Justia U.S. Supreme Court Opinion Summaries

Murphy was awarded a judgment in his federal civil rights suit against two prison guards, including an award of attorney’s fees; 42 U.S.C. 1997e(d)(2) provides that in such cases “a portion of the [prisoner’s] judgment (not to exceed 25 percent) shall be applied to satisfy the amount of attorney’s fees awarded against the defendant.” The district court ordered Murphy to pay 10% of his judgment toward the fee award, leaving defendants responsible for the remainder. The Seventh Circuit reversed, holding that section 1997e(d)(2) required the district court to exhaust 25% of the prisoner’s judgment before demanding payment from the defendants. The Supreme Court affirmed. The mandatory phrase “shall be applied” suggests that the district court has some nondiscretionary duty to perform. The infinitival phrase “to satisfy the amount of attorney’s fees awarded” specifies the purpose of the preceding verb’s nondiscretionary duty and “to satisfy” an obligation, especially a financial obligation, usually means to discharge the obligation in full. The district court does not have wide discretion to pick any “portion” that does not exceed the 25% cap. This conclusion is reinforced by section 1997e(d)’s surrounding provisions, which also limit the district court’s pre-existing discretion under section 1988(b). View "Murphy v. Smith" on Justia Law

In 1998, CNH agreed to a collective-bargaining agreement (CBA), providing health care benefits under a group benefit plan to “[e]mployees who retire under the . . . Pension Plan.” “All other coverages,” such as life insurance, ceased upon retirement. The group benefit plan was “made part of ” the CBA and ran concurrently with it. The agreement contained a general durational clause stating that it would terminate in 2004 and stated that it “dispose[d] of any and all bargaining issues, whether or not presented during negotiations.” When the agreement expired, a class of CNH retirees sought a declaration that their health care benefits vested for life. In 2015, while their lawsuit was pending, the Supreme Court decided “Tackett,” requiring interpretation of CBAs according to “ordinary principles of contract law.” The Sixth Circuit concluded that the 1998 agreement was ambiguous and that extrinsic evidence supported lifetime vesting. The Supreme Court reversed. The Sixth Circuit erred in finding that the agreement was ambiguous based on a presumption, from pre-Tackett precedent, that lifetime vesting was inferred whenever “a contract is silent as to the duration of retiree benefits” and in declining to apply the general duration clause. Such inferences are inconsistent with ordinary principles of contract law. A contract is not ambiguous unless it is subject to more than one reasonable interpretation. View "CNH Industrial N. V. v. Reese" on Justia Law

Artis filed a federal-court suit against the District of Columbia, alleging a federal employment discrimination claim and three allied claims under D.C. law; nearly two years remained on the statute of limitations for the D.C. claims. More than two years later, the district court rejected the federal claim and dismissed the D.C.-law claims under 28 U.S.C. 1367(c). Artis refiled those claims in the D.C. Superior Court 59 days later. That court dismissed them as time-barred. The D.C. Court of Appeals affirmed. The Supreme Court reversed. Section 1367(d) provides that the “period of limitations for” refiling in state court a state claim “shall be tolled while the claim is pending [in federal court] and for a period of 30 days after it is dismissed unless State law provides for a longer tolling period.” The Court rejected an argument that the section merely provides a grace period, permitting the statute of limitations to run while the claim is pending in another forum and averting the risk of a time bar by according the plaintiff a fixed period in which to refile. Considering the ordinary meaning of the statutory language, the section is a tolling provision. It suspends the statute of limitations both while the claim is pending in federal court and for 30 days post-dismissal. The stop-the-clock interpretation of section1367(d) does not present a serious constitutional problem. View "Artis v. District of Columbia" on Justia Law

