Justia U.S. Supreme Court Opinion Summaries

New York requires cable operators to set aside channels for public access. Those channels are operated by the cable operator unless the local government chooses to operate the channels or designates a private entity as the operator. New York City designated a private nonprofit corporation, MNN, to operate public access channels on Time Warner’s Manhattan cable system. Respondents produced a film critical of MNN. MNN televised the film. MNN later suspended Respondents from all MNN services and facilities. They sued, claiming that MNN violated their First Amendment free-speech rights. The Second Circuit partially reversed the dismissal of the suit, concluding that MNN was subject to First Amendment constraints.The Supreme Court reversed in part and remanded. MNN is not a state actor subject to the First Amendment. A private entity may qualify as a state actor when the entity exercises “powers traditionally exclusively reserved to the State” but “very few” functions fall into that category. Operation of public access channels on a cable system has not traditionally and exclusively been performed by government. Providing some kind of forum for speech is not an activity that only governmental entities have traditionally performed and does not automatically transform a private entity into a state actor. The City’s designation of MNN as the operator is analogous to a government license, a government contract, or a government-granted monopoly, none of which converts a private entity into a state actor unless the private entity is performing a traditional, exclusive public function. Extensive regulation does not automatically convert a private entity's action into that of the state. The City does not own, lease, or possess any property interest in the public access channels. View "Manhattan Community Access Corp. v. Halleck" on Justia Law

The company wants to mine raw uranium ore from a site near Coles Hill, Virginia. Virginia law completely prohibits uranium mining. The company alleged that, under the Constitution’s Supremacy Clause, the Atomic Energy Act (AEA) preempts state uranium mining laws like Virginia’s and makes the Nuclear Regulatory Commission (NRC) the lone regulator. The district court, the Fourth Circuit, and the Supreme Court rejected the company’s argument.The AEA does not preempt Virginia’s law banning uranium mining; the law grants the NRC extensive and sometimes exclusive authority to regulate nearly every aspect of the nuclear fuel life cycle except mining, expressly stating that the NRC’s regulatory powers arise only “after [uranium’s] removal from its place of deposit in nature,” 42 U.S.C. 2092. If the federal government wants to control uranium mining on private land, it must purchase or seize the land by eminent domain and make it federal land, indicating that state authority remains untouched. Rejecting “field preemption: and “conflict preemption” arguments, the Court stated that the only thing a court can be sure of is what can be found in the law itself and the compromise that Congress actually struck in the AEA leaves mining regulation on private land to the states. View "Virginia Uranium, Inc. v. Warren" on Justia Law

Quarles pled guilty as a felon in possession of a firearm but objected to enhanced sentencing under the Armed Career Criminal Act, 18 U.S.C. 924(e). He claimed that his 2002 Michigan conviction for third-degree home invasion did not qualify as a "violent felony," defined by section 924(e) to include “burglary.” The generic statutory term “burglary” means “unlawful or unprivileged entry into, or remaining in, a building or structure, with intent to commit a crime.” Quarles argued that Michigan’s statute, which applies when a person “breaks and enters a dwelling or enters a dwelling without permission and, at any time while ... entering, present in, or exiting the dwelling, commits a misdemeanor,” swept too broadly by encompassing situations where the defendant forms the intent to commit a crime at any time while unlawfully remaining in a dwelling, while generic remaining-in burglary occurs only when the defendant has the intent to commit a crime at the exact moment when he first unlawfully remains in a building or structure. The district court, Sixth Circuit, and a unanimous Supreme Court rejected that argument.Generic remaining-in burglary occurs when the defendant forms the intent to commit a crime at any time while unlawfully remaining in a building or structure. In ordinary usage, “remaining-in” is a continuous activity, so burglary occurs if the defendant forms the intent to commit a crime at any time during the continuous event of unlawfully remaining in a building or structure. Congress singled out burglary because of its inherent potential for harm to persons; the possibility of a violent confrontation does not depend on the exact moment when the burglar forms the intent to commit a crime while unlawfully present in a building or structure. Michigan’s home-invasion statute substantially corresponds to or is narrower than generic burglary. View "Quarles v. United States" on Justia Law

Newton worked on drilling platforms off the California coast. Newton was paid for his time on duty but not for his time on standby, during which he could not leave the platform. Newton filed a class action, alleging that California laws required compensation for standby time. The platforms were subject to the Outer Continental Shelf Lands Act (OCSLA), which provides that all law on the Outer Continental Shelf (OCS) is federal law; denies states any interest in or jurisdiction over the OCS; and deems the adjacent state’s laws to be federal law only “[t]o the extent that they are applicable and not inconsistent with” federal law, 43 U.S.C. 1333(a)(2)(A). A unanimous Supreme Court vacated a Ninth Circuit decision in favor of Newton. Where federal law addresses the relevant issue, state law is not adopted as surrogate federal law on the OCS. The Court rejected Newton's proposed pre-emption analysis; federal law is the only law on the OCS and there is no overlapping state and federal jurisdiction, so the reference to “not inconsistent” state laws presents only the question whether federal law has already addressed the issue. If so, state law on the issue is inapplicable. Some of Newton’s claims are premised on California law requiring payment for all standby time but federal law already addresses that issue. To the extent his OCS-based claims rely on California’s minimum wage, the Fair Labor Standards Act already provides for a minimum wage. View "Parker Drilling Management Services, Ltd. v. Newton" on Justia Law

