Justia U.S. Supreme Court Opinion Summaries

Providers of “habilitation services” under Idaho’s Medicaid plan are reimbursed by the state Department of Health and Welfare. Section 30(A) of the Medicaid Act requires Idaho’s plan to “assure that payments are consistent with efficiency, economy, and quality of care” while “safeguard[ing] against unnecessary utilization of . . . care and services,” 42 U.S.C. 1396a(a)(30)(A). Providers of habilitation services claimed that Idaho reimbursed them at rates lower than section 30(A) permits. The district court entered summary judgment for the providers. The Ninth Circuit affirmed, concluding that the Supremacy Clause gave the providers an implied right of action, under which they could seek an injunction requiring compliance. The Supreme Court reversed, concluding that there is no private right of action. The Supremacy Clause instructs courts to give federal law priority when state and federal law clash, but it is not the source of any federal rights and does not create a cause of action. The suit cannot proceed in equity. The power of federal courts of equity to enjoin unlawful executive action is subject to express and implied statutory limitations. The express provision of a single remedy for a state’s failure to comply with Medicaid’s requirements, the withholding of Medicaid funds by the Secretary of Health and Human Services, 42 U.S.C. 1396c, and the complexity associated with enforcing section 30(A) combine to establish Congress’s “intent to foreclose” equitable relief. View "Armstrong v. Exceptional Child Ctr., Inc." on Justia Law

Grady was convicted in North Carolina of a second degree sexual offense in 1997 and of taking indecent liberties with a child in 2006. After he served his sentence, the state held a hearing to determine whether he should be subjected to satellite-based monitoring (SBM) as a recidivist sex offender, N. C. Gen. Stat. 14–208.40(a)(1), 14– 208.40B. Grady argued that the program, under which he would be forced to wear tracking devices at all times, would violate his Fourth Amendment rights. State courts rejected his arguments. The Supreme Court, per curiam, vacated, holding that the state conducts a search when it attaches a device to a person’s body, without consent, for the purpose of tracking that individual’s movements. Although the North Carolina monitoring program is civil in nature, the government’s purpose in collecting information does not control whether the method of collection constitutes a search. The Fourth Amendment prohibits only unreasonable searches. The case was remanded to allow North Carolina courts to examine whether the monitoring program is reasonable, when properly viewed as a search. View "Grady v. North Carolina" on Justia Law

Donald, Liggins, Moore, Saine, and Zaya decided to rob a drug dealer (Makki). Donald, Moore, and Liggins drove to Makki’s home. Moore and Donald entered. Liggins waited in the car. McGinnis, a drug runner, was present, and dropped to the floor. He heard a scuffle and gunshots. After Moore and Donald left, he found Makki, dying. Moore and Donald returned to the car. Donald stated that he had stolen $320 and that Moore had accidentally shot him. Donald later went to a hospital for the wound. Weeks later, the state charged Donald with first-degree felony murder and two counts of armed robbery. Liggins and Zaya pleaded guilty. Donald was tried with Moore and Saine. His defense was that he was present, but did not participate. The court admitted a chart chronicling phone calls from the day of the crime among Moore, Saine, and Zaya. Donald’s attorney did not object, saying: “it does not affect me.’” When the trial resumed after a recess, Donald’s counsel was not in the courtroom. Ten minutes later, the lawyer returned. The judge informed him that “we only were discussing the telephone chart.” The attorney replied, “I had no dog in the race and no interest in that.” Donald was convicted. Michigan courts rejected his claim that his attorney’s absence during the phone call testimony denied him effective assistance of counsel. The federal district court granted habeas relief. The Sixth Circuit affirmed, based on the Supreme Court’s “Cronic” holding that courts may presume unconstitutional prejudice if a defendant “is denied counsel at a critical stage of his trial.” The Supreme Court, per curiam, reversed. The state court’s decision could not be “contrary to” any Supreme Court holding; no holding addresses counsel’s absence during testimony that is irrelevant within the defendant’s own theory of the case. A fair-minded jurist could conclude that a presumption of prejudice is not warranted by counsel’s short absence during testimony about other defendants, irrelevant to the defendant’s theory. View "Woods v. Donald" on Justia Law

