Justia U.S. Supreme Court Opinion Summaries

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

Petitioner, a Mexican citizen and lawful permanent resident of the U.S., pleaded no contest in a California court under a statute criminalizing “unlawful sexual intercourse with a minor who is more than three years younger than the perpetrator,” defining “minor” as “a person under the age of 18.” He was ordered removed under 8 U.S.C. 1227(a)(2)(A)(3), as an “alien who is convicted of an aggravated felony,” including “sexual abuse of a minor.” The Supreme Court reversed. Under the categorical approach employed to determine whether an alien’s conviction qualifies as an aggravated felony, the court asks whether the state statute defining the crime of conviction categorically fits within the "generic" federal definition of a corresponding aggravated felony. Petitioner’s state conviction would be an “aggravated felony” only if the least of the acts criminalized by the state statute falls within the generic federal definition of sexual abuse of a minor, regardless of the actual facts of the case. The least of the acts criminalized by the California law would be consensual sexual intercourse between a victim who is almost 18 and a perpetrator who just turned 21. The generic federal definition of “sexual abuse of a minor” requires that the victim be younger than 16 and a significant majority of state criminal codes set the age of consent at 16 for statutory rape offenses predicated exclusively on the age of the participants. View "Esquivel-Quintana v. Sessions" on Justia Law

Based on alleged work-related injuries, Nelson, a North Dakota resident, and Tyrrell, the administrator of a South Dakota estate, brought Federal Employers’ Liability Act, 45 U.S.C. 51, suits against BNSF Railroad. Neither injury occurred in Montana. Neither incorporated nor headquartered there, BNSF maintains less than five percent of its workforce and about six percent of its total track mileage in Montana. The Montana Supreme Court held that Montana courts could exercise general personal jurisdiction over BNSF because the railroad “d[id] business” in the state within the meaning of 45 U.S.C. 56. The U.S. Supreme Court reversed. Section 56 does not address personal jurisdiction over railroads but is only a venue prescription. The Montana courts’ exercise of personal jurisdiction did not comport with the Due Process Clause. Only the propriety of general personal jurisdiction was at issue because neither plaintiff alleged injury from work in or related to Montana. A state court may exercise general jurisdiction over out-of-state corporations when their “affiliations with the State are so ‘continuous and systematic’ as to render them essentially at home in the forum State.” The “paradigm” forums in which a corporate defendant is “at home” are its place of incorporation and its principal place of business. In an “exceptional case,” a corporate defendant’s operations in another forum “may be so substantial and of such a nature as to render the corporation at home in that State,” but that constraint does not vary with the type of claim asserted or business enterprise sued. View "BNSF Railroad Co. v. Tyrrell" on Justia Law

The Los Angeles County Sheriff’s Department had information that a potentially armed and dangerous parolee-at-large had been seen at a certain residence. While others searched the main house, deputies searched the property. Unbeknownst to the deputies, Mendez and Garcia were napping inside a shack where they lived. Without a search warrant and without announcing their presence, the deputies opened the shack's door. Mendez rose from the bed, holding a BB gun that he used to kill pests. The deputies shot the men multiple times. In a suit under 42 U.S.C. 1983, the court awarded nominal damages on warrantless entry and knock-and-announce claims. The court found the use of force reasonable, but cited a Ninth Circuit rule, which makes an otherwise reasonable use of force unreasonable if the officer “intentionally or recklessly provokes a violent confrontation” and “the provocation is an independent Fourth Amendment violation. The Ninth Circuit held that the officers were entitled to qualified immunity on the knock-and-announce claim; that the warrantless entry violated clearly established law; and that the provocation rule applied. The Supreme Court vacated. There is a settled, exclusive framework for analyzing whether the force used in making a seizure complies with the Fourth Amendment: “whether the totality of the circumstances justifie[s] a particular sort of search or seizure.” The provocation rule instructs courts to look back to see if a different Fourth Amendment violation was somehow tied to the eventual use of force, mistakenly and unnecessarily conflating distinct Fourth Amendment claims that should be analyzed separately. If plaintiffs cannot recover on their excessive force claim, that will not foreclose recovery for injuries proximately caused by the warrantless entry. View "County of Los Angeles v. Mendez" on Justia Law

