United States Supreme Court

2020

January 2 summaries

Retirement Plans Comm. of IBM v. Jander

In Fifth Third Bancorp v. Dudenhoeffer, 573 U.S. 409 (2014), the United States Supreme Court held that claims for breach of the duty of prudence by fiduciaries under the Employee Retirement Income Security Act of 1974 must be supported by a plausible allegation from the plaintiff that a prudent fiduciary in the same circumstances could have taken an alternative action that would not have done the fund more harm than good.

Area(s) of Law:
  • ERISA

Ritzen Group, Inc. v. Jackson Masonry, LLC

A creditor’s motion for relief from the automatic stay initiates a distinct proceeding terminating in a final, appealable order when the bankruptcy court rules dispositively on the motion.

Area(s) of Law:
  • Bankruptcy Law

February 8 summaries

Roman Catholic Archdiocese of San Juan v. Feliciano

The Puerto Rican courts lacked jurisdiction to issue payment and seizure orders after the case was removed to federal district court for Chapter 11 bankruptcy proceedings.

Area(s) of Law:
  • Bankruptcy Law

Hernandez v. Mesa

A Bivens remedy does not exist for Fourth or Fifth Amendment claims in a cross-border shooting context.

Area(s) of Law:
  • Constitutional Law

McKinney v. Arizona

A Clemons reweighing is a permissible remedy for an Eddings error, and when an Eddings error is found on collateral review, a state appellate court may conduct a Clemons reweighing on collateral review.

Area(s) of Law:
  • Habeas Corpus

Monasky v. Tagliere

A child's habitual residence under 22 U.S.C. §9003(b) depends on the totality of the circumstances and it is not necessary for there to be an actual agreement between the parents. Further, a first-impression determination of habitual residence is subject to review for clear error.

Area(s) of Law:
  • Family Law

Rodriguez v. Federal Deposit Insurance Corporation

The Bob Richards rule, which provides that in the absence of an agreement, a refund belongs to the group member responsible for the losses that led to it, promulgated in response to issues stemming from the IRS’s allowing affiliated groups of corporations to file consolidated federal tax returns, is not a legitimate exercise of federal common lawmaking.

Area(s) of Law:
  • Tax Law

Holguin-Hernandez v. U.S.

A defendant advocating for a particular sentence communicates that a longer sentence is “greater than necessary” and has thereby informed the court of the legal error for an appellate challenge to the substantive reasonableness of the sentence.

Area(s) of Law:
  • Appellate Procedure

Intel Corp. Investment Policy Committee v. Sulyma

ERISA §1113's three-year statute of limitations for breaches in which a plaintiff has "actual knowledge" requires a factual showing that the plaintiff was actually aware of the information that constitutes the alleged breach. A showing of constructive knowledge is insufficient.

Area(s) of Law:
  • ERISA

Shular v. United States

Section 924(e)(2)(A)(ii) of the Armed Career Criminal Act’s definition of “serious drug offense,” requires that the state offense involve the conduct specified in the statute; the state offense need not match certain generic offenses.

Area(s) of Law:
  • Criminal Law

March 7 summaries

Kansas v. Garcia

IRCA does not expressly or impliedly preempt state prosecution for fraudulently using another person’s information on state and federal tax-withholding forms even when that same information is found on an I-9 form.

Area(s) of Law:
  • Preemption

Allen v. Cooper Gov. of North Carolina

Congress lacks the authority to abrogate the government’ sovereign immunity from copyright infringement suits under the Copyright Remedy Clarification Act of 1990.

Area(s) of Law:
  • Copyright

Comcast Corp. v. Nat’l Ass’n of African American-Owned Media

Under the text and history of 42 U.S.C. §1981, there is no exception to depart from the common law principle requiring a plaintiff to first plead and then prove that its injury would not have occurred “but for” the defendant’s unlawful conduct.

Area(s) of Law:
  • Tort Law

Davis v. United States

When a plain error affects substantial rights, neither Rule 52(b) of the Federal Rules of Civil Procedure nor federal precedent shields any category of errors from plain-error review.

Area(s) of Law:
  • Civil Procedure

Guerrero-Lasprilla v. Barr

An appellate court may review a question of equitable tolling under the Limited Review Provision of the Immigration and Nationality Act as undisputed or established facts present a question of law.

Area(s) of Law:
  • Immigration

Kahler v. Kansas

Due process does not require that a test of insanity as a defense to a crime turn on a defendant’s ability to recognize the moral turpitude of his crime.

