Justia U.S. Supreme Court Opinion Summaries

The United States District Court for the District of Massachusetts issued a temporary restraining order (TRO) on March 10, 2025, preventing the Government from terminating various education-related grants. The order also required the Government to pay past-due grant obligations and continue paying future obligations. The District Court concluded that the respondents were likely to succeed on the merits of their claims under the Administrative Procedure Act (APA).The Government filed an application to vacate the District Court's order on March 26, 2025, which was extended on March 24, 2025. The application was presented to Justice Jackson and referred to the Supreme Court. The Supreme Court noted that the District Court's order had characteristics of a preliminary injunction, making it appealable. The Government argued that the District Court lacked jurisdiction to order the payment of money under the APA, as the APA's waiver of sovereign immunity does not apply to claims seeking money damages or to orders enforcing contractual obligations to pay money.The Supreme Court of the United States granted the Government's application to stay the District Court's order pending the appeal in the United States Court of Appeals for the First Circuit and any subsequent petition for a writ of certiorari. The Court found that the respondents had not refuted the Government's claim that it would be unlikely to recover the grant funds once disbursed and that respondents would not suffer irreparable harm while the TRO is stayed. The stay will terminate automatically if certiorari is denied or upon the sending down of the judgment of the Supreme Court if certiorari is granted. The Chief Justice would have denied the application. View "Department of Education v. California" on Justia Law

Douglas Horn, a commercial truck driver, purchased and consumed a CBD tincture called "Dixie X," marketed as THC-free by Medical Marijuana, Inc. After a random drug test by his employer detected THC in his system, Horn was fired for refusing to participate in a substance abuse program. Horn subsequently sued Medical Marijuana under the Racketeer Influenced and Corrupt Organizations Act (RICO), claiming that the company's false advertising led to his job loss.The District Court granted summary judgment in favor of Medical Marijuana, reasoning that Horn's job loss was a consequence of a personal injury (ingesting THC), and thus not recoverable under RICO, which only allows recovery for business or property injuries. The Second Circuit Court of Appeals reversed this decision, holding that Horn's job loss constituted an injury to his business under RICO, rejecting the "antecedent-personal-injury bar" that precludes recovery for business or property losses derived from personal injuries.The Supreme Court of the United States reviewed the case to determine whether civil RICO categorically bars recovery for business or property losses that derive from a personal injury. The Court held that under civil RICO, a plaintiff may seek treble damages for business or property loss even if the loss resulted from a personal injury. The Court emphasized that the statute's language allows recovery for business or property harms without excluding those that result from personal injuries. The judgment of the Second Circuit was affirmed, and the case was remanded for further proceedings consistent with this opinion. View "Medical Marijuana, Inc. v. Horn" on Justia Law

The case involves the Food and Drug Administration (FDA) denying authorization for respondents to market certain flavored e-cigarette products. The FDA's decision was based on the lack of sufficient scientific evidence demonstrating that these products would be appropriate for the protection of public health. The FDA emphasized the need for evidence from randomized controlled trials or longitudinal cohort studies, which the respondents did not provide. Instead, respondents submitted literature reviews and cross-sectional surveys, which the FDA found inadequate.The United States Court of Appeals for the Fifth Circuit, sitting en banc, reviewed the FDA's denial orders. The court found that the FDA acted arbitrarily and capriciously by applying different standards than those articulated in its predecisional guidance. The court was particularly concerned with the FDA's failure to review marketing plans, which it had previously deemed critical. The Fifth Circuit rejected the FDA's argument that any errors were harmless and remanded the case to the FDA.The Supreme Court of the United States reviewed the case and vacated the Fifth Circuit's decision. The Court held that the FDA's denial orders were consistent with its predecisional guidance regarding scientific evidence, comparative efficacy, and device type, and thus did not violate the change-in-position doctrine. However, the Court agreed with the FDA that the Fifth Circuit's interpretation of harmless error was overly broad. The Supreme Court remanded the case to the Fifth Circuit to reconsider the harmless-error question without relying on its expansive reading of Calcutt v. FDIC. View "FDA v. Wages and White Lion Investments, LLC" on Justia Law

