Antonin Scalia

In Cuomo v. Clearing House Ass'n, LLC, the New York Attorney General sought nonpublic lending records from national banks to investigate potential violations of state fair-lending laws, prompting the Office of the Comptroller of the Currency (OCC) and a banking trade group to sue for an injunction. The Supreme Court held that the OCC's regulation, which interpreted the National Bank Act (NBA) to preempt most state enforcement actions against national banks, was not a reasonable construction of the statute's bar on "visitorial powers." The Court reasoned that historical understandings, precedents, and statutory text distinguish between a sovereign's supervisory visitation (such as examinations) and ordinary judicial enforcement of valid state laws, and that the NBA does not bar the latter; states may therefore pursue enforcement through courts rather than administrative oversight. The decision reversed the lower courts' injunction that had broadly blocked the Attorney General's information request and related proceedings.

business & regulatoryfederal powercivil rights

In Melendez-Diaz v. Massachusetts, the prosecution at a state drug trial introduced sworn certificates from laboratory analysts stating that seized material was cocaine of a certain quantity, which state law treated as prima facie evidence. The defendant objected that this violated his Sixth Amendment confrontation rights under Crawford v. Washington because the analysts did not testify in person. The Supreme Court held that admitting the certificates violated the Confrontation Clause. The Court reasoned that the certificates were affidavits falling within the core class of testimonial statements, prepared under circumstances indicating they would be used at trial, so the defendant was entitled to confront the analysts.

criminal lawprocedure

The case involved environmental organizations suing the U.S. Forest Service over regulations that exempted small timber salvage sales from standard notice, comment, and appeal procedures, initially tied to a specific project called Burnt Ridge. After the parties settled the Burnt Ridge dispute, the Supreme Court held that the organizations lacked standing to challenge the remaining regulations. The Court reasoned that Article III limits federal jurisdiction to actual or imminent concrete injuries to plaintiffs, and the groups failed to show any live application of the rules that threatened their members' specific recreational or aesthetic interests in national forests; generalized procedural harms or future possibilities were insufficient.

environmentprocedurefederal power

The case concerned whether, at a murder trial, unconfronted statements made by the victim to police could be admitted into evidence against the defendant under a forfeiture-by-wrongdoing theory. The Supreme Court held that the Sixth Amendment’s Confrontation Clause bars such evidence unless the defendant engaged in conduct specifically intended to prevent the witness from testifying. The Court reasoned that neither founding-era common law nor subsequent American jurisprudence recognized a forfeiture exception that applied merely because the defendant’s criminal act caused the witness’s unavailability, as opposed to conduct aimed at silencing testimony. The state courts were directed to consider the defendant’s intent on remand.

criminal lawprocedure

The case concerned the constitutionality of 18 U.S.C. §2252A(a)(3)(B), a federal statute enacted after Ashcroft v. Free Speech Coalition to criminalize pandering and solicitation of child pornography by prohibiting offers to provide or requests to obtain such material. Respondent Williams, who had pleaded guilty to the offense while preserving his challenge, argued that the provision was facially overbroad under the First Amendment and impermissibly vague under the Due Process Clause; the district court rejected the challenge, but the Eleventh Circuit reversed. The Supreme Court held that the statute is neither overbroad nor vague. It reasoned that the provision targets collateral speech offering or seeking material that matches the categories of child pornography already held unprotected in New York v. Ferber and Miller v. California, that offers to engage in unlawful transactions receive no First Amendment protection, and that the statute's scienter requirements and defined terms provide fair notice and avoid arbitrary enforcement.

criminal lawfree speech

In Virginia v. Moore, police arrested the defendant for the misdemeanor of driving on a suspended license despite state law requiring only a summons, and a search incident to the arrest uncovered crack cocaine that was used to convict him on drug charges. The trial court admitted the evidence, but the Virginia Supreme Court reversed on Fourth Amendment grounds, holding that the arrest and search were invalid because officers should have issued a citation. The U.S. Supreme Court reversed, ruling that an arrest based on probable cause is constitutionally reasonable under the Fourth Amendment even if prohibited by state law, and that a search incident to such an arrest is permissible. The Court reasoned from founding-era history and traditional standards of reasonableness that the Fourth Amendment does not incorporate state-law restrictions on arrest authority, preferring administrable bright-line rules over variable state policies.

criminal lawprocedure

The case involved a lawsuit by Donna Riegel against Medtronic after a catheter, a Class III medical device approved by the FDA through premarket approval, ruptured during surgery on her husband. The plaintiffs claimed the device was defective under New York common law regarding design, labeling, and manufacturing. The Supreme Court decided that the Medical Device Amendments of 1976 preempt state common-law claims that challenge the safety or effectiveness of FDA-approved devices, because such claims impose requirements different from or in addition to federal requirements. The core reasoning was that premarket approval establishes specific federal requirements for the device, and common-law duties constitute state "requirements" relating to safety and effectiveness that are preempted under 21 U.S.C. §360k(a).

