Justia U.S. Supreme Court Opinion Summaries

At 2:00 a.m., December 31, 2008, Officer Edwards was patrolling Bellaire, Texas. He saw a black Nissan SUV park in front of a house; Tolan and Cooper emerged. Edwards attempted to enter the license plate number into his squad car computer, but entered an incorrect character that matched a stolen vehicle of the same color and make, which triggered an automatic alert to other police units. Edwards exited his cruiser, drew his gun and ordered the men to the ground. Accused of having stolen the car, Cooper responded, “That’s not true” and Tolan stated, “That’s my car.” Tolan laid down on the porch of the home where he lived with his parents, who came outside. Tolan’s father told Cooper to lie down, then identified Tolan and Cooper (his nephew). Tolan’s mother stated that the vehicle belonged to the family. Sergeant Cotton arrived and drew his pistol. Tolan’s mother reiterated that they owned the car. Cotton ordered her to stand against the garage. She responded, “[A]re you kidding me? We’ve lived her[e] 15 years.” Tolan, his mother, and Cooper later testified that Cotton grabbed her arm and slammed her against the garage with such force that she fell to the ground. There was photographic evidence of bruises on her arms and back. Cotton testified that he was escorting her to the garage, when she flipped her arm up and told him to get his hands off her. Tolan testified that, seeing his mother being pushed, he rose to his knees. Edwards and Cotton testified that Tolan rose to his feet. All agree that Tolan exclaimed, “[G]et your fucking hands off my mom.” Cotton drew his pistol and fired at Tolan, hitting Tolan’s chest, collapsing his right lung and piercing his liver. He survived, but suffered an injury that disrupted his budding baseball career and causes him pain on a daily basis. Dismissing a suit under 42 U.S.C. 1983, the district court found that Cotton’s use of force was not unreasonable. The Fifth Circuit affirmed. The Supreme Court vacated. In holding that Cotton’s actions did not violate clearly-established law, the Fifth Circuit failed to view the evidence in the light most favorable to Tolan as required on summary judgment; it failed to credit evidence that contradicted key factual conclusions, concerning whether the porch was dimly-lit, whether Tolan’s mother refused to remain calm, whether Tolan was verbally threatening, and whether Tolan was moving to intervene. View "Tolan v. Cotton" on Justia Law

The Copyright Act protects works published before 1978 for 28 years, renewable for up to 67 years, 17 U.S.C. 304(a). An author’s heirs inherit renewal rights. If an author who has assigned rights dies before the renewal period the assignee may continue to use the work only if the author’s successor transfers renewal rights to the assignee. The Act provides for injunctive relief and damages. Civil actions must be commenced within three years after the claim accrued-ordinarily when an infringing act occurred. Under the separate-accrual rule, each successive violation starts a new limitations period, but is actionable only within three years of its occurrence. The movie, Raging Bull, is based on the life of boxer Jake LaMotta, who, with Petrella, told his story in a screenplay copyrighted in 1963. In 1976 they assigned their rights and renewal rights to MGM. In 1980 MGM released, and registered a copyright in, Raging Bull. Petrella died during the initial copyright term, so renewal rights reverted to his daughter, who renewed the 1963 copyright in 1991. Seven years later, she advised MGM that it was violating her copyright. Nine years later she filed suit, seeking damages and injunctive relief for violations occurring after January 5, 2006. The district court dismissed, citing laches. The Ninth Circuit affirmed. The Supreme Court reversed. Laches cannot bar a claim for damages brought within the three-year window. By permitting retrospective relief only three years back, the limitations period takes account of delay. Noting the “essentially gap-filling, not legislation-overriding,” nature of laches, the Court stated that it has never applied laches to entirely bar claims for discrete wrongs occurring within a federally prescribed limitations period. It is not incumbent on copyright owners to challenge every actionable infringement; there is nothing untoward about waiting to see whether a violation undercuts the value of the copyrighted work, has no effect, or even complements the work. The limitations period, with the separate-accrual rule, allows an owner to defer suit until she can estimate whether litigation is worth the effort. Because a plaintiff bears the burden of proof, evidence unavailability is as likely to affect plaintiffs as defendants. The Court noted that in some circumstances, the equitable defense of estoppel might limit remedies. Allowing this suit to proceed will put at risk only a fraction of what MGM has earned from Raging Bull and will work no unjust hardship on innocent third parties. Should Petrella prevail on the merits, the court may fashion a remedy taking account of the delay and MGM’s alleged reliance on that delay. View "Petrella v. Metro-Goldwyn-Mayer, Inc." on Justia Law

