Justia U.S. Supreme Court Opinion Summaries

The Fair Debt Collection Practices Act authorizes private lawsuits and fines against “debt collector[s],” defined as anyone who “regularly collects or attempts to collect . . . debts owed or due . . . another,” 15 U.S.C. 1692a(6). CitiFinancial loaned money to petitioners, who defaulted. Santander purchased the defaulted loans from CitiFinancial and sought to collect in ways petitioners believe violated the Act. The district court and Fourth Circuit held that Santander was not a debt collector because it did not regularly seek to collect debts “owed . . . another” but sought instead only to collect debts that it purchased and owned. A unanimous Supreme Court affirmed. A company may collect debts that it purchased for its own account, without triggering the statutory definition. The statute’s plain language focuses on third party collection agents regularly collecting for a debt owner—not on a debt owner seeking to collect debts for itself. The Court rejected an argument that the word “owed” is the past participle of the verb “to owe,” and indicates that the debt collector definition must exclude loan originators but embrace debt purchasers. The Court stated that it would not “rewrite a constitutionally valid text under the banner of speculation about what Congress might have done had it faced a question that, on everyone’s account, it never faced.” View "Henson v. Santander Consumer USA Inc." on Justia Law

In 1999, LeBlanc, then age 16, raped a 62- year-old woman. In 2003, a state trial court sentenced him to life in prison. Virginia had abolished traditional “parole” for felony offenders and enacted its “geriatric release” program, which allows older inmates to receive conditional release under some circumstances. In 2010, the Supreme Court held, in Graham v. Florida, that the Eighth Amendment prohibits juvenile offenders convicted of nonhomicide offenses from being sentenced to life without parole and that states must give defendants “some meaningful opportunity to obtain release based on demonstrated maturity and rehabilitation.” LeBlanc sought to vacate his sentence in light of Graham. The state court denied the motion, citing the Supreme Court of Virginia’s decision in Angel v. Commonwealth, that Virginia’s geriatric release program satisfies Graham’s requirement of parole for juvenile offenders: “The regulations for conditional release under this statute provide that if the prisoner meets the qualifications for consideration contained in the statute, the factors used in the normal parole consideration process apply to conditional release decisions under this statute.” LeBlanc filed a federal habeas petition, 28 U.S.C. 2254. The Supreme Court reversed the Fourth Circuit’s grant of relief. The Virginia trial court’s ruling, resting on the Virginia Supreme Court’s ruling in Angel, was not objectively unreasonable in light of existing Supreme Court authority. View "Virginia v. LeBlanc" on Justia Law

The owners of Microsoft’s videogame console, Xbox 360, filed a putative class action alleging a design defect. The district court struck class allegations from the complaint. The Ninth Circuit denied permission to appeal that order under FRCP 23(f), which authorizes permissive interlocutory appeal of class certification orders. Instead of pursuing their individual claims, plaintiffs stipulated to a voluntary dismissal, then appealed, challenging only the interlocutory order striking their class allegations. The Ninth Circuit held it had jurisdiction to entertain the appeal under 28 U.S.C. 1291, applicable to “final decisions of the district courts,” and that the rationale for striking the class allegations was impermissible. The Supreme Court reversed. Federal courts of appeals lack jurisdiction under section 1291 to review an order denying class certification (or an order striking class allegations) after the named plaintiffs have voluntarily dismissed their claims with prejudice. Section 1291’s final-judgment rule preserves the proper balance between trial and appellate courts, minimizes the harassment and delay that would result from repeated interlocutory appeals, and promotes the efficient administration of justice. Under plaintiffs’ theory, plaintiffs alone could determine whether and when to appeal an adverse certification ruling, allowing indiscriminate appellate review of interlocutory orders. Plaintiffs in putative class actions cannot transform interlocutory orders into section 1291 final judgments simply by dismissing their claims with prejudice. Finality “is not a technical concept of temporal or physical termination.” View "Microsoft Corp. v. Baker" on Justia Law