business & regulatoryfederal powerhealthcaretorts & liability

This case involved state-court lawsuits alleging price-fixing in California's energy market, with cross-claims against U.S. government agencies, a Canadian corporation (BC Hydro) treated as a foreign state under the Foreign Sovereign Immunities Act (FSIA), and its subsidiary Powerex. After removal to federal court, the district court determined that Powerex was not a foreign state, the other cross-defendants had sovereign immunity, and it lacked subject-matter jurisdiction, leading to a remand to state court. Powerex appealed, arguing its status as a foreign sovereign under the FSIA, but the Supreme Court held that 28 U.S.C. §1447(d) bars appellate review of the remand order. The Court reasoned that the remand was based on lack of subject-matter jurisdiction under §1447(c), which shields such orders from review regardless of whether the case was properly removed initially, and there was no separate reviewable order under precedents like Waco. The Ninth Circuit's decision affirming the district court's ruling on Powerex's status was thus unreviewable.

procedurefederal power

The case concerned a Washington state law (§760) requiring public-sector unions to obtain affirmative authorization from nonmember employees before spending agency fees on election-related purposes. The U.S. Supreme Court held that the requirement does not violate the First Amendment. The Court reasoned that public-sector unions have no constitutional entitlement to nonmembers' fees beyond the minimum protections set by Abood and Hudson, and that states may impose additional limits since they could restrict or eliminate agency fees entirely. The ruling distinguished the compelled-fee context from restrictions on voluntary funds addressed in campaign-finance precedents.

labor & employmentfree speechelections

The case concerned whether a bankrupt company, Crown Vantage, breached its fiduciary duties under ERISA by rejecting a union's proposal to merge its single-employer pension plans into a multiemployer plan and instead choosing to terminate the plans through the purchase of annuities, which allowed Crown to recover a surplus of about $5 million. The Supreme Court held that Crown did not breach any fiduciary obligations because a merger is not a permissible method of plan termination under ERISA. The Court reasoned that ERISA's termination provisions in 29 U.S.C. §1341(b)(3)(A) authorize only annuities or lump-sum distributions, and it deferred to the PBGC's longstanding interpretation that merger is a distinct alternative to termination rather than a form of it. The opinion noted key differences, including that merger would keep assets under ERISA but prevent the employer from recovering surplus funds, and that merger is governed by separate statutory sections with different procedures.

labor & employmentbusiness & regulatory

In Fry v. Pliler, a state prisoner sought federal habeas relief under 28 U.S.C. §2254 after his conviction, claiming that the trial court's exclusion of defense witness testimony violated due process under Chambers v. Mississippi. The Supreme Court held that federal courts must assess the prejudicial impact of any such constitutional error using the Brecht “substantial and injurious effect” standard, whether or not the state appellate court recognized the error and applied Chapman’s “harmless beyond a reasonable doubt” review. The core reasoning was that Brecht’s less stringent standard on collateral review is driven by concerns of finality, comity, and federalism that apply regardless of the state court’s approach, and AEDPA does not require a different result.

criminal lawprocedure

The case involved a police officer who ended a high-speed car chase by using his bumper to push the fleeing vehicle off the road, resulting in a crash that left the driver quadriplegic. The driver sued under 42 U.S.C. §1983, claiming the maneuver constituted excessive force in violation of the Fourth Amendment. The Supreme Court held that the officer was entitled to summary judgment based on qualified immunity because his actions were reasonable under the Fourth Amendment. The Court reasoned that the chase posed an immediate risk of serious harm to the public, and video evidence showed that the driver's reckless conduct created that danger, outweighing the risk to the driver himself. The decision emphasized that the reasonableness of a seizure depends on balancing the governmental interest against the intrusion on individual rights, without rigid rules based on whether the force was deadly.

criminal lawcivil rightsprocedure

The case involved a qui tam action under the False Claims Act brought by former Rockwell engineer James Stone against the company for allegedly submitting false claims to the government regarding the production of solid pondcrete blocks from toxic sludge at a nuclear weapons facility. The government intervened, and after a jury verdict partially favoring the plaintiffs on pondcrete-related claims, Rockwell challenged Stone's standing. The Supreme Court held that the original-source exception to the Act's public-disclosure jurisdictional bar is a threshold requirement that must be met based on the information underlying the final allegations presented at trial. Stone failed to qualify as an original source because he lacked direct and independent knowledge of the actual defect (an insufficient cement-to-sludge ratio) that caused the insolid blocks; his pre-employment prediction of a different piping-system problem did not suffice, even though it had been disclosed publicly.