The Pregnancy Discrimination Act specifies that Title VII’s prohibition against sex discrimination applies to discrimination “because of or on the basis of pregnancy, childbirth, or related medical conditions,” 42 U.S.C 2000e(k), and that employers must treat “women affected by pregnancy . . . the same for all employment-related purposes . . . as other persons not so affected but similar in their ability or inability to work.” Young, a UPS driver, became pregnant; her doctor advised that she should not lift more than 20 pounds. UPS required drivers to lift up to 70 pounds. UPS told Young that she could not work while under a lifting restriction. Young filed a disparate-treatment claim of discrimination, identifying UPS policies that accommodated workers who were injured on the job, were covered by the Americans with Disabilities Act, or had lost Department of Transportation certifications. UPS argued that, since Young did not fall within those categories, it had not discriminated on the basis of pregnancy, but had treated her as it treated all “other” relevant “persons.” The district court granted UPS summary judgment. The Fourth Circuit affirmed. The Supreme Court vacated. Disparate treatment law normally allows an employer to implement policies that are not intended to harm members of a protected class if the employer has a nondiscriminatory, nonpretextual reason. A pregnant worker can make a prima facie case of disparate treatment by showing that she sought and was denied accommodation and that the employer did accommodate others “similar in their ability or inability to work.” The employer may then try to establish “legitimate, nondiscriminatory” reasons, other than that it is more expensive or less convenient to accommodate pregnant women. If the employer offers a reason, the plaintiff may show that it is pretextual. The plaintiff may survive a motion for summary judgment by providing sufficient evidence that the employer’s policies impose a significant burden on pregnant workers, and that the employer’s “legitimate, nondiscriminatory” reasons are not sufficiently strong to justify the burden. The plaintiff can create a genuine issue of material fact as to “significant burden” with evidence that the employer accommodates a large percentage of nonpregnant workers while failing to accommodate a large percentage of pregnant workers. Young created a genuine dispute as to whether UPS provided more favorable treatment to some employees whose situation cannot reasonably be distinguished from hers. View "Young v. United Parcel Service, Inc." on Justia Law

In 2012 Alabama redrew the boundaries of its 105 House and 35 Senate districts to minimize each district’s deviation from precisely equal population and avoid retrogression with respect to racial minorities’ “ability to elect their preferred candidates of choice” under the Voting Rights Act, 52 U.S.C. 10304(b), by maintaining roughly the same black population percentage in existing majority-minority districts. The district court rejected an equal protection claim of “racial gerrymander.” The Supreme Court vacated. Analysis of the racial gerrymandering claim as referring to the state “as a whole,” rather than district-by-district, was erroneous. Showing that race-based criteria did not significantly affect the drawing of some districts did not defeat a claim that such criteria predominantly affected the drawing of others. The objectors’ claimed that individual majority-minority districts were racially gerrymandered, and those districts must be reconsidered. There was “strong, perhaps overwhelming, evidence that race did predominate as a factor” with respect to one district. An equal population goal is not a “traditional” factor in determining whether race “predominates,” but is taken as a given. The district court and the Alabama legislature relied upon a mechanically numerical view as to what counts as forbidden retrogression and asked how to maintain the present minority percentages in majority-minority districts. The Act does not require maintenance of a particular numerical minority percentage. It requires the jurisdiction to maintain a minority’s ability to elect a preferred candidate of choice. View "Alabama Legislative Black Caucus v. Alabama" on Justia Law