The Leahy-Smith America Invents Act (AIA) of 2011 created the Patent Trial and Appeal Board, 35 U.S.C. 6(c), which conducts administrative review proceedings that enable a “person” to challenge the validity of a patent post-issuance: “inter partes review,” “post-grant review,” and “covered-business-method review” (CBM review). The Board either confirms or cancels the patent claims. Any dissatisfied party may then seek judicial review in the Federal Circuit. A patent can also be reexamined either in federal court during a defense to an infringement suit or in an ex parte reexamination by the Patent Office.USPS introduced an enhanced service to process undeliverable mail, which Return Mail asserted infringed its patent. USPS petitioned for ex parte reexamination. The Patent Office confirmed the patent’s validity. Return Mail then sued, seeking compensation for the unauthorized use of its invention. USPS petitioned for CBM review. The Patent Board concluded that the subject matter of Return Mail’s claims was ineligible to be patented. The Federal Circuit affirmed.The Supreme Court reversed. The government is not a “person” capable of instituting AIA review proceedings. Absent an express definition of “person” in the patent statutes, the Court applied a longstanding interpretive presumption that "person" does not include the sovereign, citing common usage, and the Dictionary Act. There are many references to “person[s]” in the Patent Act and the AIA: Sometimes “person” plainly includes or excludes the government, but sometimes it might be read either way. The mere existence of some government-inclusive references and the government's ability to obtain a patent do not overcome the presumption that the government is not a “person” eligible to petition for AIA review. Congress may have had good reason to authorize the government to initiate a hands-off ex parte reexamination but not to become a party to the AIA’s full-blown adversarial proceeding. View "Return Mail, Inc. v. United States Postal Service" on Justia Law

Title VII of the Civil Rights Act of 1964 prohibits discrimination in employment on the basis of race, color, religion, sex, or national origin, 42 U.S.C. 2000e–2(a)(1). A complainant must file a charge with the Equal Employment Opportunity Commission (EEOC), which notifies the employer and investigates. The EEOC may attempt informal methods of conciliation and has the first option to sue the employer. If the EEOC does not sue, the complainant is entitled to a “right-to-sue” notice and then may commence a civil action against her employer. Davis filed a charge against her employer, Fort Bend, claiming sexual harassment and retaliation for reporting the harassment. While the charge was pending, Fort Bend fired Davis because she failed to come to work on a Sunday, going to a church event instead. Davis attempted to supplement her EEOC charge by handwriting “religion” on an “intake questionnaire.” She did not amend the formal charge document. Upon receiving a right-to-sue letter, Davis filed suit, alleging discrimination on account of religion and retaliation for reporting sexual harassment. After years of litigation, only the religion-based discrimination claim remained. Fort Bend then asserted for the first time that the court lacked jurisdiction because the EEOC charge did not state a religion-based discrimination claim. The Fifth Circuit reversed dismissal of the suit.The Supreme Court affirmed. Title VII’s charge-filing requirement is not jurisdictional. A claim-processing rule requiring parties to take certain procedural steps during or before litigation may be mandatory so that a court must enforce the rule if timely raised. A mandatory rule of that sort, unlike a prescription limiting the kinds of cases a court may adjudicate, is ordinarily forfeited if not timely asserted. Title VII’s charge-filing requirement is discrete from the statutory provisions empowering federal courts to exercise jurisdiction over Title VII actions. View "Fort Bend County v. Davis" on Justia Law

Taggart owned an interest in an Oregon company. That company and its other owners (respondents) sued, claiming that Taggart had breached the company’s operating agreement. Before trial, Taggart filed for Chapter 7 bankruptcy. The Bankruptcy Court issued a discharge order that released Taggart from liability for most pre-bankruptcy debts. The Oregon state court subsequently entered judgment against Taggart in the pre-bankruptcy suit and awarded attorney’s fees to respondents. The Bankruptcy Court found respondents in civil contempt for collecting attorney’s fees in violation of the discharge order. The Bankruptcy Appellate Panel and the Ninth Circuit applied a subjective standard to hold that a “creditor’s good faith belief” that the discharge order does not apply to the claim precludes a finding of contempt, even if that belief was unreasonable. The Supreme Court vacated. Neither a standard akin to strict liability nor a purely subjective standard is appropriate. A court may hold a creditor in civil contempt for violating a discharge order if there is no fair ground of doubt as to whether the order barred the creditor’s conduct. Civil contempt principles apply to the bankruptcy statutes, which specify that a discharge order “operates as an injunction,” 11 U.S.C. 524(a)(2), and that a court may issue any “order” or “judgment” that is “necessary or appropriate” to “carry out” other bankruptcy provisions. A party’s subjective belief that she was complying with an order ordinarily will not insulate her from civil contempt if that belief was objectively unreasonable. The Court remanded, noting that subjective intent is not always irrelevant. Civil contempt sanctions may be warranted when a party acts in bad faith, and a party’s good faith may help to determine an appropriate sanction. View "Taggart v. Lorenzen" on Justia Law

