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In Cunningham v. Cornell University, the Supreme Court addressed a fundamental pleading question under the Employee Retirement Income Security Act of 1974 (ERISA). Petitioners—former and current Cornell University employees—alleged that university fiduciaries violated ERISA §1106(a)(1)(C) by causing their retirement plans to pay excessive fees for recordkeeping services to Fidelity and TIAA-CREF, both parties in interest. The Second Circuit dismissed the claim, holding that plaintiffs must also plead that the transaction wasn’t exempt under §1108(b)(2)(A), which allows for reasonable arrangements with service providers.

The Supreme Court unanimously reversed. Writing for the Court, Justice Sotomayor held that §1106(a)(1)(C) sets out a categorical bar against certain transactions between plans and parties in interest, and plaintiffs need only plausibly plead the elements of that section to state a claim. The §1108 exemptions—such as those permitting “reasonable arrangements” for necessary services—are affirmative defenses that defendants must raise and prove. Citing Meacham v. Knolls Atomic Power Lab, the Court emphasized that statutory exemptions laid out in separate provisions do not become part of a plaintiff’s burden unless Congress says otherwise.

Just Sotomayor writing for a unanimous Court. Justice Alito filed a concurrence, joined by Justices Thomas and Kavanaugh.

Read by Jeff Barnum.

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In Donald J. Trump, President of the United States, et al. v. J.G.G., et al., the Supreme Court granted the government’s application to vacate temporary restraining orders issued by the District Court for the District of Columbia, which had blocked the removal of several Venezuelan detainees allegedly affiliated with the foreign terrorist organization Tren de Aragua (TdA). The detainees challenged President Trump’s Proclamation No. 10903, issued under the Alien Enemies Act (AEA), which authorized their detention and removal.

The Court construed the TROs as appealable injunctions and held that the detainees’ claims must be brought in habeas corpus. Because the claims necessarily challenged the legality of confinement and removal under the AEA, they fell within the “core” of habeas jurisdiction. As such, jurisdiction and venue lay solely in the district of confinement—Texas—not in the District of Columbia. The Court emphasized that equitable relief cannot be sought outside habeas in this context, relying on precedents such as Ludecke v. Watkins and Heikkila v. Barber.

Although the detainees are entitled to judicial review regarding their classification and removal under the AEA—including notice and an opportunity to seek habeas relief—the proper venue to litigate those claims is the district of confinement. The Court clarified that such notice must be given promptly to allow detainees to exercise those rights before removal occurs.

Read by RJ Dieken. 

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In Dewberry Group, Inc. v. Dewberry Engineers Inc., the Supreme Court addressed the scope of monetary remedies under the Lanham Act. The case arose from a trademark dispute between two entities using the "Dewberry" name. The district court awarded the plaintiff not only the defendant's profits but also those of affiliated companies. The Fourth Circuit upheld this award, reasoning that a broad interpretation of "defendant’s profits" was permissible under the statute.​ 

The Supreme Court unanimously reversed, holding that a plaintiff in a trademark infringement case under the Lanham Act may recover only the profits of the infringing defendant itself—not those of its affiliates or related entities. The Court emphasized principles of corporate separateness and statutory interpretation, rejecting the expansive reading of "defendant’s profits" adopted by the lower court.​ 

Justice Elena Kagan delivered the opinion for a unanimous Court. 

Read by RJ Dieken.

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In Lora v. United States, the Supreme Court reviewed whether the Section 924(c) prohibition on concurrent sentences applies to sentences arising out of different subsections. Justice Jackson, writing for a unanimous Court, writes that it does not, that crimes from other sections are not subject to the ban on concurrent sentences. Guest Host Jeff Barnum. 

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In Smith v. United States, the Supreme Court reviewed whether the principle of double-jeopardy prevents a person from being retried after a trial took place in the incorrect venue and the jury was selected from the incorrect district. In a unanimous decisions, Justice Alito writes that the defendant is entitled to set aside the jury's conviction, but that a new trial in a proper venue is appropriate. Read by Jake A. Leahy. 