Area(s) of Law:
  • Constitutional Law

CITGO Asphalt Ref. Co. v. Frescati Shipping Co.

"Safe-berth" clauses in maritime contracts, depending on the language, embody a warranty of safety, imposing liability for unsafe berth regardless of the care taken by the charterer in choosing a berth.

Area(s) of Law:
  • Contract Law

April 12 summaries

Babb v. Wilkie

The plain language of the Age Discrimination in Employment Act of 1967 shows that age need not be the but-for cause of a personnel action for there to be a violation of 29 U.S.C. § 633a(a).

Area(s) of Law:
  • Employment Law

Kansas v. Glover

When an officer runs a license plate and learns that the owner has a revoked license—absent knowledge of any contradictory facts—it is reasonable for the officer to infer that the driver is also the owner of the vehicle, and the traffic stop is justified.

Area(s) of Law:
  • Criminal Procedure

Republican National Committee v. Democratic National Committee

The application for stay presented to Justice Kavanaugh and by him referred to the Court is granted. The District Court’s order granting a preliminary injunction is stayed to the extent it requires the State to count absentee ballots postmarked after April 7, 2020.

Area(s) of Law:
  • Election Law

Atlantic Richfield Co. v. Christian

A state court retains jurisdiction to hear claims arising under state common law despite Congress’ grant of exclusive original jurisdiction to the district courts to hear controversies arising under 42 U.S.C. § 9601 et seq. Landowners within a Superfund site may be considered potentially responsible parties for purposes of needing EPA approval to take remedial action under 42 U.S.C. § 9622(e)(6).

Area(s) of Law:
  • Environmental Law

Ramos v. Louisiana

The Sixth Amendment’s protection against nonunanimous felony guilty verdicts applies to States through the Fourteenth Amendment’s Due Process Clause. Duncan v. Louisiana, 391 U. S. 145 (1968)

Area(s) of Law:
  • Constitutional Law

Thryv, Inc. v. Click-To-Call Technologies, LP

35 U.S.C. § 314(d) precludes judicial review of the Patent Trial and Appeals Board's decisions regarding the application of §315(b)'s time limitation.

Area(s) of Law:
  • Patents

Barton v. Barr

The offense which disqualifies a permanent legal resident from eligibility for cancellation of removal does not have to be one of the offenses which triggered the removal action.

Area(s) of Law:
  • Immigration

County of Maui, Hawaii v. Hawaii Wildlife Fund

Environmental Protection Agency permits are required only for pollutants directly discharged into navigable waters or when the functional equivalent of a direct discharge has occurred.

Area(s) of Law:
  • Environmental Law

Romag Fasteners, Inc. v. Fossil, Inc.

The Lanham Act, 15 U.S.C. §1117(a), does not require findings of willful conduct to order an award of profits for trademark infringement.

Area(s) of Law:
  • Trademarks

Georgia v. Public.Resource.Org., Inc.

The Copyright Act, 17 U.S.C. § 102(a), does not provide protection to the annotations contained in Georgia’s official annotated code.

Area(s) of Law:
  • Copyright

Maine Community Health Options v. United States

The Patient Protection and Affordable Care Act’s expired “Risk Corridors” program established a money-mandating obligation and Petitioners properly relied on the Tucker Act to recover from the United States for its failure to reimburse them.

Area(s) of Law:
  • Insurance Law

New York State Rifle & Pistol Association v. City of New York, New York

Petitioners' claim for declaratory and injunctive relief sought against New York City is moot and any new claim for damages may be decided by the lower courts.

Area(s) of Law:
  • Constitutional Law

May 4 summaries

Kelly v. United States

A person commits wire fraud or fraud on a government entity only when they commit actual fraud and the fraud “obtain[s] property or money." 18 U.S.C. §§ 343, 666(a)(1)(A). Even if a scheme of fraud "obtains property," the second element requires that the "obtaining property or money" be the principal object of the fraud; this means that the scheme does not "obtain[] property or money" inadvertently. See Pasquantino v. United States, 544 U.S. 349, 364 (2005).

Area(s) of Law:
  • Criminal Law

U.S. v. Sineneng-Smith

Under the party presentation principle, a court’s role is to neutrally adjudicate cases as presented by the parties, not to reframe the controversy.

