January 1 summary
Arellano v. McDonough
Statutes of limitation are presumed to be subject to equitable tolling, but this presumption shifts if inconsistent with the statutory design. Irwin v. Department of Veterans Affairs, 498 U. S. 89, 95–96 (1990); John R. Sand & Gravel Co. v. United States, 552 U. S. 130, 137–138 (2008). It is inconsistent with the comprehensive statutory scheme to subject this narrow exception to equitable tolling. See 38 U. S. C. §§ 5110(a)(1), (b)(1).
Area(s) of Law:- Disability Law
February 5 summaries
Bartenwerfer v. Buckley
The text of § 523(a)(2)(A), written in the passive voice, focuses on the act, not the actor who committed it. Dean v. United States, 556 U. S. 568, 572 (2009). Contextually, neighboring provisions specify a particular debtor, while section 523(a)(2)(A) does not, supporting further that Congress was agnostic as to the actor who committed the fraud. In addition, this Court held in earlier iterations of this statute that the culpability of one partner is imputed on the entire partnership, and in reenacting the statute Congress did not take steps to correct that interpretation. Strang v. Bradner, 114 U. S. 555, 561 (1885).
Area(s) of Law:- Bankruptcy Law
Cruz v. Arizona
“An unforeseeable and unsupported state-court decision on a question of state procedure does not constitute an adequate ground to preclude this Court’s review of a federal question.” Bouie v. City of Columbia, 378 U. S. 347, 354 (1964).
Area(s) of Law:- Post-Conviction Relief
Helix Energy Sol. Grp., Inc. v. Hewitt
An employee is not considered salaried under 29 CFR §541.602(a) if his compensation is based on a daily rate. §541.604(b) allows an alternative for employees paid hourly or daily to qualify as salaried, but only if they also earn an additional guaranteed and predetermined weekly payment.
Area(s) of Law:- Employment Law
Bittner v. United States
Records and reports on foreign financial agency transactions as detailed in 31 U.S.C. §5314 and §5321 may penalize nonwillful violations up to $10,000 per inadequate report, not per foreign account that is in violation.
Area(s) of Law:- Tax Law
Delaware v. Pennsylvania
“[N]othing in the parties’ arguments, the Special Master’s Second Interim Report, or the record in these cases [showed] that the Disputed Instruments should be deemed ‘third party bank checks.’”
Area(s) of Law:- Property Law
March 2 summaries
Perez v. Sturgis Public Schools
“Nothing in IDEA shall be construed to restrict” the ability to seek “remedies” under other Federal laws protecting the rights of children with disabilities. Before filing a civil action under other federal laws seeking relief that is also available under IDEA, the procedures under [§1415](f) and (g) shall be exhausted". 20 U.S.C. §1415(l).
Area(s) of Law:- Disability Law
Wilkins v. United States
Section 2409a(g) is a non-jurisdictional claims-processing rule. A procedural requirement is only jurisdictional if Congress “clearly states” it is. Boechler v. Commissioner, 596 U.S. ___, ___ (2022) (slip op., at 3) (quoting Arbaugh, 546 U.S., at 515). This principle seeks to avoid judicial interpretations that undermine Congress’ judgment. Loosely treating procedural requirements as jurisdictional risks undermining the very reason Congress enacted them.
Area(s) of Law:- Property Law
April 5 summaries
Axon Enterprise, Inc. v. FTC
The Court applies the Thunder Basin factors to determine if Congress intended to limit jurisdiction of claims regarding federal agency actions to the statutory administrative review structure or if they may be litigated under 28 U.S.C. § 1331.
Area(s) of Law:- Civil Procedure
New York v. New Jersey
Interstate compacts are "construed as contracts under the principles of contract law."Tarrant Regional Water Dist. v. Herrmann, 569 U.S. 614, 628 (2013). To resolve a dispute over the terms of a Compact, the court must, "begin by examining the express terms of the Compact as the best indication of the intent of the parties." Tarrant, 569 U.S. at 628.
Area(s) of Law:- Contract Law
Halkbank v. United States
Whether U.S. district courts may exercise subject matter jurisdiction over criminal prosecutions against foreign sovereigns and their instrumentalities under 18 U.S.C. § 3231 and in light of the Foreign Sovereign Immunities Act, 28 U.S.C. §§ 1330, 1441(d), 1602-1611.
Area(s) of Law:- Criminal Procedure
MOAC Mall Holdings LLC v. Transform Holdco LLC
Mandatory rules within a statute do not necessarily make that statute jurisdictional. Henderson v. Shinseki, 562 U. S. 428, 435 (2011). The Court will treat a rule as jurisdictional “only if Congress says as much.” Boechler v. Commissioner of Internal Revenue, 596 U.S. ___ (2022).
Area(s) of Law:- Bankruptcy Law
Reed v. Goertz
In a procedural due process claim, the plaintiff has a complete and present claim when “the state fails to provide due process,” not when the deprivation occurs. Zinermon v. Burch, 494 U.S. 113, 125 (1990).
