Justia U.S. Supreme Court Opinion Summaries

Vermont law requires certain entities, including health insurers, to report payments and other information relating to health care claims and services for compilation in a state health care database. Liberty Mutual’s health plan, which provides benefits in all 50 states, is an “employee welfare benefit plan” under the Employee Retirement Income Security Act (ERISA); its third-party administrator, Blue Cross, is subject to the statute. Concerned that the disclosure of confidential information might violate its fiduciary duties, the Plan instructed Blue Cross not to comply and sought a declaration that ERISA preempts application of Vermont’s statute. The Second Circuit reversed summary judgment in favor of the state. The Supreme Court affirmed. ERISA expressly preempts “any and all State laws insofar as they may now or hereafter relate to any employee benefit plan,” 29 U.S.C. 1144(a) and, therefore, preempts a state law that has an impermissible “connection with” ERISA plans. ERISA mandates certain oversight systems and other standard procedures; Vermont’s law also governs plan reporting, disclosure, and recordkeeping. Preemption is necessary to prevent multiple jurisdictions from imposing differing, or even parallel, regulations, creating wasteful administrative costs and threatening to subject plans to wide-ranging liability. ERISA’s uniform rule design makes clear that the Secretary of Labor, not the states, decides whether to exempt plans from ERISA reporting requirements or to require ERISA plans to report data such as sought by Vermont. View "Gobeille v. Liberty Mut. Ins. Co." on Justia Law

Lockhart pleaded guilty to possessing child pornography, 18 U.S.C. 2252(a)(4). Because Lockhart had a prior state-court conviction for first-degree sexual abuse involving his adult girlfriend, his PSR concluded that he was subject to the 10-year mandatory minimum sentence enhancement provided in U.S.S.G. 2252(b)(2), which is triggered by prior state convictions for crimes “relating to aggravated sexual abuse, sexual abuse, or abusive sexual conduct involving a minor or ward.” The Second Circuit and Supreme Court affirmed imposition of the mandatory minimum. The “rule of the last antecedent,” a canon of statutory interpretation stating that “a limiting clause or phrase . . . should ordinarily be read as modifying only the noun or phrase that it immediately follows,” clarifies that the phrase “involving a minor or ward” modifies only the immediately preceding noun phrase “abusive sexual conduct” and that the phrases “aggravated sexual abuse” and “sexual abuse” are not so restricted. The section’s context reinforces the rule’s application in this case. The Court rejected an argument in favor of the rule of lenity, which is used to resolve ambiguity only when the ordinary canons have revealed no satisfactory construction. View "Lockhart v. United States" on Justia Law

The Federal Power Act authorizes the Federal Energy Regulatory Commission (FERC) to regulate “sale of electric energy at wholesale in interstate commerce,” including wholesale electricity rates and any rule or practice “affecting” such rates, 16 U.S.C. 824(b), 824d(a), 824e(a), leaving the states to regulate retail sales. To ensure “just and reasonable” wholesale rates. FERC encourages nonprofit entities to manage regions of the nationwide grid. These entities hold auctions to set wholesale prices, matching bids from generators with orders from utilities and other wholesale buyers. Bids are accepted from lowest to highest until all requests are met. Rates rise dramatically during peak periods and the increased flow of electricity can overload the grid. Wholesalers devised demand response programs, paying consumers for commitments to reduce power use during peak periods. Offers from aggregators of multiple users or large individual consumers can be bid into the wholesale auctions. When it costs less to pay consumers to refrain from use than it does to pay producers to supply more, demand response can lower prices and increase grid reliability. FERC required wholesalers to receive demand response bids from aggregators of electricity consumers, except when the state regulatory authority bars participation. FERC further issued Order 745, requiring market operators to pay the same price for conserving energy as for producing it, so long as accepted bids actually save consumers money. The D.C. Circuit vacated the Rule as exceeding FERC’s authority. The Supreme Court reversed. FERC has authority to regulate wholesale market operators’ compensation of demand response bids. The practice directly affects wholesale rates; FERC has not regulated retail sales. Wholesale demand response is all about reducing wholesale rates as are the rules and practices that determine how those programs operate. Transactions occurring on the wholesale market unavoidably have natural consequences at the retail level. View "Fed. Energy Regulatory Comm'n v. Elec. Power Supply Ass'n" on Justia Law

