Justia U.S. Supreme Court Opinion Summaries

Warger sued Shauers for negligence for injuries suffered in a motor vehicle accident. After the jury returned a verdict for Shauers, a juror contacted Warger’s counsel, claiming that Whipple, the jury foreperson, had revealed during deliberations that her daughter had been at fault in a fatal motor vehicle accident and that a lawsuit would have ruined her daughter’s life. With an affidavit from the juror, Warger moved for a new trial, arguing that Whipple had deliberately lied during voir dire about her impartiality and ability to award damages. The district court denied Warger’s motion, citing Federal Rule of Evidence 606(b), which bars evidence “about any statement made . . . during the jury’s deliberations.” The Eighth Circuit and a unanimous Supreme Court affirmed. Rule 606(b) unambiguously applies to “an inquiry into the validity of [the] verdict,” even to demonstrate dishonesty during voir dire. Warger’s right to an impartial jury remains protected; even if a juror lies to conceal bias, parties may bring to the court’s attention evidence of bias before the verdict is rendered and use nonjuror evidence after the verdict is rendered. The excluded affidavit is “internal.” View "Warger v. Shauers" on Justia Law

Integrity Staffing required its hourly workers, who retrieved products from warehouse shelves and packaged them for delivery to Amazon.com customers, to undergo a security screening before leaving each day. Former employees sued, alleging that they were entitled to compensation under the Fair Labor Standards Act (FLSA) for the roughly 25 minutes each day that they spent waiting and undergoing screenings. They claimed that the company could have reduced that time by adding screeners or staggering shift terminations and that the screenings were conducted to prevent theft, for the sole benefit of the employers. The Ninth Circuit found that post-shift activities are compensable as integral and indispensable to an employee’s principal activities if necessary to the principal work and performed for the employer’s benefit. A unanimous Supreme Court reversed. The Portal-to-Portal Act responds to the broad judicial interpretation previously given the FLSA’s undefined terms “work” and “workweek,” 29 U.S.C. 251(a), by exempting “activities which are preliminary to or postliminary to” performance of the principal activities that an employee is employed to perform. Security screenings were not the principal activities the employees were employed to perform, nor were they “integral and indispensable” to those activities. Whether the screenings are compensable because Integrity could have reduced the time is properly presented at the bargaining table. View "Integrity Staffing Solutions, Inc. v. Busk " on Justia Law

Shelby, Mississippi police officers alleged that they were fired, not for deficient performance, but because they brought to light criminal activities of an alderman. The district court entered summary judgment, rejecting their due process claims for failure to invoke 42 U. S. C. 1983. The Fifth Circuit affirmed. The Supreme Court reversed. Federal pleading rules call for “a short and plain statement of the claim showing that the pleader is entitled to relief,” Fed. Rule Civ. Proc. 8(a)(2); they do not contemplate dismissal for imperfect statement of the legal theory asserted. No heightened pleading rule requires plaintiffs seeking damages for violations of constitutional rights to invoke section 1983 expressly in order to state a claim. No qualified immunity analysis was implicated here, as the officers asserted a constitutional claim against the city only, not against any municipal officer. The complaint was not deficient in informing the city of the factual basis for the lawsuit. View "Johnson v. City of Shelby" on Justia Law

Pennsylvania State Police received a report that Zita had stolen a car and loaded handguns and might have fled to the Carman home and sent Officers Carroll and Roberts to that home. The officers parked at the far rear of the corner-lot property, and walked toward the house. They saw a sliding glass door that opened onto a ground-level deck. Carroll thought the door “looked like a customary entryway,” so he and Roberts decided to knock on it. As they stepped onto the deck, a man exited the house and “aggressively approached” them. The officers identified themselves, explained they were looking for Zita, and asked the man for his name. The man refused to answer, but turned away and appeared to reach for his waist. Carroll grabbed his arm to make sure he was not reaching for a weapon. He twisted away and fell into the yard. A woman came outside, identified herself as Karen Carman, identified the man as her husband, and stated that Zita was not there. Karen consented to a search. The officers searched the house, did not find Zita, then left. The Carmans sued under 42 U. S. C. 1983. Carroll argued that his entry was lawful under the “knock and talk” exception to the warrant requirement, which he contended, allows officers to knock on someone’s door, so long as they stay “on those portions of [the] property that the general public is allowed to go on.” The Carmans responded that a normal visitor would have gone to their front door. The jury returned a verdict for Carroll. The Third Circuit reversed. The Supreme Court reversed, holding that Carroll was entitled to qualified immunity. The Court declined to address whether an officer may conduct a “knock and talk” at any entrance that is open to visitors or only the front door, but stated that Carroll may reasonably have concluded that he was allowed to knock on any door that was open to visitors. View "Carroll v. Carman" on Justia Law