The case involves the interpretation of the Gun Control Act of 1968 (GCA) in relation to weapon parts kits and unfinished frames or receivers. The GCA mandates that those involved in the import, manufacture, or sale of firearms must obtain federal licenses, keep sales records, conduct background checks, and mark their products with serial numbers. The Act defines a "firearm" to include any weapon that can expel a projectile by explosive action and the frame or receiver of such a weapon. With the rise of weapon parts kits that can be assembled into functional firearms, the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) adopted a rule in 2022 to include these kits under the GCA's regulations.The District Court vacated the ATF's rule, agreeing with the plaintiffs that the GCA does not cover weapon parts kits or unfinished frames or receivers. The Fifth Circuit affirmed this decision, holding that the GCA's definition of "firearm" does not extend to weapon parts kits or unfinished frames and receivers, regardless of their completeness or ease of assembly.The Supreme Court of the United States reviewed the case and reversed the Fifth Circuit's decision. The Court held that the ATF's rule is not facially inconsistent with the GCA. The Court found that some weapon parts kits, like Polymer80's "Buy Build Shoot" kit, qualify as "weapons" under the GCA because they can be readily converted into functional firearms. Additionally, the Court held that the GCA's definition of "frame or receiver" includes some partially complete frames or receivers that can be easily finished using common tools. The Court concluded that the ATF has the authority to regulate these items under the GCA. The case was remanded for further proceedings consistent with this opinion. View "Bondi v. Vanderstok" on Justia Law

A Utah-based transportation business, All Resort Group, became insolvent in 2013 due to poor management and financial malfeasance. Two shareholders misappropriated $145,000 in company funds to pay their personal federal tax liabilities. In 2017, the company filed for bankruptcy, and the trustee sought to recover the misappropriated funds under §544(b) of the Bankruptcy Code, invoking Utah’s fraudulent-transfer statute as the applicable law.The Bankruptcy Court ruled in favor of the trustee, holding that §106(a) of the Bankruptcy Code waived the Government’s sovereign immunity for the state-law cause of action nested within the §544(b) claim. The District Court adopted this decision, and the Tenth Circuit affirmed, concluding that §106(a) abolished the Government’s sovereign immunity in an avoidance proceeding under §544(b)(1).The Supreme Court of the United States reviewed the case and reversed the Tenth Circuit’s decision. The Court held that §106(a)’s sovereign-immunity waiver applies only to the §544(b) claim itself and not to the state-law claims nested within that federal claim. The Court emphasized that waivers of sovereign immunity are jurisdictional and do not create new substantive rights or alter pre-existing ones. The Court concluded that §106(a) does not modify the substantive requirements of §544(b) and that the trustee must still identify an actual creditor who could have voided the transaction under applicable law outside of bankruptcy proceedings. View "United States v. Miller" on Justia Law

Salvatore Delligatti, an associate of the Genovese crime family, was convicted of using or carrying a firearm during a crime of violence under 18 U.S.C. §924(c). He had recruited gang members to kill a suspected police informant and provided them with a loaded revolver. Delligatti was charged with attempted murder under the violent-crimes-in-aid-of-racketeering (VICAR) statute, which required proof of attempted second-degree murder under New York law. He argued that a VICAR offense predicated on New York second-degree murder is not a crime of violence because homicide under New York law can be committed by omission.The District Court denied Delligatti’s motion to dismiss the §924(c) charge, holding that VICAR attempted murder is a crime of violence. A jury convicted Delligatti on all counts, and he was sentenced to 25 years in prison. The U.S. Court of Appeals for the Second Circuit affirmed the District Court’s decision, relying on the precedent set in United States v. Scott, which held that the knowing or intentional causation of bodily injury necessarily involves the use of physical force, even when the harm is caused by omission.The Supreme Court of the United States affirmed the Second Circuit’s decision. The Court held that the knowing or intentional causation of injury or death, whether by act or omission, necessarily involves the use of physical force against another person within the meaning of §924(c)(3)(A). The Court reasoned that it is impossible to deliberately cause physical harm without the use of physical force, extending the logic of United States v. Castleman to §924(c). The Court concluded that New York second-degree murder, including by omission, qualifies as a crime of violence under §924(c)’s elements clause. View "Delligatti v. United States" on Justia Law

Patrick Thompson took out three loans totaling $219,000 from a bank. After the bank failed, the FDIC took over the collection of the loans. Thompson disputed the $269,120.58 balance shown on his invoice, claiming he had only borrowed $110,000. He made similar statements in subsequent calls with FDIC contractors. Thompson was charged with violating 18 U.S.C. §1014, which prohibits making false statements to influence the FDIC’s actions on a loan. A jury found him guilty, and he moved for acquittal, arguing his statements were not false since he had indeed borrowed $110,000, even though he later borrowed more.The District Court denied Thompson’s motion, stating that the Seventh Circuit does not require literal falsity for a §1014 conviction and that misleading statements could suffice. The Seventh Circuit affirmed, citing its precedent that §1014 criminalizes misleading representations. The court found Thompson’s statements misleading because they implied he owed no more than $110,000, despite his total debt being $219,000.The Supreme Court of the United States reviewed the case and held that §1014 does not criminalize statements that are misleading but not false. The Court emphasized that the statute uses the word “false,” which means “not true,” and does not include “misleading.” The Court noted that many other statutes explicitly prohibit both false and misleading statements, indicating that Congress knew how to include misleading statements when it intended to do so. The Court vacated the Seventh Circuit’s judgment and remanded the case to determine whether a reasonable jury could find that Thompson’s statements were false. View "Thompson v. United States" on Justia Law