The Clean Water Act, 33 U.S.C. 1362, prohibits “any addition of any pollutant to navigable waters,” defined as “the waters of the United States.” Section 1311(a) contains exceptions, including permitting schemes under the EPA's National Pollutant Discharge Elimination System (NPDES) program and an Army Corps of Engineers program, which encompass the “waters of the United States.” The EPA and the Corps proffered the “Waters of the United States (WOTUS) Rule,” which “imposes no enforceable duty on any state, local, or tribal governments, or the private sector,” 80 Fed. Reg. 37102 and “does not establish any regulatory requirements.” Objectors challenged the Rule in district courts. Many filed “protective” petitions in Circuit Courts to preserve their challenges should their district court lawsuits be dismissed for lack of jurisdiction under 33 U.S.C. 1369(b), which enumerates EPA actions for which review lies directly and exclusively in the federal courts of appeals. Such actions include EPA actions “approving or promulgating any effluent limitation or other limitation under section 1311, 1312, 1316, or 1345,” and EPA actions “issuing or denying any permit under section 1342.” The Sixth Circuit denied motions to dismiss consolidated actions. The Supreme Court reversed. The Rule falls outside section 1369(b)(1), so challenges must be filed in district courts. It is not an “effluent limitation,” “on quantities, rates, and concentrations” of pollutants, nor is it an “other limitation under section 1311; it simply announces a regulatory definition. The Rule was promulgated under section 1361(a), which grants the EPA general rulemaking authority. The Rule neither issues nor denies NPDES permits under section 1342. View "National Association of Manufacturers. v. Department of Defense" on Justia Law

District of Columbia police officers responded to a complaint about loud music and illegal activities in a vacant house and found the house in disarray. They smelled marijuana and saw liquor. They found a makeshift strip club in the living room, and a naked woman and several men in a bedroom. The partygoers gave inconsistent stories. Two identified “Peaches” as the tenant and said that she had given permission for the party. When the officers spoke by phone to Peaches, she was agitated and evasive, eventually admitting that she did not have permission to use the house. The owner confirmed that he had not given anyone permission to be there. The officers arrested the partygoers for unlawful entry. Several partygoers sued for false arrest. The Supreme Court held that the officers had probable cause to arrest the partygoers. Considering the totality of the circumstances, the officers made an “entirely reasonable inference” that the partygoers knew they did not have permission to be in the house, The condition of the house and the conduct of the partygoers allowed the officers to make common-sense conclusions about human behavior and infer that the partygoers, who scattered and hid, knew the party was not authorized. The partygoers’ implausible answers gave the officers reason to infer that they were lying. The officers are entitled to qualified immunity under 42 U.S.C. 1983 even if they lacked actual probable cause because a reasonable officer could have interpreted the law as permitting the arrests. View "District of Columbia v. Wesby" on Justia Law

Tharpe moved to reopen his federal habeas corpus proceedings regarding his claim that the Georgia jury that convicted him of murder included a white juror, Gattie, who was biased against Tharpe because he is black. The district court denied the motion as procedurally defaulted in state court. The Eleventh Circuit denied a certificate of appealability application based on its conclusion, rooted in the state court’s fact-finding, that Tharpe had not established prejudice. The Supreme Court vacated and remanded. While the state court’s prejudice determination is binding on federal courts absent clear and convincing evidence to the contrary, Tharpe produced a sworn affidavit, signed by Gattie, indicating Gattie’s view that “there are two types of black people: 1. Black folks and 2. Niggers”; that Tharpe, “who wasn’t in the ‘good’ black folks category in my book, should get the electric chair for what he did”; that “[s]ome of the jurors voted for death because they felt Tharpe should be an example to other blacks who kill blacks, but that wasn’t my reason”; and that, “[a]fter studying the Bible, I have wondered if black people even have souls.” Gattie’s "remarkable" affidavit presents a strong factual basis for the argument that Tharpe’s race affected Gattie’s vote for a death verdict. "At the very least, jurists of reason could debate whether Tharpe has shown by clear and convincing evidence that the state court’s factual determination was wrong.” View "Tharpe v. Sellers" on Justia Law

The Acting Secretary of the Department of Homeland Security (DHS) announced steps to rescind the Deferred Action for Childhood Arrivals (DACA) program by March 2018, concluding that DACA violates the Administrative Procedure Act and the Due Process Clause. The Ninth Circuit ruled in favor of challengers. The government then moved to stay the district court order requiring completion of the administrative record until after resolution of motions to dismiss and for a preliminary injunction. The court stayed its order for one month. The government petitioned the Supreme Court, which vacated. The district court’s order required the government to turn over all “emails, letters, memoranda, notes, media items, opinions and other materials ... actually seen or considered, however briefly, by Acting Secretary ... in connection with the ... decision … all DACA-related materials considered by persons (anywhere in the government) who thereafter provided … written advice or input … all DACA-related materials considered by persons (anywhere in the government) who thereafter provided … verbal input … all comments and questions propounded ... to advisors or subordinates … and their responses, and … all materials directly or indirectly considered by former Secretary of DHS John Kelly leading to his February 2017 memorandum not to rescind DACA. The court should have first resolved the government’s threshold arguments that the decision was unreviewable as “committed to agency discretion,” 5 U.S.C. 701(a)(2), and that the Immigration and Nationality Act deprives the court of jurisdiction. The court may not compel the government to disclose any document that the government believes is privileged without first providing an opportunity to argue the issue. The Court did not consider the merits of the claims or defenses. View "In Re United States" on Justia Law

