Justia U.S. Supreme Court Opinion Summaries

Businesses challenged New York General Business Law section 518, which provides that “[n]o seller in any sales transaction may impose a surcharge on a holder who elects to use a credit card in lieu of payment by cash, check, or similar means,” as violating the First Amendment by regulating how they communicate their prices, and as unconstitutionally vague. The Second Circuit vacated a judgment in favor of the businesses, reasoning that in the context of singlesticker pricing—where merchants post one price and would like to charge more to customers who pay by credit card—the law required that the sticker price be the same as the price charged to credit card users. In that context, the law regulated a relationship between two prices: conduct, not speech. The Supreme Court vacated, limiting its review to single-sticker pricing. Section 518 regulates speech. It is not a typical price regulation, which simply regulates the amount a store can collect. The law tells merchants nothing about the amount they may collect from a cash or credit card payer, but regulates how sellers may communicate their prices. Section 518 is not vague as applied to the businesses; it bans the single-sticker pricing they wish to employ, and “a plaintiff whose speech is clearly proscribed cannot raise a successful vagueness claim.” View "Expressions Hair Design v. Schneiderman" on Justia Law

Moore was convicted of capital murder and sentenced to death for shooting a clerk during a robbery that occurred when Moore was 20 years old. A state habeas court determined that, under Supreme Court precedent, Moore was intellectually disabled and that his death sentence violated the Eighth Amendment. The court consulted the 11th edition of the American Association on Intellectual and Developmental Disabilities clinical manual (AAIDD–11) and the 5th edition of the Diagnostic and Statistical Manual of Mental Disorders and followed the generally accepted intellectual-disability definition, considering: intellectual-functioning deficits, adaptive deficits, and the onset of these deficits while a minor. The court credited six IQ scores, the average of which (70.66) indicated mild intellectual disability. Based on testimony from mental-health professionals, the court found significant adaptive deficits in all three skill sets (conceptual, social, and practical). The Texas Court of Criminal Appeals (CCA) declined the recommendation, concluding that the habeas court should have used standards for assessing intellectual disability contained in AAMR–9 and its requirement that adaptive deficits be “related” to intellectual-functioning deficits. The Supreme Court vacated. While precedent leaves to the states “the task of developing appropriate ways to enforce” the restriction on executing the intellectually disabled, that discretion is not “unfettered,” and must be “informed by the medical community’s diagnostic framework.” When an IQ score is close to, but above, 70, courts must account for the “standard error of measurement.” The CCA overemphasized Moore’s perceived adaptive strengths—living on the streets, mowing lawns, and playing pool for money—when the medical community focuses on adaptive deficits. The CCA stressed Moore’s improved behavior in prison; clinicians caution against reliance on adaptive strengths developed in controlled settings. The CCA concluded that Moore’s record of academic failure, with a history of childhood abuse and suffering, detracted from a determination that his intellectual and adaptive deficits were related; the medical community counts traumatic experiences as risk factors for intellectual disability. The CCA also departed from clinical practice by requiring Moore to show that his adaptive deficits were not related to “a personality disorder.” View "Moore v. Texas" on Justia Law

The “pictorial, graphic, or sculptural features” of a “design of a useful article” are eligible for copyright protection as artistic works if those features “can be identified separately from, and are capable of existing independently of, the utilitarian aspects of the article,” 17 U.S.C. 101. Plaintiffs have copyright registrations for two-dimensional designs, consisting of lines, chevrons, and colorful shapes, appearing on cheerleading uniforms that they design, make, and sell. They sued a competitor for infringement. The district court rejected the claims on summary judgment. The Sixth Circuit reversed. The Supreme Court affirmed. A feature incorporated into the design of a useful article is eligible for copyright protection only if the feature can be perceived as a two- or three-dimensional work of art separate from the useful article and would qualify as a protectable pictorial, graphic, or sculptural work—either on its own or fixed in some other tangible medium of expression—if it were imagined separately from the useful article into which it is incorporated. That test is satisfied here. The feature cannot be a useful article or “[a]n article that is normally a part of a useful article,” nor the replica of a useful article in another medium. While plaintiffs have no right to prevent anyone from manufacturing a cheerleading uniform that is identical in shape, cut, or dimensions to the uniforms at issue here, an artistic feature that is eligible for copyright protection on its own does not lose that protection simply because it was first created as a feature of the design of a useful article, even if it makes that article more useful. View "Star Athletica, L. L. C. v. Varsity Brands, Inc." on Justia Law

