Episoder
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FDA v. Alliance for Hippocratic Medicine
In 2000, the Food and Drug Administration approved a new drug application for mifepristone tablets marketed under the brand name Mifeprex for use in terminating pregnancies up to seven weeks. To help ensure that Mifeprex would be used safely and effectively, FDA placed additional restrictions on the drugâs use and distribution, for example requiring doctors to prescribe or to supervise prescription of Mifeprex, and requiring patients to have three in-person visits with the doctor to receive the drug. In 2016, FDA relaxed some of these restrictions: deeming Mifeprex safe to terminate pregnancies up to 10 weeks; allowing healthcare providers, such as nurse practitioners, to prescribe Mifeprex; and approving a dosing regimen that required just one in-person visit to receive the drug. In 2019, FDA approved an application for generic mifepristone. In 2021, FDA announced that it would no longer enforce the initial in-person visit requirement. Four pro-life medical associations and several individual doctors moved for a preliminary injunction that would require FDA either to rescind approval of mifepristone or to rescind FDAâs 2016 and 2021 regulatory actions. Danco Laboratories, which sponsors Mifeprex, intervened to defend FDAâs actions. The District Court agreed with the plaintiffs and in effect enjoined FDAâs approval of mifepristone, thereby ordering mifepristone off the market. FDA and Danco appealed and moved to stay the District Courtâs order pending appeal. As relevant here, this Court ultimately stayed the District Courtâs order pending the disposition of proceedings in the Fifth Circuit and this Court. On the merits, the Fifth Circuit held that plaintiffs had standing. It concluded that plaintiffs were unlikely to succeed on their challenge to FDAâs 2000 and 2019 drug approvals, but were likely to succeed in showing that FDAâs 2016 and 2021 actions were unlawful. This Court granted certiorari with respect to the 2016 and 2021 FDA actions.
Held: Plaintiffs lack Article III standing to challenge FDAâs actions regarding the regulation of mifepristone. Pp. 5â25.
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After several Starbucks employees announced plans to unionize, they invited a news crew from a local television station to visit the store after hours to promote their unionizing effort. Starbucks fired multiple employees involved with the media event for violating company policy. The National Labor Relations Board filed an administrative complaint against Starbucks alleging that it had engaged in unfair labor practices. The Boardâs regional Director then filed a petition under §10( j) of the National Labor Relations Act seeking a preliminary injunction for the duration of the administrative proceedings that would, among other things, require Starbucks to reinstate the fired employees. The District Court assessed whether the Board was entitled to a preliminary injunction by applying a two-part test that asks whether âthere is reasonable cause to believe that unfair labor practices have occurred,â and whether injunctive relief is âjust and proper.â McKinney v. Ozburn-Hessey Logistics, LLC, 875 F. 3d 333, 339. Applying this standard, the District Court granted the injunction, and the Sixth Circuit affirmed. Held: When considering the NLRBâs request for a preliminary injunction under §10( j), district courts must apply the traditional four factors articulated in Winter v. Natural Resources Defense Council, Inc., 555 U. S. 7. Pp. 4â11.
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Manglende episoder?
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Drawing on a 2016 Presidential primary debate exchange between thencandidate Donald Trump and Senator Marco Rubio, respondent Steve Elster sought to federally register the trademark âTrump too smallâ to use on shirts and hats. An examiner from the Patent and Trademark Office refused registration based on the ânames clause,â a Lanham Act prohibition on the registration of a mark that â[c]onsists of or comprises a name . . . identifying a particular living individual except by his written consent,â 15 U. S. C. §1052(c). The Trademark Trial and Appeal Board affirmed, rejecting Elsterâs argument that the names clause violates his First Amendment right to free speech. The Federal Circuit reversed.
Held: The Lanham Actâs names clause does not violate the First Amendment.
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Petitioner Truck Insurance Exchange is the primary insurer for companies that manufactured and sold products containing asbestos. Two of those companies, Kaiser Gypsum Co. and Hanson Permanente Cement (Debtors), filed for Chapter 11 bankruptcy after facing thousands of asbestos-related lawsuits. As part of the bankruptcy process, the Debtors filed a proposed reorganization plan (Plan). That Plan creates an Asbestos Personal Injury Trust (Trust) under 11 U. S. C. §524(g), a provision that allows Chapter 11 debtors with substantial asbestos related liability to fund a trust and channel all present and future asbestos-related claims into that trust. Truck is contractually obligated to defend each covered asbestos personal injury claim and to indemnify the Debtors for up to $500,000 per claim. For their part, the Debtors must pay a $5,000 deductible per claim, and assist and cooperate with Truck in defending the claims. The Plan treats insured and uninsured claims differently, requiring insured claims to be filed in the tort system for the benefit of the insurance coverage, while uninsured claims are submitted directly to the Trust for resolution. Truck sought to oppose the Plan under §1109(b) of the Bankruptcy Code, which permits any âparty in interestâ to âraiseâ and âbe heard on any issueâ in a Chapter 11 bankruptcy. Among other things, Truck argues that the Plan exposes it to millions of dollars in fraudulent claims because the Plan does not require the same disclosures and authorizations for insured and uninsured claims. Truck also asserts that the Plan impermissibly alters its rights under its insurance policies. The District Court confirmed the Plan. It concluded, among other things, that Truck had limited standing to object to the Plan because the Plan was âinsurance neutral,â i.e., it did not increase Truckâs prepetition obligations or impair its contractual rights under its insurance policies. The Fourth Circuit affirmed, agreeing that Truck was not a âparty in interestâ under §1109(b) because the plan was âinsurance neutral.â
Held: An insurer with financial responsibility for bankruptcy claims is a âparty in interestâ under §1109(b) that âmay raise and may appear and be heard on any issueâ in a Chapter 11 case.