Defendant pleaded guilty to capital murder, capital kidnaping, and first-degree rape, the statutory aggravating circumstance for the murder. At the penalty phase, the trial court denied defense counsel’s request to instruct the jury not to draw any adverse inference from defendant’s decision not to testify. He was sentenced to death. The Kentucky Supreme Court affirmed, finding that the Fifth Amendment’s requirement of a no-adverse-inference instruction to protect a non-testifying defendant at the guilt phase is not required at the penalty phase. The district court granted federal habeas relief. The Sixth Circuit affirmed. The Supreme Court reversed, holding that the Kentucky Supreme Court’s rejection of the Fifth Amendment claim was not objectively unreasonable. The high standard of 28 U.S.C. 2254(d) permits federal habeas relief only if adjudication on the merits in state court “resulted in a decision that was contrary to, or involved an [objectively] unreasonable application of, clearly established Federal law, as determined by” the Supreme Court. After examining its own precedent, the Court stated that the Kentucky Supreme Court’s conclusion was not an unreasonable application of the holdings in those cases, which cannot be read to require the type of blanket no-adverse-inference instruction requested and denied here. The defendant’s own admissions of guilt had established every relevant fact on which Kentucky bore the burden of proof. Section 2254(d)(1) does not require state courts to extend Supreme Court precedent or license federal courts to treat the failure to do so as error. The appropriate time to consider, as a matter of first impression, whether the cited cases require a penalty-phase no-adverse-inference instruction would be on direct review, not in a section 2254(d) habeas case. View "White v. Woodall" on Justia Law

The victim was sexually abused as a young girl during production of child pornography. When she was 17, she learned that images of her abuse were being trafficked on the Internet. Paroline pleaded guilty to possessing images of child pornography, 18 U.S.C. 2252, including two of the victim, who sought restitution under section 2259--about $3 million in lost income and $500,000 for future treatment and counseling. The district court declined to award restitution, citing failure to prove proximate cause. The Fifth Circuit held that each defendant who possessed the victim’s images should be held liable for the victim’s entire losses. The Supreme Court reversed. Section 2259 restitution is proper only to the extent the defendant’s offense proximately caused a victim’s losses. The prosecution has the burden of demonstrating the amount of the loss and proximate cause. Victims should be compensated and defendants should be held liable for the impact of their conduct on those victims, but not for the conduct of others. In this case, it is simple to prove aggregate losses: the victim’s costs of treatment and lost income resulting from the trauma of knowing that images of her abuse are being viewed over and over are direct and foreseeable results of child-pornography crimes. It is not possible, however, to prove that the victim’s losses would be less “but for’ one possessor’s individual role in the large, loosely connected network through which her images circulate. While it would be anomalous to deny redress to a person harmed by the combined acts of many wrongdoers simply because no wrongdoer alone caused the harm, aggregate causation logic should not be adopted incautiously for criminal restitution. The victim’s proposed theory would pose problems because there is no general federal right to contribution and no specific statutory authorization in this case; her approach could also raise questions under the Eighth Amendment Excessive Fines Clause. A court should order restitution that comports with the defendant’s relative role in the causal process underlying the victim’s general losses. A variety of factors may serve as guideposts in arriving at the relative causal significance of the defendant’s conduct. Congress has not promised victims full and swift restitution at the cost of holding a defendant liable for an amount drastically out of proportion to his individual causal relation to those losses. View "Paroline v. United States" on Justia Law

After the Supreme Court decided that the University of Michigan’s undergraduate admissions plan’s use of race-based preferences violated the Equal Protection Clause, but that its law school admission plan’s limited use did not, Michigan voters adopted a new section of the state constitution (Proposal 2), prohibiting use of race-based preferences in the admissions process for state universities. The district court upheld Proposal 2, but the Sixth Circuit reversed, concluding that it violated Supreme Court precedent. The Supreme Court reversed. Justice Kennedy, with Chief Justice Roberts and Justice Alito, reasoned that the principle that consideration of race in admissions is permissible when certain conditions are met was not challenged; the issue was whether, and how, state voters may choose to prohibit consideration of such racial preferences. The decision by Michigan voters reflects an ongoing national dialogue; there was no infliction of a specific injury of the type at issue in cases cited by the Sixth Circuit. Individual liberty has constitutional protection, but the Constitution also embraces the right of citizens to act through a lawful electoral process, as Michigan voters did. Justices Scalia and Thomas stated that the question here, as in every case in which neutral state action is said to deny equal protection on account of race, is whether the challenged action reflects a racially discriminatory purpose. Stating that it did not, the Justices stated that the proposition that a facially neutral law may deny equal protection solely because it has a disparate racial impact “has been squarely and soundly rejected.” Justice Breyer agreed that the amendment is consistent with the Equal Protection Clause, but reasoned that the amendment only applies to, and forbids, race-conscious admissions programs that consider race solely in order to obtain the educational benefits of a diverse student body; the Constitution permits, but does not require, the use of that kind of race-conscious program. The ballot box, not the courts, is the instrument for resolving debates about such programs. This case does not involve a diminution of the minority’s ability to participate in the political process. View "Schuette v. Coal. Defend Affirmative Action, Integration & Immigration Rights" on Justia Law