Petitioners, veterans Joshua Bufkin and Norman Thornton, applied for service-connected PTSD disability benefits from the Department of Veterans Affairs (VA). Bufkin's claim was denied due to insufficient evidence linking his PTSD to his military service. Thornton, who already received benefits, sought an increased disability rating, which the VA denied. Both cases were reviewed de novo by the Board of Veterans’ Appeals, which upheld the VA's decisions. Bufkin and Thornton then appealed to the U.S. Court of Appeals for Veterans Claims, arguing that the evidence was in "approximate balance" and they were entitled to the benefit of the doubt.The Veterans Court affirmed the Board's decisions, finding no clear error in the approximate-balance determinations. Petitioners appealed to the Federal Circuit, challenging the Veterans Court's interpretation of 38 U.S.C. §7261(b)(1). They argued that the Veterans Court should review the entire record de novo to determine if the evidence was in approximate balance. The Federal Circuit rejected this argument and affirmed the Veterans Court's decisions.The Supreme Court of the United States reviewed the case and held that the VA's determination of whether evidence is in "approximate balance" is predominantly a factual determination, subject to clear-error review. The Court clarified that the Veterans Court must review the VA's application of the benefit-of-the-doubt rule using the same standards as other determinations: de novo for legal issues and clear error for factual issues. The judgment of the Federal Circuit was affirmed. View "Bufkin v. Collins" on Justia Law

The City and County of San Francisco operates two combined wastewater treatment facilities that process both wastewater and stormwater. During heavy precipitation, these facilities may discharge untreated water into the Pacific Ocean or San Francisco Bay. In 2019, the Environmental Protection Agency (EPA) issued a renewal permit for San Francisco's Oceanside facility, adding two "end-result" requirements. These requirements prohibited discharges that contribute to violations of water quality standards and discharges that create pollution, contamination, or nuisance as defined by California law. San Francisco challenged these provisions, arguing they exceeded the EPA's statutory authority.The California Regional Water Quality Control Board and the EPA approved the final Oceanside NPDES permit. San Francisco appealed to the EPA's Environmental Appeals Board, which rejected the challenge. The City then petitioned for review in the Ninth Circuit, which denied the petition. The Ninth Circuit held that the Clean Water Act (CWA) authorizes the EPA to impose any limitations necessary to ensure water quality standards are met in receiving waters.The Supreme Court of the United States reviewed the case and held that Section 1311(b)(1)(C) of the CWA does not authorize the EPA to include "end-result" provisions in NPDES permits. The Court reasoned that determining the specific steps a permittee must take to meet water quality standards is the EPA's responsibility, and Congress has provided the necessary tools for the EPA to make such determinations. The Court reversed and remanded the Ninth Circuit's decision, emphasizing that the EPA must set specific rules for permittees to follow rather than imposing broad end-result requirements. View "City and County of San Francisco v. EPA" on Justia Law

Gary Waetzig, a former employee of Halliburton Energy Services, Inc., filed a federal age-discrimination lawsuit against the company. He later submitted his claims for arbitration and voluntarily dismissed his federal lawsuit without prejudice under Federal Rule of Civil Procedure 41(a). After losing in arbitration, Waetzig sought to reopen his dismissed lawsuit and vacate the arbitration award, citing Federal Rule of Civil Procedure 60(b) as the basis for reopening the case.The U.S. District Court for the District of Colorado reopened the case, ruling that a voluntary dismissal without prejudice counts as a "final proceeding" under Rule 60(b) and that Waetzig made a mistake by dismissing his case rather than seeking a stay. The District Court also granted Waetzig's motion to vacate the arbitration award. Halliburton appealed, and the Tenth Circuit reversed the District Court's decision, holding that a voluntary dismissal without prejudice does not count as a "final judgment, order, or proceeding" under Rule 60(b).The Supreme Court of the United States reviewed the case and held that a case voluntarily dismissed without prejudice under Rule 41(a) counts as a "final proceeding" under Rule 60(b). The Court reasoned that a voluntary dismissal is "final" because it terminates the case and aligns with the definitions and historical context of the term "final." The Court also concluded that a voluntary dismissal qualifies as a "proceeding" under Rule 60(b), encompassing all steps in an action's progression. The judgment of the Tenth Circuit was reversed, and the case was remanded for further proceedings consistent with the Supreme Court's opinion. View "Waetzig v. Halliburton Energy Services, Inc." on Justia Law