SOTOMAYOR, J., delivered the opinion of the Court, in which all other Members joined, except ALITO, J., who took no part in the consideration or decision of the case. -
The Indian Self-Determination and Education Assistance Act, 25 U. S. C. §5301 et seq., enables an Indian tribe to enter into a âself-determination contractâ with the Indian Health Service to assume responsibility for administering the healthcare programs that IHS would otherwise operate for the tribe. §5321(a)(1). When IHS administers such programs itself, it funds its operations through congressional appropriations and third-party insurance payments. Healthcare programs administered by a tribe under a self-determination contract have a parallel funding structure. First, IHS must provide to the tribe the Secretarial amount, which âshall not be lessâ than the congressionally appropriated amount that IHS would have used to operate such programs absent the self-determination contract. §5325(a)(1). Second, like IHS when it runs the healthcare programs, a contracting tribe can collect revenue from third-party payers like Medicare, Medicaid, and private insurers. See 42 U. S. C. §§1395qq(a), 1396j(a); 25 U. S. C. §1621e(a). These third-party funds are called âprogram incomeâ and must be used by the tribe âto further the general purposes of the contractâ with IHS. §5325(m)(1). The Secretarial amount and program income, however, do not place a contracting tribe on equal footing with IHS. That is because the tribe must incur certain overhead and administrative expenses that IHS does not incur when it runs the healthcare programs. To remedy this funding shortfall, Congress amended ISDA to require IHS to pay the tribe âcontract support costsâ to cover such âreasonable costs for activities which must be carried on by a [tribe] as a contractor to ensure compliance with the terms of the [self-determination] contract.â §5325(a)(2). Contract support costs eligible for repayment include âdirect program expenses for the operation of the Federal programâ and âany additional administrative or . . . overhead expense incurred by the [tribe] in connection with the operation of the Federal program, function, service, or activity pursuant to the contract.â §5325(a)(3)(A). Such costs are limited, however, to those âdirectly attributable toâ selfdetermination contracts. §5326. And no funds are available for âcosts associated with any contract . . . entered into between [a tribe] and any entity other than [IHS].â Ibid. These cases involve self-determination contracts between IHS and two tribesâthe San Carlos Apache Tribe and the Northern Arapaho Tribe. Both Tribes sued the Government for breach of contract, contending that although they used the Secretarial amount and program income to operate the healthcare programs they assumed from IHS under their self-determination contracts, IHS failed to pay the contract support costs they incurred by providing healthcare services using program income. The Ninth and Tenth Circuits concluded that each Tribe was entitled to reimbursement for such costs. Held: ISDA requires IHS to pay the contract support costs that a tribe incurs when it collects and spends program income to further the functions, services, activities, and programs transferred to it from IHS in a self-determination contract.
ROBERTS, C. J., delivered the opinion of the Court, in which SOTOMAYOR, KAGAN, GORSUCH, and JACKSON, JJ., joined. KAVANAUGH, J., filed a dissenting opinion, in which THOMAS, ALITO, and BARRETT, JJ., joined.
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Connelly v. United States
Michael and Thomas Connelly were the sole shareholders in Crown C Supply, a small building supply corporation. The brothers entered into an agreement to ensure that Crown would stay in the family if either brother died. Under that agreement, the surviving brother would have the option to purchase the deceased brotherâs shares. If he declined, Crown itself would be required to redeem (i.e., purchase) the shares. To ensure that Crown would have enough money to redeem the shares if required, it obtained $3.5 million in life insurance on each brother. After Michael died, Thomas elected not to purchase Michaelâs shares, thus triggering Crownâs obligation to do so. Michaelâs son and Thomas agreed that the value of Michaelâs shares was $3 million, and Crown paid the same amount to Michaelâs estate. As the executor of Michaelâs estate, Thomas then filed a federal tax return for the estate, which reported the value of Michaelâs shares as $3 million. The Internal Revenue Service (IRS) audited the return. During the audit, Thomas obtained a valuation from an outside accounting firm. That firm determined that Crownâs fair market value at Michaelâs death was $3.86 million, an amount that excluded the $3 million in insurance proceeds used to redeem Michaelâs shares on the theory that their value was offset by the redemption obligation. Because Michael had held a 77.18% ownership interest in Crown, the analyst calculated the value of Michaelâs shares as approximately $3 million ($3.86 million x 0.7718). The IRS disagreed. It insisted that Crownâs redemption obligation did not offset the life-insurance proceeds, and accordingly, assessed Crownâs total value as $6.86 million ($3.86 million + $3 million). The IRS then calculated the value of Michaelâs shares as $5.3 million ($6.86 million x 0.7718). Based on this higher valuation, the IRS determined that the estate owed an additional $889,914 in taxes. The estate paid the deficiency and Thomas, acting as executor, sued the United States for a refund. The District Court granted summary judgment to the Government. The court held that, to accurately value Michaelâs shares, the $3 million in life-insurance proceeds must be counted in Crownâs valuation. The Eighth Circuit affirmed.