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In Lac du Flambeau Band of Lake Superior Chippewa Indians v. Coughlin, the Supreme Court whether Congress abrogated tribal sovereignty in the Bankruptcy Code. Writing for the majority, Justice Kagan rules that Congress unequivocally abrogated tribal sovereign immunity in the Bankruptcy Code. Kagan reasons that "foreign or domestic" governments is a term such as "here or there;" meaning it encompasses all forms of governments anywhere. As the sole dissenter, Justice Gorsuch reasons that the words should construed more narrowly - that if Congress intended to abrogate tribal immunity, it would have done so. Hosted by Jake A. Leahy. 

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In Haaland v. Brackken, the Supreme Court reviewed whether provisions of the Indian Child Welfare Act are constitutional under several portions of the Constitution. Writing for the majority, Justice Barrett writes that the Act, which (in part) prioritizes placing Indian children with Indian (rather than non-Indian families), is within the purview of Congress. Read by Founder RJ Dieken. Also included is an update from RJ Dieken - he was started the podcast and previously hosted it. *Note: This summary uses the term "Indian" for consistency, given that language is used in the decision. 

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In Jack Daniel's Properties, Inc. v. VIP Products LLC, the Supreme Court examines the intersection of trademark law and First Amendment rights. The dispute centers around VIP's creation of a dog toy resembling a bottle of Jack Daniel's whiskey, with humorous modifications. Jack Daniel's argues that the toy infringes and dilutes their trademarks, while VIP claims it is a parody protected under the fair use exclusion. The Court addresses the application of the Rogers test and the scope of the noncommercial use exclusion in the Lanham Act. Read by guest host Jeff Barnum. 

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In Health and Hospital Corporation of Marion Cty. v. Talevski, the Supreme Court reviewed  whether the Federal Nursing Home Reform Act (FBHRA) provides a right of action under Section 1983 against a privately owned nursing home that received Medicaid funds. Hosted by Jake Leahy. 

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In Dubin v. United States, the Supreme Court reviewed whether a person who commits Medicaid fraud through fraudulent billing can also be convicted for statutory aggravated identity theft. The Court ruled for Dubin, holding that the aggravated identity theft charge can only be applied when the identity theft was at the crux of the crime, not if the fraud happened to involve personal information (here, the Medicaid number). Hosted by Jake Leahy. 

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In Allen v. Milligan, the Supreme Court reviewed whether Alabama’s Congressional maps violated Section 2 of the Voting Rights Act. A three-judge district court panel found that the plaintiffs demonstrated a sufficient likelihood on success on the merits against Alabama. Chief Justice Roberts, writing for the majority, affirmed. Read by Host, Jake Leahy. 

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In Glacier Northwest v. Teamsters, the Supreme Court reviewed whether the National Labor Relations Act preempts Glacier's state tort law claims that allege the Teamsters intentionally destroyed the company's concrete trucks when the truckers did not complete their deliveries in transit.  The Court held that these claims were not preempted by federal law, reasoning that it is well-established that the NLRA does not protect striking workers who fail to take reasonable precautions to protect against property damage. Read by Jake Leahy. 

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In Slack Technologies v. Pirani the Court held that Section 11 of the Securities Act of 1933 requires the plaintiff to prove that they purchased securities that were registered under a materially misleading registration statement. The Court rejected the argument that the term "such security" could include securities that were not registered under an allegedly misleading registration statement. Read by Jeff Barnum. 

