Justia U.S. Supreme Court Opinion Summaries

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

In 2007, beneficiaries of the Edison 401(k) Savings Plan sued Plan fiduciaries, to recover damages for alleged losses suffered because of alleged breaches of fiduciary duties. The beneficiaries claimed violations with respect to mutual funds added to the Plan in 1999 and mutual funds added to the Plan in 2002, by acted imprudently in offering higher priced retail-class mutual funds as Plan investments when materially identical lower priced institutional-class mutual funds were available. Because ERISA requires a breach of fiduciary duty complaint to be filed no more than six years after “the date of the last action which constitutes a part of the breach or violation” or “in the case of an omission the latest date on which the fiduciary could have cured the breach or violation,” 29 U.S.C. 1113, the district court found the complaint as to the 1999 funds untimely. The Ninth Circuit affirmed, concluding that beneficiaries had not established a change in circumstances that might trigger an obligation to conduct a full due diligence review of the funds within the six-year period. A unanimous Supreme Court vacated. ERISA’s fiduciary duty is derived from the common law of trusts, which provides that a trustee has a continuing duty, separate from the duty to exercise prudence in initially selecting investments, to monitor, and remove imprudent trust investments. So long as a claim alleging breach of the continuing duty of prudence occurred within six years of suit, the claim is timely. The Court remanded for the Ninth Circuit to consider claims that the fiduciaries breached their duties within the relevant 6-year statutory period, considering analogous trust law. View "Tibble v. Edison Int’l" on Justia Law

After being charged with the felony offense of distributing marijuana, Henderson was required, as a condition of bail, to turn over firearms that he lawfully owned. Henderson pleaded guilty, and, as a felon, was prohibited under 18 U.S.C. 922(g) from possessing any firearms. Henderson asked the FBI, which had custody of his firearms, to transfer them to his friend. The agency refused. The district court reasoned that Henderson’s requested transfer would give him constructive possession of the firearms. The Eleventh Circuit affirmed. The unanimous Supreme Court vacated: A court-ordered transfer of a felon’s lawfully owned firearms from government custody to a third party is not barred by section 922(g) if the court is satisfied that the recipient will not give the felon control over the firearms, so that he could either use them or direct their use. The government’s view conflated possession, which section 922(g) prohibits, with an owner’s right to alienate his property, which it does not. The Court stated that a felon may select a firearms dealer or third party to sell his guns; a court, with proper assurances from the recipient, may also grant a felon’s request to transfer his guns to a person who expects to maintain custody of them. View "Henderson v. United States" on Justia Law

Maryland has a “state” income tax, Md. Tax-Gen. Code 10–105(a), and a “county” income tax, sections 10–103, 10–106. Residents who pay income tax to another jurisdiction for income earned in that other jurisdiction get a credit against the state tax but not the county tax. Nonresidents who earn income from Maryland sources must pay the state income tax; nonresidents not subject to the county tax must pay a “special nonresident tax.” Residents who earned pass-through income from a Subchapter S corporation that earned income in several states claimed an income tax credit on their Maryland tax return for taxes paid to other states. The Comptroller allowed a credit against state income tax but not against county income tax and assessed a tax deficiency. The Court of Appeals of Maryland held that the tax unconstitutionally discriminated against interstate commerce. The Supreme Court affirmed: Maryland’s personal income tax scheme violates the dormant Commerce Clause. The Court noted previous decisions invalidating state tax schemes that might lead to double taxation of out-of-state income and that discriminated in favor of intrastate over interstate economic activity. That conclusion is not affected by the fact that these cases involved a tax on gross receipts rather than net income, and a tax on corporations rather than individuals. Maryland’s income tax scheme fails the internal consistency test; if every state adopted its tax structure, interstate commerce would be taxed at a higher rate than intrastate commerce. The scheme is inherently discriminatory and operates as a tariff. The Court rejected an argument that, by offering residents who earn income in interstate commerce a credit against the state portion of the tax, Maryland receives less tax revenue from residents who earn interstate, rather than intrastate, commerce income; the total tax burden on interstate commerce is higher. View "Comptroller of Treasury of Md. v. Wynne" on Justia Law