Held: A corporationâs contractual obligation to redeem shares is not necessarily a liability that reduces a corporationâs value for purposes of the federal estate tax. -
In Cantero v. Bank of America, the Supreme Court reviewed a Second Circuit decision that struck down a New York bank regulation, finding that the State's authority was preempted by federal law. The Court held that Dodd-Frank requires a nuanced analysis -- rather than a bright line test -- on the issue of federal preemption. Justice Kavanaugh, writing for a unanimous Court, reversed and remanded with instructions on the analysis required to determine preemption.
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Petitioner National Rifle Association (NRA) sued respondent Maria Vulloâformer superintendent of the New York Department of Financial Services (DFS)âalleging that Vullo violated the First Amendment by coercing DFS-regulated parties to punish or suppress the NRAâs gun-promotion advocacy. The Second Circuit held that Vulloâs alleged actions constituted permissible government speech and legitimate law enforcement. The Court granted certiorari to address whether the NRAâs complaint states a First Amendment claim. The NRAâs âwell-pleaded factual allegations,â Ashcroft v. Iqbal, 556 U. S. 662, 678â679, are taken as true at this motion-to-dismiss stage. DFS regulates insurance companies and financial services institutions doing business in New York, and has the power to initiate investigations and civil enforcement actions, as well as to refer matters for criminal prosecution. The NRA contracted with DFS-regulated entitiesâ affiliates of Lockton Companies, LLC (Lockton)âto administer insurance policies the NRA offered as a benefit to its members, which Chubb Limited (Chubb) and Lloydâs of London (Lloydâs) would then underwrite. In 2017, Vullo began investigating one of these affinity insurance policiesâCarry Guardâon a tip passed along from a gun-control advocacy group. The investigation revealed that Carry Guard insured gun owners from intentional criminal acts in violation of New York law, and that the NRA promoted Carry Guard without the required insurance producer license. Lockton and Chubb subsequently suspended Carry Guard. Vullo then expanded her investigation into the NRAâs other affinity insurance programs. On February 27, 2018, Vullo met with senior executives at Lloydâs, expressed her views in favor of gun control, and told the Lloydâs executives âthat DFS was less interested in pursuingâ infractions unrelated to any NRA business âso long as Lloydâs ceased providing insurance to gun groups, especially the NRA.â App. to Pet. for Cert. at 199â 200, ¶21. Vullo and Lloydâs struck a deal: Lloydâs âwould instruct its syndicates to cease underwriting firearm-related policies and would scale back its NRA-related business,â and âin exchange, DFS would focus its forthcoming affinity-insurance enforcement action solely on those syndicates which served the NRA.â Id., at 223, ¶69. On April 19, 2018, Vullo issued letters entitled, âGuidance on Risk Management Relating to the NRA and Similar Gun Promotion Organizations.â Id., at 246â251 (Guidance Letters) . . .
Held: The NRA plausibly alleged that respondent violated the First Amendment by coercing regulated entities to terminate their business relationships with the NRA in order to punish or suppress gun-promotion advocacy.
