Justia U.S. Supreme Court Opinion Summaries

Plaintiffs filed a putative collective action under the Fair Labor Standards Act, seeking backpay for time spent donning and doffing pieces of protective gear required by the employer because of hazards at its steel plants. The employer argued that the time, otherwise compensable under the Act, is noncompensable under its collective bargaining agreement with plaintiffs’ union. Under 29 U.S.C. 203(o), parties may collectively bargain over whether “time spent in changing clothes ... at the beginning or end of each workday” must be compensated. The district court granted the employer partial summary judgment. The Seventh Circuit and Supreme Court affirmed, concluding that the protective gear constitutes “clothes,” even if integral and indispensable to the work. Whether one exchanges street clothes for work clothes or simply layers one over the other may be a matter of purely personal choice, and section 203(o) should not be read to allow workers to opt into or out of its coverage at random or at will when another reading is textually permissible. Although safety glasses, earplugs, and a respirator do not fit the interpretation of “clothes,” the relevant question is whether the period at issue can, on the whole, be fairly characterized as “time spent in changing clothes or washing.” In this case, time spent donning and doffing safety glasses and earplugs was minimal. View "Sandifer v. United States Steel Corp." on Justia Law

The IRS advised Ford Motor that it had underpaid its taxes from 1983 until 1989. Ford remitted $875 million to stop the accrual of interest that Ford would otherwise owe once audits were completed and the amount of its underpayment was finally determined. Eventually it was determined that Ford had overpaid its taxes in the relevant years, entitling Ford to a return of the overpayment and. Ford argued that “the date of overpayment” for purposes of 26 U.S.C. 6611(a) was the date that it first remitted the deposits to the IRS. The IRS countered that the relevant date was the date that Ford requested that the IRS treat the remittances as payments of tax. The difference between the competing interpretations is worth some $445 million. The district court granted judgment on the pleadings in favor of the government. The Sixth Circuit affirmed, concluding that section 6611 is a waiver of sovereign immunity that must be strictly construed in favor of the government. The Supreme Court vacated and remanded, noting that the government was arguing, for the first time, that the only general waiver of sovereign immunity that encompasses Ford’s claim is the Tucker Act, 28 U. S. C. 1491(a). Although the government acquiesced in jurisdiction in the district court, the Tucker Act applies, jurisdiction over this case was proper only in the Court of Federal Claims. The Sixth Circuit should have the first opportunity to consider the argument. View "Ford Motor Co. v. United States" on Justia Law

Woods and McCombs participated in a tax shelter to generate paper losses to reduce their taxable income. They purchased currency-option spread packages consisting of a long option, for which they paid a premium, and a short option, which they sold and for which they collected a premium. Because the premium paid was largely offset by that received, the net cost of the packages was substantially less than the cost of the long option alone. Woods and McCombs contributed the spreads, plus cash, to partnerships, which used the cash to purchase stock and currency. In calculating their basis in the partnership interests, they considered only the long component of the spreads and disregarded the nearly offsetting short component. When the partnerships’ assets were disposed of for modest gains, they claimed huge losses. Although they had contributed $3.2 million in cash and spreads to the partnerships, they claimed losses of more than $45 million. The IRS sent notices, finding that the partnerships lacked “economic substance,” disallowing related losses, and concluding that the partners could not claim a basis greater than zero for their partnership interests and that tax underpayments would be subject to a 40-percent penalty for gross valuation misstatements. The district court held that the partnerships were properly disregarded as shams but that the penalty did not apply. The Fifth Circuit affirmed. The Supreme Court reversed, first holding that the district court had jurisdiction to make the determination. The Tax Equity and Fiscal Responsibility Act authorizes courts in partnership-level proceedings to provisionally determine the applicability of any penalty that could result from an adjustment to a partnership item, even though imposing the penalty requires a subsequent, partner-level proceeding. In the later proceeding, a partner may raise reasons why the penalty may not be imposed on him personally. However, the valuation-misstatement penalty applies in this case. Once the partnerships were deemed shams, no partner could legitimately claim a basis greater than zero. Any underpayment resulting from use of a non-zero basis would be attributable to a partner having claimed an adjusted basis that exceeded the correct amount. When an asset’s adjusted basis is zero, a valuation misstatement is automatically deemed gross. The valuation¬misstatement penalty encompasses misstatements that rest on both legal and factual errors, so it is applicable to misstatements that rest on use of a sham partnership. View "United States v. Woods" on Justia Law