Harris filed a Chapter 13 bankruptcy petition. His court-confirmed plan provided that he would make monthly mortgage payments to Chase, and that $530 per month would be withheld from his post-petition wages and remitted to the Chapter 13 trustee, Viegelah, to pay down the mortgage arrearage, with remaining funds to other creditors. Harris again fell behind on his mortgage payments. Chase foreclosed on his home. Viegelahn continued to receive $530 per month from Harris’ wages, but stopped making the Chase payments. A year after the foreclosure, Harris converted his case to Chapter 7. Viegelahn distributed $5,519.22 in accumulated withheld wages mainly to creditors. Harris obtained an order directing refund. The Fifth Circuit reversed. The Supreme Court unanimously reversed: A debtor who converts to Chapter 7 is entitled to return of post-petition wages not distributed by the Chapter 13 trustee. Absent a bad-faith conversion, 11 U.S.C. 348(f) limits a converted Chapter 7 estate to property belonging to the debtor “as of the date” of the original Chapter 13 filing. By excluding post-petition wages from the converted Chapter 7 estate, the statute removes those earnings from the pool of assets to be liquidated and distributed to creditors. Allowing a terminated Chapter 13 trustee to disburse those earnings to the same creditors would be incompatible with that statutory design. When a case is converted, the Chapter 13 trustee is stripped of authority to distribute “payment[s] in accordance with the plan.” Because Chapter 13 is a voluntary alternative to Chapter 7, a debtor’s post-conversion receipt of some wages he earned and would have kept, had he initially filed under Chapter 7, does not provide a “windfall.” Creditors may protect against excess accumulations in the hands of trustees by seeking to have a Chapter 13 plan include regular disbursement of collected funds. View "Harris v. Viegelahn" on Justia Law

After filing for Chapter 13 bankruptcy, Bullard submitted a proposed repayment plan. Bullard’s mortgage lender objected to the plan’s treatment of its claim. The Bankruptcy Court sustained the Bank’s objection and declined to confirm the plan. Bullard appealed to the First Circuit Bankruptcy Appellate Panel, which concluded that denial of confirmation was not a final, appealable order, 28 U.S.C.158(a)(1), but heard the appeal under a provision permitting interlocutory appeals “with leave of the court,” and agreed that Bullard’s proposed plan was not allowed. The First Circuit dismissed for lack of jurisdiction, finding that the order denying confirmation was not final so long as Bullard remained free to propose another plan. A unanimous Supreme Court affirmed. The relevant proceeding is the entire process of attempting to arrive at an approved plan that would allow the bankruptcy case to move forward. Only plan confirmation, or case dismissal, alters the status quo and fixes the parties’ rights and obligations; denial of confirmation with leave to amend changes little. Additional considerations—that the statute defining core bankruptcy proceedings lists “confirmations of plans,” but omits any reference to denials; that immediate appeals from denials would result in delays and inefficiencies; and that inability to immediately appeal a denial encourages the debtor to work with creditors and the trustee to develop a confirmable plan—bolster this conclusion. View "Bullard v. Blue Hills Bank" on Justia Law