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Thornell v. Jones
Respondent Danny Lee Jones was convicted of the premeditated firstdegree murders of Robert and Tisha Weaver and the attempted premeditated murder of Robertâs grandmother Katherine Gumina. Arizona law at the time required the trial court to âimpose a sentence of deathâ if it found âone or moreâ statutorily enumerated âaggravating circumstancesâ and âno mitigating circumstances sufficiently substantial to call for leniency.â Ariz. Rev. Stat. Ann. §13â703(E). The trial court found three aggravating circumstances that applied to both Robertâs and Tishaâs murders: Jones committed multiple homicides, §13â 703(F)(8); he was motivated by âpecuniaryâ gain, §13â703(F)(5); and the murders were âespecially heinous, cruel or depraved,â §13â 703(F)(6). The trial court found an additional aggravating circumstance with respect to Tishaâs murder: she was a young child, §13â 703(F)(9). The trial court also concluded that Jones had established four mitigating circumstances: long-term substance abuse, drug and alcohol impairment at the time of the murders, head trauma, and childhood abuse. 9 Record 2465. The court concluded that these mitigating circumstances were ânot sufficiently substantial to outweigh the aggravating circumstances,â so it sentenced Jones to death. Ibid. The Arizona Supreme Court affirmed after âreview[ing] the entire recordâ and âindependently weighing all of the aggravating and mitigating evidence presented.â 185 Ariz. 471, 492, 917 P. 2d 200, 221. Jones later sought state postconviction review on the theory that defense counsel was ineffective, but the Arizona courts rejected Jonesâs claims. Jones next filed a federal habeas petition in District Court and reasserted his ineffective-assistance-of-counsel claims. The District Court held an evidentiary hearing but ultimately concluded that Jones could not show prejudice because the additional information he presented â âbarely. . . alter[ed] the sentencing profile presented to the sentencing judge.â â Jones v. Schriro, 450 F. Supp. 2d 1023, 1043 (quoting Strickland v. Washington, 466 U. S. 668, 700). The Ninth Circuit reversed, but this Court vacated that judgment and remanded for the Ninth Circuit to determine whether, in light of Cullen v. Pinholster, 563 U. S. 170, it had been proper to consider the new evidence presented at the federal evidentiary hearing. See Ryan v. Jones, 563 U. S. 932. On reconsideration, the Ninth Circuit again granted habeas relief. The panel held that it was permissible to consider the new evidence and concluded that there was a â âreasonable probabilityâ â that âJones would not have received a death sentenceâ if that evidence had been presented at sentencing. Jones v. Ryan, 52 F. 4th 1104, 1137. Ten judges dissented from the denial of en banc review. One dissent, joined by eight judges, asserted that the Ninth Circuit panel flouted Strickland by crediting âquestionable, weak, and cumulative mitigation evidenceâ as âenough to overcome . . . weight[y] . . . aggravating circumstances.â Id., at 1155. Held: The Ninth Circuitâs interpretation and application of Strickland was in error.
Reversed and remanded.
ALITO, J., delivered the opinion of the Court, in which ROBERTS, C. J., and THOMAS, GORSUCH, KAVANAUGH, and BARRETT, JJ., joined. SOTOMAYOR, J., filed a dissenting opinion, in which KAGAN, J., joined. JACKSON, J., filed a dissenting opinion.
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Coinbase v. Suski
The dispute here involves a conflict between two contracts executed by petitioner Coinbase, Inc., operator of a cryptocurrency exchange platform, and respondents, who use Coinbase. The first contractâthe Coinbase User Agreement that respondents agreed to when they created their accountsâcontains an arbitration provision with a delegation clause. Per this provision, an arbitrator must decide all disputes under the contract, including whether a given disagreement is arbitrable. The second contractâthe Official Rules for a promotional sweepstakes respondents enteredâcontains a forum selection clause providing that California courts âshall have sole jurisdiction of any controversies regarding the [sweepstakes] promotion.â Respondents ultimately filed a class action in the U. S. District Court for the Northern District of California, alleging that the sweepstakes violated various California laws. Coinbase moved to compel arbitration based on the User Agreementâs delegation clause. The District Court determined that the Official Rulesâ forum selection clause controlled the partiesâ dispute and accordingly denied the motion. The Ninth Circuit affirmed. Held: Where parties have agreed to two contractsâone sending arbitrability disputes to arbitration, and the other either explicitly or implicitly sending arbitrability disputes to the courtsâa court must decide which contract governs. -
These cases concern the application of the Armed Career Criminal Act to state drug convictions that occurred before recent technical amendments to the federal drug schedules. ACCA imposes a 15-year mandatory minimum sentence on defendants who are convicted for the illegal possession of a firearm and who have a criminal history thought to demonstrate a propensity for violence. As relevant here, a defendant with âthree previous convictionsâ for âa serious drug offenseâ qualifies for ACCAâs enhanced sentencing. 18 U. S. C. §924(e)(1). For a state crime to qualify as a âserious drug offense,â it must carry a maximum sentence of at least 10 yearsâ imprisonment, and it must âinvolv[e] . . . a controlled substance . . . as defined in section 102 of the Controlled Substances Act.â §§924(e)(1), (2)(A)(ii). Under the categorical approach, a state drug offense counts as an ACCA predicate only if the Stateâs definition of the drug in question âmatche[s]â the definition under federal law. Shular v. United States, 589 U. S. 154, 158. The question presented is whether a state crime constitutes a âserious drug offenseâ if it involved a drug that was on the federal schedules when the defendant possessed or trafficked in it but was later removed. Petitioners Justin Rashaad Brown and Eugene Jackson were separately convicted of the federal crime of possession of a firearm by a convicted felon in violation of §922(g)(1). In both cases, an ACCA enhancement was recommended based on prior state felony drug convictions. And both defendants argued that their prior convictions did not qualify as âserious drug offense[ s].â
Held: A state drug conviction counts as an ACCA predicate if it involved a drug on the federal schedules at the time of that offense. Pp. 4â 19.
