Justia U.S. Supreme Court Opinion Summaries

Mellouli, a lawful permanent resident, pleaded guilty to a misdemeanor offense under Kansas law, the possession of drug paraphernalia “to . . . store [or] conceal . . . a controlled substance,” consisting of a sock in which he had placed four unidentified orange tablets. An Immigration Judge ordered him deported under 8 U.S.C. 1227(a)(2)(B)(i), which authorizes the deportation of an alien “convicted of a violation of . . . any law or regulation of a State, the United States, or a foreign country relating to a controlled substance (defined in section 802 of Title 21).” Section 802 limits “controlled substance” to a “drug or other substance” included in federal schedules. Kansas defines “controlled substance” according to its own schedules, without reference to Section 802, and included substances not on the federal lists. The Board of Immigration Appeals affirmed. The Eighth Circuit denied a petition for review. The Supreme Court reversed. Mellouli’s Kansas conviction for concealing unnamed pills in his sock did not trigger removal. Under the categorical approach, a state conviction triggers removal only if, by definition, the underlying crime falls within a category of removable offenses defined by federal law. The BIA’s reasoning, that there is no need to show that the type of controlled substance involved in a paraphernalia conviction is one defined in section 802, leads to the anomalous result of treating less grave paraphernalia possession misdemeanors more harshly than drug possession and distribution offenses. The Court rejected the government’s argument that aliens who commit any drug crime in states whose drug schedules substantially overlap the federal schedules are deportable, because the state statutes are laws “relating to” federally controlled substances. To trigger removal under 1227(a)(2)(B)(i), the government must connect an element of the alien’s conviction to a drug defined in section 802. View "Mellouli v. Lynch" on Justia Law

Elonis used the Web site Facebook to post lyrics containing graphically violent language and imagery concerning his wife, co-workers, children, and law enforcement, interspersed with disclaimers that the lyrics were “fictitious” and that Elonis was exercising his First Amendment rights. His boss fired him. His wife obtained an order of protection. Elonis’s former employer contacted the FBI. The agency monitored Elonis’s Facebook activity and charged him under 18 U.S.C. 875(c), which makes it a crime to transmit in interstate commerce “any communication containing any threat . . . to injure the person of another.” Elonis requested a jury instruction that the government was required to prove that he intended to communicate a “true threat.” The district court told the jury that Elonis could be found guilty if a reasonable person would foresee that his statements would be interpreted as a threat. Elonis was convicted. The Third Circuit affirmed. The Supreme Court reversed and remanded. The instruction, requiring only negligence with respect to communication of a threat, is not sufficient to support conviction under Section 875(c). Mere omission from a criminal enactment of any mention of criminal intent does not eliminate that requirement. Wrongdoing must be conscious to be criminal. This does not mean that a defendant must know that his conduct is illegal, but a defendant must have knowledge of “the facts that make his conduct fit the definition of the offense.” In some cases, a general requirement that a defendant act knowingly is sufficient, but where such a requirement would not protect an innocent actor, the statute must be read to require specific intent. The crucial element separating legal innocence from wrongful conduct under Section 875(c) is the threatening nature of the communication, so the mental state requirement must apply to the fact that the communication contains a threat. The requirement is satisfied if the defendant transmits a communication for the purpose of issuing a threat or with knowledge that the communication will be viewed as a threat. The Court did not address whether a mental state of recklessness would also suffice or First Amendment issues. View "Elonis v. United States" on Justia Law

Abercrombie refused to hire Elauf, a practicing Muslim, because the headscarf that she wore pursuant to her religious obligations conflicted with Abercrombie’s employee dress policy. The Equal Employment Opportunity Commission (EEOC) filed suit, alleging violation of Title VII of the Civil Rights Act of 1964, which prohibits a prospective employer from refusing to hire an applicant because of the applicant’s religious practice when the practice could be accommodated without undue hardship. The EEOC prevailed in the district court. The Tenth Circuit reversed, holding that failure-to-accommodate liability attaches only when the applicant provides the employer with actual knowledge of his need for an accommodation. The Supreme Court reversed and remanded. Title VII’s disparate-treatment provision requires Elauf to show that Abercrombie “fail[ed] . . . to hire” her “because of ” “[her] religion” (including a religious practice), 42 U.S.C. 2000e–2(a)(1). Rather than imposing a knowledge standard, the statute prohibits certain motives, regardless of the state of the actor’s knowledge. An employer may not make an applicant’s religious practice, confirmed or otherwise, a factor in employment decisions. Title VII allows failure-to-accommodate challenges to be brought as disparate-treatment claims and gives favored treatment to religious practices, rather than demanding that religious practices be treated no worse than other practices. View "Equal Emp't Opportunity Comm'n v. Abercrombie & Fitch Stores, Inc." on Justia Law

