Justia U.S. Supreme Court Opinion Summaries

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

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

The Federal Election Campaign Act of 1971 and the Bipartisan Campaign Reform Act of 2002, impose base limits, restricting how much money a donor may contribute to a particular candidate or committee, and aggregate limits, restricting how much money a donor may contribute in total to all candidates or committees, 2 U.S.C. 441a. In the 2011–2012 election cycle, McCutcheon contributed to 16 federal candidates, complying with all base limits. He alleges that the aggregate limits prevented him from contributing to additional candidates and political committees and that he wishes to make similar contributions in the future. McCutcheon and the Republican National Committee challenged the aggregate limits under the First Amendment. The district court dismissed. The Supreme Court reversed, with five justices concluding that those limits are invalid. Regardless whether strict scrutiny or the “closely drawn” test applies, the analysis depends on the fit between stated governmental objectives and the means selected to achieve the objectives. The aggregate limits fail even under the “closely drawn” test. Contributing to a candidate is an exercise of the right to participate in the electoral process through political expression and political association. A restriction on how many candidates and committees an individual may support is not a “modest restraint.” To require a person to contribute at lower levels because he wants to support more candidates or causes penalizes that individual for “robustly exercis[ing]” his First Amendment rights. The proper focus is on an individual’s right to engage in political speech, not a collective conception of the public good. The aggregate limits do not further the permissible governmental interest in preventing quid pro quo corruption or its appearance. The justices noted the line between quid pro quo corruption and general influence and that the Court must “err on the side of protecting political speech.” Given regulations already in effect, fear that an individual might make massive unearmarked contributions to entities likely to support particular candidate is speculative. Experience suggests that most contributions are retained and spent by their recipients; the government provided no reason to believe that candidates or committees would dramatically shift their priorities if aggregate limits were lifted. Multiple alternatives could serve the interest in preventing circumvention without “unnecessary abridgment” of First Amendment rights, such as targeted restrictions on transfers among candidates and committees, tighter earmarking rules, and disclosure. View "McCutcheon v. Fed. Election Comm'n" on Justia Law

Northwest terminated plaintiff’s membership in its frequent flyer program. A provision in the frequent flyer agreement gave Northwest sole discretion to determine whether a participant had abused the program. Plaintiff claimed that Northwest breached its contract by revoking his membership without valid cause and violated the duty of good faith and fair dealing because it terminated his membership in a way that contravened his reasonable expectations. The district court dismissed, holding that the Airline Deregulation Act of 1978 pre-empted the breach of the duty of good faith and fair dealing claim. The Ninth Circuit reversed, finding that claim “too tenuously connected to airline regulation to trigger” ADA pre-emption. A unanimous Supreme Court reversed. The Act pre-empts a state-law claim for breach of the implied covenant of good faith and fair dealing if it seeks to enlarge contractual obligations that the parties voluntarily adopted. The Act prohibits states from “enact[ing] or enforc[ing] a law, regulation, or other provision having the force and effect of law related to [an air carrier’s] price, route, or service,” 49 U.S.C. 41713(b)(1). The phrase “other provision having the force and effect of law” includes state common-law rules like the claimed implied covenant. Exempting common-law claims would disserve the Act’s central purpose: to eliminate federal regulation of rates, routes, and services so they could be set by market forces. Northwest’s program connects to “rates” by awarding credits redeemable for tickets and upgrades, thus eliminating or reducing ticket prices. It also connects to “services,” i.e., access to flights and higher service categories. Because the implied covenant claim sought to enlarge contractual agreement, it is pre-empted. Under controlling Minnesota law, parties may not contract out of the implied covenant; when state law does not authorize parties to free themselves from the covenant, a breach of covenant claim is pre-empted. Participants in frequent flyer programs can protect themselves by avoiding airlines with poor reputations and enrolling in more favorable rival programs; the Department of Transportation has authority to investigate complaints about frequent flyer programs. The Court also noted that the plaintiff did not appeal his breach of contract claim. View "Northwest, Inc. v. Ginsberg" on Justia Law

Castleman was indicted under 18 U.S.C. 922(g)(9), for possession of a firearm by a person convicted of a “misdemeanor crime of domestic violence.” He argued that his Tennessee conviction for “intentionally or knowingly caus[ing] bodily injury to” the mother of his child did not qualify as a “misdemeanor crime of domestic violence” because it did not involve “use or attempted use of physical force.” The district court dismissed, reasoning that “physical force” must entail violent contact and that bodily injury can be caused without violent contact, e.g., by poisoning. The Sixth Circuit affirmed on different reasoning: that the degree of physical force required for a “misdemeanor crime of domestic violence” is the same as that required for a “violent felony” under the Armed Career Criminal Act, violent force, and that Castleman could have been convicted for causing slight injury by nonviolent conduct. The Supreme Court reversed, holding that section 922(g)(9)’s “physical force” requirement is satisfied by the “offensive touching” degree of force that supports a common-law battery conviction. Congress presumably intends to incorporate the common-law meaning of terms and nothing suggests a different intention here. While the word “violent” or “violence” standing alone “connotes a substantial degree of force,” “domestic violence,” is a term of art encompassing acts that one might not characterize as “violent” in a nondomestic context. There is no anomaly in grouping domestic abusers convicted of generic assault or battery offenses with others disqualified by section 922(g) from gun ownership. Application of the modified categorical approach—consulting the indictment to determine whether Castleman’s conviction entailed the elements necessary to constitute the generic federal offense—is straightforward. The “knowing or intentional causation of bodily injury” necessarily involved use of physical force. The common-law concept of “force” encompasses even its indirect application; the knowing or intentional application of force is a “use” of force. View "United States v. Castleman" 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