Lexmark holds patents on the components of toner cartridges that it manufactures and sells. Lexmark allows consumers to buy a cartridge at full price, with no restrictions, or to buy a cartridge at a discount through Lexmark’s “Return Program,” by signing a contract agreeing to use the cartridge only once and to refrain from transferring the cartridge to anyone but Lexmark. Remanufacturers acquire empty Lexmark cartridges—including Return Program cartridges—from purchasers in the U.S. and overseas, refill them, and resell them in the U.S. Lexmark sued remanufacturers with respect to Return Program cartridges that Lexmark had sold within the U.S. and cartridges that Lexmark had sold abroad and that remanufacturers imported into the country. The Federal Circuit ruled for Lexmark with respect to both. The Supreme Court reversed. Lexmark exhausted its patent rights (35 U.S.C. 271(a)) in all of the cartridges. A patentee’s decision to sell a product exhausts all of its patent rights in that item, regardless of any restrictions the patentee purports to impose. If a patentee negotiates a contract restricting the purchaser’s right to use or resell an item, it may be able to enforce that restriction as a matter of contract law, but may not do so through a patent infringement lawsuit. The exhaustion doctrine is not a presumption about the authority that comes along with a sale; it is a limit on the scope of the patentee’s rights. The Patent Act just ensures that the patentee receives one reward—of whatever it considers satisfactory compensation—for every item that passes outside the scope of its patent monopoly. View "Impression Products, Inc. v. Lexmark International, Inc." on Justia Law

The patent venue statute, 28 U.S.C. 1400(b), provides that “[a]ny civil action for patent infringement may be brought in the judicial district where the defendant resides, or where the defendant has committed acts of infringement and has a regular and established place of business.” In its 1957 “Fourco” decision, the Supreme Court concluded that for purposes of section 1400(b) a domestic corporation “resides” only in its state of incorporation, rejecting the argument that section 1400(b) incorporates the broader definition of corporate “residence” contained in the general venue statute, 28 U.S.C. 1391(c). Congress has not amended section 1400(b) since Fourco. Kraft filed a patent infringement suit in the District of Delaware against TC, a competitor, organized under Indiana law and headquartered in Indiana. TC ships the allegedly infringing products into Delaware. Reversing the district court and Federal Circuit, the Supreme Court held that, ss applied to domestic corporations, “reside[nce]” in section 1400(b) refers only to the state of incorporation. Section 1400(b) was enacted as a "stand alone" statute. Amendments to section 1391 did not modify the meaning of 1400(b) as interpreted by Fourco. View "TC Heartland LLC v. Kraft Foods Group Brands LLC" on Justia Law

Water Splash sued Menon, a former employee, in Texas state court. Because Menon resided in Canada, Water Splash obtained permission to effect service by mail. Menon declined to answer or enter an appearance. The trial court issued a default judgment. Menon argued that service by mail was impermissible under the Convention on the Service Abroad of Judicial and Extrajudicial Documents in Civil and Commercial Matters (Hague Service Convention). Vacating a Texas Court of Appeals decision in Menon’s favor, the Supreme Court held that the Convention does not prohibit service of process by mail. Article 10(a) uses the term “judicial documents” and the ordinary meaning of the word “send” is broad enough to cover the transmission of any judicial documents. The Convention’s drafting history strongly suggests that the drafters understood that service by postal channels was permissible; in the half-century since the Convention was adopted, the Executive Branch has consistently maintained that it allows service by mail. Other Convention signatories have consistently adopted that view. That Article 10(a) encompasses service by mail does not mean that it affirmatively authorizes such service; service by mail is permissible if the receiving state has not objected to service by mail and if such service is authorized under other applicable laws. View "Water Splash, Inc. v. Menon" on Justia Law