Barkes was arrested in 2004, for violating probation, and taken to a Wilmington Delaware Correctional Institution. During intake, a nurse who worked for the contractor providing healthcare at the Institution conducted a suicide screening, based on a model form developed by the National Commission on Correctional Health Care in 1997. Barkes disclosed that he had a history of psychiatric treatment and was on medication and that he had attempted suicide in 2003, but stated that he was not currently thinking about killing himself. Because only two risk factors were apparent, the nurse gave Barkes a “routine” referral to mental health services and did not initiate special suicide prevention measures. Barkes was placed in a cell by himself. He called his wife and told her that he was going to kill himself; she did not inform the Institution of this call. The next morning, correctional officers observed Barkes behaving normally at 10:45, 10:50, and 11:00 a.m. At 11:35 a.m., an officer discovered that Barkes had hanged himself with a sheet. His wife sued officials, alleging violation of Barkes’s constitutional right to be free from cruel and unusual punishment, by failing to supervise and monitor the private contractor. The Third Circuit held that it was clearly established that an incarcerated individual had an Eighth Amendment “right to the proper implementation of adequate suicide prevention protocols” and that there were material factual disputes. There was evidence that the screening process did not comply with NCCHC’s latest standards, as required by contract. The Supreme Court unanimously reversed, finding that the officials were entitled to qualified immunity. No Supreme Court precedent establishes a right to proper implementation of adequate suicide prevention protocols; appellate authority in 2004 suggested that such a right did not exist. Even if the Institution’s suicide screening and prevention measures had the alleged shortcomings, no precedent would have made clear to the officials that they were overseeing a system that violated the Constitution. View "Taylor v. Barkes" on Justia Law

Debtors filed for Chapter 7 bankruptcy; each owned a house encumbered by a senior mortgage lien and by a junior mortgage lien held by Bank of America. Because the amount owed on each senior mortgage is greater than each house’s current market value, the bank would receive nothing if the properties were sold today. The debtors sought to void their junior mortgage liens under 18 U.S.C. 506, which provides, “To the extent that a lien secures a claim against the debtor that is not an allowed secured claim, such lien is void.” In each case, the Bankruptcy Court granted the motion; the district court and the Eleventh Circuit affirmed. The Supreme Court reversed and remanded. A debtor in a Chapter 7 bankruptcy may not void a junior mortgage lien under section 506(d) when the debt owed on a senior mortgage lien exceeds the current value of the collateral if the creditor’s claim is both secured by a lien and allowed under Bankruptcy Code section 502. The bank’s claims are “allowed” under the Code. Acknowledging the statutory reference to “an unsecured claim to the extent that the value of such creditor’s interest . . . is less than the amount of such allowed claim,” the Court stated that a “secured claim” is supported by a security interest in property, regardless of whether the value of that property would be sufficient to cover the claim. The Court declined to distinguish between debts that are partially and those that are entirely “underwater.” View "Bank of America, N. A. v. Caulkett" on Justia Law

Private parties may file civil qui tam actions to enforce the False Claims Act (FCA), 31 U.S.C. 3729(a)(1). A qui tam action must be brought within six years of a violation, but the Wartime Suspension of Limitations Act (WSLA) suspends the statute of limitations “applicable to any offense” involving fraud against the government, 18 U.S.C. 3287. The FCA’s “first-to-file bar” precludes a qui tam suit “based on the facts underlying [a] pending action.” In 2005, Carter worked for a defense contractor in Iraq. He filed a qui tam complaint, alleging that defense contractors had fraudulently billed the government for water purification services that were not performed or performed improperly. In 2010, the government informed the parties that an earlier-filed qui tam suit (Thorpe) had similar claims. Carter was dismissed without prejudice. While appeal was pending, Thorpe was dismissed for failure to prosecute. Carter filed a new complaint; the court dismissed it because Carter I’s appeal was pending. After dismissing that appeal, more than six years after the alleged fraud, Carter filed a third complaint, which was dismissed with prejudice under the first-to-file rule because of a pending Maryland suit. The court also stated that the actions were untimely. Reversing, the Fourth Circuit concluded that the WSLA applied to civil claims and that the first-to-file bar ceases to apply once a related action is dismissed. A unanimous Supreme Court held that the WSLA applies only to criminal offenses, not to civil claims, so that the claims were untimely. Dismissal with prejudice under the first-to-file bar was improper however. That bar keeps new claims out of court only while related claims are still alive, not in perpetuity. View "Kellogg Brown & Root Servs., Inc. v. United States ex rel. Carter" on Justia Law

Commil, holder of a patent for a method of implementing short-range wireless networks, sued, claiming that Cisco Systems, a maker and seller of wireless networking equipment, had directly infringed Commil’s patent in its networking equipment and had induced others to infringe the patent by selling the infringing equipment for use. After two trials, Cisco was found liable for both direct and induced infringement. Cisco had raised the defense that it had a good-faith belief that Commil’s patent was invalid, but the court found Cisco’s supporting evidence inadmissible. The Federal Circuit held that the trial court erred in excluding evidence of a good-faith belief that Commil’s patent was invalid. The Supreme Court vacated and remanded. A defendant’s belief regarding patent validity is not a defense to an induced infringement claim. The Court noted the long held presumption that a patent is valid; 35 U.S.C. 282(a) establishes a high bar, the clear and convincing standard, to rebut the presumption. If a patent is actually shown to be invalid, there is no patent to be infringed. Orderly administration of the patent system requires courts to interpret and implement the statutory framework to determine the procedures and sequences that the parties must follow to prove the act of wrongful inducement and any related issues of patent validity. Accused inducers who believe a patent is invalid have other, proper ways to obtain a ruling to that effect, including seeking ex parte reexamination. View "Commil USA, LLC v. Cisco Systems, Inc." on Justia Law