The Patent Act provides: “The court in exceptional cases may award reasonable attorney fees to the prevailing party,” 35 U.S.C. 285. The Federal Circuit has interpreted section 285 as authorizing fee awards only “when there has been some material inappropriate conduct,” or when it is both “brought in subjective bad faith” and “objectively baseless.” A health insurance company obtained a declaratory judgment that a patent was invalid and not infringed. The district court found the case “exceptional” and awarded attorney fees of $4,694,727.40, $209,626.56 in expenses, and $375,400.05 in expert fees. The court found a pattern of “vexatious” and “deceitful” conduct by the defendant in attempting to force other companies to purchase licenses, even after its own experts determined that its claims lacked merit. The Federal Circuit reviewed the determination de novo and reversed in part. A unanimous Supreme Court vacated. All aspects of a district court’s exceptional-case determination should be reviewed for abuse of discretion. That determination is based on statutory text that emphasizes that the district court is better positioned to make the “multifarious and novel” determination, which is not susceptible to “useful generalization” of the sort that de novo review provides, and is “likely to profit from the experience that an abuse-of discretion rule will permit to develop.” The word “exceptional” should be given its ordinary meaning: “one that stands out from others with respect to the substantive strength of a party’s litigating position (considering both the governing law and the facts of the case) or the unreasonable manner in which the case was litigated,” considering the totality of the circumstances. View "Highmark Inc. v. Allcare Health Mgmt. Sys., Inc." on Justia Law

The Patent Act authorizes district courts to award attorney’s fees to prevailing parties in “exceptional cases,” 35 U.S.C. 285. In Brooks Furniture, the Federal Circuit defined an “exceptional case” as one which either involves “material inappropriate conduct” or is both “objectively baseless” and “brought in subjective bad faith” as shown by clear and convincing evidence. ICON sued Octane for patent infringement. The district court granted summary judgment to Octane, but denied attorney’s fees under section 285. The Federal Circuit affirmed. The Supreme Court reversed, finding the Brooks Furniture framework “unduly rigid’ in light of the statutory grant of discretion to district courts. Section 285 imposes only one constraint on the award of attorney’s fees, limiting it to “exceptional” cases. Because the Patent Act does not define “exceptional,” the term should be given it ordinary meaning: “uncommon,” “rare,” or “not ordinary.” An “exceptional” case is simply one that stands out from others with respect to the substantive strength of a party’s litigating position (considering both governing law and the facts) or the unreasonable manner in which the case was litigated. District courts may determine whether a case is “exceptional” in the case-by-case exercise of their discretion, considering the totality of the circumstances. The Brooks Furniture standard was so demanding that it appeared to render section 285 superfluous of the courts’ inherent power to award fees in cases involving misconduct or bad faith. Section 285 imposes no specific evidentiary burden. View "Octane Fitness, LLC v. ICON Health & Fitness, Inc." on Justia Law