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In Waetzig v. Halliburton Energy Services, Inc., the Supreme Court held that a case voluntarily dismissed without prejudice under Federal Rule of Civil Procedure 41(a) qualifies as a "final proceeding" under Rule 60(b), allowing a district court to reopen the case. Gary Waetzig sued Halliburton for age discrimination but later dismissed his case without prejudice and pursued arbitration. After losing in arbitration, he sought to reopen his federal case and vacate the arbitration award under Rule 60(b). The district court granted his motion, but the Tenth Circuit reversed. Writing for a unanimous Court, Justice Alito explained that the text, context, and history of Rule 60(b) support treating a voluntary dismissal as final for purposes of post-judgment relief. The ruling clarifies that Rule 60(b) relief is discretionary and distinct from appellate finality, ensuring courts retain flexibility to revisit cases when necessary. The Court reverses and remands for further proceedings.

Justice Alito delivered the opinion for a unanimous Court.

Read by RJ Dieken. 

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Supreme Court's decision is here. 

The False Claims Act allows for private citizens to bring a cause of action on behalf of the United Sates, against a person who "knowingly" submits a "false claim" to a federal program. The defendant can meet the knowledge requirement by, 1.) actual knowledge that the reported prices were not "usual and customary," 2.) being aware of a substantial risk that the retail prices were not usual and customary, or 3.) awareness of a substantial and unjustifiable risk but the defendant decided to submit the claim regardless. The Court adopted a subjective standard, even if an objective test would not meet the same requirement. 

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In Dupree v. Younger, the Supreme Court addressed whether a post-trial motion of a purely legal issue that was resolved at summary judgment, requires a post-trial motion to be preserved on appeal. Kevin Younger sued Neil Dupree, who was a correctional officer under Section 1983. Dupree moved for summary judgment alleging that Younger had failed to exhaust administrative remedies. The district court denied the motion. After Younger prevailed at trial by obtaining $700,000 in damages, Dupree appealed alleging the district court improperly dismissed the suit. Under Fourth Circuit precedent, that court ruled against Younger reasoning that he was required to file a Rule 50 post-trial motion to preserve the issue on appeal. The Supreme Court reversed, finding that pure questions of law resolved in summary judgment do not require a post-trial motion to preserve the issue for appeal. The Court writes in the syllabus: "And it makes sense: Factual development at trial will not change the district court’s pretrial answer to a purely legal question, so a post-trial motion requirement would amount to an empty exercise." Read by Jake Leahy. 

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In Sackett v. Environmental Protection Agency, the Supreme Court examines the scope the terms "waters" under the Clean Water Act. The EPA ordered the Sackets, who purchased property in Idaho, to restore the property after the family had backfilled it with dirt. The EPA claimed that putting dirt on their property violated the Clean Water Act, and threatened the family with $40,000 in penalties daily. 

The Sacketts claimed that the Clean Water Act did not apply as "waters of the United states" refers only to permanent bodies of water, such as streams, rivers, lakes, and adjacent wetlands that have a continuous surface connection to those bodies of water.  The EPA asked the Court for a broader interpretation of the statute. The Court ruled against the EPA, reasoning that there must be a clear connection between wetlands and traditionally navigable waters to obtain jurisdiction under the Clean Water Act. Read by guest host Jeff Barnum. 

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In Tyler v. Hennepin County, Chief Justice Roberts writes for the majority, reversing the Eighth Circuit. The District Court and Circuit Court had rejected a taxpayer's claim that Hennepin County keeping the $25,000 surplus after a tax sale violated both the Takings Clause under the Fifth Amendment and the prohibition on excessive fines under the Eighth Amendment. The Court reversed, finding that the state is not entitled to recover the surplus after a property is sold after the owner's failure to pay real estate taxes. 

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The Supreme Court reversed the Sixth Circuit Court of Appeals, reasoning that the Court of Appeals must reverse the administrative agency if it reaches the same outcome for a different reason. Once an administrative agency has made an error of law, the decision must be remanded back to the administrative agency. Per Curiam. Read by Jake Leahy.

