Supreme Court Decision Syllabus (SCOTUS Podcast) – Details, episodes & analysis

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No one Authorized President Trump to impose these "Emergency" Tariffs under the IEEPA (International Emergency Economic Powers Act).

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The Court Below granted relief when it should have not.

Judge Niemeyer of the 4th Circuit was the lone dissent--contending that the majority had defied AEDPA’s standard of review--the 84 year old Jurist with 36 years service on that court was correct.

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Goldey v. Fields

PER CURIAM. In Bivens v. Six Unknown Fed. Narcotics Agents, 403 U. S. 388 (1971), this Court recognized an implied cause of action for damages against federal officers for certain alleged violations of the Fourth Amendment. The Court subsequently recognized two additional contexts where implied Bivens causes of action were permitted, neither of which was an Eighth Amendment excessive-force claim. After 1980, we have declined more than 10 times to extend Bivens to cover other constitutional violations. Those many post1980 Bivens “cases have made clear that, in all but the most unusual circumstances, prescribing a cause of action is a job for Congress, not the courts.” Egbert v. Boule, 596 U. S. 482, 486 (2022). Despite those precedents, the U. S. Court of Appeals for the Fourth Circuit permitted the plaintiff here to maintain an Eighth Amendment excessive-force Bivens claim for damages against federal prison officials. 

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This Court has repeatedly emphasized that “recognizing a cause of action under Bivens is ‘a disfavored judicial activity.’” Egbert, 596 U. S., at 491. To determine whether a Bivens claim may proceed, the Court has applied a two-step test. First, the Court asks whether the case presents “a new Bivens context”—that is, whether the case “is different in a meaningful way” from the cases in which this Court has recognized a Bivens remedy. Ziglar v. Abbasi, 582 U. S. 120, 139 (2017); see Carlson v. Green, 446 U. S. 14 (1980); Davis v. Passman, 442 U. S. 228 (1979); Bivens, 403 U. S. 388. Second, if so, we then ask whether there are “special factors” indicating that “the Judiciary is at least arguably less  equipped than Congress to ‘weigh the costs and benefits of allowing a damages action to proceed.’” Egbert, 596 U. S., at 492. That analysis is anchored in “separation-of-powers principles.” Ziglar, 582 U. S., at 135. This case arises in a new context, and “special factors” counsel against recognizing an implied Bivens cause of action for Eighth Amendment excessive-force violations. To begin with, Congress has actively legislated in the area of prisoner litigation but has not enacted a statutory cause of action for money damages. See Ziglar, 582 U. S., at 148– 149. In addition, extending Bivens to allow an Eighth Amendment claim for excessive force could have negative systemic consequences for prison officials and the “inordinately difficult undertaking” of running a prison. Turner v. Safley, 482 U. S. 78, 84–85 (1987). Moreover, “an alternative remedial structure” already exists for aggrieved federal prisoners. Ziglar, 582 U. S., at 137; see Correctional Services Corp. v. Malesko, 534 U. S. 61, 74 (2001). The existence of such alternative remedial procedures counsels against allowing Bivens suits even if such “procedures are ‘not as effective as an individual damages remedy.’” Egbert, 596 U. S., at 498. For the past 45 years, this Court has consistently declined to extend Bivens to new contexts. See Egbert, 596 U. S., at 490–491. We do the same here. The petition for certiorari is granted, the judgment of the U. S. Court of Appeals for the Fourth Circuit is reversed, and the case is remanded for further proceedings consistent with this opinion. It is so ordered. 

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 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 “three previous convictions” for “a serious drug offense” qualifies for ACCA’s enhanced sentencing. 18 U. S. C. §924(e)(1). For a state crime to qualify as a “serious drug offense,” it must carry a maximum sentence of at least 10 years’ imprisonment, and it must “involv[e] . . . a controlled substance . . . as defined in section 102 of the Controlled Substances Act.” §§924(e)(1), (2)(A)(ii). Under the categorical approach, a state drug offense counts as an ACCA predicate only if the State’s definition of the drug in question “matche[s]” the definition under federal law. Shular v. United States, 589 U. S. 154, 158. The question presented is whether a state crime constitutes a “serious drug offense” 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 “serious drug offense[ s].” 

 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. 4– 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. 

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 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 map’s constitutionality must disentangle race and politics to show that race was the legislature’s “predominant” 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 Court’s 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 court’s racial-gerrymandering analysis also guided the analysis of the Challengers’ 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 “enacted a particular voting scheme as a purposeful device to minimize or cancel out the voting potential of racial or ethnic minorities.” Miller, 515 U. S., at 911. In other words, the plaintiff must show that the State’s districting plan “has the purpose and effect” of diluting the minority vote. Shaw v. Reno, 509 U. S. 630, 649. In light of these two errors in the District Court’s analysis, a remand is appropriate. Pp. 34–35. 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 III–C. THOMAS, J., filed an opinion concurring in part. KAGAN, J., filed a dissenting opinion, in which SOTOMAYOR and JACKSON, JJ., joined. 

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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 “Stay of proceedings where issue therein referable to arbitration,” provides that when a dispute is subject to arbitration, the court “shall 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.” 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 statute’s use of the word “shall” “creates an obligation impervious to judicial discretion.” 

Reversed and remanded.   SOTOMAYOR, J., delivered the opinion for a unanimous Court. 

Read by Jeff Barnum

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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 “[n]o Money shall be drawn from the Treasury, but in Consequence of Appropriations made by Law.” 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 “reasonably necessary to carry out” the Bureau’s 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 associations’ argument that the Bureau’s funding mechanism violates the Appropriations Clause. 

Held: Congress’ statutory authorization allowing the Bureau to draw money from the earnings of the Federal Reserve System to carry out the Bureau’s 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 associations’ three principal arguments for why the Bureau’s 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. 

Read by RJ Dieken

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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, petitioners’ cars were seized under an Alabama civil forfeiture law that permitted seizure of a car “incident to an arrest” so long as the State then “promptly” initiated a forfeiture case. Ala. Code §20–2–93(b)(1), (c). The State of Alabama filed forfeiture complaints against Culley’s and Sutton’s 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 petitioners’ 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. 

Read by RJ Dieken. 

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Warner Chappell Music v. Nealy

Under the Copyright Act, a plaintiff must file suit “within three years after the claim accrued.” 17 U. S. C. §507(b). On one understanding of that limitations provision, a copyright claim “accrue[s]” when “an infringing act occurs.” 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 “the plaintiff discovers, or with due diligence should have discovered,” 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 Nealy’s 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 Act’s 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 Act’s remedial sections. But those provisions merely state that an infringer is liable either for statutory damages or for the owner’s actual damages and the infringer’s profits. See §504(a)–(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 Court’s decision in Petrella also does not support a three-year damages cap. There, the Court noted that the Copyright Act’s statute of limitations allows plaintiffs “to gain retrospective relief running only three years back from” 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 defendant’s 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 case’s 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 Act’s limitations provision. If Nealy’s claims are thus timely, he may obtain damages for them. Pp. 4–7. 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. 

Read by Jeff Barnum.