A timeline of U.S. Supreme Court decisions

Decision On: Ford Motor Co. v. United States

When a taxpayer overpays his taxes, he is entitled to interest from the government for the period between the date of overpayment and the ultimate refund, but the “date of overpayment” is not specifically defined.

The Internal Revenue Service (IRS) informed the Ford Motor Company (Ford) that it had underpaid on its taxes between 1983 and 1989. Ford subsequently submitted deposits to the IRS that covered the underpayment. Ford later requested that the deposits be considered to cover additional taxes that Ford owed. The parties eventually determined that Ford had overpaid its taxes and was owed a refund. Ford argued that the date of overpayment was the date that it first submitted the deposits to the IRS for the underpayment of taxes, and the Government argued that the date of overpayment was the date when Ford requested that the payment cover additional taxes. Ford sued the Government in federal district court, and the court found in favor of the Government. The U.S. Court of Appeals for the Sixth Circuit affirmed.                                                                                                                                              In a per curiam decision, the Court held that, because the Government changed its jurisdictional argument in the reply to the petition for certiorari, the case should have been heard in the U.S. Court of Federal Claims rather than the federal district court. The Supreme Court is a court of final review, not first review, and therefore the new jurisdictional claim should have been heard by a lower court before being argued before the Supreme Court. The Court vacated the decision and remanded the case for further proceedings.

Sources: FORD MOTOR COMPANY v. UNITED STATES. The Oyez Project at IIT Chicago-Kent College of Law. 10 September 2014. <http://www.oyez.org/cases/2010-2019/2013/2013_13_113>.

Click here to read a PDF of the opinion of the court.

Decision On: Williams v. Johnson

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This Supreme Court case is in regard to Tara Williams;  who was convicted of first-degree murder by a California court. She was charged with first-degree murder for being the get-away driver for two friends who robbed a liquor store and fatally wounded the store owner. This particular case pertains to her appeal that states the court violated the 6th Amendment and California Penal code. Her grounds for making these statements are based on the fact that Juror 6 was dismissed due to bias, and replaced with a different juror. Her appeal was denied and sent back to lower courts for review.

Additional references:



Decision On: Harris v. Quinn

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Pamela J. Harris is a personal care assistant who provides in-home care to disabled participants in the Home Services Program administered by a division of the Illinois Department of Human Services (Disabilities Program). The state pays the wages of assistants who work with participants in either the Disabilities Program or a program run by the Division of Rehabilitation Services (Rehabilitation Program). In 2003, a majority of the Rehabilitation Program personal assistants elected Service Employees International Union Healthcare Illinois & Indiana as their collective bargaining representative. The union and the state negotiated a collective bargaining agreement that included a “fair share” provision, which required all personal assistants who are not union members to pay a proportionate share of the costs of the collective bargaining process and contract administration. The Disabilities Program assistants rejected union membership in 2009.

In 2010, Harris and other personal assistants from both programs sued Governor Pat Quinn and the unions and claimed that the fair share fees violated their freedom of speech and freedom of association rights under the First and Fourteenth Amendments. The district court dismissed the plaintiffs’ claims. On appeal, the U.S. Court of Appeals for the Seventh Circuit affirmed. The appellate court held that the state may require its employees, including personal assistants such as the plaintiffs, to pay fair share fees and further held that the claims of the Disability Program were not ripe for judicial review.

, undecided. Justice Samuel A. Alito, Jr. delivered the opinion for the 5-4 majority. The Court held that the apparently controlling precedent of Abood v. Detroit Board of Education, which stated the necessity of the fair share provision to prevent non-union members from taking advantage of the union’s collective bargaining, cannot justify the violation of the petitioners’ First Amendment rights in this case. Upon review, the Court held that the analysis in the Abood decision fundamentally misconstrued previous judicial precedent on the issue of collective bargaining as well as the differences between union relations in public- and private-sector employment. That precedent especially does not apply in this case because the petitioners are not full public-sector employees but are only considered such for the sake of limited collective bargaining. Because the union’s role is so narrow in this case, there is no compelling interest served by forcing the petitioners to contribute that cannot be satisfied by less restrictive means.

Justice Elena Kagan wrote a dissent in which she argued that the precedent Aboodestablished was highly influential in protecting the best interests of employees and government entities by enabling the government to bargain with a single body without allowing non-union members to take advantage of these benefits. Although the majority opinion focused on the ways in which the petitioners are not public-sector employees and not subject to this precedent, Justice Kagan emphasized the vast degree of oversight the state exercised over them and the state’s interest in working with an effective bargaining agent. Therefore, there is no reason to differentiate this case from the ruling required by the Abood precedent. Justice Ruth Bader Ginsburg, Justice Stephen G. Breyer, and Justice Sonia Sotomayor joined in the dissent.

Sources: HARRIS v. QUINN. The Oyez Project at IIT Chicago-Kent College of Law. 17 September 2014. <http://www.oyez.org/cases/2010-2019/2013/2013_11_681>.

Decision On: Burwell v. Hobby Lobby Stores, Inc.

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This particular case was filed by the arts and craft store Hobby Lobby in 2012. Their reason for filing the lawsuit was that they believed the  Patient Protection and Affordable Care Act violated their rligious rights. Their specific objections were to the mandatory insurance coverage of contraceptives.