Sharif tried to discharge a debt to Wellness in his Chapter 7 bankruptcy. Wellness argued that a trust Sharif claimed to administer was actually Sharif’s alter ego, and that its assets were part of his bankruptcy estate. The Bankruptcy Court entered default judgment against Sharif. While appeal was pending, but before briefing concluded, the Supreme Court held (Stern v. Marshall) that Article III forbids bankruptcy courts to enter final judgment on claims that seek only to “augment” the bankruptcy estate and would otherwise “exis[t] without regard to any bankruptcy proceeding.” The district court denied Sharif permission to file a supplemental brief and affirmed. The Seventh Circuit determined that Sharif’s “Stern” objection could not be waived and reversed, holding that the Bankruptcy Court lacked constitutional authority to enter judgment on the alter ego claim. The Supreme Court reversed. Article III permits bankruptcy judges to adjudicate Stern claims with the parties’ knowing and voluntary consent. The right to adjudication before an Article III court is “personal” and “subject to waiver,” unless Article III’s structural interests as “an inseparable element of the constitutional system of checks and balances” are implicated; parties “cannot by consent cure the constitutional difficulty.” Allowing bankruptcy courts to decide Stern claims by consent does not usurp the constitutional prerogatives of Article III courts. Bankruptcy judges are appointed and may be removed by Article III judges, hear matters solely on a district court’s reference, and possess no free-floating authority to decide claims traditionally heard by Article III courts. Consent to adjudication by a bankruptcy court need not be express, but must be knowing and voluntary. The Seventh Circuit should decide on remand whether Sharif’s actions evinced the requisite knowing and voluntary consent and whether Sharif forfeited his Stern argument. View "Wellness Int’l Network, Ltd. v. Sharif" on Justia Law

A federal litigant who is too poor to pay court fees may proceed in forma pauperis and commence a civil action without prepaying fees or paying certain expenses, 28 U.S.C. 1915(a), but a “three strikes” provision prevents a court from granting in forma pauperis status to a prisoner who “has, on 3 or more prior occasions, while incarcerated . . . , brought an action or appeal in a court of the United States that was dismissed on the grounds that it is frivolous, malicious, or fails to state a claim upon which relief may be granted.” A state prisoner filed three federal lawsuits that were dismissed on grounds enumerated in section 1915(g). While the third dismissal was pending on appeal, he filed four additional federal lawsuits, moving to proceed in forma pauperis in each. The district court denied the motion. The Sixth Circuit and a unanimous Supreme Court affirmed. A prior dismissal on statutorily enumerated grounds is a strike, even if the dismissal is the subject of an ongoing appeal. Section 1915 describes dismissal as an action by a single court, not as a sequence of events involving multiple courts. The Court noted that a judgment normally takes effect, and its preclusive effect is immediate, despite a pending appeall. The “three strikes” provision was “designed to filter out the bad claims and facilitate consideration of the good.” To refuse to count a prior dismissal because of a pending appeal would produce a leaky filter. View "Coleman v. Tollefson" on Justia Law

Sheehan lived in a group home for individuals with mental illness. After Sheehan threatened to kill her social worker, San Francisco dispatched officers to escort Sheehan to a facility for evaluation and treatment. When the officers entered Sheehan’s room, she grabbed a knife and threatened them. They retreated and closed the door. Concerned about what Sheehan might do, and without considering whether they could accommodate her disability, the officers reentered. Sheehan, knife in hand, again confronted them. After pepper spray proved ineffective, the officers shot Sheehan multiple times. Sheehan sued under the Americans with Disabilities Act, 42 U.S.C. 12132 and 42 U.S.C. 1983. The Ninth Circuit held that the ADA applied and that the officers were not entitled to qualified immunity. The Supreme Court dismissed certiorari as to whether the ADA “requires law enforcement officers to provide accommodations to an armed, violent, and mentally ill suspect in the course of bringing the suspect into custody,” because, instead of arguing that the ADA does not apply when an officer faces an armed and dangerous individual, San Francisco argued only that Sheehan was not “qualified” for an accommodation, because she “pose[d] a direct threat to the health or safety of others,” which could not “be eliminated by a modification of policies, practices or procedures, or by the provision of auxiliary aids or services.” The lower courts did not address that question. The officers are entitled to qualified immunity from liability for injuries suffered by Sheehan. Their use of force was also reasonable. Any Fourth Amendment right involving accommodation of a disability, even assuming it exists, was not clearly established. View "City & Cnty. of San Francisco v. Sheehan" on Justia Law