Area(s) of Law:
  • Appellate Procedure

Lucky Brand Dungarees v. Marcel

Defense preclusion is not applicable in a second action when the same defenses from the first action are asserted but applied to different conduct, legal theories, and occurred at different times than those asserted in the first action and did not pose a risk of negatively affecting the first judgment.

Area(s) of Law:
  • Civil Procedure

Opati v. Republic of Sudan

Federal causes of action under section 1605A(c) can seek punitive damages because Congress expressly authorized them when it amended the statute.

Area(s) of Law:
  • Tort Law

June 16 summaries

Banister v. Davis

Under 28 U.S.C. § 2244(b), Rule 59(e) motions to change or amend a judgment of the habeas court is not a “second or successive habeas application."

Area(s) of Law:
  • Habeas Corpus

Fin. Oversight & Mgmt. Bd. for Puerto Rico v. Aurelius Inv., LLC.

The Appointments Clause of the Constitution, Art. II, §2, cl. 2, applies to the appointments of some territorial officials, but not to officials whose powers and duties are primarily local.

Area(s) of Law:
  • Constitutional Law

GE Energy Power Conversion France SAS Corp. v. Outokumpu Stainless USA, LLC.

"A written provision in any maritime transaction or a contract evidencing a transaction involving commerce to settle by arbitration a controversy thereafter arising out of such contract or transaction*** shall be valid, irrevocable, and enforceable, save upon such grounds as exist at law or in equity for the revocation of any contract." 9 USC §2.

Area(s) of Law:
  • Contract Law

Nasrallah v. Barr

In the context of federal immigration law, Convention Against Torture (CAT) orders may be reviewed alongside final orders of removal.

Area(s) of Law:
  • Immigration

Thole v. U. S. Bank N. A.

Plaintiffs lack standing under the Employee Retirement Income Security Act of 1974 (ERISA) if they would receive the benefit of fixed payments regardless of the outcome on their claims.

Area(s) of Law:
  • Standing

Lomax v. Ortiz-Marquez

The three-strikes provision under 28 U.S.C. § 1915, denying prisoners the ability to bring suit without paying a filing fee if three or more prior suits were dismissed, includes all dismissals for failure to state a claim—with or without prejudice.

Area(s) of Law:
  • Civil Procedure

Andrus v. Texas

In assessing whether a defendant has made a showing of prejudice, a reviewing court must consider “the totality of the available mitigation evidence - both that adduced at trial, and the evidence adduced in the habeas proceeding' - and 'reweig[h] it against the evidence in aggravation." Williams v. Taylor, 529 U.S. 362, 397-98 (2000).

Area(s) of Law:
  • Habeas Corpus

Bostock v. Clayton County

Title VII is violated when an employee is fired on the basis of being gay, lesbian, or transgender.

Area(s) of Law:
  • Employment Law

U.S. Forest Serv. v. Cowpasture River Pres. Ass’n

"Rights-of-way through any Federal lands may be granted by the Secretary of the Interior or appropriate agency head for pipeline purposes for the transportation of oil, natural gas, synthetic liquid or gaseous fuels, or any refined product produced therefrom to any applicant possessing the qualifications provided in section 181 of this title in accordance with the provisions of this section." 30 U.S.C. § 185(a).

Area(s) of Law:
  • Administrative Law

Dep't of Homeland Sec. v. Regents of the Univ. of Cal.

Under the Administrative Procedure Act (APA), the Department of Homeland Security’s (DHS) decision to terminate Deferred Action for Childhood Arrivals (DACA) was arbitrary and capricious because there were no reasons offered for terminating the forbearance policy, DHS did not consider alternatives within the ambit of the existing forbearance policy, and it did not address whether there was legitimate reliance on the prior DACA memorandum.

Area(s) of Law:
  • Administrative Law

Dep't of Homeland Sec. v. Thuraissigiam

Illegal Immigration Reform and Immigrant Responsibility Act’s (IIRIRA) limitations on asylum seekers seeking habeas review is constitutional and does not violate due process.

Area(s) of Law:
  • Habeas Corpus

Agency for Int'l Development v. Alliance for Open Society Int'l, Inc.

The Policy Requirement in the Leadership Act does not violate the First Amendment as applied to United States corporation's foreign affiliates because the U.S. Constitution does not apply to non-U.S. citizens outside of U.S. soil.

Area(s) of Law:
  • First Amendment

June Med. Servs. L. L. C. v. Russo

Louisiana’s admitting-privileges law for abortion doctors represents a substantial obstacle to a woman pursuing an abortion and is therefore unconstitutional.