Hargis tried to register its trademark for SEALTITE with the U.S. Patent and Trademark Office. B&B opposed registration, claiming that SEALTITE is too similar to B&B’s SEALTIGHT trademark. The Trademark Trial and Appeal Board (TTAB) concluded that SEALTITE should not be registered because of the likelihood of confusion. Hargis did not seek judicial review. Later, in an infringement suit, B&B argued that Hargis was precluded from contesting likelihood of confusion because of the TTAB’s decision. The district court disagreed. The Eighth Circuit affirmed. The Supreme Court reversed. If the other elements of issue preclusion are met, when the usages adjudicated by the TTAB are materially the same as those before a court, issue preclusion should apply. When Congress authorizes agencies to resolve disputes, issue preclusion applies except when a contrary statutory purpose is evident. Neither the Lanham Act’s (15 U.S.C. 1051) text nor its structure rebuts a presumption in favor of preclusive effect. There is no categorical reason why registration decisions can never meet the ordinary elements of issue preclusion. That many registrations will not satisfy those elements does not mean that none will. The same likelihood-of-confusion standard applies to both registration and infringement. The factors that the TTAB and the courts use to assess likelihood of confusion are not fundamentally different; the operative statutory language is essentially the same. Congress’ creation of an elaborate registration scheme confirms that registration decisions can be weighty enough to ground issue preclusion. View "B&B Hardware, Inc. v. Hargis Indus., Inc." on Justia Law

The Securities Act of 1933 requires that a company issuing securities file a registration statement containing specified information, 15 U.S.C. 77aa. The statement may include other representations of fact or opinion. A purchaser of securities may sue an issuer if it either “contain[s] an untrue statement of a material fact” or “omit[s] to state a material fact . . . necessary to make the statements therein not misleading.” The buyer need not prove intent to deceive. Omnicare filed a registration statement for a public offering of common stock. In addition to required disclosures, the statement expressed the company’s opinion that it was in compliance with federal and state laws. After the government sued Omnicare for receiving kickbacks from pharmaceutical manufacturers, purchasers of Omnicare Funds sued, claiming that the legal-compliance statements constituted “untrue statement[s] of . . . material fact” and that Omnicare “omitted to state [material] facts necessary” to make those statements not misleading. The district court dismissed. The Sixth Circuit reversed, holding that subjective disbelief was not required. The Supreme Court vacated. A statement of opinion is not an “untrue statement of . . . fact” simply because that opinion ultimately proves incorrect. Opinions qualify as untrue statements of fact if the opinion was not sincerely held or if they contain embedded statements of untrue facts. Under section 11’s omissions clause, whether a statement is “misleading” is an objective inquiry based on a reasonable investor’s perspective. A reasonable investor may understand an opinion to convey facts about the speaker’s basis for holding that view; if the real facts are otherwise, but not provided, the opinion will mislead by omission. An opinion, however, is not misleading simply because the issuer knows, but fails to disclose, some fact cutting the other way. Section 11 creates liability only for the omission of material facts that cannot be squared with a fair reading of the registration as a whole. The case was remanded for determination of whether the complaint adequately alleged that Omnicare omitted some fact that would have been material to a reasonable investor. View "Omnicare, Inc. v. Laborers Dist. Council Constr. Indus. Pension Fund" on Justia Law

The Administrative Procedure Act (APA) establishes procedures federal administrative agencies use for “formulating, amending, or repealing a rule,” 5 U.S.C. 551(5), and distinguishes between “legislative rules,” issued through notice-and-comment rulemaking and having the “force and effect of law,” and “interpretive rules.” Interpretive rules “advise the public of the agency’s construction of the statutes and rules which it administers,” do not require notice-and-comment, and do not have the force and effect of law. In 1999 and 2001, the DOL Wage and Hour Division issued opinions that mortgage-loan officers do not qualify for the administrative exemption to Fair Labor Standard Act overtime pay requirements. In 2004, DOL issued new regulations regarding the exemption. MBA requested a new interpretation. In 2006, the Division opined that mortgage-loan officers fell within the exemption under the 2004 regulations. In 2010, DOL again altered its interpretation of the exemption. Without notice or an opportunity for comment, it withdrew the 2006 opinion and issued an Administrator’s Interpretation concluding that mortgage-loan officers do not qualify for the exemption. MBA sued. The D.C. Circuit applied the “Paralyzed Veterans doctrine,” which required an agency to use notice-and-comment procedures to issue a new interpretation of a regulation that deviates significantly from a previous interpretation. The Supreme Court reversed. The doctrine is contrary to the text of the APA and improperly imposes on agencies an obligation beyond the APA’s maximum requirements. Because an agency is not required to use notice-and-comment procedures to issue an initial interpretive rule, it is not required to use those procedures to amend that rule. Regulated entities may be protected by the arbitrary and capricious standard or by safe-harbor provisions in legislation that shelter regulated entities from liability when they rely on previous agency interpretations. MBA has waived its argument that the 2010 Interpretation was a legislative rule. View "Perez v. Mortgage Bankers Ass'n" on Justia Law

