United States Supreme Court

Opinions Filed in 2016

January 11 summaries

Bruce v. Samuels

Inmates must make monthly payments on lawsuit filing fees simultaneously with other previously unsatisfied filing fees, rather than making each filing fee payment sequentially.

Area(s) of Law:
  • Civil Procedure

Hurst v. Florida

A capital sentencing proceeding that allows a judge, and not the jury, to make the final determination in imposing the death penalty violates the Sixth Amendment.

Area(s) of Law:
  • Criminal Procedure

Campbell-Ewald v. Gomez

Refusal of a settlement offer does not efface a claim.

Area(s) of Law:
  • Civil Procedure

Kansas v. Carr

The Eighth Amendment does not (1) require a court to instruct a jury engaged in capital sentencing that mitigating factors need not be proven beyond a reasonable doubt, or (2) require separate hearings for multiple defendants in a capital sentencing case.

Area(s) of Law:
  • Criminal Law

Montanile v. Board of Trustees of the National Elevator Industry Health Benefit Plan

ERISA employee benefit plans can only sue to recover equitable liens limited to the specifically identified settlement funds established in the subrogation provisions.

Area(s) of Law:
  • ERISA

Amgen Inc. v. Harris

For a claim of breach of a fiduciary's duty of prudence, claimant must allege an alternative action that the fiduciary could have taken that would have been consistent with securities laws and that a prudent fiduciary in the same circumstances would not have viewed as more harmful than helpful.

Area(s) of Law:
  • Civil Procedure

FERC v. Electric Power Supply Assn.

The FERC has authority to regulate demand response bids regarding wholesale market operators' compensation, and the Rule is valid.

Area(s) of Law:
  • Administrative Law

James v. City of Boise, Idaho

State courts are bound to the Supreme Court’s interpretation of federal laws.

Area(s) of Law:
  • Constitutional Law

Menominee Tribe of Wisconsin v. United States

To establish equitable tolling of a statute of limitations, the litigant must show the delay was extraordinary and beyond the litigant's control.

Area(s) of Law:
  • Civil Procedure

Montgomery v. Louisiana

Juveniles who were sentenced to life without parole before the decision in Miller can petition for parole if they were not allowed to present mitigation evidence during sentencing.

Area(s) of Law:
  • Criminal Law

Musacchio v. United States

A sufficiency challenge should be assessed by the elements of the alleged crime not by an erroneous jury instruction and a defendant cannot raise a §3282(a) statute of limitations bar for the first time on appeal.

Area(s) of Law:
  • Appellate Procedure

February 0 summaries

March 12 summaries

Gobielle v. Liberty Mutual Insurance Company

ERISA pre-empts state law that would otherwise require health insurance providers to report health care claims and other information to a state agency.

Area(s) of Law:
  • Insurance Law

Lockhart v. United States

When interpreting a statute, a court should interpret a limiting clause or phrase at the end of the sentence to only modify the noun or phrase immediately preceding it.

Area(s) of Law:
  • Sentencing

Americold Realty Trust v. ConAgra Foods, Inc.

For purposes of diversity jurisdiction, a real estate investment trust, an unincorporated entity, has the citizenship of its shareholders.

Area(s) of Law:
  • Civil Procedure

V.L. v. E.L.

When a state court has jurisdiction over an adoption judgement, the Full Faith and Credit clause requires recognition of that adoption by another state.

Area(s) of Law:
  • Civil Procedure

Wearry v. Cain

The Louisiana Court failed to recognize and grant Appellant relief for a Brady v. Maryland violation committed by state prosecutors after they failed to turn over material evidence that prejudiced the appellant.

Area(s) of Law:
  • Criminal Procedure

Caetano v. Massachusetts

Blanket prohibitions on the possession of stun guns and other arms not in existences at the time of the founding violate the Second and Fourteenth Amendments.

Area(s) of Law:
  • Constitutional Law

Hawkins v. Community Bank

Lenders can seek repayment from a spouse of the business owner who took the loan.

Area(s) of Law:
  • Civil Law

Nebraska v. Parker

The 1882 Act between the United States and the Omaha Tribe did not diminish reservation land and tribal ordinances apply to the land referred to in the Act.

Area(s) of Law:
  • Indian Law

Sturgeon v. Frost

The National Park Service regulations regarding ‘non-public’ lands within Alaska are inconsistent with the Alaska National Interest Lands Conservation Act (ANILCA).

Area(s) of Law:
  • Land Use

Tyson Foods, Inc. v. Bouaphakeo

Employees seeking unpaid overtime for time donning and doffing protective clothing under Iowa state law and federal law can use representative evidence to establish a common injury.