The Immigration and Nationality Act, 8 U.S.C. 1401(a)(7), provides a path to citizenship for a child born abroad if the child’s U.S.-citizen parent has 10 years’ physical presence in the U.S. before the child’s birth, “at least five of which were after attaining” age 14. Section 1409(c) provides that an unwed U.S.-citizen mother's citizenship can be transmitted to a child born abroad if she has lived continuously in the U.S. for one year before the child’s birth. Morales-Santana’s father, José, moved to the Dominican Republic 20 days before his 19th birthday, so he did not satisfy 1401(a)(7)’s requirement for physical presence after age 14. A Dominican woman gave birth to Morales-Santana in 1962. José accepted parental responsibility. Morales-Santana has lived in the U.S. since he was 13. In 2000, the government sought to remove Morales-Santana based on criminal convictions, ranking him as alien. The Supreme Court affirmed the Second Circuit, ruling in Morales-Santana’s favor. The statute’s gender line is incompatible with the Fifth Amendment’s equal protection requirement. Morales-Santana has third-party standing to vindicate his deceased father’s rights. The Court applied “heightened scrutiny” and found no important governmental interest for the law’s “overbroad generalizations.” Given the choice between extending favorable treatment to the excluded class or withdrawing favorable treatment from the favored class, the Court noted that extension of favorable treatment to fathers would displace Congress’ general rule, the longer physical-presence requirements. Pending Congressional action, the five-year requirement should apply, prospectively, to children born to unwed U.S-citizen mothers. View "Sessions v. Morales-Santana" on Justia Law

The Biologics Price Competition and Innovation Act, concerning FDA approval of a drug that is biosimilar to an already-licensed biological “reference product,” 42 U.S.C. 262(k), treats submission of a biosimilar application as an “artificial” patent infringement. An applicant must provide its biosimilar application and manufacturing information to the reference product’s sponsor. The parties collaborate to identify patents for immediate litigation. Second phase litigation is triggered when the applicant gives the sponsor notice at least 180 days before commercially marketing the biosimilar. Amgen claims patents on methods of manufacturing and using filgrastim. Sandoz sought FDA approval to market a biosimilar, Zarxio, and notified Amgen that it had submitted an application, that it intended to market Zarxio immediately upon receiving FDA approval, and that it did not intend to provide application and manufacturing information. Amgen sued for patent infringement and asserted that Sandoz engaged in “unlawful” conduct under California law by failure to provide its application and manufacturing information and by notification of commercial marketing before obtaining FDA licensure. The FDA licensed Zarxio. Sandoz provided Amgen another notice of commercial marketing. The Supreme Court unanimously held that section 262(l)(2)(A) is not enforceable by injunction under federal law, but the Federal Circuit should determine whether a state-law injunction is available. Submitting an application constitutes artificial infringement; failing to disclose the application and manufacturing information does not. Section 262(l)(9)(C) provides a remedy for failure to turn over the application and manufacturing information, authorizing the sponsor, but not the applicant, to bring an immediate declaratory-judgment action, thus vesting in the sponsor the control that the applicant would otherwise have exercised over the scope and timing of the patent litigation. An applicant may provide notice under section 262(l)(8)(A) before obtaining FDA licensure. View "Sandoz Inc. v. Amgen Inc." on Justia Law

The Employee Retirement Income Security Act (ERISA) obligates private employers offering pension plans to adhere to rules designed to ensure plan solvency and protect plan participants, 29 U.S.C. 1003(b)(2). ERISA exempts “A plan established and maintained for its employees . . . by a church . . . [which] includes a plan maintained by an organization . . . the principal purpose . . . of which is the administration or funding of [such] plan . . . for the employees of a church . . . , if such organization is controlled by or associated with a church,” section 1002(33)(C)(i). Defendants, church-affiliated nonprofits that run hospitals, offer their employees defined-benefit pension plans, which were established by the hospitals themselves, and are managed by internal employee-benefits committees. Current and former employees filed class actions alleging that the hospitals’ plans did not fall within ERISA’s "church plan" exemption because they were not established by a church. The lower courts agreed with the employees. The Supreme Court reversed. A plan maintained by a principal-purpose organization qualifies as a “church plan,” regardless of who established it. In amending ERISA, Congress deemed the category of plans “established and maintained by a church” to “include” plans “maintained by” principal-purpose organizations. View "Advocate Health Care Network v. Stapleton" on Justia Law

Sherman paid $2.7 million for land in Chester, New York, then sought approval of his development plan. Years later, he filed a regulatory takings suit. Laroe moved to intervene under FRCP 24(a)(2), which requires a court to permit intervention by a litigant that “claims an interest related to the property or transaction that is the subject of the action, and is so situated that disposing of the action may as a practical matter impair or impede the movant’s ability to protect its interest, unless existing parties adequately represent that interest.” Laroe alleged that it had paid Sherman $2.5 million in relation to the project, that its resulting equitable interest would be impaired if it could not intervene, and that Sherman would not adequately represent its interest. A unanimous Supreme Court held that a litigant seeking to intervene as of right under Rule 24(a)(2) must meet Article III standing requirements if the intervenor seeks relief not requested by a plaintiff. To establish Article III standing, a plaintiff seeking compensatory relief must have suffered an injury-in-fact, that is fairly traceable to the defendant's challenged conduct, and that is likely to be redressed by a favorable judicial decision. An intervenor-of-right must demonstrate Article III standing when it seeks relief beyond that requested by the plaintiff. The Second Circuit must address, on remand, whether Laroe seeks different relief than Sherman. If Laroe wants only a money judgment of its own running directly against the town, then it seeks damages different from those sought by Sherman and must establish its own standing to intervene. View "Town of Chester v. Laroe Estates, Inc. " on Justia Law