The National Railroad Passenger Corporation (Amtrak) has priority to use track systems owned by the freight railroads for passenger rail travel, at agreed rates or rates set by the Surface Transportation Board. In 2008, Congress gave Amtrak and the Federal Railroad Administration (FRA) joint authority to issue “metrics and standards” addressing performance and scheduling of passenger railroad services, 122 Stat. 4907, including Amtrak’s on-time performance and delays caused by host railroads. The Association of American Railroads sued. The District of Columbia Circuit accepted a separation of powers claim, reasoning that Amtrak is a private corporation and cannot constitutionally be granted regulatory power. The Supreme Court vacated. For purposes of determining the validity of the standards, Amtrak is a governmental entity. The D.C. Circuit relied on the statutory command that Amtrak “is not a department, agency, or instrumentality of the United States,” 49 U.S.C. 24301(a)(3), and “shall be operated and managed as a for profit corporation,” but independent inquiry reveals that the political branches control most of Amtrak’s stock and its Board of Directors, most of whom are appointed by the President. The political branches exercise substantial, statutorily mandated supervision over Amtrak’s priorities and operations: Amtrak is required to pursue broad public objectives; certain day-to-day operations are mandated by Congress; and Amtrak has been dependent on federal financial support during every year of its existence. Amtrak is not an autonomous private enterprise and, in jointly issuing the metrics and standards with the FRA, Amtrak acted as a governmental entity for separation of powers purposes. Treating Amtrak as governmental for these purposes is not an unbridled grant of authority to an unaccountable actor. On remand, the court may address any remaining issues respecting the lawfulness of the metrics and standards. View "Dep't of Transp. v. Ass'n of Am. Railroads" on Justia Law

Alabama imposes sales and use taxes on railroads purchasing or consuming diesel fuel, but exempts their competitors: trucking companies and companies that transport goods interstate through navigable waters. Motor carriers pay an alternative fuel-excise tax on diesel, but water carriers pay neither sales tax nor excise tax. CSX, an interstate rail carrier, alleged discrimination against a rail carrier under the Railroad Revitalization and Regulation Reform Act, 49 U.S.C. 11501(b)(4). The Supreme Court held that a tax “discriminates” when it treats “groups [that] are similarly situated” differently without sufficient justification. On remand, the Eleventh Circuit held that CSX could establish discrimination by showing that Alabama taxed rail carriers differently than their competitors, but rejected Alabama’s argument that the fuel-excise tax on motor carriers justified the sales tax on rail carriers. The Supreme Court reversed and remanded. CSX’s competitors are an appropriate comparison class; the class need not consist of “general commercial and industrial taxpayers.” The Act’s subsections (b)(1) to (b)(3), addressing property taxes, limits the comparison class to commercial and industrial property in the same assessment jurisdiction. Subsection (b)(4) contains no such limitation, so the comparison class is based on the claimed theory of discrimination. When a railroad alleges discrimination compared to transportation industry competitors, its competitors in that jurisdiction are the comparison class. The comparison class must consist of individuals similarly situated to the claimant. Discrimination in favor of competitors frustrates the Act’s purpose of restoring railways’ financial stability while fostering competition among all carriers. The Eleventh Circuit erred in refusing to consider Alabama’s proposed justification. An alternative, roughly equivalent tax is one possible justification. On remand, the court is to consider whether Alabama’s fuel-excise tax is the rough equivalent of sales tax on diesel fuel and whether any alternative rationales justify the water carrier exemption. View "Ala. Dep't of Revenue v. CSX Transp., Inc." on Justia Law