ALITO, J., delivered the opinion of the Court, in which ROBERTS, C. J., and THOMAS, SOTOMAYOR, KAVANAUGH, and BARRETT, JJ., joined. JACKSON, J., filed a dissenting opinion, in which KAGAN, J., joined, and in which GORSUCH, J., joined as to Parts I, II, and III. -
Alexander v. NAACP
The Constitution entrusts state legislatures with the primary responsibility for drawing congressional districts, and legislative redistricting is an inescapably political enterprise. Claims that a map is unconstitutional because it was drawn to achieve a partisan end are not justiciable in federal court. By contrast, if a legislature gives race a predominant role in redistricting decisions, the resulting map is subjected to strict scrutiny and may be held unconstitutional. These doctrinal lines collide when race and partisan preference are highly correlated. This Court has endorsed two related propositions when navigating this tension. First, a party challenging a mapâs constitutionality must disentangle race and politics to show that race was the legislatureâs âpredominantâ motivating factor. Miller v. Johnson, 515 U. S. 900, 916. Second, the Court starts with a presumption that the legislature acted in good faith. To disentangle race from other permissible considerations, plaintiffs may employ some combination of direct and circumstantial evidence. Cooper v. Harris, 581 U. S. 285, 291. Where race and politics are highly correlated, a map that has been gerrymandered to achieve a partisan end can look very similar to a racially gerrymandered map. Thus, in Easley v. Cromartie, 532 U. S. 234, the Court held that the plaintiffs failed to meet the high bar for a racial-gerrymandering claim when they failed to produce an alternative map showing that a rational legislature sincerely driven by its professed partisan goals would have drawn a different map with greater racial balance. Id., at 258. Without an alternative map, the Court also found it difficult for plaintiffs to defeat the starting presumption that the legislature acted in good faith.
Held: 1. The District Courtâs finding that race predominated in the design of District I in the Enacted Plan was clearly erroneous.
2. Because the same findings of fact and reasoning that guided the courtâs racial-gerrymandering analysis also guided the analysis of the Challengersâ independent vote-dilution claim, that conclusion also cannot stand. The District Court also erred in conflating the two claims. A plaintiff pressing a vote-dilution claim cannot prevail simply by showing that race played a predominant role in the districting process, but rather must show that the State âenacted a particular voting scheme as a purposeful device to minimize or cancel out the voting potential of racial or ethnic minorities.â Miller, 515 U. S., at 911. In other words, the plaintiff must show that the Stateâs districting plan âhas the purpose and effectâ of diluting the minority vote. Shaw v. Reno, 509 U. S. 630, 649. In light of these two errors in the District Courtâs analysis, a remand is appropriate. Pp. 34â35. Reversed in part and remanded in part. ALITO, J., delivered the opinion of the Court, in which ROBERTS, C. J., and GORSUCH, KAVANAUGH, and BARRETT, JJ., joined, and in which THOMAS, J., joined as to all but Part IIIâC. THOMAS, J., filed an opinion concurring in part. KAGAN, J., filed a dissenting opinion, in which SOTOMAYOR and JACKSON, JJ., joined. -
In Harrow v. Department of Defense, Stuart Harrow appealed an adverse administrative decision after the 60-day deadline -- claiming that he was unaware of the deadline. He filed this appeal to the Federal Circuit. Because the Federal Circuit saw the mandatory "shall" language in the statute (that is, it shall be filed within 60 days), the Court denied his request, reasoning that it lacked jurisdiction. The issue in front of the Supreme Court was whether this provision was jurisdictional. Justice Kagan, writing for a unanimous Court, decided that the provision was mandatory, but not jurisdictional, and the lower court therefore, could exercise its discretion to hear the case. Vacated and remanded.
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Smith v. Spizzirri
The Federal Arbitration Act (FAA) sets forth procedures for enforcing arbitration agreements in federal court. Section 3 of the FAA, entitled âStay of proceedings where issue therein referable to arbitration,â provides that when a dispute is subject to arbitration, the court âshall on application of one of the parties stay the trial of the action until such arbitration has been had in accordance with the terms of the agreement, providing the applicant for the stay is not in default in proceeding with such arbitration.â 9 U. S. C. §3. In this case, petitioners filed suit against respondents in state court alleging violations of federal and state employment laws. Respondents then removed to federal court and filed a motion to compel arbitration and dismiss the suit. Petitioners agreed their claims were arbitrable, but contended that §3 of the FAA required the District Court to stay the action pending arbitration rather than dismissing it entirely. The District Court issued an order compelling arbitration and dismissed the case without prejudice. The Ninth Circuit affirmed.