Quality Stores made severance payments to employees who were involuntarily terminated in its Chapter 11 bankruptcy. The payments were made pursuant to plans that did not tie payments to the receipt of state unemployment insurance and varied based on job seniority. Quality Stores paid and withheld taxes required under FICA, 26 U.S.C. 3101. Later, believing that the payments should not have been taxed as FICA wages, Quality Stores sought a refund on behalf of itself and about 1,850 former employees. The IRS neither allowed nor denied the refund, Quality Stores initiated proceedings in the Bankruptcy Court, which granted summary judgment in its favor. The district court and Sixth Circuit affirmed. The Supreme Court reversed, finding that the severance payments were taxable FICA wages. FICA defines “wages” broadly as “all remuneration for employment.” Severance payments are a form of remuneration made only to employees in consideration for employment. By varying according to a terminated employee’s function and seniority, the Quality Stores severance payments confirm the principle that “service” “mea[ns] not only work actually done but the entire employer-employee relationship for which compensation is paid.” FICA’s exemption for severance payments made because of "retirement for disability,” would be unnecessary were severance payments generally not considered wages. FICA has contained no general exception for severance payments since 1950. The Internal Revenue Code, section 3401(a), also has a broad definition of “wages” and specifies that “supplemental unemployment compensation benefits,” which include severance payments, be treated “as if” they were wages; simplicity of administration and consistency of statutory interpretation indicate that the meaning of “wages” should generally be the same for income-tax withholding and for FICA calculations. View "United States v. Quality Stores, Inc." on Justia Law

The General Railroad Right-of-Way Act of 1875 provides railroad companies “right[s] of way through the public lands of the United States,” 43 U.S.C. 934. One such right of way, created in 1908, crosses land that the government conveyed to the Brandt family in a 1976 land patent. That patent stated that the land was granted subject to the right of way, but it did not specify what would occur if the railroad relinquished those rights. A successor railroad abandoned the right of way with federal approval. The government sought a declaration of abandonment and an order quieting its title to the abandoned right of way, including the stretch across the Brandt patent. Brandt argued that the right of way was a mere easement that was extinguished upon abandonment. The district court quieted title in the government. The Tenth Circuit affirmed. The Supreme Court reversed. The right of way was an easement that was terminated by abandonment, leaving Brandt’s land unburdened. The Court noted that that the government had argued the opposite position in an earlier case. In that case, the Court found the 1875 Act’s text “wholly inconsistent” with the grant of a fee interest. An easement disappears when abandoned by its beneficiary. View "Marvin M. Brandt Revocable Trust v. United States" on Justia Law

Rosemond participated in a drug deal in which either he or one of his associates fired a gun. Because the shooter’s identity was disputed, the government charged Rosemond with violating 18 U.S.C. 924(c) by using or carrying a gun in connection with a drug trafficking crime, or, in the alternative, aiding and abetting that offense under 18 U.S.C. 2. The judge instructed the jury that Rosemond was guilty of aiding and abetting the section924(c) offense if he “knew his cohort used a firearm in the drug trafficking crime” and “knowingly and actively participated in the drug trafficking crime.” The instruction deviated from Rosemond’s proposed instruction that the jury must find that he acted intentionally “to facilitate or encourage” the firearm’s use. Rosemond was convicted. The Tenth Circuit affirmed. The Supreme Court vacated. The prosecution establishes that a defendant aided and abetted a 924(c) violation by proving that the defendant actively participated in the underlying drug trafficking or violent crime with advance knowledge that a confederate would use or carry a gun during commission of the crime. In addition to active conduct extending to some part of the crime, aiding and abetting requires intent extending to the whole crime. An active participant in a drug transaction has the intent needed to aid and abet a 924(c) violation when he knows that a confederate will carry a gun. This must be advance knowledge. The jury instructions were erroneous in failing to require that Rosemond knew in advance that an associate would be armed, with sufficient time to withdraw. The case was remanded for consideration of whether any error was harmless. View "Rosemond v. United States" on Justia Law

Alvarez and Lozano lived with their daughter in London until November 2008, when Alvarez and the child moved to a women’s shelter. In July 2009, they left the U.K., ultimately settling in New York. Lozano did not locate them until November 2010. He filed a Petition for Return of Child pursuant to the Hague Convention on the Civil Aspects of International Child Abduction. Under the Convention, if a parent files a petition within one year of the child’s removal, a court “shall order the return of the child forthwith.” When the petition is filed after that period, the court is to order return, “unless it is demonstrated that the child is now settled in its new environment.” Because it was filed more than one year after removal, the district court denied the petition, finding that the child was now settled. The Second Circuit and Supreme Court affirmed. There is no presumption that equitable tolling applies to treaties and the parties to the Convention did not intend that it apply to the one-year period. The International Child Abduction Remedies Act, 42 U. S. C. 11601–11610, enacted to implement the Convention, neither addresses equitable tolling nor purports to alter the Convention and, therefore, does not affect this conclusion. Even if the Convention were subject to a presumption that statutes of limitations may be tolled, the one-year period is not a statute of limitations. The remedy available to the left-behind parent continues to be available after one year; expiration of one year simply mandates consideration of a third party’s interests. The drafters did not choose to delay the period’s commencement until discovery of the child’s location. View "Lozano v. Montoya Alvarez" on Justia Law