Justia U.S. Supreme Court Opinion Summaries

Helsinn makes a treatment for chemotherapy-induced nausea using the chemical palonosetron. While developing that product, Helsinn granted another company the right to market a 0.25 mg dose of palonosetron in the United States; that company was required to keep proprietary information confidential. Nearly two years later, in 2003, Helsinn filed a provisional patent application covering a 0.25 mg dose of palonosetron. Helsinn filed four patent applications that claimed priority to the 2003 date. Helsinn’s fourth application, filed in 2013 (the 219 patent), is covered by the Leahy-Smith America Invents Act (AIA). In 2011, Teva sought approval to market a generic 0.25 mg palonosetron product. Helsinn sued for infringement. Teva countered that the 219 patent was invalid under the “on sale” provision of the AIA, which precludes a person from obtaining a patent on an invention that was “in public use, on sale, or otherwise available to the public before the effective filing date of the claimed invention,” 35 U.S.C. 102(a)(1), arguing the 0.25 mg dose was “on sale” more than one year before Helsinn filed the 2003 application.The Federal Circuit held, and the Supreme Court unanimously agreed, that the sale was publicly disclosed, regardless of whether the details of the invention were publicly disclosed in the agreements. A commercial sale to a third party who is required to keep the invention confidential may place the invention “on sale” under section 102(a). The patent statute in force immediately before the AIA included an on-sale bar. Supreme Court and Federal Circuit precedent interpreting that provision indicated that a sale or offer of sale need not make an invention available to the public to constitute invalidating prior art. The Court applied the presumption that when Congress reenacted the “on sale” language in the AIA, it adopted earlier judicial constructions. View "Helsinn Healthcare S. A. v. Teva Pharmaceuticals USA, Inc." on Justia Law

Stokeling pleaded guilty to possessing a firearm and ammunition after having been convicted of a felony, 18 U.S.C. 922(g)(1). The probation office recommended the mandatory minimum 15-year prison term that the Armed Career Criminal Act (ACCA) provides for 922(g) violators who have three previous convictions “for a violent felony.” Stokeling objected that his prior Florida robbery conviction was not a “violent felony,” which ACCA defines as “any crime punishable by imprisonment for a term exceeding one year” that “has as an element the use, attempted use, or threatened use of physical force against the person of another,” section 924(e)(2)(B)(i). The Eleventh Circuit and Supreme Court held that Stokeling qualified for the enhancement. ACCA’s elements clause encompasses a robbery offense that requires the defendant to overcome the victim’s resistance. The force necessary to overcome resistance by a victim is inherently “violent” in the sense contemplated by precedent and “suggest[s] a degree of power that would not be satisfied by the merest touching.” Stokeling’s suggested definition of “physical force” as force “reasonably expected to cause pain or injury” is inconsistent with the degree of force necessary to commit robbery at common law. The term “physical force” in ACCA encompasses the degree of force necessary to commit common-law robbery. View "Stokeling v. United States" on Justia Law

Oliveira is a driver for a trucking company, under an agreement that calls him an independent contractor and contains a mandatory arbitration provision. Oliveira filed a class action alleging that the company denies its drivers lawful wages. The company invoked the Federal Arbitration Act, arguing that questions regarding arbitrability should be resolved by the arbitrator. The First Circuit and Supreme Court agreed that a court should determine whether the Act's section 1 exclusion applies before ordering arbitration. A court’s authority to compel arbitration under the Act does not extend to all private contracts. Section 2 provides that the Act applies only when the agreement is “a written provision in any maritime transaction or a contract evidencing a transaction involving commerce.” Section 1 provides that “nothing” in the Act “shall apply” to “contracts of employment of seamen, railroad employees, or any other class of workers engaged in foreign or interstate commerce.” The sequencing is significant. A “delegation clause,” giving the arbitrator authority to decide threshold questions of arbitrability is merely a specialized type of arbitration agreement and is enforceable under sections 3 and 4 only if it appears in a contract consistent with section 2 that does not trigger section 1’s exception. Because “contract of employment” refers to any agreement to perform work, Oliveira’s contract falls within that exception. At the time of the Act’s 1925 adoption, the phrase “contract of employment” was not a term of art; dictionaries treated “employment” as generally synonymous with “work," not requiring a formal employer-employee relationship. Congress used the term “contracts of employment” broadly. View "New Prime Inc. v. Oliveira" on Justia Law