Held: When a district court finds that a lawsuit involves an arbitrable dispute and a party has requested a stay of the court proceeding pending arbitration, §3 compels the court to issue a stay, and the court lacks discretion to dismiss the suit. Statutory text, structure, and purpose all point to this conclusion. The plain text of §3 requires a court to stay the proceeding upon request. The statuteâs use of the word âshallâ âcreates an obligation impervious to judicial discretion.â
Reversed and remanded. SOTOMAYOR, J., delivered the opinion for a unanimous Court.
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CONSUMER FINANCIAL PROTECTION BUREAU ET AL. v. COMMUNITY FINANCIAL SERVICES ASSOCIATION OF AMERICA, LTD., ET AL.
The Constitution gives Congress control over the public fisc subject to the command that â[n]o Money shall be drawn from the Treasury, but in Consequence of Appropriations made by Law.â Art. I, §9, cl. 7. For most federal agencies, Congress provides funding through annual appropriations. For the Consumer Financial Protection Bureau, however, Congress provided a standing source of funding outside the ordinary annual appropriations process. Specifically, Congress authorized the Bureau to draw from the Federal Reserve System an amount that its Director deems âreasonably necessary to carry outâ the Bureauâs duties, subject only to an inflation-adjusted cap. 12 U. S. C. §§5497(a)(1), (2). In this case, several trade associations representing payday lenders and credit-access businesses challenged regulations issued by the Bureau pertaining to high-interest consumer loans on statutory and constitutional grounds. As relevant here, the Fifth Circuit accepted the associationsâ argument that the Bureauâs funding mechanism violates the Appropriations Clause.
Held: Congressâ statutory authorization allowing the Bureau to draw money from the earnings of the Federal Reserve System to carry out the Bureauâs duties satisfies the Appropriations Clause.
(a) Under the Appropriations Clause, an appropriation is a law that authorizes expenditures from a specified source of public money for designated purposes.
(b) The associationsâ three principal arguments for why the Bureauâs funding mechanism violates the Appropriations Clause are unpersuasive.
51 F. 4th 616, reversed and remanded. THOMAS, J., delivered the opinion of the Court, in which ROBERTS, C. J., and SOTOMAYOR, KAGAN, KAVANAUGH, BARRETT, and JACKSON, JJ., joined. KAGAN, J., filed a concurring opinion, in which SOTOMAYOR, KAVANAUGH, and BARRETT, JJ., joined. JACKSON, J., filed a concurring opinion. ALITO, J., filed a dissenting opinion, in which GORSUCH, J., joined.
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Culley v. Marshall
Petitioner Halima Culley loaned her car to her son, who was later pulled over by Alabama police officers and arrested for possession of marijuana. Petitioner Lena Sutton loaned her car to a friend, who was stopped by Alabama police and arrested for trafficking methamphetamine. In both cases, petitionersâ cars were seized under an Alabama civil forfeiture law that permitted seizure of a car âincident to an arrestâ so long as the State then âpromptlyâ initiated a forfeiture case. Ala. Code §20â2â93(b)(1), (c). The State of Alabama filed forfeiture complaints against Culleyâs and Suttonâs cars just 10 and 13 days, respectively, after their seizure. While their forfeiture proceedings were pending, Culley and Sutton each filed purported class-action complaints in federal court seeking money damages under 42 U. S. C. §1983, claiming that state officials violated their due process rights by retaining their cars during the forfeiture process without holding preliminary hearings. In a consolidated appeal, the Eleventh Circuit affirmed the dismissal of petitionersâ claims, holding that a timely forfeiture hearing affords claimants due process and that no separate preliminary hearing is constitutionally required.
Held: In civil forfeiture cases involving personal property, the Due Process Clause requires a timely forfeiture hearing but does not require a separate preliminary hearing.
KAVANAUGH, J., delivered the opinion of the Court, in which ROBERTS, C. J., and THOMAS, ALITO, GORSUCH, and BARRETT, JJ., joined. GORSUCH, J., filed a concurring opinion, in which THOMAS, J., joined. SOTOMAYOR, J., filed a dissenting opinion, in which KAGAN and JACKSON, JJ., joined.