Mont had a five-year federal term of supervised release, scheduled to end on March 6, 2017. In June 2016, he was arrested on state drug trafficking charges. In October 2016, Mont pleaded guilty to state charges. He then admitted in a federal court filing that he violated his supervised-release conditions by virtue of the new state convictions. The district court rescheduled his hearing several times to allow the state court to first sentence Mont. On March 21, 2017, Mont was sentenced to six years’ imprisonment. His 10 months of pretrial custody were credited as time served. On March 30, the district court set a supervised-release hearing. Mont unsuccessfully challenged the court’s jurisdiction, arguing that his supervised release had expired on March 6. The court ordered him to serve an additional 42 months’ imprisonment consecutive to his state sentence. The Sixth Circuit and Supreme court affirmed, citing 18 U.S.C. 3624(e), which provides that a “term of supervised release does not run during any period in which the person is imprisoned in connection with a conviction for a . . . crime unless the imprisonment is for a period of less than 30 consecutive days.” Pretrial detention later credited as time served for a new conviction is "imprisonment in connection with a conviction" and tolls the supervised-release term, even if the court must make the tolling calculation after learning whether the time will be credited. The Court noted that there is no reason to give a defendant the windfall of satisfying a new sentence of imprisonment and an old sentence of supervised release with the same period of pretrial detention. The defendant need not be supervised when he is in custody; there is nothing unfair about the defendant not knowing during pretrial detention whether he is also under supervised release. View "Mont v. United States" on Justia Law

The Medicare program offers additional payments to institutions that serve a “disproportionate number” of low-income patients, 42 U.S.C. 1395ww(d)(5)(F)(i)(I), calculated using the hospital’s “Medicare fraction.” The fraction’s denominator is the time the hospital spent caring for patients entitled to Medicare Part A benefits; the numerator is the time the hospital spent caring for Part-A-entitled patients who were also entitled to income support payments under the Social Security Act. Medicare Part C (Medicare Advantage) was created in 1997. Part C, beneficiaries may choose to have the government pay their private insurance premiums rather than pay for their hospital care directly. Part C enrollees tend to be wealthier than Part A enrollees, so counting them makes the fraction smaller and reduces hospitals’ payments. In 2014, the Medicare website indicated that fractions for fiscal year 2012 included Part C patients. Hospitals sued, claiming violation the Medicare Act’s requirement to provide public notice and a 60-day comment period for any “rule, requirement, or other statement of policy . . . that establishes or changes a substantive legal standard governing . . . the payment for services.”The Supreme Court affirmed the D.C. Circuit in agreeing with the hospitals. The government has not identified a lawful excuse for neglecting its statutory notice-and-comment obligations. The 2014 announcement established or changed a “substantive legal standard” not an interpretive legal standard. The Medicare Act and the Administrative Procedures Act do not use the word “substantive” in the same way. The Medicare Act contemplates that “statements of policy” can establish or change a “substantive legal standard." Had Congress wanted to follow the APA in the Medicare Act and exempt interpretive rules and policy statements from notice and comment, it could have cross-referenced the APA exemption, 5 U.S.C. 553(b)(A). View "Azar v. Allina Health Services" on Justia Law

New Indiana law altered the manner in which abortion providers may dispose of fetal remains. It excluded fetal remains from the definition of infectious and pathological waste, thereby preventing incineration of fetal remains along with surgical byproducts. It also authorized simultaneous cremation of fetal remains, which Indiana does not generally allow for human remains. The law did not affect a woman’s right under existing law “to determine the final disposition of the aborted fetus.” The Supreme Court reversed the Seventh Circuit, upholding the provision. The law does not create an undue burden on a woman’s right to obtain an abortion and does not implicate a fundamental right; it is subject only to ordinary rational basis review. The Supreme Court has previously acknowledged that a state has a “legitimate interest in proper disposal of fetal remains.” Indiana’s law is rationally related to that interest, even if it is not perfectly tailored to that end. The Court denied certiorari and declined to address the second issue, i.e., whether Indiana may prohibit the knowing provision of sex-, race-, and disability- selective abortions. Only the Seventh Circuit has addressed that kind of law and the Supreme Court ordinarily denies petitions insofar as they raise legal issues that have not been considered by additional Courts of Appeals. View "Box v. Planned Parenthood of Indiana and Kentucky, Inc." on Justia Law