The Individuals with Disabilities Education Act (IDEA) offers states federal funds to provide every eligible child a “free appropriate public education” (FAPE), by means of an “individualized education program” (IEP). 20 U.S.C. 1401(9)(D), 1412(a)(1), “reasonably calculated to enable the child to receive educational benefits.” For children fully integrated in the regular classroom, this typically requires an IEP “reasonably calculated to enable the child to achieve passing marks and advance from grade to grade.” Endrew, who has autism, received annual IEPs. By fourth grade, Endrew’s parents believed his academic and functional progress had stalled and enrolled him in a specialized private school, where he made significant progress. School district representatives later presented a new fifth grade IEP, but the parents considered it no better than the original plan. They sought reimbursement for tuition. The Colorado Department of Education denied the claim. The district court and Tenth Circuit affirmed. The Supreme Court vacated. A school must offer an IEP reasonably calculated to enable a child to make progress appropriate in light of the child’s circumstances. Focus on the particular child is the core of the IDEA. Precedent does not provide concrete guidance concerning a child who is not fully integrated in the regular classroom and not able to achieve on grade level. A child’s IEP need not aim for grade-level advancement if that is not a reasonable prospect, but every child should have the chance to meet challenging objectives. This standard is more demanding than the “merely more than de minimis” test applied by the Tenth Circuit. The Court declined to hold that the Act requires states to provide educational opportunities that are “substantially equal to the opportunities afforded children without disabilities.” The adequacy of an IEP turns on the unique circumstances of the child for whom it was created. View "Endrew F. v. Douglas County School District RE–1" on Justia Law

Jevic filed for Chapter 11 bankruptcy after its purchase in a leveraged buyout. Former Jevic drivers were awarded a judgment for violations of state and federal Worker Adjustment and Retraining Notification (WARN) Acts, part of which was a priority wage claim under 11 U.S.C. 507(a)(4), entitling them to payment ahead of general unsecured claims. In another suit, a court-authorized committee representing unsecured creditors sued Sun Capital and CIT for fraudulent conveyance in the buyout; the parties negotiated a structured dismissal of Jevic’s bankruptcy, under which the drivers would receive nothing on their WARN claims, but lower-priority general unsecured creditors would be paid. The Bankruptcy Court reasoned that the proposed payouts would occur under a structured dismissal rather than an approved plan, so failure to follow ordinary priority rules did not bar approval. The district court and Third Circuit affirmed. The Supreme Court reversed. The drivers have standing, having “suffered an injury in fact,” or “likely to be redressed by a favorable judicial decision.” A settlement that respects ordinary priorities remains a reasonable possibility and the fraudulent-conveyance claim could have litigation value. Bankruptcy courts may not approve structured dismissals that provide for distributions that do not follow ordinary priority rules without the consent of affected creditors. Section 349(b), which permits a bankruptcy judge, “for cause, [to] orde[r] otherwise,” gives courts flexibility to protect reliance interests, not to make general end-of-case distributions that would be impermissible in a Chapter 11 plan or Chapter 7 liquidation. Here, the priority-violating distribution is attached to a final disposition and does not preserve the debtor as a going concern, nor make the disfavored creditors better off, promote the possibility of a confirmable plan, help to restore the status quo ante, or protect reliance interests. There is no “rare case” exception, permitting courts to disregard priority in structured dismissals for “sufficient reasons.” View "Czyzewski v. Jevic Holding Corp. " on Justia Law