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In Andy Warhol Foundation for the Visual Arts, Inc. v. Goldsmith et al., the Supreme Court ruled that the commercial licensing of a derivative artwork by Andy Warhol, based on a copyrighted photograph taken by Lynn Goldsmith, did not qualify as fair use. The case involved the licensing of Warhol's "Orange Prince" image. This well-known image includes a silkscreen portrait of musician Prince, which was derived from Goldsmith's photograph. The Court found that despite adding new expression, meaning, or message to the photograph, the purpose and character of the use were not sufficiently distinct from the original work. Held: the “purpose and character” of the Warhol' use of Goldsmith’s original photograph in commercially licensing Orange Prince to Condé Nast does not favor Warhol's fair use defense to copyright infringement. Justice Sotomayor delivered the Opinion of the Court. Justice Kagan filed a dissenting Opinion, which Chief Justice Roberts joined.  Read by guest host Jeff Barnum. 

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In Ohio Adjutant General's Department v. FLRA, the Supreme Court ruled that the Federal Service Labor-Management Relations Statute (FSLMRS) grants jurisdiction to the Federal Labor Relations Authority (FLRA) over labor disputes involving state National Guards when they hire and supervise dual-status technicians in their civilian roles. These technicians are both employed by the Ohio National Guard, as well as the Army and the Air Force.  The Court's decision was based on three main reasons,  1.) statutory terms, 2.) the authority granted to the Ohio Adjutant General, and 3.) the historical precedent of federal agency-employee relations. Justice Thomas delivered the Opinion of the Court (7-2), Justice Alito filed a dissent, in which Justice Gorsuch joined. Read by guest host Jeff Barnum. 

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On the same day, the Court released its decision in Twitter v. Taamneh. The Court largely disposed of the claims in Twitter, stating that Taamneh had failed to state a claim under the federal statute. Here, the Court in its per curiam opinion, writes that it need not consider the veracity of the Section 230 claims because Twitter's reasoning requires disposal of the claims here. Read by Jake Leahy.

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The patent requires certain particularity, such that any person skilled in the craft would be able to manufacture, make, construct, or use the invention. The Court held that Amgen's patent failed to provide the detail required to protect its interest, in part, because the patent applies to a wide range of antibodies and requires a certain level of trial/error for a skilled person to replicate it. A pharmaceutical patent case. Gorsuch delivered the opinion of the unanimous Court. Read by Jake Leahy. Contact us at scotusdecisions@gmail.com.

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Taamneah brought suit against social media companies, alleging that the companies were "aiding and abetting" ISIS by providing a platform and recommendations to the companies. HELD: The social media companies did not knowingly aid and abet ISIS, and therefore, no claim can be brought under the Anti-Terrorism Act. 

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In Glossip v. Oklahoma, the Supreme Court held that a criminal defendant is entitled to a new trial when the prosecution knowingly fails to correct false testimony and that error could have contributed to the verdict. Richard Glossip was convicted and sentenced to death based primarily on the testimony of Justin Sneed, who claimed Glossip orchestrated the 1997 murder of Barry Van Treese. Years later, newly discovered evidence revealed that the prosecution withheld key documents, allowed Sneed to give false testimony about his mental health history, and engaged in other misconduct. Oklahoma’s attorney general ultimately conceded that Glossip’s conviction was tainted and supported granting him a new trial, but the Oklahoma Court of Criminal Appeals rejected the argument and upheld the conviction. The Supreme Court ruled that the prosecution’s failure to correct Sneed’s false testimony violated Napue v. Illinois, which prohibits the government from allowing false evidence to go unchallenged. Given that Sneed’s credibility was central to Glossip’s conviction, the Court found a reasonable likelihood that the error influenced the jury and reversed the lower court’s decision, granting Glossip a new trial.

Justice Sotomayor delivered the opinion of the Court, joined by Chief Justice Roberts and Justices Kagan, Kavanaugh, and Jackson, with Justice Barrett joining in part. Justice Barrett also filed a separate opinion concurring in part and dissenting in part. Justice Thomas filed a dissenting opinion, joined by Justice Alito, with Justice Barrett joining certain sections. Justice Gorsuch took no part in the decision.