The Menominee Tribe of Wisconsin contracted with the Indian Health Service (IHS) to operate what would otherwise have been a federal program, pursuant to the Indian Self-Determination and Education Assistance Act (ISDA), 25 U.S.C. 450f, 450j–1(a). After other tribes successfully litigated complaints against the government for failing to honor its obligation to pay contract support costs, the Menominee Tribe presented its own claims to the IHS under the Contract Disputes Act. The contracting officer denied some claims as not presented within the CDA’s 6-year limitations period. The Tribe argued that the limitations period should be tolled for the two years in which a putative class action, brought by tribes with parallel complaints, was pending. The district court denied the equitable-tolling claim. The Court of Appeals and Supreme Court affirmed, holding that no extraordinary circumstances caused the delay. To be entitled to equitable tolling of a statute of limitations, a litigant must establish both that he has been pursuing his rights diligently and that some extraordinary circumstances prevented timely filing. The Court rejected the Tribe’s argument that diligence and extraordinary circumstances should be considered together as factors in a unitary test. The “extraordinary circumstances” prong is met only where the circumstances that caused the delay are both extraordinary and beyond the litigant’s control. The Tribe had unilateral authority to present its claims in a timely manner. Any significant risk and expense associated with litigating its claims were far from extraordinary. View "Menominee Tribe of Wis. v. United States" on Justia Law

Montgomery was 17 years old in 1963, when he killed a deputy in Louisiana. The jury returned a verdict of “guilty without capital punishment,” which carried an automatic sentence of life without parole. Nearly 50 years later, the Supreme Court decided, in Miller v. Alabama, that mandatory life without parole for juvenile offenders violates the Eighth Amendment’s prohibition on cruel and unusual punishments. The trial court denied his motion for relief. His application for a supervisory writ was denied by the Louisiana Supreme Court, which had previously held that Miller does not have retroactive effect in state collateral review. The Supreme Court reversed. Courts must give retroactive effect to new watershed procedural rules and to substantive rules of constitutional law. Substantive constitutional rules include “rules forbidding criminal punishment of certain primary conduct” and “rules prohibiting a certain category of punishment for a class of defendants because of their status or offense.” Miller announced a substantive rule of constitutional law, which is retroactive because it necessarily carries a significant risk that a defendant faces a punishment that the law cannot impose. A state may remedy a Miller violation by extending parole eligibility to juvenile offenders. This would neither impose an onerous burden nor disturb the finality of state convictions and would afford someone like Montgomery, who may have evolved from a troubled, misguided youth to a model member of the prison community, the opportunity to demonstrate the truth of Miller’s central intuition—that children who commit even heinous crimes are capable of change. View "Montgomery v. Louisiana" on Justia Law

The stockholders, former employees, who participated in employee stock option plans qualified under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1107(d)(3)(A), sued fiduciaries for breach of the duty of prudence. The plan held the employer’s stock, which dropped in value. On remand from the Supreme Court in 2014, the Ninth Circuit held that the complaint stated a claim. The Supreme Court again reversed and remanded. The Court has previously held that such ERISA fiduciaries are not entitled to a presumption of prudence but are “subject to the same duty of prudence that applies to ERISA fiduciaries in general, except that they need not diversify the fund’s assets,” and that Congress sought to encourage the creation of employee stock-ownership plans. Such fiduciaries confront unique challenges given “the potential for conflict.” To state a claim for breach of the duty of prudence on the basis of inside information, a plaintiff must plausibly allege an alternative action that the defendant could have taken that would have been consistent with the securities laws and that a prudent fiduciary in the same circumstances would not have viewed as more likely to harm the fund. Courts must consider whether the fiduciary might have concluded that stopping purchases or publicly disclosing negative information would do more harm than good by causing a drop in the stock price and a concomitant drop in the value of the stock held by the fund. The Ninth Circuit failed to assess whether the complaint plausibly alleged that a prudent fiduciary in the same position “could not have concluded” that the alternative action “would do more harm than good.” View "Amgen Inc. v. Harris" on Justia Law

Under federal law, a court has discretion to “allow the prevailing party, other than the United States, a reasonable attorney’s fee” in a civil rights lawsuit filed under 42 U.S.C. 1983 or 42 U.S.C. 1988. The Supreme Court has interpreted section 1988 to permit a prevailing defendant to recover fees only if “the plaintiff ’s action was frivolous, unreasonable, or without foundation.” The Idaho Supreme Court concluded that it was not bound by that interpretation and awarded attorney’s fees under section 1988 to a prevailing defendant without first determining that “the plaintiff ’s action was frivolous, unreasonable, or without foundation.” The fee award rested solely on that court's interpretation of federal law; the court explicitly refused to award fees under state law. The Supreme Court reversed. Section 1988 is a federal statute; once the Supreme Court has spoken, it is the duty of other courts to respect that understanding of the governing rule of law. If state courts were permitted to disregard the Court’s rulings on federal law, “the laws, the treaties, and the constitution of the United States would be different in different states, and might, perhaps, never have precisely the same construction, obligation, or efficacy, in any two states." View "James v. Boise" on Justia Law