In 2003, SCA notified First Quality that its adult incontinence products infringed an SCA patent. First Quality responded that its patent antedated SCA’s patent and made it invalid. In 2004, SCA sought reexamination of its patent. In 2007, the Patent and Trademark Office confirmed the SCA patent’s validity. SCA sued for patent infringement in 2010. The district court granted First Quality summary judgment, citing equitable estoppel and laches. While SCA’s appeal was pending, the Supreme Court held that laches could not preclude a claim for damages incurred within the Copyright Act’s 3-year limitations period. The Federal Circuit nevertheless affirmed, based on Circuit precedent, which permitted laches to be asserted against a claim incurred within the Patent Act’s 6-year limitations period, 35 U.S.C. 286. The Supreme Court vacated. Laches cannot be invoked as a defense against a claim for damages brought within the limitations period. A statute of limitations reflects a congressional decision that timeliness is better judged by a hard and fast rule instead of a case-specific judicial determination. Applying laches within a statutory limitations period would give judges a “legislation-overriding” role that exceeds the Judiciary’s power and would clash with the gap-filling purpose for which the laches defense developed in the equity courts. View "SCA Hygiene Products Aktiebolag v. First Quality Baby Products, LLC" on Justia Law

The Constitution requires that the President obtain “the Advice and Consent of the Senate” before appointing “Officers of the United States” (PAS officers). The Federal Vacancies Reform Act of 1998 (FVRA), section 3345(a), provides in paragraph (1), that generally, if a PAS vacancy arises, the first assistant to that office “shall perform” the office’s “functions and duties temporarily in an acting capacity,” but “notwithstanding paragraph (1),” the President “may direct” a person already serving in another PAS office, or a senior employee in the agency, to serve in an acting capacity. Subsection (b)(1) states: “Notwithstanding subsection (a)(1), a person may not serve as an acting officer” if the President nominates him for the vacant PAS office and, during the 365-day period preceding the vacancy, the person “did not serve in the position of first assistant” or “served . . . for less than 90 days.” The National Labor Relations Board's general counsel is a PAS office. In June 2010, a vacancy arose in that office. The President directed Solomon to serve as acting general counsel. Solomon qualified under subsection (a)(3) as an NLRB senior employee. In January 2011, the President nominated Solomon to serve as permanent general counsel. The Senate never took action on the nomination. Meanwhile, an NLRB Regional Director, acting on Solomon’s behalf, issued a complaint against SW. An ALJ and the Board concluded that SW had committed unfair labor practices. SW argued that the complaint was invalid because, under subsection (b)(1), Solomon could not act as general counsel after being nominated to that position. The NLRB countered that subsection (b)(1) applies only to first assistants acting under subsection (a)(1), not to officers who serve under (a)(2) or (a)(3). The DC Circuit vacated the Board’s order. The Supreme Court affirmed. Subsection (b)(1) prevents a person who has been nominated to fill a vacant PAS office from performing the duties of that office in an acting capacity and is not limited to first assistants acting under subsection (a)(1). View "National Labor Relations Board v. SW General, Inc" on Justia Law

During a traffic stop, officers searched Manuel and found a vitamin bottle containing pills. Suspecting the pills were illegal drugs, officers conducted a field test, which came back negative for any controlled substance. They arrested Manuel. At the police station, an evidence technician tested the pills and got a negative result, but claimed that one pill tested “positive for the probable presence of ecstasy.” An arresting officer reported that, based on his “training and experience,” he “knew the pills to be ecstasy.” Another officer charged Manuel with unlawful possession of a controlled substance. Relying exclusively on that complaint, a judge found probable cause to detain Manuel pending trial. The Illinois police laboratory tested the pills and reported that they contained no controlled substances. Manuel spent 48 days in pretrial detention. More than two years after his arrest, but less than two years after his case was dismissed, Manuel filed a 42 U.S.C. 1983 lawsuit against Joliet and the officers. The district court dismissed, holding that the two-year statute of limitations barred his unlawful arrest claim and that pretrial detention following the start of legal process could not give rise to a Fourth Amendment claim. The Seventh Circuit affirmed. The Supreme Court reversed. Pretrial detention can violate the Fourth Amendment when it precedes or when it follows, the start of the legal process. The Fourth Amendment prohibits government officials from detaining a person absent probable cause. Where legal process has begun but has done nothing to satisfy the probable-cause requirement, it cannot extinguish a detainee’s Fourth Amendment claim. Because the judge’s determination of probable cause was based solely on fabricated evidence, it did not expunge Manuel’s Fourth Amendment claim. On remand, the Seventh Circuit should determine the claim’s accrual date, unless it finds that the city waived its timeliness argument. View "Manuel v. Joliet" on Justia Law

