Justia U.S. Supreme Court Opinion Summaries

In a maritime insurance dispute between Great Lakes Insurance, a German company, and Raiders Retreat Realty, a Pennsylvania company, the Supreme Court of the United States ruled that choice-of-law provisions in maritime contracts are presumptively enforceable under federal maritime law, with certain narrow exceptions not applicable in this case.The dispute originated when Raiders Retreat Realty's boat ran aground, and Great Lakes Insurance denied coverage, alleging that Raiders breached the insurance contract by failing to maintain the boat’s fire-suppression system. The insurance contract contained a choice-of-law provision that selected New York law to govern future disputes. Raiders argued that Pennsylvania law, not New York law, should apply. The District Court ruled in favor of Great Lakes, finding that the choice-of-law provision was presumptively valid and enforceable under federal maritime law. The Third Circuit Court of Appeals vacated this decision, holding that choice-of-law provisions must yield to the strong public policy of the state where the suit is brought.The Supreme Court reversed the Third Circuit's decision, emphasizing the importance of uniformity and predictability in maritime law. The Court concluded that choice-of-law provisions allow maritime actors to avoid later disputes and the ensuing litigation and costs, thus promoting maritime commerce. Therefore, such provisions are presumptively enforceable under federal maritime law. The Court further clarified that exceptions to this rule exist but are narrow, and none of them applied in this case. View "Great Lakes Insurance SE v. Raiders Retreat Realty Co." on Justia Law

A consumer, Reginald Kirtz, secured a loan from the Rural Housing Service, part of the U.S. Department of Agriculture. Although Kirtz repaid his loan by mid-2018, the USDA continued to tell credit report company TransUnion that his account was past due, harming his credit score. The USDA failed to correct its records after being notified of the error, and Kirtz sued the agency under the Fair Credit Reporting Act.The USDA argued that the case should be dismissed based on sovereign immunity, since the Supreme Court has held that the federal government is immune from suits for damages unless Congress waives that immunity. The agency claimed that the FCRA does not make the federal government amenable to suit for a violation. The district court agreed, but the Third Circuit Court of Appeals reversed, finding that the FCRA authorizes suits for damages against any person who violates the Act, and “person” is defined to include any government agency.The U.S. Supreme Court affirmed the decision of the Third Circuit, finding that sovereign immunity did not bar Kirtz’s claim. The Court held that the federal government is susceptible to suit when it provides false information to credit reporting agencies. It noted that dismissing a suit like Kirtz’s case would effectively negate a claim that Congress has clearly authorized. The Court’s ruling resolved a circuit split between the Third, Seventh, and D.C. Circuits, with which the Court agreed, and the Fourth and Ninth Circuits, with which it disagreed. View "Department of Agriculture Rural Development Rural Housing Service v. Kirtz" on Justia Law

Trevor Murray worked as a research strategist at UBS, a securities firm. His job involved reporting on commercial mortgage-backed securities markets to current and future customers. Under SEC regulations, Murray was required to certify that his reports were produced independently and reflected his own views. When two leaders of the CMBS trading desk pressured him to make his reports more supportive of their business strategies, Murray told his supervisor about it. The supervisor told Murray not to alienate the trading desk and to write what the business line wanted. He eventually recommended that Murray be removed from his position, despite having recently given him a strong performance review. When the CMBS trading desk did not accept Murray as a transfer, he was fired.Murray argued that he was terminated in violation of the whistleblower protection provision in the Sarbanes-Oxley Act because UBS fired him in response to his internal reporting about fraud on shareholders. He prevailed at trial, but the Second Circuit Court of Appeals vacated the jury’s verdict and remanded for a new trial. It found that the whistleblower protection provision requires an employee to prove retaliatory intent, which a clarifying jury instruction had not properly indicated.The U.S. Supreme Court disagreed, instead agreeing with the Fifth and Ninth Circuits that the whistleblower protection provision does not impose this type of requirement. The Court acknowledged that a whistleblower must prove that his protected activity was a contributing factor in the adverse action against him, but it noted that the text of the statute does not include or refer to a requirement of proving retaliatory intent, which it treated as similar to “animus.” The Court noted that the statute contains a burden-shifting framework, requiring the whistleblower to show that their protected activity was a contributing factor in the adverse action, after which the employer must show that it would have taken the same action anyway. It found that a requirement of proving retaliatory intent would be incompatible with the burden-shifting framework. View "Murray v. UBS Securities, LLC" on Justia Law

Deborah Laufer has filed numerous lawsuits against hotels for not providing information on their websites about the availability of rooms accessible to disabled individuals, as required by the Americans with Disabilities Act (ADA). Laufer's actions have led to a split among the circuit courts, with the Second, Fifth, and Tenth Circuits ruling that she lacks standing to sue, while the First, Fourth, and Eleventh Circuits have ruled in her favor. The case at hand was brought to the Supreme Court by Acheson Hotels, LLC, from the First Circuit to resolve this split.After the Supreme Court granted review, Laufer's lawyer was suspended by the United States District Court for the District of Maryland for fraudulent practices. Following this, Laufer voluntarily dismissed her pending lawsuits, including the one against Acheson. She then suggested to the Supreme Court that her case was moot. Acheson, however, argued that the standing issue, which was the reason the case was brought to the Supreme Court, should be resolved for the sake of efficiency and to prevent future manipulation of the Court's jurisdiction.The Supreme Court, while acknowledging Acheson's concerns, ruled that Laufer's case against Acheson was moot and dismissed it on that ground. The Court emphasized that it might exercise its discretion differently in a future case. The judgment was vacated, and the case was remanded to the United States Court of Appeals for the First Circuit with instructions to dismiss the case as moot. View "Acheson Hotels, LLC v. Laufer" on Justia Law