May 11 summaries
Ciminelli v. United States
Petitioners were indicted and convicted under 18 U. S. C. § 1343 and §1349, wire fraud and conspiracy to commit wire fraud. On appeal, the Supreme Court reversed, holding the wire fraud statutes protect only interests “long . . . recognized as property,” and intangible economic information is not such an interest. McNally v. United States, 483 U. S. 350, 360 (1987); Carpenter v. United States, 484 U. S. 19, 26 (1987).
Area(s) of Law:- Property Law
Financial Oversight and Management Board for Puerto Rico v. Centro de Periodismo Investigativo, Inc.
Congress must make its intent to abrogate sovereign immunity unmistakably clear in the language of the statute. Kimel v. Florida Bd. of Regents, 528 U. S. 62, 73.
Area(s) of Law:- Sovereign Immunity
National Pork Producers Council v. Ross
The anti-discrimination principle is fundamental to the dormant Commerce Clause; to show violation of the dormant Commerce Clause, petitioner must show discrimination by a statute on out of state economies, evidenced by a substantial burden on the interstate economy. Additionally, under Pike v. Bruce Church, Inc., 397 U.S. 137 (1970), if there is a burden on interstate economy from a facially neutral law, that burden is allowed so long as it is outweighed by putative local benefits.
Area(s) of Law:- Constitutional Law
Percoco v. United States
Petitioner was convicted, in relevant part, under 18 U. S. C. §§1343, 1346, and 1349, conspiracy to commit “honest-services” wire fraud. The Second Circuit affirmed. On appeal, the Supreme Court reversed, holding that private citizens may enter circumstances involving the government in which they owe a duty of honesty to the public, this is not always the case. See Skilling v. United States, 561 U. S. 358, 408 (2010).
Area(s) of Law:- Property Law
Santos-Zacaria v. Garland
A rule is jurisdictional “only if Congress ‘clearly states’ that it is.” Boechler v. Commissioner, 596 U.S. ___ (2022). A motion for reconsideration is subject to discretionary review and is not an appeal as of right, and therefore is not subject to the exhaustion requirement of §1252(d)(1).
Area(s) of Law:- Immigration
Andy Warhol Foundation for the Visual Arts v. Goldsmith
If an original work and a secondary use share the same or highly similar purposes, and the secondary use is of a commercial nature, the first factor is likely to weigh against fair use, absent some other justification for copying.
Area(s) of Law:- Copyright
Polselli v. IRS
The IRS may issue summonses to determine whether a taxpayer owes money and also to collect any outstanding liability. When the IRS conducts an investigation for purposes of “determining the liability” of a taxpayer, it must provide notice, 26 U.S.C. §7609(a)(1). But once the IRS has reached the stage of “collecting any such liability,” §7602(a)—which is a distinct activity—notice may not be required, §7609(c)(2)(D).
Area(s) of Law:- Tax Law
Twitter, Inc. v. Taamneh
The phrase “aids and abets” in §2333(d)(2), as elsewhere, refers to a conscious, voluntary, and culpable participation in another’s wrongdoing.
Area(s) of Law:- Tort Law
Calcutt v. Federal Deposit Insurance Corporation
“[…] If the record before the agency does not support the agency action, [or] if the agency has not considered all relevant factors, … the proper course, except in rare circumstances, is to remand to the agency for additional investigation or explanation.” 598 U.S. 623, 628.
Area(s) of Law:- Administrative Law
Sackett v. EPA
The Court held that the CWA extends to only those “wetlands with a continuous surface connection to bodies that are ‘waters of the United States’ in their own right,” so that they are “indistinguishable” from those waters. Rapanos v. United States, 547 U.S. 715, 739, 126 S.Ct. 2208, (2006).
Area(s) of Law:- Environmental Law
Tyler v. Hennepin County
Under the Takings Clause of the Fifth Amendment, government cannot bootstrap a delinquent tax to take more than what is owed.
Area(s) of Law:- Constitutional Law
June 21 summaries
Haaland v. Brackeen
The Indian Child Welfare Act is upheld against constitutional challenges because Article I, Section 8, Clause 3 of the Constitution gives the federal government "virtually all authority over [...] Indian tribes." Seminole Tribe of Fla. v. Florida, 517 U. S. 44, 62 (1996). Anti-commandeering principles do not apply when public and private entities are equally burdened. Murphy v. National Collegiate Athletic Assn., 584 U.S. ___ (2018) (slip op., at 19–20).
Area(s) of Law:- Constitutional Law
Glacier Northwest, Inc. v. International Brotherhood of Teamsters Local Union No. 174
On appeal, the Court held that Petitioner’s claims were not preempted by NLRA. Longshoremen v. Davis, 476 U. S. 380, 396 (1986) (The “arguably” protected [standard] . . . is not without substance). Accepting the facts alleged in the complaint as true, Respondent intentionally caused destruction of Petitioner’s property during the strike, clearly failing the “reasonable precautions” test for a strike action to be protected by the NRLA. Bethany Medical Center, 328 N. L. R. B. 1094 (1999).
Area(s) of Law:- Labor Law
United States ex rel. Schutte v. SuperValu, Inc.