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Warner Chappell Music v. Nealy
Under the Copyright Act, a plaintiff must file suit âwithin three years after the claim accrued.â 17 U. S. C. §507(b). On one understanding of that limitations provision, a copyright claim âaccrue[s]â when âan infringing act occurs.â Petrella v. Metro-Goldwyn-Mayer, Inc., 572 U. S. 663, 670. But under an alternative view, the so-called discovery rule, a claim accrues when âthe plaintiff discovers, or with due diligence should have discovered,â the infringing act. Ibid., n. 4. That rule enables a diligent plaintiff to raise claims about even very old infringements if he discovered them within the three years prior to suit. In this case, respondent Sherman Nealy invoked the discovery rule to sue Warner Chappell Music for copyright infringements going back ten years. Nealy argued that his claims were timely because he first learned of the infringing conduct less than three years before he sued. In the District Court, Warner Chappell accepted that the discovery rule governed the timeliness of Nealyâs claims. But it argued that, even if Nealy could sue under that rule for older infringements, he could recover damages or profits for only those occurring in the last three years. The District Court agreed. On interlocutory appeal, the Eleventh Circuit reversed, rejecting the notion of a three-year damages bar on a timely claim. Held: The Copyright Act entitles a copyright owner to obtain monetary relief for any timely infringement claim, no matter when the infringement occurred. The Actâs statute of limitations establishes a threeyear period for filing suit, which begins to run when a claim accrues (here, the Court assumes without deciding, upon its discovery). That provision establishes no separate three-year limit on recovering damages. If any time limit on damages exists, it must come from the Actâs remedial sections. But those provisions merely state that an infringer is liable either for statutory damages or for the ownerâs actual damages and the infringerâs profits. See §504(a)â(c). There is no time limit on monetary recovery. So a copyright owner possessing a timely claim is entitled to damages for infringement, no matter when the infringement occurred. The Courtâs decision in Petrella also does not support a three-year damages cap. There, the Court noted that the Copyright Actâs statute of limitations allows plaintiffs âto gain retrospective relief running only three years back fromâ the filing of a suit. 572 U. S., at 672. Taken out of context, that line might seem to address the issue here. But that statement merely described how the limitations provision worked in Petrella, where the plaintiff had long known of the defendantâs infringing conduct and so could not avail herself of the discovery rule to sue for infringing acts more than three years old. The Court did not go beyond the caseâs facts to say that even if the limitations provision allows a claim for an earlier infringement, the plaintiff may not obtain monetary relief. Unlike the plaintiff in Petrella, Nealy has invoked the discovery rule to bring claims for infringing acts occurring more than three years before he filed suit. The Court granted certiorari in this case on the assumption that such claims may be timely under the Actâs limitations provision. If Nealyâs claims are thus timely, he may obtain damages for them. Pp. 4â7. 60 F. 4th 1325, affirmed. KAGAN, J., delivered the opinion of the Court, in which ROBERTS, C. J., and SOTOMAYOR, KAVANAUGH, BARRETT, and JACKSON, JJ., joined. GORSUCH, J., filed a dissenting opinion, in which THOMAS and ALITO, JJ., joined.
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Muldrow v. City of St. Louis
Sergeant Jatonya Clayborn Muldrow maintains that her employer, the St. Louis Police Department, transferred her from one job to another because she is a woman. From 2008 through 2017, Muldrow worked as a plainclothes officer in the Departmentâs specialized Intelligence Division. In 2017, the new Intelligence Division commander asked to transfer Muldrow out of the unit so he could replace her with a male police officer. Against Muldrowâs wishes, the Department approved the request and reassigned Muldrow to a uniformed job elsewhere in the Department. While Muldrowâs rank and pay remained the same in the new position, her responsibilities, perks, and schedule did not. After the transfer, Muldrow no longer worked with high-ranking officials on the departmental priorities lodged in the Intelligence Division, instead supervising the day-to-day activities of neighborhood patrol officers. She also lost access to an unmarked take-home vehicle and had a less regular schedule involving weekend shifts. Muldrow brought this Title VII suit to challenge the transfer. She alleged that the City, in ousting her from the Intelligence Division, had âdiscriminate[d] againstâ her based on sex âwith respect toâ the âterms [or] conditionsâ of her employment. 42 U. S. C. §2000eâ2(a)(1). The District Court granted the City summary judgment. The Eighth Circuit affirmed, holding that Muldrow had toâbut could notâshow that the transfer caused her a âmaterially significant disadvantage.â 30 F. 4th 680, 688. Muldrowâs lawsuit could not proceed, the court said, because the transfer âdid not result in a diminution to her title, salary, or benefitsâ and had caused âonly minor changes in working conditions.â
Held: An employee challenging a job transfer under Title VII must show that the transfer brought about some harm with respect to an identifiable term or condition of employment, but that harm need not be significant. Pp. 5â11.
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McIntosh v. United States
Petitioner Louis McIntosh was indicted on multiple counts of Hobbs Act robbery and firearm offenses. The indictment set forth the demand that McIntosh âshall forfeit . . . all property . . . derived from proceeds traceable to the commission of the [Hobbs Act] offenses.â The Government also later provided McIntosh with a pretrial bill of particulars that included as property subject to forfeiture $75,000 in cash and a BMW that McIntosh purchased just five days after one of the robberies. After a jury convicted McIntosh, the District Court imposed a forfeiture of $75,000 and the BMW at the sentencing hearing. Although the District Court also ordered the Government to submit an order of forfeiture for the courtâs signature within a week from the hearing, the Government failed to do so. On appeal, the Government moved for a limited remand to supplement the record with a written order of forfeiture. The Second Circuit granted the unopposed motion. Back in District Court, McIntosh argued that the failure to comply with Federal Rule of Criminal Procedure 32.2(b)(2)(B)âwhich provides that â[u]nless doing so is impractical,â a federal district court âmust enter the preliminary order [of forfeiture] sufficiently in advance of sentencing to allow the parties to suggest revisions or modifications before the order becomes final as to the defendantââmeant that the District Court could not proceed with forfeiture at all. The District Court overruled McIntoshâs objections, finding that the Rule is a timerelated directive, and that the failure to enter a preliminary order of forfeiture before sentencing did not prevent the court from ordering forfeiture because the missed deadline did not prejudice McIntosh. The Second Circuit affirmed in relevant part. Held: A district courtâs failure to comply with Rule 32.2(b)(2)(B)âs requirement to enter a preliminary order before sentencing does not bar a judge from ordering forfeiture at sentencing subject to harmless-error principles on appellate review.
