In Burns v. United States, the petitioner pled guilty to theft of government funds, false claims, and tax evasion after defrauding the government of over $1.2 million through his position at AID, with a presentence report recommending a Guidelines range of 30-37 months and no departure. The district court instead departed upward to 60 months' imprisonment without prior notice, citing the duration of the conduct, disruption to government functions, and use of tax evasion to conceal other crimes; the D.C. Circuit affirmed, but the Supreme Court reversed. The Court held that Federal Rule of Criminal Procedure 32 requires a district court to provide notice and an opportunity to comment before departing upward from the Sentencing Guidelines range on its own initiative. This requirement follows from the rule's mandate that parties have an opportunity to comment on matters relating to the sentence, the need for accurate and fair resolution of disputed sentencing factors under the Guidelines system established by the Sentencing Reform Act, and the absence of any indication that Congress intended to allow sua sponte departures without notice.
This case concerned whether a debtor could include a mortgage lien on farm property in a Chapter 13 bankruptcy reorganization plan after the underlying personal debt had been discharged in a prior Chapter 7 liquidation. The Supreme Court held that the lien survives as a "claim" under the Bankruptcy Code that can be modified in the Chapter 13 plan. The reasoning centered on the broad statutory definition of "claim," which encompasses the creditor's in rem rights against the property even after personal liability is extinguished, consistent with the Code's provisions allowing modification of secured claims and the principle that liens pass through bankruptcy.
This case involved whether federal admiralty jurisdiction extended to a claim by Exxon against Central Gulf Lines and its vessel for an unpaid bill for bunker fuel that Exxon procured as Waterman's agent from a local supplier in Saudi Arabia under a long-term marine fuel contract. The lower courts dismissed the action for lack of jurisdiction, applying Minturn v. Maynard as establishing a per se rule that agency contracts are excluded from admiralty. The Supreme Court overruled Minturn and held that no such categorical exception exists. The Court reasoned that admiralty jurisdiction under 28 U.S.C. §1333(1) turns on whether the contract's subject matter relates to the protection of maritime commerce, so courts must examine the nature of the services performed rather than the agency form of the agreement.
This case involved an animal welfare lawsuit filed in Louisiana state court by organizations and individuals seeking to protect monkeys used in federally funded medical experiments, based on state laws regarding animal cruelty and tort damages. The National Institutes of Health (NIH), a federal agency and defendant, removed the case to federal court under a statute allowing certain federal defendants to remove state suits. The Supreme Court held that removal was improper, ruling that 28 U.S.C. § 1442(a)(1) permits removal only by federal officers, not by federal agencies themselves, and therefore the case must be remanded to state court. The Court reasoned that the statutory language distinguishes between officers and agencies, and petitioners had standing to challenge the removal as it affected their choice of forum.
This case involved a shareholder derivative action under the Investment Company Act of 1940 alleging that an investment adviser obtained approval of its contract through a materially misleading proxy statement. The plaintiff did not make a pre-suit demand on the board of directors, asserting that it would have been futile under the circumstances. Lower courts dismissed the claim by adopting a federal common law "universal demand" rule that eliminates the futility exception to the demand requirement. The Supreme Court reversed, holding that state law governs the scope of the demand requirement in such federal derivative actions because it embodies the incorporating state's allocation of corporate governance powers and a futility exception does not impede the Act's purposes.
The case concerned whether a savings and loan association could claim tax-deductible losses under the Internal Revenue Code by exchanging participation interests in one set of residential mortgages for interests in a different set of mortgages held by other lenders, as facilitated by a Federal Home Loan Bank Board regulation allowing such swaps without reporting book losses. The Supreme Court held that the exchanges produced realized losses eligible for deduction. The Court reasoned that under § 1001(a), realization occurs upon a "sale or other disposition" of property when the exchanged assets are materially different in kind or extent, meaning the parties receive distinct legal entitlements; here, the mortgages were secured by different properties and obligors, satisfying that standard and triggering recognition of the losses based on the difference between adjusted basis and fair market value.
