David Hackett Souter

The case arose from the 1989 Exxon Valdez oil spill in Prince William Sound, Alaska, where plaintiffs sought compensatory and punitive damages for economic losses after Exxon's supertanker ran aground due to the actions of its captain and crew. The jury found recklessness and awarded $287 million in compensatory damages plus $5 billion in punitive damages against Exxon. The Supreme Court held that the Clean Water Act does not preempt punitive damages under maritime law and left undisturbed the lower court's ruling on corporate liability for such damages. It further ruled that the punitive award was excessive as a matter of maritime common law and limited it to a 1:1 ratio with compensatory damages to achieve consistency and fairness in maritime cases.

torts & liabilityenvironmentbusiness & regulatory

In this case, older employees laid off during a workforce reduction at a government contractor sued under the Age Discrimination in Employment Act, alleging that the employer's use of subjective manager ratings for performance, flexibility, and critical skills had a disparate impact on workers age 40 and over. The Supreme Court held that the employer bears both the burden of production and the burden of persuasion to prove the statutory affirmative defense that the challenged employment action was based on reasonable factors other than age. The Court reached this conclusion from the ADEA's text and structure, which place the RFOA exemption alongside the BFOQ defense in a separate provision from the general prohibitions, following the longstanding rule that the party claiming an exemption must prove it, consistent with FLSA enforcement precedents. The decision rejected the business-necessity test as inapplicable to ADEA disparate-impact claims and clarified that the RFOA defense focuses on the reasonableness of the non-age factor rather than negating liability.

labor & employmentcivil rights

The case involved a dispute between Hall Street Associates and Mattel over whether an arbitration agreement could allow a court to review an arbitrator's legal conclusions for errors, in addition to the grounds specified in the Federal Arbitration Act (FAA). The Supreme Court decided that the FAA's provisions for vacating or modifying arbitration awards are exclusive and cannot be expanded by private agreement when parties seek the expedited review process under the Act. The Court reasoned that the statutory text, particularly section 9's requirement to confirm awards unless vacated or modified as prescribed in sections 10 and 11, precludes broader contractual review standards. This interpretation aligns with the FAA's goal of providing limited judicial oversight to maintain arbitration's efficiency in resolving disputes.

procedurebusiness & regulatory

The case involved Michael Boulware, who was charged with criminal tax evasion under 26 U.S.C. §7201 for diverting funds from his closely held corporation, HIE. Boulware sought to introduce evidence that the corporation had no earnings and profits, arguing the diversions qualified as nontaxable returns of capital under §§301 and 316(a) up to his stock basis. The district court and Ninth Circuit, following the Miller precedent, excluded this evidence because Boulware failed to show a contemporaneous intent to treat the distributions as returns of capital. The Supreme Court reversed, holding that a defendant in a criminal tax evasion case may rely on return-of-capital treatment without evidence of such intent at the time of the distribution. The Court reasoned that tax classifications under §§301 and 316(a) turn on objective facts like the existence of earnings and profits and the shareholder's basis, not on subjective intent, consistent with the economic realities of the transaction.

criminal lawtaxes

The case involved a Wyoming ranch owner who refused to grant the federal government an easement across his property after discovering that a prior easement had not been recorded. He alleged that Bureau of Land Management officials then engaged in a pattern of harassment and retaliatory actions, including administrative charges, permit revocations, and other measures, prompting claims under RICO for extortion and a Bivens action for violations of Fourth and Fifth Amendment rights. The Supreme Court held that no Bivens damages remedy was available for the alleged retaliation against the exercise of property rights. The Court reasoned that alternative administrative and judicial processes existed to address the grievances and that special factors, including the risk of expanding litigation against federal officials, counseled against creating a new remedy. The Court also rejected the RICO claim.

propertycivil rightsfederal power

In Brendlin v. California, police stopped a vehicle without suspicion of unlawful operation, recognized passenger Brendlin as a parole violator, arrested him, and discovered methamphetamine evidence during a search. Brendlin moved to suppress the evidence, claiming the stop was an unconstitutional seizure of his person under the Fourth Amendment. The Supreme Court held that a passenger in a vehicle is seized during a traffic stop and therefore may challenge the stop's constitutionality. The Court reasoned that a reasonable passenger would not feel free to terminate the encounter, as the stop diverts both driver and passenger from traffic and subjects them to police authority and potential scrutiny. The case was remanded for further proceedings on whether suppression was warranted on other grounds.

criminal lawcivil rights

The case concerned whether insurance companies using consumer credit reports to set higher initial insurance premiums must provide adverse action notices under the Fair Credit Reporting Act (FCRA), and whether a failure to do so constitutes a willful violation allowing for statutory and punitive damages. The Supreme Court held that an initial rate qualifies as an adverse action if it is higher than it would have been with a neutral credit score, and that willful violations include those committed in reckless disregard of FCRA obligations. The Court reasoned that the statutory text defining adverse action for insurance covers unfavorable changes in terms for policies applied for, and that the common-law understanding of willfulness extends to reckless conduct. Applying this to the facts, the Court concluded that Safeco's interpretation of the statute was not reckless, so it did not willfully violate the notice requirement.