Before suing for employment discrimination under Title VII of the Civil Rights Act of 1964, the Equal Employment Opportunity Commission (EEOC) must “endeavor to eliminate [the] alleged unlawful employment practice by informal methods of conference, conciliation, and persuasion,” 42 U. S. C. 2000e–5(b). Nothing said or done during conciliation may be “used as evidence in a subsequent proceeding without written consent of the persons concerned.” After investigating a sex discrimination charge against Mach Mining, EEOC determined that reasonable cause existed to believe that the company had engaged in unlawful hiring practices and invited the parties to participate in informal conciliation. A year later, EEOC sent Mach another letter stating that conciliation efforts had been unsuccessful, then filed suit. Mach alleged that EEOC had not attempted to conciliate in good faith. The Seventh Circuit held that EEOC’s statutory conciliation obligation was unreviewable. The Supreme Court vacated, noting a “strong presumption” that Congress means to allow judicial review of administrative action. EEOC’s argument that review is limited to checking the facial validity of its two letters falls short of Title VII’s demands; the aim of judicial review is to verify that the EEOC actually tried to conciliate. The Court rejected Mach’s proposal for specific requirements or a code of conduct as conflicting with the wide latitude Congress gave EEOC and with Title VII’s confidentiality protections. A sworn affidavit from EEOC that it informed the employer about the specific discrimination allegation and tried to engage the employer in a discussion to give the employer a chance to remedy the allegedly discriminatory practice should suffice. Should the employer present concrete evidence that the EEOC did not provide the requisite information or attempt to engage in conciliation, a court must conduct the fact-finding necessary to resolve that limited dispute. View "Mach Mining, LLC v. Equal Emp't Opportunity Comm'n" on Justia Law

Florida voters elect judges. The Florida Supreme Court adopted Canon 7C(1) of its Code of Judicial Conduct, stating that judicial candidates “shall not personally solicit campaign funds . . . but may establish committees of responsible persons” to raise money for election campaigns. Yulee mailed and posted online a letter soliciting financial contributions to her campaign for judicial office. The Florida Bar disciplined her for violating a Bar Rule requiring candidates to comply with Canon 7C(1). The Florida Supreme Court upheld the sanction against a First Amendment challenge. The U.S. Supreme Court affirmed. Florida’s interest in preserving public confidence in the integrity of its judiciary is compelling.. Unlike the legislature or the executive, the judiciary “has no influence over either the sword or the purse,” so its authority largely depends on the public’s willingness to respect its decisions. Canon 7C(1) raises no fatal underinclusivity concerns. The solicitation ban aims squarely at the conduct most likely to undermine public confidence in the integrity of the judiciary: it is not riddled with exceptions. Allowing a candidate to use a committee and to write thank you notes reflect Florida’s effort to respect the First Amendment interests of candidates and contributors. Canon 7C(1) is not overinclusive It allows judicial candidates to discuss any issue with any person at any time; to write letters, give speeches, and put up billboards; to contact potential supporters in person, on the phone, or online; and to promote their campaigns through the media. Though they cannot ask for money, they can direct their campaign committees to do so. Florida has reasonably determined that personal appeals for money by a judicial candidate inherently create an appearance of impropriety. Canon 7C(1) must be narrowly tailored, not “perfectly tailored” to address that concern. View "Williams-Yulee v. Florida Bar" on Justia Law

The Federal Tort Claims Act (FTCA) provides that a tort claim against the United States “shall be forever barred” unless presented to the appropriate federal agency for review within two years after the claim accrues,” 28 U.S.C. 2401(b). If the agency denies the claim, the claimant may file suit in federal court within six months of the denial. Wong failed to file her FTCA claim in federal court within six months, but argued that the district court had not permitted her to file until after the period expired. June failed to present her FTCA claim to a federal agency within two years, but argued that her untimely filing should be excused because the government concealed facts vital to her claim. In each case, the district court dismissed the FTCA claim, holding that those time bars are jurisdictional and not subject to equitable tolling. The Ninth Circuit reversed. The Supreme Court affirmed and remanded. Section 2401(b)’s time limits are subject to equitable tolling. Congress must do something special to tag a statute of limitations as jurisdictional and prohibit a court from tolling it, but did no such thing in section 2401(b). Separation of a filing deadline from a jurisdictional grant often indicates that the deadline is not jurisdictional; the FTCA’s jurisdictional grant appears in another section and is not expressly linked to the limitations periods. The phrase “shall be forever barred” was commonplace in statutes of limitations enacted around the time of the FTCA, and does not carry jurisdictional significance. View "United States v. Wong" on Justia Law