For representation in administrative proceedings, the Social Security Act provides that if a fee agreement exists, fees are capped at the lesser of 25% of past-due benefits or a set dollar amount—currently $6,000, 42 U.S.C. 406(a)(2)(A); absent an agreement, the agency may set any “reasonable” fee, section 406(a)(1). In either case, the agency is required to withhold up to 25% of past-due benefits for direct payment of fees. For representation in court proceedings, section 406(b) caps fees at 25% of past-due benefits; the agency may withhold benefits to pay these fees. Culbertson represented Wood in Social Security disability benefit proceedings before the agency and in court. The agency ultimately awarded Wood past-due benefits, withheld 25%, and awarded Culbertson fees under section 406(a) for representation before the agency. Culbertson sought a separate award under 406(b) for the court proceedings, requesting 25% of past-due benefits. The Eleventh Circuit held that 406(b)’s 25% limit applies to the total fees awarded under both sections.The Supreme Court reversed. Section 406(b)(1)(A)’s 25% cap applies only to fees for court representation, not to the aggregate fees awarded under 406(a) and (b). The subsections address different stages of the representation and use different methods for calculating fees. Applying 406(b)’s 25% cap on court-stage fees to 406(a) agency-stage fees, or the aggregate fees, would make little sense and would subject 406(a)(1)’s reasonableness limitation to 406(b)’s 25% cap—a limitation not included in the statute. The fact that the agency presently withholds a single pool of past-due benefits for payment of fees does not support an aggregate reading. The amount of past-due benefits that the agency can withhold for payment does not delimit the amount of fees that can be approved for representation before the agency or the court. View "Culbertson v. Berryhill" on Justia Law

Archer sued Schein, alleging violations of federal and state antitrust law and seeking both money damages and injunctive relief. The contract between the parties provided for arbitration of any dispute arising under or related to the agreement, except for actions seeking injunctive relief. Schein argued that because the rules governing the contract provide that arbitrators have the power to resolve arbitrability questions, an arbitrator—not the court—should decide whether the arbitration agreement applied. The Fifth Circuit affirmed the denial of Schein’s motion to compel arbitration. A unanimous Supreme Court vacated. Under the Federal Arbitration Act, arbitration is a matter of contract. Courts must enforce arbitration contracts according to their terms. The parties may agree to have an arbitrator decide not only the merits of a particular dispute but also “gateway” questions of “arbitrability.” When the parties’ contract delegates the arbitrability question to an arbitrator, a court may not override the contract, even if the court thinks that the arbitrability claim is wholly groundless. The Court declined “to redesign the Act” and noted that the Act contains no “wholly groundless” exception. Arbitrators are capable of efficiently disposing of frivolous cases and deterring frivolous motions; such motions do not appear to have caused a substantial problem in Circuits that have not recognized a “wholly groundless” exception. The Fifth Circuit may address whether this contract actually delegated the arbitrability question to an arbitrator on remand. View "Henry Schein, Inc. v. Archer & White Sales, Inc." on Justia Law

The Sixth Circuit held that Hill, who was sentenced to death in 1986, was entitled to habeas relief under 28 U.S.C. 2254(d)(1) because the decisions of the Ohio courts concluding that he is not intellectually disabled were contrary to clearly established Supreme Court precedent. The court relied on the 2017 Supreme Court decision, Moore v. Texas. The Supreme Court vacated and remanded so that Hill’s intellectual disability claim can be evaluated based solely on holdings that were clearly established at the relevant time. The Court rejected the Sixth Circuit reasoning “that Moore’s holding regarding adaptive strengths [was] merely an application of what was clearly established by” the Court’s 2002 decision, Atkins v. Virginia. In 2008, when the Ohio Court of Appeals rejected Hill’s claim, Atkins had not provided any comprehensive definition of “mental retardation” for Eighth Amendment purposes. While Atkins noted that standard definitions of mental retardation included as a necessary element “significant limitations in adaptive skills . . . that became manifest before age 18,” Atkins did not definitively resolve how that element was to be evaluated but instead left its application in the first instance to the states. The Moore majority primarily relied on medical literature that postdated the Ohio courts’ decisions. View "Shoop v. Hill" on Justia Law

In April 2013, Escondido police responded to a 911 call from Emmons about domestic violence at the apartment where she lived with her husband, her children, and a roommate, Douglas. The officers arrested her husband. He was later released. In May 2013, Escondido police received a 911 call, from Douglas’s mother (Trina) about another disturbance at Emmons’ apartment. Trina had been on the phone with her daughter, who was at the apartment. Trina heard her daughter and Emmons yelling and heard Douglas screaming for help before the call disconnected. Officers Houchin and Craig responded, having been notified that children could be present and that calls to the apartment had gone unanswered. There is a body-camera video of the response. No one answered the door. Officers spoke with Emmons through an open window. A man in the apartment told Emmons to back away from the window. Sergeant Toth and two officers arrived as backup. Minutes later, a man opened the door and came outside. Officer Craig said not to close the door. The man closed the door and tried to brush past Craig, who took the man quickly to the ground and handcuffed him without hitting the man or displaying any weapon. The man was not in observable pain. Within minutes, officers helped him up and arrested him for misdemeanor resisting and delaying a police officer. The man, Emmons’ father, Marty, sued under 42 U. S. C. 1983, claiming excessive force. The Ninth Circuit agreed that the officers had probable cause to arrest Marty but remanded the excessive force claims.The Supreme Court reversed as to Toth and vacated as to Craig. The decision concerning Toth was “quite puzzling” in light of the district court’s conclusion that only Craig was involved in the excessive force claim. As to Craig, it does not suffice for a court simply to state that an officer may not use unreasonable and excessive force, deny qualified immunity, and then remand for a trial on the question of reasonableness. An officer cannot be said to have violated a clearly established right unless the right’s contours were sufficiently definite that any reasonable official in the defendant’s shoes would have understood that he was violating it. The Ninth Circuit’s formulation of the clearly established right was far too general; the court made no effort to explain how case law prohibited Craig’s actions in this case. View "Escondido v. Emmons" on Justia Law