business & regulatory

Bell Atlantic Corp. v. Twombly was a class action by subscribers of local telephone and high-speed Internet services against incumbent local exchange carriers (ILECs) for alleged violations of Section 1 of the Sherman Act. The complaint claimed the ILECs conspired to restrain trade through parallel conduct that inhibited competitive local exchange carriers and by agreeing not to compete in each other's markets. The district court dismissed the complaint, the Second Circuit reversed, and the Supreme Court reversed the Second Circuit, holding that the complaint failed to state a claim. The Court reasoned that Section 1 prohibits only concerted action stemming from an agreement, parallel conduct alone is ambiguous and consistent with independent competitive behavior, and Federal Rule of Civil Procedure 8 requires enough factual matter to suggest an agreement was made rather than a bare assertion of conspiracy.

business & regulatoryprocedure

The case involved a trust challenging an IRS levy on its bank account, made to collect taxes owed by the trust's creators, after the trust missed the nine-month deadline for filing a wrongful levy action under 26 U.S.C. §7426(a)(1). The trust attempted to pursue the claim instead through a tax refund action under 28 U.S.C. §1346(a)(1), which has longer time limits. The Supreme Court ruled that the specific wrongful levy provision provides the exclusive remedy for such third-party claims, preventing use of the more general refund jurisdiction to circumvent the shorter limitations period. The Court reasoned that a precisely drawn statute preempts broader remedies, particularly where allowing the alternative would extend the filing deadline in a way irreconcilable with the specific statute.

taxesprocedure

The case concerned whether a legal permanent resident's state conviction for aiding and abetting cocaine possession, treated as a felony under South Dakota law but a misdemeanor under the federal Controlled Substances Act, qualified as an "aggravated felony" under the Immigration and Nationality Act, which would bar discretionary cancellation of removal. The Supreme Court held that it did not, ruling that a state offense counts as a "felony punishable under the Controlled Substances Act" only if the underlying conduct is punishable as a felony under federal law. The Court reasoned that the INA's reference to "illicit trafficking" in controlled substances ordinarily implies commercial dealing, which simple possession lacks, and that Congress intended to incorporate federal felony definitions rather than varying state classifications. It rejected the government's argument that state felony status alone sufficed, noting inconsistencies with ordinary usage and the statutory structure. The decision reversed the Eighth Circuit and Board of Immigration Appeals rulings that had ordered removal.

immigrationcriminal law

In Kircher v. Putnam Funds Trust, mutual fund investors filed separate state-court class actions asserting state-law claims for alleged devaluation of their holdings by respondent funds. The cases were removed to federal district court under the Securities Litigation Uniform Standards Act of 1998, which bars certain state-law securities class actions and authorizes removal, but the district court remanded them to state court for lack of subject-matter jurisdiction, reasoning that the claims by share "holders" did not meet the Act's "in connection with the purchase or sale" requirement. The Seventh Circuit reviewed the remands and held on the merits that the Act precluded the claims, but the Supreme Court reversed that approach. The Court decided that orders remanding cases for want of preclusion under the Act are subject to 28 U.S.C. §1447(d)'s general rule of nonappealability, as the district court had characterized its remand as based on lack of removal jurisdiction. This bars appellate review regardless of any legal error in the district court's characterization or conclusion.

business & regulatoryprocedure

The case concerned whether a company operating hydroelectric dams on a Maine river needed state water quality certifications under section 401 of the Clean Water Act when seeking renewal of federal operating licenses from FERC. The company argued that its dams did not produce a "discharge" because they merely released unaltered river water after passing it through turbines. The Supreme Court held that the dams triggered the certification requirement because they created a discharge within the ordinary meaning of that term. The Court reasoned that "discharge" is not limited to the addition of pollutants, that prior cases and agency practice supported this reading, and that the statute's broad goal of preserving state authority over water quality supported requiring certifications for activities that alter river flow and conditions.

environmentfederal powerbusiness & regulatory

The case involved a Bivens action by respondent Moore, a company executive, alleging that U.S. Postal Service inspectors retaliated against his company's lobbying efforts by instigating a criminal prosecution against him and his firm; the charges were ultimately dismissed for lack of evidence. The Supreme Court held that a plaintiff bringing a retaliatory-prosecution claim must plead and prove the absence of probable cause for the underlying criminal charges. The Court reasoned that while First Amendment retaliation claims generally require showing but-for causation between animus and injury, the involvement of an immune prosecutor and the presumption of regularity in prosecutorial decisions create an additional causal gap that lack of probable cause helps bridge, serving as key circumstantial evidence. The decision reversed the lower courts' rulings that had allowed the claim to proceed without that showing.

free speechcriminal lawcivil rightsprocedure

In Georgia v. Randolph, police searched a marital home for drug evidence after obtaining consent from the respondent's estranged wife, despite the respondent being present and explicitly refusing permission. The respondent was indicted for cocaine possession, but the trial court denied his motion to suppress; the Georgia Supreme Court reversed, holding the search invalid. The U.S. Supreme Court affirmed, ruling that a physically present co-occupant's refusal renders a warrantless search unreasonable and invalid under the Fourth Amendment as to that person. The core reasoning relied on widely shared social expectations about privacy in shared premises, distinguishing the case from United States v. Matlock where the non-consenting co-tenant was absent, and emphasized that disputed consent does not justify entry without a warrant or other basis.