A Colorado jury convicted Peña-Rodriguez of harassment and unlawful sexual contact. Following the jury’s discharge, two jurors told defense counsel that, during deliberations, Juror H.C. had expressed anti-Hispanic bias toward Peña-Rodriguez and his alibi witness. Counsel, with court supervision, obtained affidavits from the two jurors describing H.C.'s biased statements. The court acknowledged H.C.’s apparent bias but denied a motion for a new trial, stating that Colorado Rule of Evidence 606(b) generally prohibits a juror from testifying as to statements made during deliberations during an inquiry into the validity of the verdict. The Colorado Supreme Court affirmed, citing Supreme Court precedent rejecting constitutional challenges to the federal no-impeachment. The Supreme Court reversed. Where a juror makes a clear statement indicating that he relied on racial stereotypes or animus to convict a defendant, the Sixth Amendment requires that the no-impeachment rule give way. The Court noted that it has previously indicated that the rule may have exceptions for “juror bias so extreme that, almost by definition, the jury trial right has been abridged” and that racial bias, unlike the behavior in previous cases, implicates unique historical, constitutional, and institutional concerns that, unaddressed, threaten systemic injury to the administration of justice. Before the no-impeachment bar can be set aside, there must be a threshold showing that a juror made statements exhibiting overt racial bias that cast serious doubt on the fairness and impartiality of deliberations and verdict. The statement must tend to show that racial animus was a significant motivating factor in the juror’s vote to convict. The Court did not address what procedures a court must follow when deciding a motion for a new trial based on juror testimony of racial bias or the appropriate standard for determining when such evidence is sufficient to require that the verdict be set aside. View "Pena-Rodriguez v. Colorado" on Justia Law

Beckles was convicted of possession of a firearm by a convicted felon, 18 U.S.C. 922(g)(1). The court imposed a “career offender” sentencing enhancement under U.S.S.G. 4B1.1(a), finding that his offense qualified as a “crime of violence” under the residual clause. The Eleventh Circuit affirmed his sentence and the denial of post-conviction relief. In the meantime, the Supreme Court held (Johnson v. United States) that the identically worded residual clause in the Armed Career Criminal Act (ACCA), section 924(e)(2)(b), was unconstitutionally vague. The Eleventh Circuit affirmed again. The Supreme Court affirmed. The Sentencing Guidelines, including section 4B1.2(a)’s residual clause, are not subject to vagueness challenges under the Due Process Clause. Johnson held that the ACCA’s residual clause fixed, in an impermissibly vague way, a higher range of sentences for certain defendants; the advisory Guidelines do not fix the permissible range of sentences. They merely guide the exercise of a court’s discretion in choosing an appropriate sentence within the statutory range. Congress has long permitted a “wide discretion to decide whether the offender should be incarcerated and for how long.” The Guidelines have been rendered “effectively advisory” by the Supreme Court. The Guidelines do not implicate the concerns underlying vagueness doctrine: providing notice and preventing arbitrary enforcement. The statutory range, which establishes the permissible bounds of the court’s sentencing discretion, provides the required notice. The Guidelines do not invite arbitrary enforcement because they do not permit a court to prohibit behavior or to prescribe the sentencing ranges available. View "Beckles v. United States" on Justia Law