Musacchio resigned as president of ETS in 2004, but with help from the former head of ETS’s information-technology department, he accessed ETS’s computer system without authorization through early 2006. In 2010, Musacchio was indicted under 18 U.S.C. 1030(a)(2)(C), which makes it a crime if a person “intentionally accesses a computer without authorization or exceeds authorized access” and thereby “obtains . . . information from any protected computer.” A 2012 superseding indictment changed the access date to “[o]n or about” November 23–25, 2005. Musacchio never raised the 5-year statute of limitations. The government did not object to jury instructions referring to: “intentionally access a computer without authorization and exceed authorized access” although the conjunction “and” added an additional element. The jury found Musacchio guilty. In affirming his conviction, the Fifth Circuit assessed Musacchio’s sufficiency challenge against the charged elements of the conspiracy count rather than against the heightened jury instruction, and concluded that he had waived his statute-of-limitations defense. The Supreme Court affirmed. A sufficiency challenge should be assessed against the elements of the charged crime, not against the elements set forth in an erroneous jury instruction. Sufficiency review essentially addresses whether the case was strong enough to reach the jury. Musacchio did not dispute that he was properly charged with conspiracy to obtain unauthorized access or that the evidence was sufficient to convict him of the charged crime. A defendant cannot successfully raise section 3282(a)’s statute-of-limitations bar for the first time on appeal. The history of section 3282(a)’s limitations bar confirms that the provision does not impose a jurisdictional limit. View "Musacchio v. United States" on Justia Law

A Kansas jury sentenced Gleason to death for killings to cover up a robbery. Another Kansas jury sentenced the Carr brothers to death after they were convicted of rape, kidnapping, and five execution-style shootings. The Kansas Supreme Court vacated the death sentences, holding that the sentencing instructions violated the Eighth Amendment and that the Carrs’ rights to individualized capital sentencing determinations was violated. The Supreme Court reversed. The Eighth Amendment and Supreme Court precedent do not require capital-sentencing courts to instruct a jury that mitigating circumstances need not be proved beyond a reasonable doubt. Ambiguity in capital-sentencing instructions constitutes constitutional error only if there is a reasonable likelihood that the jury applied the challenged instruction in a way that prevented consideration of constitutionally relevant evidence. The instructions at issue clarified that both the existence of aggravating circumstances and the conclusion that they outweigh mitigating circumstances must be proved beyond a reasonable doubt but that mitigating circumstances must merely be “found to exist.” No juror would reasonably speculate that “beyond a reasonable doubt” was the correct burden for mitigating circumstances. The Constitution did not require severance of the Carrs’ joint sentencing proceedings. Claiming that admission of mitigating evidence by one Carr brother could have “so infected” jury consideration of the other’s sentence as to amount to a due process denial was “beyond the pale.” Joint proceedings are often preferable when the joined defendants’ criminal conduct arises out of a single chain of events. Limiting instructions, like those given in the Carrs’ proceeding, often suffice to cure any risk of prejudice. View "Kansas v. Carr" on Justia Law

Employee benefits plans regulated by the Employee Retirement Income Security Act (ERISA) often contain subrogation clauses requiring participants to reimburse the plan for medical expenses if they later recover money from a third party. Montanile was seriously injured by a drunk driver. His ERISA plan paid more than $120,000 for his medical expenses. Montanile sued the drunk driver, obtaining a $500,000 settlement. The plan administrator sought reimbursement from the settlement. Montanile’s attorney refused and indicated that the funds would be transferred from a trust account to Montanile unless the administrator objected. The administrator did not respond. Montanile received the settlement. Six months later, the administrator sued under ERISA 502(a)(3), which authorizes plan fiduciaries to file suit “to obtain . . . appropriate equitable relief . . . to enforce . . . the plan.” 29 U.S.C. 1132(a)(3). The district court rejected Montanile’s arguments, The Eleventh Circuit affirmed, holding that even if Montanile had completely dissipated the fund, the plan was entitled to reimbursement from Montanile’s general assets. The Supreme Court reversed and remanded for determination of whether Montanile had dissipated the settlement. When an ERISA-plan participant wholly dissipates a third-party settlement on nontraceable items, the plan fiduciary may not bring suit under section 502(a)(3) to attach the participant’s separate assets. Historical equity practice does not support enforcement of an equitable lien against general assets. View "Montanile v. Bd. of Trs. of Nat'l Elevator Indus. Health Benefit Plan" on Justia Law