In 2005, Smith’s wife was killed at home by a blow to the head from a log roller. The home appeared to have been ransacked. Jewelry was missing. Smith was charged with first-degree murder. The prosecution presented evidence that he was unfaithful for many years, that his wife was threatening a divorce, and that he told an employee that “the ‘only way’ … out of their marriage was ‘to die’.” Smith’s DNA was found on the murder weapon, duct tape found near the body, and a matchstick that may have been used to burn the body. The missing jewelry was discovered in the trunk of Smith’s car, wrapped in duct tape from the same roll as pieces found near the body. Smith claimed that he could not have delivered the fatal blow due to surgery weeks before the murder. The prosecution successfully requested an aiding-and-abetting instruction and argued that even if he had not delivered the fatal blow, he could be convicted. The jury did not specify which theory it adopted. The California Court of Appeal affirmed, rejecting an assertion that Smith had inadequate notice of the aiding-and-abetting theory. The California Supreme Court denied his petition for review. The Ninth Circuit affirmed the district court’s grant of habeas relief, stating that the information charging first degree murder was initially sufficient, because under California law, aiding and abetting is the same substantive offense as perpetrating the crime, but that Smith’s Sixth Amendment and due process right to notice were violated because the prosecution (until it sought an aiding-and-abetting instruction) had tried the case on the theory that Smith himself had delivered the fatal blow. The Supreme Court reversed. When a state prisoner seeks federal habeas relief on the ground that a state court, in adjudicating a claim on the merits, misapplied federal law, a federal court may grant relief only if the state court’s decision was “contrary to, or involved an unreasonable application of, clearly established Federal law, as determined by the Supreme Court of the United States,” 28 U. S. C. 2254(d)(1). The Ninth Circuit relied only on its own precedent in this case. View "Lopez v. Smith" on Justia Law

Under Title VII (42 U.S.C. 2000e–2(a)(1)), an employer’s liability for workplace harassment may depend on the status of the harasser. If the harassing employee is the victim’s co-worker, the employer is liable only if it was negligent in controlling working conditions. If the harasser is a “supervisor,” however, and the harassment culminates in a tangible employment action, the employer is strictly liable. If there was no tangible employment action, the employer may escape liability by establishing that the employer exercised reasonable care to prevent and correct harassing behavior and that the plaintiff unreasonably failed to take advantage of preventive or corrective opportunities provided by the employer. Vance, an African-American woman, sued her employer, BSU, alleging that a fellow employee, Davis, created a racially hostile work environment in violation of Title VII. The district court entered summary judgment, holding that BSU was not vicariously liable for Davis’ alleged actions because Davis, who could not take tangible employment actions against Vance, was not a supervisor. The Seventh Circuit and Supreme Court affirmed. An employee is a "supervisor" for purposes of vicarious liability under Title VII only if empowered by the employer to take tangible employment actions against the victim. A definition that draws a sharp line between co-workers and supervisors, with the authority to take tangible employment actions as the defining characteristic of a supervisor, can be readily applied. Supervisor status will often be discerned before or soon after litigation commences and is likely to be resolved as a matter of law before trial. This definition will not leave employees unprotected against harassment by co-workers who possess some authority to assign daily tasks and accounts for the fact that many modern organizations have abandoned a hierarchical management structure in favor of giving employees overlapping authority with respect to assignments. View "Vance v. Ball State Univ." on Justia Law

The Texas university medical center has an agreement with Parkland Memorial Hospital, requiring the Hospital to offer vacant staff physician posts to University faculty members. A physician of Middle Eastern descent, both a University faculty member and a Hospital staff physician, claimed that Levine, one of his University supervisors, was biased against him because of his religion and ethnic heritage. He complained to Fitz, Levine’s super¬visor. He wanted to continue working at the Hospital without also being on the University faculty. He resigned his teaching post and sent a letter to Fitz and others, stating that he was leaving because of Levine’s harassment. Fitz, wanting public exoneration for Levine, objected to the Hospital’s job offer, which was then withdrawn. The doctor sued, claiming that Levine’s harassment resulted in his constructive discharge from the University, in violation of 42 U.S.C. 2000e–2(a), and that Fitz’s efforts to prevent his hiring were in retaliation for complaining about that harassment, in violation of section 2000e–3(a). A jury agreed on both claims. The Fifth Circuit vacated as to the constructive-discharge claim, but affirmed with respect to retaliation, reasoning that retaliation claims under 2000e–3(a) require only a showing that retaliation was a motivating factor for the adverse employment action, not its but-for cause. The Supreme Court vacated and remanded. Title VII retaliation claims must be proved according to traditional principles of but-for causation, not the lessened causation test stated in section 2000e–2(m). Title VII’s anti-retaliation provision appears in a different section from its status-based discrimination ban and uses the term “because,” indicating that retaliation claims require proof that desire to retaliate was the but-for cause of the challenged employment action. The Court noted that retaliation claims are made with “ever¬increasing frequency” and that lessening the standard could contribute to the filing of frivolous claims. View "Univ. of TX. SW Med. Ctr. v. Nassar" on Justia Law