Defendants were each convicted of unlawfully possessing a firearm, 18 U.S.C. 922(g)(1); each was sentenced to the mandatory minimum 15-year prison term required by the Armed Career Criminal Act (ACCA) for section 922(g)(1) offenders who have at least three previous convictions for certain “violent” or drug-related felonies. ACCA defines “violent felony” to include “any crime punishable by imprisonment for a term exceeding one year . . . that . . . is burglary,” section 924(e)(2)(B). Defendants’ prior convictions were for violations of statutes that prohibit burglary of a structure or vehicle that has been adapted or is customarily used for overnight accommodation. The Courts of Appeals vacated both sentences.A unanimous Supreme Court held that the term “burglary” in ACCA includes burglary of a structure or vehicle that has been adapted or is customarily used for overnight accommodation. Under the categorical approach, courts evaluate a prior state conviction based on the elements of the state offense, not the defendant’s behavior on a particular occasion. A prior state conviction does not qualify as generic burglary where those elements are broader than those of generic burglary: “an unlawful or unprivileged entry into, or remaining in, a building or other structure, with intent to commit a crime.” The Arkansas and Tennessee statutes satisfy those elements. When ACCA was passed, most state burglary statutes covered vehicles adapted or customarily used for lodging. Congress also viewed burglary as an inherently dangerous crime that “creates the possibility of a violent confrontation.” An offender who breaks into a mobile home, an RV, a camping tent, or another structure or vehicle that is adapted or customarily used for lodging creates a similar risk of violent confrontation. View "United States v. Stitt" on Justia Law

In 2001, the Fish and Wildlife Service listed the dusky gopher frog as an endangered species, under the Endangered Species Act of 1973, 16 U.S.C. 1533(a)(1), which required the Service to designate the frog's “critical habitat.” The Service proposed designating a site in St. Tammany Parish, Louisiana (Unit 1). The frog had once lived in Unit 1, but the land had long been used as a commercial timber plantation; no frogs had been spotted there for decades. The Service concluded that Unit 1 met the statutory definition of unoccupied critical habitat because of its rare, high-quality breeding ponds and distance from existing frog populations. The Service commissioned a report, which found that designation might bar future development, depriving the owners of up to $33.9 million, but concluded that the potential costs were not disproportionate to the conservation benefits and designated Unit 1 as critical habitat. The owners sued, contending that the closed-canopy timber plantation on Unit 1 could not be critical habitat for the frog, which lives in open-canopy forests. The district court and Fifth Circuit affirmed.The Supreme Court vacated. The decision not to exclude an area from critical habitat is subject to judicial review. An area is eligible for designation as critical habitat only if it is habitat for the species. Section 1533(a)(3)(A)(i), the sole source of authority for critical-habit designations, states that when the Secretary lists a species as endangered he must also “designate any habitat of such species which is then considered to be critical habitat.” Whether the frog could survive in Unit 1; whether habitat can include areas where the species could not currently survive; and whether the assessment of the costs and benefits of designation and resulting decision were arbitrary, capricious, or an abuse of discretion, must be addressed on remand. View "Weyerhaeuser Co. v. United States Fish and Wildlife Service" on Justia Law

Plaintiffs alleged that the Mount Lemmon Arizona Fire District terminated their employment as firefighters in violation of the Age Discrimination in Employment Act (ADEA). The District responded that it was too small to qualify as an “employer” under the ADEA, which provides that “‘employer’ means a person engaged in an industry affecting commerce who has twenty or more employees . . . . The term also means (1) any agent of such a person, and (2) a State or political subdivision of a State” 29 U.S.C. 630(b). The Supreme Court ruled in favor of the plaintiffs. Section 630’s two-sentence delineation and the expression “also means” establish separate categories: persons engaged in an industry affecting commerce with 20 or more employees and states or political subdivisions with no attendant numerosity limitation. Reading section 630(b) to apply to states and political subdivisions regardless of size gives the ADEA broader reach than Title VII, but this disparity is a consequence of the different language Congress chose to employ. The Court noted that the Equal Employment Opportunity Commission has, for 30 years, interpreted the ADEA to cover political subdivisions regardless of size, and a majority of the states impose age discrimination proscriptions on political subdivisions with no numerical threshold. View "Mount Lemmon Fire District v. Guido" on Justia Law