Area(s) of Law:
  • Employment Law

Friedrichs v. California Teacher's Association

Union agency shop arrangements are constitutionally valid.

Area(s) of Law:
  • First Amendment

Luis v. United States

A pretrial injunction prohibiting a criminal defendant from using personal assets unrelated to the criminal offense to retain counsel is a violation of the Sixth Amendment.

Area(s) of Law:
  • Constitutional Law

April 4 summaries

Evenwel v. Abbott

The equal protection principle of “one person, one vote” permits States to apportion legislative districts using total population, and does not mandate that districts be apportioned based upon registered or eligible voter population.

Area(s) of Law:
  • Constitutional Law

Nichols v. United States

The Sex Offender Registration and Notification Act (SORNA) requires an offender to appear in a current jurisdiction to report updates of his or her information.

Area(s) of Law:
  • Criminal Law

Woods v. Etherton

It is inappropriate to use the "fairminded jurist" standard when evaluating an appellant's claims for relief on appeal.

Area(s) of Law:
  • Criminal Procedure

Welch v. United States

Collateral petitioners convicted under the Armed Career Criminal Act may seek retroactive relief consistent with the Court’s prior ruling that the residual clause of the Act is void for vagueness.

Area(s) of Law:
  • Criminal Procedure

May 21 summaries

Franchise Tax Board of California v. Hyatt

The Constitution does not permit Nevada to award damages against California agencies under Nevada law that are greater than it could award against Nevada agencies in similar circumstances.

Area(s) of Law:
  • Constitutional Law

Hughes v. Talen Energy Marketing

States may not implement programs which interfere with FERC's regulatory authority by adjusting wholesale electricity rates.

Area(s) of Law:
  • Administrative Law

BANK MARKAZI v. PETERSON

22 U.S.C. §8772, a provision of the Iran Threat Reduction and Syria Human Rights Act of 2012, does not violate constraints placed on the Executive and Legislative Branches by the separation of powers principles in the Constitution.

Area(s) of Law:
  • Constitutional Law

Harris v. Arizona Independent Redistricting Comm’n

The State of Arizona did not violate the Fourteenth Amendment when the redrawing of the State legislative districts resulted in a population deviation of 8.8%.

Area(s) of Law:
  • Constitutional Law

United States v. Shaw

Whether “scheme to defraud a financial institution” in subsection (1) of the bank-fraud statute, 18 U.S.C. §1344, requires proof of a specific intent not only to deceive, but also to cheat a bank?

Area(s) of Law:
  • Corporations

Heffernan v. City of Paterson

Employers may be held liable under the First Amendment and 42 U.S.C. § 1983 for demoting an employee in an attempt to prevent them from engaging in political activity protected by the First Amendment, even if the employer is factually mistaken about the nature of their employee’s activity.

Area(s) of Law:
  • First Amendment

Ocasio v. United States

Defendants may be criminally liable for conspiring to violate the Hobbs Act if the government can prove that the defendant agreed with the property owner to acquire that property under color of official right.

Area(s) of Law:
  • Criminal Law

Husky Int’l Electronics, Inc. v. Ritz

"'Actual fraud' encompasses other traditional forms of fraud and can be accomplished without a false representation, such as a fraudulent conveyance of property made to evade payment to creditors."

Area(s) of Law:
  • Bankruptcy Law

Kernan v. Hinojosa

The Antiterrorism and Effective Death Penalty Act presumes that a state decision rejecting a claim is a ruling on the merits that can be rebutted by looking through summary denials by state appellate courts to an earlier state ruling.

Area(s) of Law:
  • Habeas Corpus

Sheriff v. Gillie

Independent Counsels' use of the Ohio Attorney General's letterhead to collect debt was not a misleading or deceptive practice under the Fair Debt Collection Practices Act, when the attorneys were acting as special counsel on behalf of the Attorney General, for purposes of collecting debts for the state and its instrumentalities.

Area(s) of Law:
  • Consumer Credit

Spokeo, Inc. v. Robins

In a federal claim, an allegation of a mere procedural violation of law is not concrete enough to satisfy the injury-in-fact requirement of standing.

Area(s) of Law:
  • Civil Procedure

Zubik v. Burwell

It is feasible for employers to contract with insurers to provide health care to their employees, excluding some or all types of contraception, and for those insurers to cover contraception to said employees, which effectively eliminates the employer's obligation to give notice of their objections of contraception coverage.