Before the resumption of federal student-loan repayments that had been suspended during the coronavirus pandemic, the Secretary of Education announced a Plan that would discharge $10,000-$20,000 of an eligible borrower’s debt. The Secretary invoked the 2003 Higher Education Relief Opportunities for Students Act (HEROES Act), which authorizes the Secretary “to waive or modify any provision” applicable to federal student financial assistance programs as “necessary” to ensure that recipients of student financial assistance are no worse off “financially in relation to that financial assistance because” of a national emergency or disaster, 20 U.S.C. 1098. The Act exempts rules promulgated under it from otherwise-applicable negotiated rulemaking and notice-and-comment processes. Borrowers who did not qualify for the Plan's maximum relief alleged that the Secretary was required to follow those rulemaking procedures.The Supreme Court held that the borrowers lacked Article III standing, having failed to establish that any injury they suffer from not having their loans forgiven is fairly traceable to the Plan.The Department also claims authority to forgive loans under the Higher Education Act (HEA), 20 U.S.C. 1082(a)(6). The borrowers cannot show that their purported injury of not receiving HEA loan relief is fairly traceable to the Department’s decision to grant relief under the HEROES Act. They are not claiming that they are injured by not being sufficiently included among the Plan’s beneficiaries but argue the Plan is unlawful and instead seek HEA debt forgiveness. The Department’s authority to grant HEA loan relief is not affected by whether the Plan is lawful. Any incidental effect of the Plan on the likelihood that the Department will undertake loan forgiveness under a different statute is too speculative to show that the absence of HEA-based loan forgiveness is fairly traceable to the Plan. View "Department of Education v. Brown" on Justia Law

The Higher Education Act governs federal financial aid, 20 U.S.C. 1070(a), and authorizes the Secretary of Education to cancel or reduce loans held by some public servants and borrowers who have died, become permanently and totally disabled, are bankrupt, or whose schools falsely certify them, close down, or fail to pay lenders. Under the Higher Education Relief Opportunities for Students Act (HEROES Act), the Secretary “may waive or modify" any statutory or regulatory provision applicable to the loan programs as the Secretary deems "necessary in connection with a war or other military operation or national emergency.” As the COVID–19 pandemic was ending, the Secretary invoked the HEROES Act to issue “waivers and modifications” reducing or eliminating most borrowers' federal student debt. States challenged the plan. The Eighth Circuit issued a nationwide preliminary injunction.The Supreme Court found that the plan exceeded the Secretary’s authority, first holding that at least Missouri had standing. The plan would cost the state's nonprofit government corporation about $44 million a year in fees.The HEROES Act allows the Secretary to “waive or modify” existing statutory or regulatory provisions but does not allow the Secretary to rewrite the Education Act to the extent of canceling $430 billion of student loan principal. The Secretary may make modest adjustments to existing provisions, not transform them. The Act includes narrowly-delineated situations that qualify a borrower for loan discharge; the Secretary has extended such discharge to nearly every borrower. The plan constitutes “effectively" a "whole new regime.” The question is not whether something should be done; it is who has the authority to do it. The basic and consequential tradeoffs inherent in mass debt cancellation are ones that Congress would likely have intended for itself. View "Biden v. Nebraska" on Justia Law

Smith, wanting to expand her graphic design business to include wedding websites, worried that the Colorado Anti-Discrimination Act would require her to create websites celebrating marriages that defy her belief that marriage should be between one man and one woman. Smith intends to produce a story for each couple using her own words and original artwork, combined with the couple’s messages. The Tenth Circuit affirmed the denial of Smith’s request for an injunction.The Supreme Court reversed. The First Amendment prohibits Colorado from forcing a website designer to create expressive designs conveying messages with which the designer disagrees. The First Amendment protects an individual’s right to speak his mind regardless of whether the government considers his speech “misguided.” Generally, the government may not compel a person to speak preferred messages. The wedding websites Smith seeks to create involve her speech and are pure speech protected by the First Amendment. Colorado seeks to put Smith to a choice prohibited by precedent. If she wishes to speak, she must either speak as Colorado demands or face sanctions for expressing her own beliefs.Public accommodations laws are vital to realizing the civil rights of all Americans; governments have a “compelling interest” in eliminating discrimination in places of public accommodation. States may protect gay persons, just as they protect other classes of individuals. However, public accommodations laws are not immune from the demands of the Constitution. Smith does not seek to sell an ordinary commercial good but intends to create “customized and tailored” expressive speech “to celebrate and promote the couple’s wedding.” Speakers do not shed their First Amendment protections by accepting compensation or employing the corporate form to disseminate their speech. Smith will gladly conduct business with those having protected characteristics when the product she is creating does not violate her beliefs. View "303 Creative LLC v. Elenis" on Justia Law