The False Claims Act's scienter element refers to the subjective knowledge of the accused, not to the knowledge of an objective reasonable person. Even if a term is facially ambiguous, “either actual knowledge, deliberate ignorance, or recklessness will suffice” to establish knowledge. Universal Health Services, Inc. v. United States ex rel. Escobar, 579 U. S. 176, 187 (2016).
Area(s) of Law:- Insurance Law
Allen v. Milligan
The Gingles framework itself imposes meaningful constraints on proportionality. Forcing proportional representation is unlawful and inconsistent with this Court’s approach to implementing §2.
Area(s) of Law:- Election Law
Dubin v. United States
Under 18 U.S.C. § 1028A(a)(1), a defendant “uses” another person’s means of identification “in relation to” a predicate offense when this use is at the crux of what makes the conduct criminal. [T]he means of identification specifically must be used in a manner that is fraudulent or deceptive.
Area(s) of Law:- Criminal Law
Health & Hosp. Corp. v. Talevski
A statute creates a §1983-enforceable right when the statute “unambiguously confer[s] individual federal rights. Gonzaga Univ. v. Doe, 535 U.S. 273, 280 (2002).
Area(s) of Law:- Civil Rights § 1983
Health and Hospital Corp. of Marion City v. Talevski
Any law created by Congress which confers rights to individuals may give rise to a cause of action pursuant to 42 U.S.C § 1983 unless doing so "would thwart any enforcement mechanism" of the law. Gonzaga Univ. v. Doe, 536 U. S., 273, 284 (2002).
Area(s) of Law:- Civil Law
Lac Du Flambeau Band of Lake Superior Chippewa Indians v. Coughlin
On appeal, the Court affirmed, holding the Bankruptcy code abrogates sovereign immunity for “governmental unit[s],” which include federally recognized Tribes like defendant. 11 U. S. C. §§ 106(a), 101(27).
Area(s) of Law:- Sovereign Immunity
Smith v. United States
Violations of the Constitution's Venue, Vicinage, and Double Jeopardy Clauses during the course of a criminal trial in Federal court should be remedied via retrial. “[T]he appropriate remedy for prejudicial trial error, in almost all circumstances, is simply the award of a retrial, not a judgment barring reprosecution.” United States v. Morrison, 449 U.S. 361, 364 (1981).
Area(s) of Law:- Constitutional Law
Lora v. United States
When a federal court imposes multiple prison sentences, it can choose whether to run the sentences concurrently or consecutively under 18 U.S.C. § 3584. The exception under subsection (c) of 924 provides that, “no term of imprisonment imposed on a person under this subsection shall run concurrently with any other term of imprisonment.” 924(c)(1)(D)(ii).
Area(s) of Law:- Sentencing
Arizona v. Navajo Nation
In 1868, the United States set apart a large reservation “for the use and occupation of the Navajo tribe” within the new American territory in the western United States.
Area(s) of Law:- Indian Law
Jones v. Hendrix
A prisoner may not proceed under the general habeas corpus statute simply because of limitations imposed on filing additional alternative postconviction remedy motions. 28 U.S.C. §§ 2241, 2255(h)(1)-(2).
Area(s) of Law:- Habeas Corpus
Pugin v. Garland
An offense may "relat[e] to obstruction of justice" under §1101(a)(43)(S) even if the offense does not require that an investigation or proceeding be pending.
Area(s) of Law:- Immigration
Yegiazaryan v. Smagin
The RICO Act provides a private right of action to “any person injured in his business or property by reason of a violation of” RICO’s substantive provisions. 18 U.S.C. §1964(c).
Area(s) of Law:- Civil Law
Samia v. United States
Whether the Confrontation Clause bars the admission of a nontestifying codefendant’s confession where (1) the confession has been modified to avoid directly identifying the nonconfessing codefendant and (2) the court offers a limiting instruction that jurors may consider the confession only with respect to the confessing codefendant.
Area(s) of Law:- Evidence
United States v. Texas
Challenges to an agency's exercise of enforcement discretion are not the kind redressable by federal courts.
Area(s) of Law:- Constitutional Law
Counterman v. Colorado
The State must prove in true-threats cases that the defendant had some understanding of his statements’ threatening nature… A recklessness standard is enough.
Area(s) of Law:- First Amendment
Moore v. Harper
Whether the Elections Clause of the Federal Constitution vests state legislatures with the authority to set rules governing federal elections free from restrictions imposed under state law.
Area(s) of Law:- Election Law
Groff v. DeJoy
“‘More than a de minimis cost…’ does not suffice to establish ‘undue hardship’ under Title VII.” “Undue hardship” under Hardison “is shown when a burden is substantial in the overall context of an employer’s business.”
Area(s) of Law:- Employment Law
Students for Fair Admissions, Inc. v. President and Fellows of Harvard College
Under the Equal Protection Clause of the Fourteenth Amendment of the United States Constitution, schools are prohibited from using race-based affirmative action in admissions decisions.
Area(s) of Law:- Constitutional Law
303 Creative LLC v. Elenis
It is a violation of the Free Speech Clause of the First Amendment of the United States Constitution for a state to compel speech with which the speaker does not agree.
Area(s) of Law:- First Amendment