North Carolina redrew Congressional Districts 1 and 12 after the 2010 census. Previously, neither district had a majority black voting-age population (BVAP), but both consistently elected candidates preferred by most African-American voters. The state needed to add 100,000 people to District 1 to comply with the one-person-one-vote principle; it took most of them from heavily black areas of Durham—increasing the district’s BVAP from 48.6% to 52.7%. District 12’s BVAP increased from 43.8% to 50.7%. State courts upheld the redistricting. The district court found it unconstitutional. The Supreme Court affirmed. Although the state court’s decision is relevant, the district court properly concluded that race furnished the predominant rationale for District 1’s redesign and that compliance with the Voting Rights Act could not justify that consideration of race, which subordinated other criteria. The redistricting cannot withstand strict scrutiny under the “Gingles” factors. For nearly 20 years, African-Americans made up less than a majority of District 1’s voters, but their preferred candidates scored victories. District 1 was a “crossover” district, in which members of the majority help a “large enough” minority to elect its candidate. History gave the state no reason to think that the Act required it to ramp up District 1’s BVAP. The evidence, even without an alternative map, adequately supported the conclusion that race, not politics, accounted for District 12’s reconfiguration. “By slimming the district and adding a couple of knobs to its snakelike body, North Carolina added 35,000 African-Americans and subtracted 50,000 whites, turning District 12 into a majority-minority district,” indicating a determination to concentrate black voters. View "Cooper v. Harris" on Justia Law

Filing a bankruptcy proof of claim that is obviously time-barred is not a false, deceptive, misleading, unfair, or unconscionable practice under the Fair Debt Collection Practices Act (FDCPA).Midland filed a proof of claim in Johnson’s Chapter 13 bankruptcy case, asserting a credit-card debt and noting that the last time any charge appeared on Johnson’s account was more than 10 years ago. The Alabama limitations period is six years. The Bankruptcy Court disallowed the claim. Johnson filed suit under the FDCPA, 15 U.S.C. 1692. The Supreme Court reversed the Eleventh Circuit. The Bankruptcy Code defines “claim” as a “right to payment,” 11 U.S.C. 101(5)(A); state law usually determines whether a person has such a right. Alabama law provides that a creditor has the right to payment of a debt even after the limitations period has expired. The word “enforceable” does not appear in the Code’s definition. The law treats unenforceability of a claim due to the expiration of the limitations period as an affirmative defense. There is nothing misleading or deceptive in filing a proof of claim that follows the Code’s similar system. Concerns that a consumer might unwittingly repay a time-barred debt have diminished force in a Chapter 13 bankruptcy, where: the consumer initiates the proceeding; a knowledgeable trustee is available; procedural rules guide evaluation of claims; and the claims resolution process is “less unnerving” than facing a collection lawsuit. View "Midland Funding, LLC v. Johnson" on Justia Law

Kentucky ruling that authority to bind a principal to arbitration must be explicitly stated in power of attorney violated the Federal Arbitration Act.When the patients moved into Kindred’s nursing home, their relatives used powers of attorney to complete necessary paperwork, including an agreement that any claims arising from the patient’s stay at Kindred would be resolved through binding arbitration. After the patients died, their estates filed suits alleging that Kindred’s substandard care had caused their deaths. The trial court denied Kindred’s motions to dismiss. The Kentucky Supreme Court affirmed, finding the arbitration agreements invalid because neither power of attorney specifically entitled the representative to enter into an arbitration agreement. Because the Kentucky Constitution declares the rights of access to the courts and trial by jury to be “sacred,” the court reasoned, an agent could deprive her principal of such rights only if expressly provided in the power of attorney. The U.S. Supreme Court reversed. The Kentucky Supreme Court’s clear-statement rule violates the Federal Arbitration Act, 9 U.S.C. 2, by singling out arbitration agreements for disfavored treatment. The Act preempts any state rule that discriminates on its face against arbitration or that covertly accomplishes the same objective by disfavoring contracts that have the defining features of arbitration agreements. The FAA is concerned with both the enforcement and initial validity of arbitration agreements. View "Kindred Nursing Centers, L. P. v. Clark" on Justia Law