Groff, an Evangelical Christian who believes that Sunday should be devoted to worship and rest, took a mail delivery job with the Postal Service (USPS). USPS subsequently began facilitating Amazon’s Sunday deliveries. To avoid working Sundays on a rotating basis, Groff transferred to a rural USPS station. After Amazon deliveries began at that station, Groff received progressive discipline for failing to work on Sundays. He eventually resigned. Groff sued under Title VII of the Civil Rights Act, asserting that USPS could accommodate his Sunday Sabbath practice “without undue hardship" to its business, 42 U.S.C. 2000e(j). The Third Circuit affirmed summary judgment in favor of USPS, reasoning that under Supreme Court precedent, “requiring an employer ‘to bear more than a de minimis cost’ to provide a religious accommodation is an undue hardship.”The Supreme Court vacated. Title VII requires an employer that denies a religious accommodation to show that the burden of granting an accommodation would result in substantially increased costs in relation to the conduct of its particular business. After tracing Establishment Clause and Title VII jurisprudence, the Court concluded that showing “more than a de minimis cost,” as that phrase is used in common parlance, does not establish “undue hardship” under Title VII. Undue hardship is shown when a burden is substantial in the overall context of the business–a fact-specific inquiry. Courts must consider all relevant factors, including the accommodations at issue and their practical impact, given the nature, size, and operating cost of an employer. Impacts on coworkers are relevant only to the extent those impacts affect the conduct of the business. Title VII requires that an employer “reasonably accommodate” an employee’s practice of religion, not merely assess the reasonableness of a particular possible accommodation. An employer must do more than conclude that forcing other employees to work overtime would constitute an undue hardship; other options must be considered. View "Groff v. DeJoy" on Justia Law

Hetronic (a U.S. company) manufactures remote controls for construction equipment. Abitron Austria, once a licensed Hetronic distributor, claimed ownership of the rights to much of Hetronic’s intellectual property and began employing Hetronic’s marks on products it sold. Hetronic sued Abitron in the Western District of Oklahoma under the Lanham Act, 15 U.S.C. 1114(1)(a), 1125(a)(1). A jury awarded Hetronic approximately $96 million. The Tenth Circuit affirmed, concluding that the Lanham Act extended to “all of [Abitron’s] foreign infringing conduct.”The Supreme Court vacated. Applying the presumption against extraterritoriality, the relevant sections of the Lanham Act are not extraterritorial and extend only to claims where the infringing use in commerce is domestic. Neither provision provides an express statement of extraterritorial application or any other clear indication that it is one of the “rare” provisions that nonetheless applies abroad. Both simply prohibit the use “in commerce” of protected trademarks when that use “is likely to cause confusion.” Because sections 1114(1)(a) and 1125(a)(1) are not extraterritorial, the Court considered the location of the conduct relevant to the focus of the statutory provisions: the unauthorized “use in commerce” of a protected trademark under certain conditions. “Use in commerce” provides the dividing line between foreign and domestic applications of these provisions. View "Abitron Austria GmbH v. Hetronic International, Inc." on Justia Law

In the Harvard College admissions process, “race is a determinative tip for” a significant percentage “of all admitted African American and Hispanic applicants.” University of North Carolina (UNC) also considers the applicant’s race. SFFA challenged both systems.The Supreme Court held that both programs violate the Equal Protection Clause of the Fourteenth Amendment. The Court first held that SFFA complies with the standing requirements for organizational plaintiffs as a voluntary membership organization with identifiable members who support its mission and whom SFFA represents in good faith.Tracing the history of Fourteenth Amendment precedent, the Court acknowledged its "role in that ignoble history,” and subsequent efforts to eliminate racial discrimination. The core purpose of the Equal Protection Clause is to eliminate all governmentally-imposed discrimination based on race. Any exceptions must survive strict scrutiny. which asks whether the racial classification is used to advance compelling governmental interests and whether the use of race is narrowly tailored--necessary to achieve that interest. Previous holdings permitted race-based college admissions only in compliance with strict scrutiny and acknowledged that, eventually, they must end.The admissions programs at issue are not sufficiently measurable to permit strict scrutiny. The identified "compelling" interests include training future leaders, acquiring new knowledge based on diverse outlooks, promoting a robust marketplace of ideas, and preparing engaged and productive citizens. The question of whether a particular mix of minority students produces those results is standardless. The systems fail to articulate a meaningful connection between the means they employ and those goals; they use racial categories that are overbroad, arbitrary or undefined, or underinclusive.The systems also use race as a “negative” and employ stereotypes. College admissions are zero-sum. A benefit provided to some applicants is necessarily at the expense of others. The systems employ “the offensive and demeaning assumption" that students of a particular race think alike. The systems lack a “logical endpoint. View "Students for Fair Admissions, Inc. v. President and Fellows of Harvard College" on Justia Law