The Clean Air Act (CAA) requires national ambient air quality standards (NAAQS) for pollutants at levels that will protect public health, 42 U.S.C. 7408. Once EPA establishes NAAQS, it designates “nonattainment” areas; each state must submit a State Implementation Plan, (SIP), within three years of any new or revised NAAQS. From the date EPA determines that a SIP is inadequate, EPA has two years to promulgate a Federal Implementation Plan (FIP). SIPs must comply with a Good Neighbor Provision, and “contain adequate provisions ... prohibiting .. . any source or other type of emissions activity within the State from emitting any air pollutant in amounts which will ... contribute significantly to nonattainment in, or interfere with maintenance by, any other State with respect to” NAAQS. In response to flaws in its 2005 Clean Air Interstate Rule, identified by the D. C. Circuit, EPA promulgated the Cross-State Air Pollution Rule (Transport Rule), curbing nitrogen oxide and sulfur dioxide emissions in 27 upwind states to achieve downwind attainment of three NAAQS and providing that an upwind state contributed significantly to downwind nonattainment if its exported pollution produced at least one percent of a NAAQS in a downwind state and could be eliminated cost-effectively. EPA created an annual emissions “budget” for each upwind state and contemporaneously promulgated FIPs allocating each state’s budget among its pollution sources. The D.C. Circuit vacated the rule as exceeding EPA’s authority. The Supreme Court reversed. The CAA does not require that states be given another opportunity to file a SIP after EPA has quantified interstate pollution obligations. Disapproval of a SIP, without more, triggers EPA’s obligation to issue a FIP within precise deadlines. That EPA had previously accorded upwind states a chance to allocate emission budgets among their sources does not show that it acted arbitrarily by refraining to do so in this instance. The Good Neighbor Provision does not dictate a method of apportionment, so EPA had authority to select from among reasonable options; nothing precludes the final calculation from relying on costs. By imposing uniform cost thresholds on regulated states, the rule is efficient and is stricter on states that have done less pollution control in the past and does not amount to “over-control.” View "Envtl. Prot. Agency v. EME Homer City Generation, L. P." on Justia Law

A California Highway Patrol officer stopped a pickup truck that matched the description of a vehicle that a 911 caller had recently reported as having run her off the road. As officers approached the truck, they smelled marijuana. They searched the truck’s bed, found 30 pounds of marijuana, and arrested defendants, who moved to suppress the evidence, arguing that the traffic stop violated the Fourth Amendment. The motion was denied. They pleaded guilty to transporting marijuana. The California Court of Appeal and the U.S. Supreme Court affirmed. The Fourth Amendment permits brief investigative stops when an officer has “a particularized and objective basis for suspecting the particular person stopped of ... criminal activity.” Reasonable suspicion considers “the totality of the circumstances,” and depends “upon both the content of information possessed by police and its degree of reliability.” The totality of the circumstances indicated that the officer had reasonable suspicion that the truck’s driver was intoxicated. The 911 call bore adequate indicia of reliability for the officer to credit the caller’s account. The caller claimed an eyewitness basis of knowledge. The apparently short time between the reported incident and the 911 call suggests that the caller had little time to fabricate the report. A reasonable officer could conclude that a false tipster would think twice before using the 911 system. The tip created reasonable suspicion of drunk driving. Reasonable suspicion “need not rule out the possibility of innocent conduct.” The officer’s failure to observe additional suspicious conduct during the short period that he followed the truck did not dispel the reason able suspicion of drunk driving. View "Navarette v. California" on Justia Law

Lexmark sells the only type of toner cartridges that work with its laser printers; remanufacturers acquire and refurbish used Lexmark cartridges to sell in competition with Lexmark’s new and refurbished cartridges. Lexmark’s “Prebate” program gives customers a discount on new cartridges if they agree to return empty cartridges to the company. Every Prebate cartridge has a microchip that disables the empty cartridge unless Lexmark replaces the chip. Static Control makes and sells components for cartridge remanufacture and developed a microchip that mimicked Lexmark’s. Lexmark sued for copyright infringement. Static Control counterclaimed that Lexmark engaged in false or misleading advertising under the Lanham Act, 15 U.S.C. 1125(a), and caused Static Control lost sales and damage to its business reputation. The district court held that Static Control lacked “prudential standing,” applying a multifactor balancing test. The Sixth Circuit reversed, applying a “reasonable interest” test. A unanimous Supreme Court affirmed. The Court stated that the issue was not “prudential standing.” Whether a plaintiff comes within a statute’s zone of interests requires traditional statutory interpretation. The Lanham Act includes in its statement of purposes, “protect[ing] persons engaged in [commerce within the control of Congress] against unfair competition.” “Unfair competition” is concerned with injuries to business reputation and sales. A section 1125(a) plaintiff must show that its injury flows directly from the deception caused by the defendant’s advertising; that occurs when deception causes consumers to withhold trade from the plaintiff. The zone-of-interests test and the proximate-cause requirement identify who may sue under section 1125(a) and provide better guidance than the multi-factor balancing test, the direct-competitor test, or the reasonable-interest test. Static Control comes within the class of plaintiffs authorized to sue under section 1125(a). Its alleged injuries fall within the zone of interests protected by the Act, and it sufficiently alleged that its injuries were proximately caused by Lexmark’s misrepresentations. View "Lexmark Int’l, Inc. v. Static Control Components, Inc." on Justia Law