Area(s) of Law:
  • Insurance Law

Betterman v. Montana

The Sixth Amendment right to a speedy trial does not apply once a defendant has been found guilty at trial or pleaded guilty, including the time between conviction and sentencing, although other Due Process challenges may still be raised.

Area(s) of Law:
  • Criminal Procedure

CRST Van Expedited, Inc. v. EEOC

A judgment on the merits is not necessary to find that a defendant has prevailed for the purposes of determining whether a defendant can recover attorney’s fees.

Area(s) of Law:
  • Attorney Fees

Luna Torres v. Lynch

State crimes constitute "aggravated felonies" for purposes of the Immigration and Nationality Act if the state crime has all of the elements of a corresponding federal statute except the federal jurisdictional element.

Area(s) of Law:
  • Immigration

Foster v. Chatman

The Constitution prohibits exercising preemptory strikes during voir dire used to remove potential jurors for discriminatory purposes and the three part Batson test is used to determine whether a strike was discriminatory.

Area(s) of Law:
  • Constitutional Law

Green v. Brennan

In a constructive discharge claim, the “matter alleged to be discriminatory” includes an employee’s resignation and therefore, the 45-day limitation period begins to run only after the employee resigns.

Area(s) of Law:
  • Employment Law

Wittman v. Personhuballah

To satisfy the Article III standing requirements, a party must raise more than a mere allegation of an injury, but must also present evidence that an injury resulted from the challenged conduct.

Area(s) of Law:
  • Standing

Army Corps of Engineers v. Hawkes Co.

"Approved jurisdictional determinations,” issued by the U. S. Army Corps of Engineers, are final agency actions that are judicially reviewable under the APA.

Area(s) of Law:
  • Administrative Law

Lynch v. Arizona

Simmons applies even in instances where there is a possibility that the defendant may be eligible for parole due to legislative action or clemency in the future.

Area(s) of Law:
  • Criminal Procedure

State Farm Fire and Casualty Co. v. United States ex rel. Rigsby

What standard governs the decision of whether to dismiss a relator's seal requirement under the False Claims Act?

Area(s) of Law:
  • Civil Procedure

June 33 summaries

Buck v. Smith

Whether Petitioner's circumstances are extraordinary enough to warrant relief under Rule 60(b)(6), based on an ineffective assistance of counsel argument, from denial of his habeas claim when: his counsel called an expert witness to testify during sentencing and the expert stated that Petitioner's race made him more likely to be dangerous in the future, the prosecution alluded to Petitioner's race in closing as support for Petitioner's future dangerousness, and Petitioner was sentenced to death after it was determined that Petitioner had the potential to commit future violent acts.

Area(s) of Law:
  • Criminal Procedure

Moore v. Texas

Whether it is a violation of the Eighth Amendment to use outdated State approved medical standards in determining whether a person is intellectually disabled for death penalty purposes, instead of using current medical standards.

Area(s) of Law:
  • Criminal Law

Ross v. Blake

Under the Prison Litigation Reformation Act of 1995 (PRLA), there is no “special circumstances” exception that allows prisoners to bring a lawsuit without having first exhausted all administrative remedies available.

Area(s) of Law:
  • Criminal Procedure

Simmons v. Himmelreich

There is no categorical exclusion of the exemptions under the FTCA.

Area(s) of Law:
  • Tort Law

Commonwealth of Puerto Rico v. Luis M. Sanchez Valle

Pursuant to the dual-sovereignty doctrine, the United States and Puerto Rico may not prosecute a single person for the same offense under analogous criminal laws.

Area(s) of Law:
  • Criminal Procedure

Dietz v. Bouldin

Federal courts have an inherent limited power to call a jury back into the courtroom for continued deliberation after the jury has been dismissed but before the court has issued a final judgment in a civil case, however a district court should use discretion when exercising this power to ensure that the jury has not been prejudiced during the time they were dismissed.

Area(s) of Law:
  • Civil Procedure

Williams v. Pennsylvania

There is an impermissible risk of bias, in violation of the Fourteenth Amendment Due Process Clause, when a judge’s prior involvement in a case as the prosecutor is significant, personal, and related to a critical decision.

Area(s) of Law:
  • Constitutional Law

Commonwealth of Puerto Rico v. Franklin California Tax-Free Trust

Puerto Rico is a “state” for purposes of Federal Bankruptcy Code preemption.

Area(s) of Law:
  • Preemption

Halo Electronics, Inc. v. Pulse Electronics, Inc.

Enhanced damages under § 284 of the Patent Act are awarded on a discretionary basis against egregious and willful patent infringers, and non-discretionary frameworks or tests for enhanced patent infringement damages are not permissible when inconsistent with § 284.