criminal law

The case arose after customs agents seized computer equipment during a search; when it was returned damaged, the owner sued the United States under the Federal Tort Claims Act for negligence and later sued the individual agents under Bivens for a due-process violation. After the FTCA claim was dismissed under a statutory exception to the government's waiver of sovereign immunity, the agents sought dismissal of the Bivens action on the ground that the FTCA judgment bar, 28 U.S.C. §2676, precluded further litigation against them. The district court denied the motion, and the Second Circuit affirmed after exercising jurisdiction under the collateral-order doctrine. The Supreme Court held that an order refusing to apply the judgment bar does not qualify for immediate collateral appeal because the bar functions like ordinary claim preclusion rather than an immunity that protects a weighty public interest that would be lost if review were deferred until final judgment. The Court therefore vacated the judgment below and remanded with instructions to dismiss the appeal for lack of jurisdiction.

federal powerproceduretorts & liability

This case involved two Kentucky counties that posted large copies of the Ten Commandments in their courthouses, prompting a lawsuit by the ACLU under 42 U.S.C. §1983 alleging a violation of the First Amendment's Establishment Clause. The counties modified the displays multiple times, first adding resolutions referencing Christian principles and then incorporating other historical documents with religious references, claiming the exhibits aimed to show the Commandments as foundational to American law. The District Court issued a preliminary injunction against the displays, which the Sixth Circuit affirmed, applying the Lemon v. Kurtzman test and finding that the counties lacked a secular purpose. The Supreme Court affirmed, holding that a government's predominant purpose of advancing religion, as demonstrated by the history and context of the displays, violates the Establishment Clause's requirement of official religious neutrality.

religious libertycivil rights

The case involved copyright holders, including movie studios, suing companies that distributed free peer-to-peer file-sharing software, alleging that the distributors were liable for users' widespread unauthorized sharing of copyrighted music and videos. The lower courts ruled for the distributors, finding no liability under contributory or vicarious infringement theories because the software was capable of substantial noninfringing uses and the companies lacked specific knowledge of individual infringements due to the networks' decentralized design. The Supreme Court reversed, holding that a distributor is liable for third-party copyright infringement if it distributes a device with the object of promoting its use to infringe, as shown by clear expression or affirmative steps taken to foster infringement. The Court pointed to evidence that the companies marketed the software as a Napster alternative, actively encouraged infringement, and made no effort to filter copyrighted material, while profiting from increased advertising revenue tied to user growth.

propertybusiness & regulatory

In Rompilla v. Beard, the petitioner, convicted of murder and sentenced to death in Pennsylvania, claimed ineffective assistance of counsel under Strickland v. Washington because his trial attorneys failed to investigate and present mitigating evidence regarding his childhood, mental health, and alcoholism, including by not reviewing the court file on his prior rape conviction that the prosecution planned to use as an aggravating factor. The state courts rejected the claim, finding counsel's efforts adequate, but the U.S. Supreme Court reversed, holding that counsel's performance was deficient. The Court reasoned that, even when a defendant and family indicate no mitigation evidence exists, defense counsel has a duty to make reasonable efforts to obtain and review materials the prosecution is known to rely on for aggravation at sentencing, as this is necessary to respond effectively and is consistent with professional standards. The case was remanded for further proceedings on prejudice.

criminal lawprocedure

The case involved a quiet title action filed in state court by Grable & Sons Metal Products after the IRS seized and sold its property to Darue to satisfy a tax debt; Grable claimed invalid title because federal tax law (26 U.S.C. §6335) required personal service rather than certified mail for notice of the sale. Darue removed the case to federal court on the ground that it raised a federal question under 28 U.S.C. §1331. The Supreme Court held that federal-question jurisdiction was proper because the claim necessarily raised a contested and substantial federal issue—the meaning of the IRS notice statute—whose resolution belonged in federal court without upsetting the balance of federal and state judicial responsibilities. The Court reasoned that the government has a strong interest in the uniform interpretation of federal tax provisions governing property sales, such cases are rare, and precedent supported exercising jurisdiction over embedded federal issues in state-law claims.

taxesfederal powerprocedure

In Miller-El v. Dretke, the petitioner, convicted of capital murder and sentenced to death in Texas, claimed that Dallas County prosecutors violated the Equal Protection Clause by using peremptory strikes to exclude 10 of 11 qualified black venire members from his jury, citing a history of racial exclusion in the district attorney's office. On review of a federal habeas petition, the Supreme Court held that Miller-El was entitled to relief under Batson v. Kentucky because he had shown purposeful racial discrimination in jury selection. The Court reasoned that the 91% exclusion rate of eligible black panelists was statistically improbable, that side-by-side comparisons revealed the prosecutors' stated reasons for striking black venire members applied equally to white jurors who were seated, and that the trial court's acceptance of those explanations was an unreasonable determination of the facts in light of the evidence.

criminal lawcivil rights