The Drug Price Competition and Patent Term Restoration Act of 1984 (Hatch-Waxman Act), 21 U.S.C. 355(j)(2)(A)(vii)(IV) established procedures for identifying and resolving patent disputes between brand-name and generic drug manufacturers. One procedure requires a prospective generic manufacturer to certify to the FDA that any listed, relevant patent is invalid or will not be infringed by the manufacture, use, or sale of the generic drug (paragraph IV). Generic manufacturers filed paragraph IV applications for generic drugs modeled after Solvay’s FDA-approved, patented drug AndroGel. Solvay claimed patent infringement, 35 U.S.C. 271(e)(2)(A). The FDA approved the generic product, but the generic companies entered into “reverse payment” settlements, agreeing not to bring the generic to market for a number of years and to promote AndroGel to doctors in exchange for millions of dollars. The FTC sued, alleging violation of section 5 of the Federal Trade Commission Act by agreeing to abandon patent challenges, to refrain from launching low-cost generic drugs, and to share in Solvay’s monopoly profits. The district court dismissed. The Eleventh Circuit affirmed. The Supreme Court reversed and remanded, calling for application of a “rule of reason” approach rather than a “quick look.” Although the anti-competitive effects of the reverse settlement might fall within the exclusionary potential of Solvay’s patent, the agreement is not immune from antitrust attack. It would be incongruous to determine antitrust legality by looking only at patent law policy, and not at antitrust policies. The Court noted the Hatch-Waxman Act’s general pro-competitive thrust, facilitating challenges to a patent’s validity and requiring parties to a paragraph IV dispute to report settlement terms to antitrust regulators. Payment for staying out of the market keeps prices at patentee-set levels and divides the benefit between the patentee and the challenger, while the consumer loses. That a large, unjustified reverse payment risks antitrust liability does not prevent parties from settling their lawsuits; they may settle in other ways, e.g., by allowing the generic to enter the market before the patent expires without payment to stay out prior to that point. View "Fed. Trade Comm'n v. Actavis, Inc." on Justia Law

The Armed Career Criminal Act (ACCA) increases the sentences of federal defendants who have three prior convictions “for a violent felony,” including “burglary, arson, or extortion,” 18 U.S.C. 924(e). Under the “categorical approach” courts compare the statutory elements of a prior conviction with the elements of the “generic” crime, the offense as commonly understood. If the statutory elements are the same as, or narrower than, those of the generic offense, a prior conviction qualifies as an ACCA predicate. A “modified categorical approach” is employed when a prior conviction is for violating a “divisible statute” that sets out one or more elements in the alternative, such as burglary involving entry into a building or an automobile. That approach permits the court to consult certain documents, such as indictments and jury instructions, to determine which alternative element was the basis of the prior conviction. Descamps, convicted of being a felon in possession of a firearm, had three prior convictions, including one under a California statute, which provides that a “person who enters” certain locations “with intent to commit grand or petit larceny or any felony is guilty of burglary.” The district court concluded that the conviction could serve as an ACCA predicate. The Ninth Circuit affirmed. The Supreme Court reversed. Instead of reviewing extra-statutory documents only to determine which alternative element was the basis for the conviction, the Ninth Circuit examined those materials to discover what the defendant actually did. Generic unlawful entry is not an element, or an alternative element of, the California law, so a conviction under that statute is never for generic burglary and ACCA enhancement was improper. The modified categorical approach does not apply to statutes that contain a single, indivisible set of elements. An elements-centric categorical approach is consistent with ACCA’s text and history, avoids Sixth Amendment concerns arising from sentencing courts’ making factual findings that properly belong to juries, and averts “the practical difficulties and potential unfairness of a factual approach.”View "Descamps v. United States" on Justia Law

Davila, under indictment on tax fraud charges, wrote to the district court, expressing dissatisfaction with his court-appointed attorney, whom, he claimed, simply advised him to plead guilty. Davila requested new counsel. A magistrate held an in camera hearing with Davila and his attorney, but no representative of the prosecution, and told Davila that he would not get another court-appointed attorney and that his best course, given the strength of the prosecution’s case, was to plead guilty. More than three months later, Davila pleaded guilty to a conspiracy charge in exchange for dismissal of 33 other charges. He stated under oath that he was not forced or pressured to enter the plea and did not mention the hearing. Before sentencing, Davila moved to vacate his plea and dismiss the indictment, asserting that he had entered the plea to force the prosecution to acknowledge errors in the indictment. The district judge denied the motion, finding the plea knowing and voluntary. Davila did not mention the in camera hearing. The Eleventh Circuit held that the magistrate’s violation of Federal Rule of Criminal Procedure 11(c)(1), prohibiting court participation in plea discussions, required automatic vacatur. The Supreme Court vacated, noting that both Rule 11 and Rule 52(a), governing trial court error in general, allow for harmless error. Vacatur of the plea is not in order if the record shows no prejudice to Davila’s decision to plead guilty. Rule 11(c)(1) was adopted as a prophylactic measure, not one impelled by the Due Process Clause or any other constitutional requirement, so its violation does not belong in the highly exceptional category of structural errors (denial of counsel of choice or denial of a public trial) that trigger automatic reversal because they undermine the fairness of the entire criminal proceeding. The Court noted that three months elapsed between the in camera meeting and Davila’s appearance before the district judge who examined and accepted his guilty plea after an "exemplary" Rule 11 colloquy. View "United States v. Davila" on Justia Law