping in “other foreign or domestic government[s].” Reading the statute to carve out certain governments from the definition of “governmental unit” would risk upending the Code’s policy choices. Federally recognized tribes are indisputably governments. Congress need not use any particular words to make its abrogation intent clear. View "Lac du Flambeau Band of Lake Superior Chippewa Indians v. Coughlin" on Justia Law

The Indian Child Welfare Act (ICWA) governs state court adoption and foster care proceedings involving Indian children, requiring placement of an Indian child according to the Act’s hierarchical preferences absent a finding of “good cause” to depart from them, 25 U.S.C. 1915(a), (b). Indian families or institutions from any tribe (not just the tribe to which the child has a tie) outrank unrelated non-Indians or non-Indian institutions. The child’s tribe may alter the prioritization order. The preferences of the Indian child or her parent generally cannot trump those set by statute or tribal resolution. In involuntary proceedings, the Indian child’s parent or custodian and tribe must be given notice of any custody proceedings, and the right to intervene. ICWA requires a party seeking to terminate parental rights or to remove an Indian child from an unsafe environment to satisfy the court that active efforts have been made to provide remedial services; a court cannot order relief unless the party demonstrates, by a heightened burden of proof and expert testimony, that the child is likely to suffer serious harm. A biological parent who voluntarily gives up an Indian child cannot necessarily choose the child’s placement. The tribe has a right to intervene and can enforce ICWA’s placement preferences. States must keep certain records and transmit specified information to the Secretary of the Interior.The Supreme Court concluded that ICWA is consistent with Congress’s Article I authority and that conflicting state family law is preempted. Requirements concerning “active efforts” to keep Indian families together do not command the states to deploy their executive or legislative power to implement federal policy. The provisions apply to “any party” who initiates an involuntary proceeding–private individuals, agencies, and government entities. Legislation that applies “evenhandedly” to state and private actors does not typically implicate the Tenth Amendment. ICWA’s requirement that state agencies perform a “diligent search” for placements that satisfy ICWA’s hierarchy also applies to both private and public parties. Congress can require state courts to enforce federal law and may impose ancillary record-keeping requirements related to state-court proceedings without violating the Tenth Amendment.The Court did not address an equal protection challenge to ICWA’s placement preferences and a non-delegation challenge to the provision allowing tribes to alter the placement preferences, citing lack of standing to raise the challenges. View "Haaland v. Brackeen" on Justia Law

Smith was indicted in the Northern District of Florida for theft of trade secrets from StrikeLines’ website. Smith moved to dismiss the indictment, citing the Constitution’s Venue Clause and the Vicinage Clause. Smith argued that he had accessed the website from his Alabama home and that the servers storing StrikeLines’ data were in Orlando, Florida. The Eleventh Circuit determined that venue was improper and vacated Smith’s conviction, but held that a trial in an improper venue did not bar reprosecution.The Supreme Court affirmed. The Constitution permits the retrial of a defendant following a trial in an improper venue conducted before a jury drawn from the wrong district. Except as prohibited by the Double Jeopardy Clause, when a defendant obtains a reversal of a prior, unsatisfied conviction, he may be retried. Nothing in the Venue Clause suggests that a new trial in the proper venue is not an adequate remedy for its violation. The Vicinage Clause—which guarantees the right to “an impartial jury of the State and district wherein the crime shall have been committed,” concerns jury composition, not the place where a trial may be held, and concerns the district where the crime was committed, rather than the state. The vicinage right is one aspect of the Sixth Amendment’s jury-trial rights and retrials are the appropriate remedy for violations of other jury-trial rights.The Double Jeopardy Clause is not implicated by retrial in a proper venue. A judicial decision on venue is fundamentally different from a jury’s verdict of acquittal. Culpability is the touchstone; when a trial terminates with a finding that the defendant’s criminal culpability had not been established, retrial is prohibited. Retrial is permissible when a trial terminates on a basis unrelated to factual guilt. The reversal of a conviction based on a violation of the Venue or Vicinage Clauses, even when called a “judgment of acquittal,” does not resolve the question of criminal culpability. View "Smith v. United States" on Justia Law

VIP makes a chewable dog toy that looks like a Jack Daniel’s whiskey bottle; the words “Jack Daniel’s” become “Bad Spaniels.” “Old No. 7 Brand Tennessee Sour Mash Whiskey” turns into “The Old No. 2 On Your Tennessee Carpet.” Jack Daniel’s demanded that VIP stop selling the toy.VIP sought a declaratory judgment that Bad Spaniels neither infringed nor diluted Jack Daniel’s trademarks. Jack Daniel’s counterclaimed. The Lanham Act defines a trademark by its primary function: identifying a product’s source and distinguishing that source from others. A typical infringement case examines whether the defendant’s use of a mark is “likely to cause confusion, or to cause mistake, or to deceive,” 15 U.S.C. 1114(1)(A), 1125(a)(1)(A). A typical dilution case considers whether the defendant “harm[ed] the reputation” of a trademark. VIP cited the “Rogers test,” which requires dismissal of an infringement claim when “expressive works” are involved unless the complainant can show either that the challenged use of a mark “has no artistic relevance to the underlying work” or that it “explicitly misleads as to the source or the content of the work.” The Ninth Circuit ruled in favor of VIP.The Supreme Court vacated. When an alleged infringer uses a trademark as a designation of source for the infringer’s own goods, the Rogers test does not apply. Consumer confusion about source is most likely to arise when someone uses another’s trademark as a trademark. Bad Spaniels was not automatically entitled to Rogers’ protection because it “communicate[d] a humorous message.” VIP used the Bad Spaniels trademark and trade dress as source identifiers. Although VIP’s effort to parody Jack Daniel’s does not justify the application of the Rogers test, it may make a difference in the standard trademark analysis on remand. View "Jack Daniel's™ Properties, Inc. v. VIP Products LLC" on Justia Law