Read by Jeff Barnum. 

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Chief Justice Roberts writes for the majority in this case: "As an old joke goes: 'I believe we should all pay taxes with a smile. I tried but they wanted cash.'"

The IRS is authorized by statute to issue a summons to third parties to aid in the "collection" of an assessment against a taxpayer. There are certain notice requirements and exceptions to the requirements as they pertain to summonses. The question presented is whether the statute requires notice when a summons is issued to a third-party, or if notice is only required to the taxpayer in an account where the taxpayer holds a beneficial interest. HELD: The exception to the notice requirement in §7609(c)(2)(D)(i) does not only apply if the delinquent taxpayer has a legal interest in summons issued by the IRS. 

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In National Pork Producers v. Ross, the Supreme Court reviewed whether California's Proposition 12 regulatory requirements relating to conditions for in-state pork sales unconstitutionally interfered with out-of-state businesses in violation of the dormant commerce clause. 

From Justice Gorsuch's majority opinion: "Assuredly, under this Court’s dormant Commerce Clause decisions, no State may use its laws to discriminate purposefully against out-of-state economic interests. But the pork producers do not suggest that California’s law offends this principle. Instead, they invite us to fashion two new and more aggressive constitutional restrictions on the ability of States to regulate goods sold within their borders. We decline that invitation. While the Constitution addresses many weighty issues, the type of pork chops California merchants may sell is not on that list."

Read by guest host Ryan Barnum. 

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"The question presented is whether the statute categorically abrogates (legalspeak for eliminates) any sovereign immunity the board enjoys from legal claims. We hold it does not. Under long-settled law, Congress must use unmistakable language to abrogate sovereign immunity. Nothing in the statute creating the board meets that high bar." (First paragraph of Justice Kagan's majority opinion). 

The Puerto Rico Oversight, Management, and Economic Stability Act (PROMESA) was enacted in 2016 to address Puerto Rico's financial crisis, established the Board as an entity within the territorial government of Puerto Rico. The Court held that nothing in PROMESA explicitly abrogates the Board's immunity, and Congress must clearly state if its intent to do so. 

The Court emphasized that PROMESA does not provide for suits against the Board or Puerto Rico, nor does it create a cause of action. Although certain provisions in PROMESA reference judicial review and declaratory relief, they do not indicate a general abrogation of the Board's immunity. The Court concluded that the statutory language and the Board's protections are consistent with the retention of sovereign immunity. 

Read by Jake A. Leahy. Feel free to shoot the podcast an email at scotusdecisions@gmail.com.

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In Percoco v. United States, the Supreme Court considered whether a private citizen with influence over government decision-making can be convicted for wire fraud on the theory that he or she deprived the public of its “intangible right of honest services.” Joseph Percoco, former Executive Deputy Secretary to New York Governor Andrew Cuomo, was charged with conspiracy to commit honest-services wire fraud. Percoco accepted payments while on hiatus from government service to assist a real-estate development company (while he was running Governor Cuomo's re-election campaign for eight months). 

The trial court instructed the jury based on the Second Circuit's 1982 decision in Margiotta, which held that a private person can commit honest-services fraud if they dominate and control government decisions. The Supreme Court ruled that instructing the jury based on Margiotta was an error, stating that the Margiotta theory was overly vague and lacked sufficient clarity. Reversed and remanded. Read by Jake A. Leahy. 

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In Ciminelli v. United States, the Supreme Court ruled that the Second Circuit's right-to-control theory of wire fraud cannot be used as the basis for a conviction under federal fraud statutes. Louis Ciminelli was convicted of federal wire fraud for his involvement in a scheme to rig the bid process for state-funded development projects under Governor Andrew Cuomo. The Government relied on the right-to-control theory, which establishes wire fraud by depriving a victim of potentially valuable economic information. The conviction turned on whether the Second Circuit's established "righto-to-control" theory is sufficient to establish federal wire fraud. The Supreme Court held that the right to valuable economic information is not a traditional property interest and therefore cannot form the basis for a wire fraud conviction under the relevant statutes. Read by Jake A. Leahy. 