Residents of Argentina sued Daimler, a German company, in a California federal district court, alleging that Mercedes-Benz Argentina, a Daimler subsidiary, collaborated with state security forces during Argentina’s 1976–1983 “Dirty War” to kidnap, detain, torture, and kill MB Argentina workers, related to the plaintiffs. They asserted claims under the Alien Tort Statute and the Torture Victim Protection Act of 1991, and under California and Argentina law. Personal jurisdiction was predicated on the California contacts of Mercedes-Benz USA (MBUSA), another Daimler subsidiary, incorporated in Delaware with its principal place of business in New Jersey. MBUSA distributes Daimler-manufactured vehicles to independent U.S. dealerships, including some in California. The district court dismissed. The Ninth Circuit reversed, holding that MBUSA, which it assumed to fall within the California courts’ all-purpose jurisdiction, was Daimler’s “agent” for jurisdictional purposes. The Supreme Court reversed. Daimler is not amenable to suit in California for injuries allegedly caused by MB Argentina outside the U.S. California’s long-arm statute allows the exercise of personal jurisdiction to the full extent permissible under the U. S. Constitution. Even if California is home to MBUSA, Daimler’s affiliations with California are not sufficient to subject it to the general jurisdiction of that State’s courts. The proper inquiry is whether a foreign corporation’s “affiliations with the State are so ‘continuous and systematic’ as to render [it] essentially at home in the forum State.” Neither Daimler nor MBUSA is incorporated in California; neither has its principal place of business there. If Daimler’s California activities sufficed to allow adjudication of this case in California, the same global reach would presumably be available in every other state in which MBUSA’s sales are sizable. View "Daimler AG v. Bauman" on Justia Law

The California Supreme Court held that limiting marriage to opposite-sex couples violated the California Constitution; state voters then passed a ballot initiative, Proposition 8, amending the state constitution to define marriage as a union between a man and a woman. Same-sex couples who wished to marry filed suit in federal court, challenging Proposition 8. State officials refused to defend the law, so the district court allowed the initiative’s official proponents to intervene, declared Proposition 8 unconstitutional, and enjoined its enforcement. State officials declined to appeal. The intervenors appealed. The Ninth Circuit certified a question, which the California Supreme Court answered: official proponents of a ballot initiative have authority to assert the state’s interest to defend the constitutionality of the initiative when public officials refuse to do so. The Ninth Circuit concluded that petitioners had standing and affirmed. The Supreme Court vacated and remanded, holding that the intervenors did not have standing to appeal. Article III of the Constitution confines the power of federal courts to deciding actual “Cases” or “Controversies.” A litigant must demonstrate a personal and tangible harm throughout all stages of litigation. The intervenors had standing to initiate this case against the California officials responsible for enforcing Proposition 8, but once the district court issued its order, they no longer had any injury to redress and state officials chose not to appeal. The intervenors had not been ordered to do or refrain from doing anything. Their “generalized grievance” is insufficient to confer standing. The fact that a state thinks a private party should have standing to seek relief for a generalized grievance cannot override settled law to the contrary. View "Hollingsworth v. Perry" on Justia Law