Hamer filed an employment discrimination suit. The district court granted the defendants summary judgment, entering final judgment on September 14, 2015. Before October 14, the date Hamer’s notice of appeal was due, her attorneys filed a motion to withdraw and for an extension of the appeal filing deadline to give Hamer time to secure new counsel. The court granted a two-month extension, even though Federal Rule of Appellate Procedure, 4(a)(5)(C), confines such extensions to 30 days. Concluding that Rule 4(a)(5)(C)’s time prescription is jurisdictional, the Seventh Circuit dismissed Hamer’s appeal. A unanimous Supreme Court vacated. Rule 4(a)(5)(C)’s limitation on extensions of time to file a notice of appeal is a court-made rule and not jurisdictional. It is a mandatory claim-processing rule that may be waived or forfeited. If a time prescription governing the transfer of adjudicatory authority from one Article III court to another appears in a statute, the limitation is jurisdictional; otherwise, the time specification fits within the claim-processing category. View "Hamer v. Neighborhood Housing Services of Chicago" on Justia Law

More than 30 years ago, Madison shot a police officer in the head at close range. An Alabama jury found Madison guilty of capital murder. In 2016, he sought suspension of his death sentence, arguing that, due to recent strokes, he has become incompetent. The court heard testimony from psychologists who had examined Madison. The court’s appointed psychologist reported that, although Madison may have “suffered a significant decline post-stroke, . . . [he] understands the exact posture of his case,” and appears to have a “rational understanding ” of his death sentence. A psychologist hired by Madison’s counsel reported that Madison “able to understand the nature of the pending proceeding and … what he was tried for” and that . . . [Alabama is] seeking retribution” for that crime, but Madison cannot recall “the sequence of events from the offense to his arrest to the trial” and believes that he “never went around killing.” The trial court denied Madison’s petition. Madison sought federal habeas relief. The Eleventh Circuit reversed the denial of that petition. The Supreme Court reversed, reinstating the denial, citing its “Panetti” and “Ford” holdings. Neither decision “clearly established” that a prisoner is incompetent to be executed because of a failure to remember his commission of the crime, as distinct from a failure to rationally comprehend the concepts of crime and punishment as applied to him. The state court did not unreasonably apply those decisions in holding that Madison is competent to be executed because he recognizes that he will be put to death as punishment for the murder he was found to have committed. Nor was the state court’s decision founded on an unreasonable assessment of the evidence. View "Dunn v. Madison" on Justia Law

Cuero, on parole, driving under the influence of methamphetamine and without a license, while carrying a gun, drove his car into and seriously injured a pedestrian. A California court permitted the state to amend a criminal complaint to which the Cuero had pleaded guilty, acknowledging that permitting the amendment would lead to a higher sentence. The amendment added another “strike” to Cuero’s criminal history. The court reasoned that the case was distinguishable from “a situation where the [State] might, after a guilty plea, seek to amend” by adding “new charges” or facts that fundamentally alter the substance of the complaint.Cuero was allowed to withdraw his guilty plea, then pleaded guilty to the amended complaint and was sentenced to a term with a minimum of 25 years. The Ninth Circuit held that the California court had made a mistake of federal law, reasoning that Cuero was entitled to specific performance of the 14-year, 4-month sentence that he would have received had the complaint not been amended. The Supreme Court reversed, citing the Antiterrorism and Effective Death Penalty Act, 28 U.S.C. 2254(d)(1), stating that none of its prior decisions clearly require the state court to impose the lower sentence that the parties originally expected. Even if the state violated the Constitution when it moved to amend the complaint there is no Supreme Court precedent that “clearly established” specific performance as a remedy. Circuit precedent does not constitute “clearly established Federal law, as determined by the Supreme Court.” View "Kernan v. Cuero" on Justia Law