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In Santos-Zacaria v. Garland, the Supreme Court reviewed two questions. First, whether §1252(d)(1) is jurisdictional; and second, whether a non-citizen is required to request reconsideration of an adverse board action to fully exhaust administrative remedies under the law.

HELD: Santos-Zacaria is correct and the Fifth Circuit was incorrect to find that §1252(d)(1) is jurisdictional. The statute in question is not jurisdictional, as Congress did not clearly demonstrate that it intended to make the statute jurisdictional. Second, the law does not require non-citizens to request discretionary forms of review, such as asking a Board to reconsider its ruling, because the law only requires the exhaustion of remedies as "right," while discretionary actions involve the discretion of the administrative agencies. Vacated in part and remanded.

Read the entire opinion here.

Read by Jake A. Leahy. 

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Section 363(m) of the U.S. Bankruptcy Code is not a jurisdictional provision. Courts should not construe a statute to be jurisdictional unless clearly stated. A jurisdictional provisions puts a limit on the jurisdiction of federal courts. Guest recorded by Jeff Barnum. 

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Turkiye Halk Bankasi A.S. (Halkbank) vs. the United States involves the criminal prosecution against Halkbank for evading American economic sanctions against Iran.  Halkbank claims immunity, as an instrumentality of a foreign state under the Foreign Sovereign Immunities Act of 1976 (FSIA). The Supreme Court held that the District Court has jurisdiction over this criminal prosecution of Halkbank, that the FSIA's comprehensive scheme governing claims of immunity in civil actions against foreign states, and their instrumentalities does not cover criminal cases. The Court concluded that the FSIA's provisions extend only to the civil context. Guest recorded by Jeff Barnum. 

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In Wilkins v. United States, the Supreme Court addressed a dispute between property owners in rural Montana and the government regarding a road easement. The government claimed that the easement included public access, while the property owners disagreed. The property owners sued the government under the Quiet Title Act, but the government argued that their claim was barred by a 12-year time limit in the Act. The Court held that the time limit was a nonjurisdictional claims-processing rule and not a jurisdictional bar. It concluded that the Act's text and context did not indicate a clear statement of jurisdictional consequences. The Court also determined that previous Supreme Court decisions did not definitively interpret the relevant statute as jurisdictional. Justice Sotomayor delivered the majority opinion, joined by Justices Kagan, Gorsuch, Kavanaugh, Barrett, and Jackson. Justice Thomas filed a dissenting opinion, joined by Chief Justice Roberts and Justice Alito. Syllabus read by guest reader Jeff Barnum. 

Feel free to contact the show with any feedback you have to scotusdecisions@gmail.com.

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New York and New Jersey entered into a compact in 1953 to establish the Waterfront Commission of New York Harbor to conduct regulatory and law enforcement activities at the Port, and in 2018, New Jersey sought to withdraw from the Compact, resulting in New York filing a bill of complaint in this Court. HELD: Despite New York's opposition, New Jersey is permitted to withdraw from the Waterfront Commission Compact. Recorded by Jeff Barnum. 