(a) Although the District Court did not comply with Rule 32.2(b)(2)(B) when it failed to enter a preliminary order of forfeiture before McIntoshâs initial sentencing, the District Court retained its power to order forfeiture against McIntosh.
(b) McIntoshâs contrary arguments are unpersuasive. He points to he Ruleâs use of the word âmustâ to highlight its mandatory character, but such language standing âalone has not always led this Court to interpret statutes to bar judges . . . from taking action to which a missed statutory deadline refers.â
(c) Noncompliance with Rule 32.2(b)(2)(B) is a procedural error subject to harmlessness review. Because McIntosh did not challenge the lower courtsâ harmlessness analysis in either his certiorari petition or his opening brief, this Court need not revisit it. P. 13.
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Petitioner James Rudisill enlisted in the United States Army in 2000 and served a total of eight years over three separate periods of military service. He became entitled to Montgomery Bill benefits as a result of his first period of service. Rudisill earned an undergraduate degree and used 25 months and 14 days of Montgomery benefits to finance his education. Through his subsequent periods of service, Rudisill also became entitled to more generous educational benefits under the Post-9/11 GI Bill. Rudisill sought to use his Post-9/11 benefits to finance a graduate degree. Rudisill understood that such benefits would be limited to 22 months and 16 days under §3695âs 48-month aggregate-benefits cap. But the Government informed Rudisill that he was only eligible for 10 months and 16 days of Post-9/11 benefits (the length of his unused Montgomery benefits) due to §3327, a provision in the Post-9/11 Bill designed to coordinate benefits for those servicemembers meeting the criteria for both Montgomery benefits and Post-9/11 benefits. Section 3327 provides that a servicemember meeting the criteria for both GI bills can elect to swap Montgomery benefits for the more generous Post-9/11 benefits, up to a total of 36 months of benefits. §3327(d)(2)(A). Ultimately, the Federal Circuit, sitting en banc, sided with the Government, explaining that when Rudisill sought to use his Post-9/11 benefits, he had made an âelectionâ under §3327(a)(1) to swap his Montgomery benefits for Post 9/11 benefits, making his benefits subject to §3327(d)(2)âs 36-month limit.
Held: Servicemembers who, through separate periods of service, accrue educational benefits under both the Montgomery and Post-9/11 GI Bills may use either one, in any order, up to §3695(a)âs 48-month aggregate-benefits cap. Pp. 8â18.
(a) The Government claims that someone in Rudisillâs position is subject to §3322(d)âs mandatory coordination clause, so, to receive any Post-9/11 benefits, he must make an election under §3327(a), which in turn subjects him to §3327(d)(2)âs 36-month benefit limit. Rudisill counters that §3322(d) does not apply to him because he has earned two separate entitlements to benefits. Rudisill further maintains that §3327(a)âs election mechanism is optional in any event, and that he does not forfeit any entitlement by declining to make a §3327(a) election. The statutory text resolves this case in Rudisillâs favor.
(b) Section 3322(d), which creates a mechanism for certain servicemembers to âcoordinateâ their benefits, does not limit Rudisillâs entitlement. First, nothing in the statute imposes a duty for any veteran to âcoordinateâ entitlements in order to receive benefits. Section 3322(d) does not mention the receipt of benefits but addresses instead the âcoordination of entitlement.â Because Rudisill is already entitled to two separate benefits, he has no need to coordinate any entitlement under §3327. As used in the statute, the word âcoordinationâ denotes a swap. Section 3327, to which §3322(d) points, describes coordination as making an election that permits the individual to get Post-9/11 benefits âinstead ofâ Montgomery benefits. §3327(d)(1).
(c) The contention that Rudisill can only use his Post-9/11 benefits by invoking §3327 is contradicted by that provisionâs text.
Reversed and remanded.
JACKSON, J., delivered the opinion of the Court, in which ROBERTS, C. J., and SOTOMAYOR, KAGAN, GORSUCH, KAVANAUGH, and BARRETT, JJ., joined. KAVANAUGH, J., filed a concurring opinion, in which BARRETT, J., joined. THOMAS, J., filed a dissenting opinion, in which ALITO, J., joined.
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