Area(s) of Law:
  • Constitutional Law

Seila Law LLC v. Consumer Financial Protection Bureau

The structure of the Consumer Financial Protection Bureau renders it unconstitutional because it is dominated by a single director and isolated from removal by the president, however, the provisions are severable.

Area(s) of Law:
  • Constitutional Law

Espinoza v. Montana Dept. of Revenue

Denying a benefit, generally available, based only on religious identity imposes on the free exercise clause and can only be justified by the highest order of state interest.

Area(s) of Law:
  • First Amendment

United States PTO v. Booking.com B.V.

Whether a term is generic for the purposes of federal trademark registration depends on its meaning to consumers and this distinctiveness inquiry focuses on the term’s whole meaning and not its isolated parts.

Area(s) of Law:
  • Trademarks

July 7 summaries

Barr v. Am. Ass'n of Political Consultants, Inc.

The 2015 amendment to the Telephone Consumer Protection Act of 1991 excluding robocalls made to collect government debts from the general prohibition against robocalls to cellular phones is unconstitutional and therefore severed.

Area(s) of Law:
  • Constitutional Law

Chiafalo v. Washington

Article II does not “expressly prohibit[] States from taking away presidential electors’ voting discretion as Washington does.” And that “’[l]ong settled and established practice’ may have ‘great weight in a proper interpretation of constitutional provisions.’” quoting The Pocket Veto Case, 279 U. S. 655, 689 (1929).

Area(s) of Law:
  • Constitutional Law

Little Sisters of the Poor Saints Peter and Paul Home v. Pennsylvania

The Patient Protection and Affordable Care Act (ACA) provision granted the Health Resources and Services Administration (HRSA) virtually unbridled discretion to recognize and craft exemptions from its Guidelines and Congress “declined to expressly require contraceptive coverage in the ACA itself.”

Area(s) of Law:
  • Administrative Law

McGirt v. Oklahoma

Congress has the sole power to disestablish a Native American reservation; the Major Crimes Act requires federal prosecution of certain crimes within “Indian country,” including the Creek Reservation in Oklahoma.

Area(s) of Law:
  • Indian Law

Trump v. Mazars, USA, LLP

Interbranch conflicts between the President and Congress calls for a level of scrutiny higher than what is required for an ordinary subpoena, but lower than what is required to overcome executive privilege.

Area(s) of Law:
  • Sovereign Immunity

Trump v. Vance

Neither the Supremacy Clause, nor Article II categorically preclude, or necessitate a heightened standard for, state criminal subpoenas issued to a sitting President.

Area(s) of Law:
  • Constitutional Law

Barr v. Lee

Unless and until the Supreme Court decides that the use of single-dose Pentobarbital as the Federal Government’s lethal injection protocol constitutes cruel and unusual punishment in violation of the Eighth Amendment, that proposition will not support a preliminary injunction of scheduled executions.

Area(s) of Law:
  • Sentencing

August 0 summaries

September 0 summaries

October 0 summaries

November 0 summaries

December 5 summaries

Carney, Governor of DE v. Adams

For a judicial candidate to have standing to bring a claim regarding eligibility for the position, it must be shown that the candidate is “able and ready” to apply for a judicial vacancy in the immediate future and thus would suffer a concrete injury.

Area(s) of Law:
  • Constitutional Law

Rutledge, Att'y Gen. of AK v. Pharmaceutical Care Management Ass'n

The purpose of the Employee Retirement Income Security Act of 1974 “to make the benefits promised by an employer more secure by mandating certain oversight systems and other standard procedures.” Gobeille v. Liberty Mut. Ins. Co., 577 U. S. 312, 320-321 (2016).

Area(s) of Law:
  • Preemption

Tanzin v. Tanvir

In suits against government officials, damages are an appropriate form of relief.

Area(s) of Law:
  • Remedies

United States v. Briggs

Under the Uniform Code of Military Justice (UCMJ), no time limitation exists for bringing charges on crimes which are “punishable by death” under the USMJ.

Area(s) of Law:
  • Criminal Law

Texas v. New Mexico

Under the Pecos River Compact, New Mexico is entitled to receive delivery credit for the water that evaporated during temporary storage of water at Texas’s request even though some of that water was not delivered to Texas.

Area(s) of Law:
  • Water Rights

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