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In Lackey v. Stinnie, the Supreme Court held that plaintiffs who secure only preliminary injunctive relief before their case becomes moot do not qualify as "prevailing parties" entitled to attorney’s fees under 42 U.S.C. §1988(b). Virginia drivers challenged the constitutionality of a law suspending licenses for unpaid court fines. After a district court granted a preliminary injunction, the Virginia General Assembly repealed the law, and restored licenses -- making the case moot. Writing for the Court, Chief Justice Roberts explains that preliminary injunctions do not constitute enduring, merits-based relief because they are temporary and do not resolve the case. The ruling reinforces prior precedents, including Buckhannon Board & Care Home v. West Virginia DHHR and Sole v. Wyner, requiring a judicially sanctioned, enduring change in the legal relationship between parties to qualify for attorney’s fees. The Court also notes that this decision does not apply to consent decrees, since that does provide lasting relief that's sanctioned by a court. The Court reverses the Fourth Circuit's en banc decision, emphasizing a bright-line rule to ensure clarity in fee disputes. 

Chief Justice Roberts writing for the majority, joined by Justices Thomas, Alito, Kagan, Gorsuch, Kavanaugh, and Barrett. Justice Jackson filed a dissenting opinion, which was joined by Justice Sotomayor. 

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Michelle Cochran and Axon Enterprise each filed a federal district court lawsuit, challenging the constitutionality of the agency proceedings against them in separate enforcement actions initiated in the SEC and the FTC. Both suits were initially dismissed for lack of jurisdiction, but the Fifth Circuit disagreed as to the SEC question, finding that Cochran's claim would not receive "meaningful judicial review" in a court of appeals, was "wholly collateral to the Exchange Act's statutory-review scheme," and fell "outside the SEC's expertise." The Ninth Circuit affirmed the district court's dismissal of Axon's constitutional challenges to the FTC proceeding. HELD: District court's continue to have jurisdiction over federal questions arising from constitutional challenges, notwisthstanding the Securities Exchange Act and Federal Trade Commission Act. 

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Miguel Luna Perez, a deaf student who attended schools in Michigan's Sturgis Public School District, was denied graduation. his family filed a complaint with the Michigan Department of Education claiming that the district failed to provide him with a free and appropriate public education under the Individuals with Disabilities Education Act (IDEA). The parties reached a settlement, and Perez then sued under the Americans with Disabilities Act (ADA), seeking compensatory damages, but the district court dismissed the suit, and the Sixth Circuit affirmed; based on IDEA's requirement that plaintiffs exhaust administrative procedures before seeking relief that is also available under IDEA. HELD: The Individuals with Disabilities Education Act does not require Perez to exhaust administrative remedies before filing an action, because IDEA does not provide for compensatory damages. 

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The Disposition of Abandoned Money Orders and Traveler's Checks Act requires that abandoned property from a "money order . . . or other similar written instrument," be returned to the state where the property was purchased. This rule is different from the common law, which requires that unclaimed property be returned to the state of incorporation, not the state of purchase. The Supreme Court held that Agent Checks and Teller's Checks, offered by MoneyGram, were sufficiently similar to a money order to be governed by the statutory framework. As a result, these products offered by MoneyGram should be returned to the state of purchase when unclaimed, rather than the state of incorporation (most often, Delaware). Justice Jackson delivered the opinion of the unanimous court (although the Court was not unanimous for a portion of the decision, there is no dissent regarding that portion).

Delaware v. Pennsylvania

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Bittner, was required to file reports under the Bank Secrecy Act (BSA). In 2004, Congress amended the law to create a penalty for the non-willful failure to file certain reports pertaining to foreign bank accounts. After filing reports, Bittner was assessed penalties for over fifty accounts that he had failed to report over several years. The Secretary of the Treasury assessed a penalty for his non-willful failure to file in the amount of $10,000 per account per year, while Bittner claimed the amount should be $10,000 per annual report. Bittner was assessed a penalty of $2.7 million. The Fifth Circuit ruled in favor of the United States. Bittner appealed. Justice Gorsuch wrote the opinion of the court reversing the Fifth Circuit, finding in favor of Bittner. Recorded by Jake Leahy.
Bittner v. United States

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In Bartenwerfer v. Buckley, the Supreme Court held that the discharge exceptions under Section 523(a)(2)(a) of the U.S. Bankruptcy Code apply to an individual debtor, regardless of said debtor's culpability in the fraud. Recorded by Jake Leahy.