Titlow and Rogers were charged with the murder of Rogers’s husband. After explaining to Titlow that the evidence could support a first-degree murder conviction, Titlow’s attorney negotiated a manslaughter plea in exchange for testimony against Rogers. Three days before trial, Titlow retained a new attorney, Toca, who demanded a lower sentence in exchange for the plea and testimony. The prosecutor rejected the proposal. Titlow withdrew the plea. Rogers was acquitted. Titlow was convicted of second-degree murder. On direct appeal, Titlow argued that Toca provided ineffective assistance by advising plea withdrawal without determining the strength of the evidence. The Michigan Court of Appeals concluded that Toca’s actions were reasonable, given his client’s claims of innocence. The federal district court denied habeas relief. The Sixth Circuit reversed, holding that the factual predicate for the state court’s decision, that the plea withdrawal was based on Titlow’s assertion of innocence, unreasonable, given Toca’s explanation at the withdrawal hearing that the plea offer was higher than the Michigan guidelines sentencing range. The Supreme Court reversed, applying the “doubly deferential” standard of review set forth in the Antiterrorism and Effective Death Penalty Act, 28 U.S.C. 2254(d)(2). The record supports a factual finding that Toca advised withdrawal of the guilty plea only after Titlow’s proclamation of innocence. Titlow passed a polygraph test, discussed the case with a jailer who advised against pleading guilty if Titlow was innocent, and hired Toca days before the trial at which Titlow was to self-incriminate. The facts strongly suggest that Titlow had second thoughts about confessing and proclaimed her innocence. The Sixth Circuit’s conclusion that Toca was ineffective because the record contained no evidence that he gave constitutionally adequate advice is contrary to the principle that counsel should be “strongly presumed to have rendered adequate assistance.” That Toca failed to retrieve the file from former counsel before withdrawing the plea cannot overcome that presumption. Titlow admitted in open court that former counsel had explained that the evidence would support a first-degree murder conviction. Toca justifiably relied on this to conclude that Titlow understood the strength of the prosecution’s case. View "Burt v. Titlow" on Justia Law

Sprint, a national telecommunications company, declined to pay intercarrier access fees imposed by Windstream, an Iowa telecommunications carrier, for long distance Voice over Internet Protocol (VoIP) calls, concluding that the Telecommunications Act of 1996 (TCA) preempted intrastate regulation of VoIP traffic. Windstream threatened to block Sprint customer calls; Sprint sought an injunction from the Iowa Utilities Board (IUB). Windstream retracted its threat, and Sprint sought to withdraw its complaint. Concerned that the dispute would recur, IUB continued the proceedings, ruling that intrastate fees applied to VoIP calls. Sprint sought a declaration that the TCA preempted the IUB decision. Sprint also sought review in Iowa state court. Invoking Younger v. Harris, the district court abstained from adjudicating Sprint’s complaint in deference to the state-court proceeding. The Eighth Circuit affirmed, concluding that Younger abstention was required because the state-court review concerned Iowa’s important interest in regulating and enforcing state utility rates. The Supreme Court reversed. The case does not fall within any of the classes of exceptional cases for which Younger abstention is appropriate to avoid federal intrusion into ongoing state criminal prosecutions; interfering with pending “civil proceedings . . . uniquely in furtherance of the state courts’ ability to perform their judicial functions;” and certain civil enforcement proceedings. IUB’s proceeding was not criminal and did not touch on a state court’s ability to perform its judicial function. Nor is the IUB order an act of civil enforcement of the kind to which Younger has been extended; the proceeding is not “akin to a criminal prosecution,” nor was it initiated by “the State in its sovereign capacity,” to sanction a wrongful act. The court rejected an argument that once Sprint withdrew its complaint the proceedings became, essentially, a civil enforcement action. IUB’s authority was invoked to settle a civil dispute between private parties. View "Sprint Commc'ns, Inc. v. Jacobs" on Justia Law