criminal lawprocedureenvironment

The case involved a plaintiff arrested for murder in 1994 who was later released when charges were dropped in 2002 and who sued Chicago police officers in 2003 under 42 U.S.C. §1983 for damages based on an allegedly unlawful arrest violating the Fourth Amendment. The Supreme Court affirmed dismissal of the suit as time-barred, ruling that the two-year Illinois statute of limitations for personal-injury claims began to run when the plaintiff was first held pursuant to legal process after his arrest, not when the charges were dismissed years later. The Court reasoned that false-arrest claims are analogous to false-imprisonment torts, for which the limitations period starts at the end of the detention without legal process, and rejected the argument that Heck v. Humphrey required accrual only after any related conviction was invalidated.

criminal lawcivil rightsprocedure

In MedImmune, Inc. v. Genentech, Inc., a patent licensee paid royalties under protest after the licensor claimed coverage of its product and threatened enforcement action, then sought a declaratory judgment that the patent was invalid and unenforceable. The lower courts dismissed the case for lack of subject-matter jurisdiction, holding that a licensee in good standing could not challenge the patent's validity. The Supreme Court reversed, ruling that the dispute satisfied the Article III case-or-controversy requirement because the licensee's royalty payments were made under the coercive threat of a patent infringement suit that could result in treble damages and an injunction. The Court reasoned that a party need not expose itself to liability by refusing to pay or breaching the agreement to establish jurisdiction for a declaratory judgment action.

procedurebusiness & regulatory

The case concerned a criminal defendant whose chosen attorney was denied admission pro hac vice by the district court, which then limited the defendant's ability to consult with that attorney during trial, resulting in a conviction. The Supreme Court held that an erroneous deprivation of a defendant's Sixth Amendment right to counsel of his or her choice requires automatic reversal of the conviction. The Court reasoned that this right guarantees the accused the specific counsel he or she selects, independent of any showing of prejudice or ineffective assistance by substitute counsel, and that such a violation qualifies as structural error not subject to harmless-error review because its effects are unquantifiable. The decision reaffirmed limits on the right to counsel of choice but accepted the government's concession of error in this instance.

criminal lawprocedure

Davis v. Washington consolidated two domestic violence prosecutions in which the victims did not appear at trial. In the first, the trial court admitted a recording of a 911 call in which the victim identified her assailant; in the second, it admitted an affidavit and statements the victim gave to police officers who responded to the scene. The Supreme Court held that the Confrontation Clause prohibits admission of testimonial statements by an absent witness unless the witness is unavailable and the defendant had a prior opportunity for cross-examination. Statements made during police interrogation are nontestimonial when the primary purpose, viewed objectively, is to enable police assistance for an ongoing emergency, but they are testimonial when there is no ongoing emergency and the purpose is to establish or prove past events for later prosecution. Applying that distinction, the Court concluded the 911 statements were nontestimonial and admissible, while the affidavit and police-interview statements were testimonial and should have been excluded.

criminal lawprocedure

In Hudson v. Michigan, Detroit police executing a search warrant for narcotics and weapons entered the petitioner's home in violation of the Fourth Amendment's knock-and-announce rule. The Supreme Court affirmed the conviction, holding that evidence found during the search should not be suppressed because of the violation. The Court reasoned that the exclusionary rule applies only where its deterrence benefits outweigh substantial social costs, and here the interests protected by the knock-and-announce rule—such as preventing violence, property damage, and affronts to dignity—have no connection to the seizure of evidence described in a valid warrant, making suppression unwarranted. Deterrence is also minimal given other mechanisms like civil suits and police professionalism.

criminal lawcivil rights

The case concerned the validity under the Fourth Amendment of an anticipatory search warrant for a residence, issued based on an affidavit showing that a package of child pornography ordered by the defendant would be delivered there, but which did not list that delivery as the triggering condition on the face of the warrant itself. The Supreme Court held that anticipatory warrants are not categorically unconstitutional and that this particular warrant satisfied constitutional requirements. The Court reasoned that probable cause exists when there is a fair probability contraband will be found at the place when the warrant is executed, and that the Fourth Amendment's particularity clause requires only a specific description of the place to be searched and the items to be seized, not any conditions precedent to execution.

criminal lawprocedure

The case involved respondent John McDonald, a Black man and sole shareholder/president of JWM Investments, Inc., who sued Domino's Pizza under 42 U.S.C. §1981, alleging that Domino's breached contracts with JWM due to racial animus toward him personally, causing him monetary and emotional harm. The District Court dismissed the claim, finding McDonald was not a party to any contract with Domino's, but the Ninth Circuit reversed, allowing non-parties with distinct injuries to sue. The Supreme Court reversed, holding that a plaintiff cannot state a §1981 claim unless he has (or would have) rights under the contract he seeks to make and enforce. The Court's reasoning rested on the statute's text, which protects the equal right of all persons to make and enforce contracts without regard to race and requires an impaired contractual relationship under which the plaintiff has rights; as a corporate shareholder and agent, McDonald had no such rights under JWM's contracts.

civil rightsbusiness & regulatory