Area(s) of Law:
  • Patents

United States v. Bryant

The Sixth Amendment does not preclude the use of uncounseled tribal court convictions as predicate offenses for purposes of 18 U.S.C. § 117

Area(s) of Law:
  • Indian Law

Kingdomware Technologies, Inc. v. United States

Under 38 U.S.C. § 8127(d), the Department of Veteran Affairs is required to employ the Rule of Two in awarding contracts, even though the Department will otherwise meet its annual contracting objectives.

Area(s) of Law:
  • Contract Law

Kirtsaeng v. John Wiley & Sons, Inc.

When granting attorney fees in a copyright infringement case, a district court may examine the objective reasonableness of the losing party’s claim because doing so is in keeping with the legislative purpose of §505 of the U.S. Copyright Act.

Area(s) of Law:
  • Copyright

Universal Health Services, Inc. v. United States ex rel. Escobar

The implied false certification theory of the False Claims Act can be a basis for liability when a defendant makes representations about the goods or services that it provides, but fails to disclose noncompliance with material legal requirements that make those representations misleading half-truths. Liability does not turn on whether the requirements are expressly designated as conditions of payment.

Area(s) of Law:
  • Civil Law

Cuozzo Speed Technologies, LLC v. Lee

Under the Leahy-Smith America Invents Act, 35 U.S.C. § 314(d) does bar judicial review and 35 U.S.C. § 316(a)(4) authorizes the Patent Office to regulate when it is reasonable and within their authority to do so.

Area(s) of Law:
  • Patents

Encino Motocars, LLC v. Navarro

Whether a government agency who has been given the authority to interpret and promulgate a regulation may be given deference in the absence of an explanation for a change that is inconsistent with the agency's longstanding earlier position.

Area(s) of Law:
  • Employment Law

National Labor Relations Board v. SW General, Inc.

Whether the precondition in Federal Vacancies Reform Act of 1998 § b(1) on service in an acting capacity by a person nominated by the President to fill the office on a permanent basis applies only to first assistants who take office under Subsection (a)(1) of FVRA, or whether it also limits acting service by officials who assume acting responsibilities under Subsections (a)(2) and (a)(3)?

Area(s) of Law:
  • Constitutional Law

RJR Nabisco v. European Community

The Racketeering Influenced and Corrupt Organizations Act (RICO) applies to certain international situations but does not permit recovery for civil damages in the U.S. for injuries that occurred outside of the U.S.

Area(s) of Law:
  • Corporations

Taylor v. United States

The prosecution in a Hobbs Act case satisfies the Act’s commerce element when it proves that the defendant robbed or attempted to rob a drug dealer of drugs or drug proceeds.

Area(s) of Law:
  • Criminal Law

Utah v. Strieff

Evidence acquired in violation of the Fourth Amendment’s exclusionary rule is admissible when an officer, conducting a good faith, bona fide investigation, discovers a valid warrant against the defendant, which qualifies as an intervening circumstance in application of the attenuation exception to the exclusionary rule.

Area(s) of Law:
  • Criminal Procedure

Birchfield v. North Dakota

Under the Fourth Amendment, “implied consent laws” that require breath tests are constitutional because they are “reasonable searches” incident to arrest, which do not require a warrant.

Area(s) of Law:
  • Constitutional Law

Dollar General Corp. v. Mississippi Band of Choctaw Indians

Tribal Courts have jurisdiction over non-Indians who enter into a consensual relationship with the tribe through commercial dealing, contracts, leases or other arrangements.

Area(s) of Law:
  • Indian Law

Fisher v. University of Texas at Austin

Affirmative-action admission policies at public universities may be permissible under the Equal Protection Clause, because promoting racial diversity in student bodies and classrooms is a compelling state interest, but schools have an ongoing obligation to refine the management their admission policies to ensure that equal protection violations are not occurring as demographics change.

Area(s) of Law:
  • Constitutional Law

Richard Mathis v. United States

If, for purposes of determining penalty under the Armed Career Criminal Act, the court finds that a defendant was previously convicted under a statute with alternative means of satisfying one element of a crime, then the court shall determine whether the elements of the prior conviction, and not the facts of the records except for limited circumstances, sufficiently match the elements of the Act’s generic crimes

Area(s) of Law:
  • Criminal Law

McDonnell v. United States

The government’s interpretation of the term “official act” in the federal bribery statute, 18 U.S.C. 201(a)(3), was overly broad and would lead to the criminalization of a variety of legitimate acts that public officials perform daily in their duty as representatives of the will of the voters.