In the 1970s, federal district courts began ordering disgorgement in Securities and Exchange Commission enforcement proceedings. The Commission may also seek monetary civil penalties; 28 U.S.C. 2462 establishes a five-year limitations period for “an action, suit or proceeding for the enforcement of any civil fine, penalty, or forfeiture.” In 2009, the Commission brought an enforcement action against Kokesh for concealing the misappropriation of $34.9 million from business development companies, seeking monetary civil penalties, disgorgement, and an injunction. A jury found that Kokesh’s actions violated securities laws. The district court determined that section 2462’s limitations period applied to the monetary civil penalties but did not apply to the $34.9 million disgorgement judgment. The Tenth Circuit affirmed. A unanimous Supreme Court reversed. SEC disgorgement operates as a penalty under section 2462. It is imposed by the courts as a consequence for violating public laws, i.e., a violation committed against the United States rather than an aggrieved individual, and is imposed for punitive purposes. SEC disgorgement is often not compensatory. Disgorged profits are paid to the courts, which have discretion to determine how the money will be distributed. When an individual is made to pay a noncompensatory sanction to the government as a consequence of a legal violation, the payment is a penalty. Although disgorgement may sometimes serve compensatory goals, “sanctions frequently serve more than one purpose.” View "Kokesh v. Securities and Exchange Commission" on Justia Law

Terry managed sales and inventory for a Tennessee hardware store owned by his brother, Tony. They were indicted for federal drug crimes including conspiracy to distribute a product used in methamphetamine production. The government sought judgments of $269,751 against each brother, under the Comprehensive Forfeiture Act, which mandates forfeiture of “any property constituting, or derived from, any proceeds the person obtained, directly or indirectly, as the result of” certain drug crimes, 21 U.S.C. 853(a)(1). Tony pleaded guilty and agreed to forfeit $200,000. Terry was convicted. Despite conceding that Terry had no controlling interest in the store and did not stand to benefit personally from sales of the product, the government asked the court to hold him jointly and severally liable for the profits from the illegal sales and sought a judgment of $69,751.98, the outstanding conspiracy profits. The Sixth Circuit agreed that the brothers, as co-conspirators, were jointly and severally liable. The Supreme Court reversed. Forfeiture under section 853(a)(1) is limited to property the defendant himself actually acquired as the result of the crime; the provision does not permit forfeiture with regard to Terry. Use of the adverbs “directly” and “indirectly” to refer to how a defendant obtains the property does not negate the requirement that he “obtain” it. Congress did not incorporate into the section the principle that conspirators are legally responsible for each other’s foreseeable actions in furtherance of their common plan. View "Honeycutt v. United States" on Justia Law

The North Carolina General Assembly redrew state legislative districts in 2011 to account for population changes revealed by the 2010 census. Plaintiffs alleged that 28 majority-black districts in the new plan were unconstitutional racial gerrymanders. The district court ruled for the plaintiffs in August 2016, declined to require changes before the November 2016 election, but ordered the General Assembly to redraw the map. Three weeks after the November 2016 election, the court set a March 2017 deadline for drawing new districts, ordering that “[t]he term of any legislator elected in 2016” from a district later redrawn would be replaced by new ones, to be chosen in court-ordered special elections in fall, 2017, to serve a one-year term. The court suspended provisions of the North Carolina Constitution requiring prospective legislators to reside within a district for one year before they may be elected to represent it. The Supreme Court granted a stay pending appeal and subsequently vacated the remedial order. Relief in redistricting cases is “‘fashioned in the light of well-known principles of equity.’” The district court “addressed the balance of equities in only the most cursory fashion.” In determining whether or when a special election may be a proper remedy for a racial gerrymander, obvious considerations include the severity and nature of the particular constitutional violation, the extent of the likely disruption to the ordinary processes of governance if early elections are imposed, and the need to act with proper judicial restraint when intruding on state sovereignty. View "North Carolina v. Covington" on Justia Law