Bartenwerfer v. Buckley

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In Helix Energy Solutions Group, Inc., et al. v. Hewitt, the Supreme Court ruled that an employee paid a daily rate does not qualify for an exemption from the Fair Labor Standards Act (FLSA) overtime pay requirements, unless they satisfy the conditions set out in Section 541.604(b). Michael Hewitt, a former employee of Helix, sued his employer claiming overtime pay under FLSA, as he worked 84 hours a week while on the vessel, but Helix paid him a daily-rate basis with no overtime compensation. The Court concluded that Hewitt was not paid on a salary basis as defined in Section 602(a), and thus was not an executive exempt from FLSA's overtime pay guarantee.

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Cruz v. Arizona is a case heard by the US Supreme Court that questioned whether the Arizona Supreme Court's ruling was an adequate ground to preclude review of a federal question. The petitioner, John Montenegro Cruz, was found guilty of capital murder and sentenced to death, and argued that under Simmons v. South Carolina, he should have been allowed to inform the jury that a life sentence in Arizona would be without parole. Cruz sought to raise the Simmons issue again in a state post-conviction petition under Arizona Rule of Criminal Procedure 32.1(g). The Arizona Supreme Court denied relief after concluding that Lynch was not "a significant change in the law". The US Supreme Court held that the Arizona Supreme Court's holding that Lynch was not a significant change in the law is an exceptional case where a state-court judgment rests on such a novel and unforeseeable interpretation of a state-court procedural rule that the decision is not adequate to foreclose review of the federal claim.

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In Arellano v. McDonough, the Supreme Court of the United States ruled that Section 5110(b)(1) of the Veterans' Benefits Act is not subject to equitable tolling. The case involves the effective date of an award of disability compensation to a veteran of the United States military. Adolfo Arellano applied to the Department of Veterans Affairs (VA) for disability compensation based on his psychiatric disorders approximately 30 years after his honorable discharge from the Navy. Arellano argued that his award's effective date should be governed by an exception in § 5110(b)(1), which makes the effective date the day following the date of the veteran's discharge or release if application is received within one year of such date. However, the Supreme Court held that equitably tolling the provision would depart from the terms that Congress "specifically provided."

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Rodney Reed was found guilty of murder and sentenced to death in Texas. He filed a motion under Texas's post-conviction DNA testing law, requesting DNA testing on certain evidence, which he believed would help identify the true perpetrator. The state trial court denied Reed's motion, citing an inadequate chain of custody for the evidence he sought to test. Reed then sued in federal court, arguing that Texas's post-conviction DNA testing law violated procedural due process. The Fifth Circuit dismissed Reed's claim as time-barred, but the Supreme Court held that the statute of limitations for a procedural due process claim begins to run when the state litigation ends, in this case when the Texas Court of Criminal Appeals denied Reed's motion for rehearing. The Court ultimately reversed the Fifth Circuit's decision and remanded the case for further proceedings.

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In Williams v. Reed, the Supreme Court rejects Alabama’s administrative-exhaustion rule, holding that states cannot require claimants to complete an allegedly delayed administrative process before filing a 42 U.S.C. §1983 lawsuit challenging that very delay. Writing for the Court, Justice Kavanaugh explains that the Alabama Supreme Court’s decision effectively immunized state officials from §1983 claims, contradicting prior precedents such as Felder v. Casey and Haywood v. Drown. The ruling clarifies that a state law cannot shield officials from federal civil rights litigation by erecting procedural roadblocks. The Court reverses and remands, rejecting arguments that alternative remedies like mandamus petitions justify Alabama’s exhaustion requirement. Justice Thomas dissents, joined in part by Justices Alito, Gorsuch, and Barrett, arguing that the Court improperly disregards Alabama’s jurisdictional framework. 

Read by RJ Dieken.

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