Officer Stanton and his partner responded to a call about a disturbance involving a person with a baseball bat. Stanton was familiar with the LaMesa neighborhood, known for gang violence. The officers, wearing uniforms and driving a marked police vehicle, approached the location and noticed men walking in the street. Seeing the police car, two men turned into an apartment complex. Patrick crossed the street about 25 yards in front of Stanton’s car and ran toward a residence. Stanton did not see a baseball bat, but considered Patrick’s behavior suspicious and decided to investigate. Stanton exited his car, called out “police,” and ordered Patrick to stop. Patrick did not stop, but “looked directly at Stanton,” and went through the gate of the six-foot wooden fence enclosing Sims’ front yard. Stanton believed that Patrick had committed a jailable misdemeanor by disobeying his order, “fear[ed] for [his] safety” and made the “split-second decision” to kick open the gate. Sims was behind the gate when it flew open, striking and injuring Sims. Sims sued, 42 U. S. C. 1983. The district court granted summary judgment to Stanton. The Ninth Circuit reversed, holding that Stanton’s warrantless entry was unconstitutional because Sims had the same expectation of privacy in her curtilage as in her home itself, there was no immediate danger, and Patrick had committed only a minor offense; under clearly established law Stanton’s pursuit of Patrick did not justify warrantless entry and Stanton was not entitled to qualified immunity. The Supreme Court reversed, noting that courts nationwide are divided on whether an officer with probable cause to arrest a suspect for a misdemeanor may enter a home without a warrant while in hot pursuit of that suspect. The Ninth Circuit read “too broadly” Supreme Court precedent that did not involve hot pursuit. The Court did not determine whether Stanton’s entry was constitutional; Stanton may have been mistaken in believing his actions were justified, but was not “plainly incompetent.” View "Stanton v. Sims" on Justia Law

Hartford is the administrator of Wal-Mart’s Group Disability Plan, which is covered by the Employee Retirement Income Security Act. The policy requires any suit to recover benefits pursuant to ERISA, 29 U. S. C. 1132(a)(1)(B), to be filed within three years after “proof of loss” is due. Heimeshoff filed a claim for long-term disability benefits. Following mandatory administrative review process, Hartford issued a final denial. Almost three years after the final denial but more than three years after proof of loss was due, Heimeshoff sought judicial review under ERISA. The district court dismissed, reasoning that while ERISA does not provide a statute of limitations, the contractual limitations period was enforceable under state law and Circuit precedent. The Second Circuit affirmed. The Supreme Court affirmed, finding the limitations provision enforceable. A participant’s ERISA cause of action does not accrue until the plan issues a final denial, but it does not follow that a plan and its participants cannot agree to commence the limitations period before that time. The Court noted that contractual limitations provisions should ordinarily be enforced as written. The period at issue is not unreasonably short and does not undermine ERISA’s two-tiered remedial scheme by causing participants to shortchange the internal review process. If administrators attempt to prevent judicial review by delaying the resolution of claims in bad faith, the penalty for failure to meet regulatory deadlines is immediate access to judicial review for the participant and courts can apply waiver or estoppel. Plans offering appeals beyond what is contemplated in the internal review regulations must agree to toll the limitations provision during that time, 29 CFR 2560.503–1(c)(3)(ii). View "Heimeshoff v. Hartford Life & Accident Ins. Co." on Justia Law

After Cheever was charged with capital murder, the Kansas Supreme Court found the state death penalty scheme unconstitutional. State prosecutors dismissed their charges to allow federal authorities to prosecute Cheever, who filed notice of intent to introduce expert evidence that methamphetamine intoxication negated his ability to form specific intent. The district court ordered Cheever to submit to a psychiatric evaluation. The federal case was eventually dismissed. In the meantime, the Supreme Court found the Kansas death penalty scheme constitutional. The state brought a second prosecution. Cheever raised a voluntary intoxication defense, offering expert testimony regarding his methamphetamine use. The prosecution sought to present testimony from the expert who had examined Cheever by the federal court order. Defense counsel argued that since Cheever had not agreed to the examination, introduction of the testimony would violate the Fifth Amendment. The trial court allowed the testimony. The jury found Cheever guilty and imposed a death sentence. The Kansas Supreme Court vacated the conviction. A unanimous Supreme Court vacated and remanded. If a defense expert who has examined the defendant testifies that the defendant lacked the requisite mental state, the prosecution may present psychiatric evidence in rebuttal. The rule is not limited to situations where the evaluation was requested jointly by the defense and the prosecution, nor does it matter whether state law referred to extreme emotional disturbance as an affirmative defense. The Court rejected an argument that Cheever did not waive his Fifth Amendment privilege because voluntary intoxication is not a mental disease or defect under state law. Mental status, rather than “Mental disease or defect” is the salient issue. When a criminal defendant chooses to testify, the Fifth Amendment does not allow him to refuse to answer related cross-examination questions. Excluding the testimony would have undermined the core truth-seeking function of trial. View "Kansas v. Cheever" on Justia Law