Area(s) of Law:
  • Criminal Law

Voisine v. United States

A person convicted of a misdemeanor crime of reckless domestic violence is prohibited from possessing a firearm or ammunition under 18 U. S. C. §922(g)(9).

Area(s) of Law:
  • Criminal Law

Whole Women's Health v. Hersedt

Portions of a bill requiring doctors performing abortions to have privileges at a hospital not more than thirty (30) miles away and that the clinic performing the abortion meet the requirements of ambulatory surgical centers places a substantial burden on women seeking abortions.

Area(s) of Law:
  • Constitutional Law

Czyzewski v. Jevic Holding Corporation

Whether a bankruptcy court may authorize the distribution of settlement proceeds in a manner that violates the statutory priority scheme?

Area(s) of Law:
  • Bankruptcy Law

Donnika Ivy, et. al. v. Morath

Whether the relationship between a public entity and a private vendor can trigger obligations to accommodate persons with disabilities when no prior express contractual relationship exists between the public entity and private vendor?

Area(s) of Law:
  • Disability Law

Fry, Stacy, et vir v. Napoleon Community Sch., et al

Whether the HCPA commands exhaustion in a suit, when it is brought under the Americans with Disabilities Act and the Rehabilitation Act, that seeks damages if that remedy that is not available under the IDEA?

Area(s) of Law:
  • Disability Law

Lynch v. Morales-Santana

Whether it is a violation of the equal protection clause to impose different requirements on unwed mothers and fathers of foreign-born children for citizenship purposes, under U.S.C. 1401 and 1409?

Area(s) of Law:
  • Constitutional Law

Venezuela v. Helmerich & Payne International

Whether FSIA has an exception to the takings rules for foreign nations, in the event that the taking is not in violation of international law, and if an exception permits corporation shareholders to assert ownership rights to the property and question and whether “wholly insubstantial and frivolous” is the appropriate standard for dismissing a claim for jurisdictional issues?

Area(s) of Law:
  • Corporations

Visa Inc., Et Al. v. Osborn, Sam, Et Al And Visa Inc., Et Al. v. Stoumbos, Mary, Et Al.

Whether allegations that a member of a business association adhered to the association’s rules and possessed governance rights in the association are sufficient to plead the element of conspiracy under Section 1 of the Sherman Act?

Area(s) of Law:
  • Corporations

Wells Fargo & Co., et al., Petitioners v. City of Miami, Florida; Bank of America Corp., et al., Petitioners v. City of Miami, Florida

Whether: (1) the zone of interest requirement for "aggrieved person[s] under the FHA is as broad as the injury-in-fact requirement of Article III standing; 2) the FHA requires more than indirect harm to be pled to establish proximate cause.

Area(s) of Law:
  • Standing

July 0 summaries

August 0 summaries

September 0 summaries

October 1 summary

Bosse v. Oklahoma

Payne v. Tennessee did not implicitly overrule Booth v. Maryland's holding that the Eighth Amendment prohibits a capital sentencing jury from considering evidence of a victim’s family members’ opinions about the crime, the defendant, and the appropriate sentence.

Area(s) of Law:
  • Criminal Procedure

November 1 summary

Bravo-Fernandez v. United States

The Double Jeopardy Clause’s issue-preclusion component does not prevent the government from retrying a defendant following a jury’s return of irreconcilably inconsistent verdicts of conviction and acquittals where a legal error separate and apart from the inconsistencies led to the vacation of the convictions.

Area(s) of Law:
  • Constitutional Law

December 4 summaries

Salman v. United States

A person who indirectly receives insider information and trades on that information fully knowing it was improperly disclosed violates Section 10(b) of the Securities Exchange Act and the Securities Exchange Commission’s Rule 10b-5.

Area(s) of Law:
  • Trade Secrets

Samsung Electronics Co., Ltd., Et. Al. v. Apple Inc.

When determining a damages award for patent infringement under section 289 of the Patent Act, the relevant “article of manufacture” does not solely refer to the product sold to consumers but can also refer to components of the product.

Area(s) of Law:
  • Patents

State Farm Fire & Casualty Co. v. United States ex rel. Rigsby

Failure to abide by the seal requirement of the False Claims Act does not mandate the dismissal of a complaint filed under the False Claims Act.

Area(s) of Law:
  • Civil Procedure

Shaw v. U.S.

Convictions for “knowingly execut[ing] a scheme … to defraud a financial institution,” pursuant to 18 U.S.C. §1344(1), are valid if the scheme defrauds bank customer accounts, because financial institutions have property rights in customer accounts.

Area(s) of Law:
  • Criminal Law

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