The issue being debated was whether a for profit business should be allowed exemption from particular laws due to religious objection. Anthother issue under debate was whether or not a for profit business could be considered  a ‘person’ capable of exercising religion. Hobby Lobby made their case based on the  Religious Freedom Restoration Act and the  free-exercise of religion clause.

Hobby Lobby won the case with a 5-4 vote. The verdict was reached on the grounds that the mandate was not the “least restrictive” method of implementing the government’s interest.        

Additional sources: http://www.supremecourt.gov/opinions/13pdf/13-354_olp1.pdf          http://www.bbc.com/news/28093756                                                                    http://www.politico.com/story/2014/06/supreme-court-hobby-lobby-decision-contraception-mandate-108429.html                                  http://www.usatoday.com/story/news/politics/2014/06/30/supreme-court-hobby-lobby-religion-contraception-obama/11473189/      http://www.washingtonpost.com/news/volokh-conspiracy/wp/2014/06/30/scotusblog-reports-closely-held-corporations-cannot-be-required-to-provide-contraception-coverage/                                                                                                                                                                  

Decision On: McCullen v. Coakley

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In 2009, the Massachusetts state legislature created a 35-foot buffer zone around the entrances, exits, and driveways of abortion clinics. The petitioners, individuals who routinely engage in “pro-life counseling” outside of state abortion clinics, sued in federal district court and argued that the law violated the First Amendment protection of free speech. The district court held that, although the law placed a restriction on the time, place, and manner of speech, the law was constitutional because it was content-neutral and still left adequate, if not perfect, alternative means of communications. The U.S. Court of Appeals for the First Circuit affirmed and held that the Supreme Court, in Hill v. Colorado had already affirmed a similar statute in Colorado that prohibited certain activities within 100 feet of abortion clinics.

Chief Justice John G. Roberts, Jr. delivered the opinion for the 9-0 majority. The Court held that the Massachusetts law was content-neutral on its face because a violation depends not on the speech itself but on the location of the speech, and therefore does not need to be analyzed under strict scrutiny. However, the Court also held that the law is still not sufficiently narrowly tailored to serve a significant government interest because it places too great a burden on the petitioners’ First Amendment Rights. By denying the petitioners the ability to engage in conversation and leafleting on public streets and sidewalks, the law prevents the petitioners from engaging in exactly the transmission of ideas the First Amendment is meant to protect. The Court also held that, in enacting the law, Massachusetts overlooked other options that could serve the same interests without placing an undue burden on historical avenues of speech and debate.

In his opinion concurring in the judgment, Justice Antonin Scalia wrote that the law is content-based and therefore must be examined under strict scrutiny. A blanket prohibition of speech in areas where only one type of politically charged speech is likely to occur cannot be content-neutral. Justice Scalia also pointed out that the majority opinion did not address the question of whether Hill v. Colorado should be limited or overruled. Because Justice Scalia argued that the law was content-based and therefore subject to strict scrutiny, he wrote that Hill should be overruled because it contradicts First Amendment jurisprudence. Justice Anthony M. Kennedy and Justice Clarence Thomas joined in the opinion concurring in judgment. Justice Samuel A. Alito, Jr. wrote a separate opinion concurring in judgment in which he argued that the law’s exemption for clinic employees and volunteers constitutes viewpoint discrimination because it silences abortion opponents while allowing clinic workers and supporters to express their views.

Sources: MCCULLEN v. COAKLEY. The Oyez Project at IIT Chicago-Kent College of Law. 10 September 2014. <http://www.oyez.org/cases/2010-2019/2013/2013_12_1168>.

Decision On: NLRB v. Noel Canning

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The National Labor Relations Act (NLRA) established the National Labor Relations Board (Board) to decide labor disputes among employers, unions, and employees. Parties first file unfair labor practice allegations to a Regional Office, which then conducts an investigation and, if necessary, files a complaint. An Administrative Law Judge (ALJ) presides over the hearing on the complaint and issues a recommendation to the Board. Unless a party to the dispute files a timely appeal, the ALJ’s recommendation becomes the final order of the Board. To hear a case and issue a ruling, the Board must have at least three of its five members present. The NLRA allows parties to appeal a Board ruling to the U.S. Court of Appeals for the area where the alleged unfair labor practice occurred or to the U.S. Court of Appeals for the District of Columbia Circuit. Board members are appointed by the president and serve five-year terms.

In 2010, Noel Canning, a bottler and distributor of Pepsi-Cola products, was engaged in negotiations with its employee union, the International Brotherhood of Teamsters Local 760 (Union). During the final bargaining session that December, Noel Canning agreed to submit two wage and pension plans to a vote by the Union membership. The membership approved the union’s preferred proposal. However, Noel Canning argued that the discussions did not amount to a binding agreement and refused to incorporate the changes into a new collective bargaining agreement. The Union filed a complaint with the Board alleging that Noel Canning’s actions constituted an unfair labor practice in violation of the NLRA. An ALJ determined that the agreement was binding and ordered Noel Canning to sign the collective bargaining agreement. The Board affirmed the ruling against Noel Canning.

Noel Canning appealed to the U.S. Court of Appeals for the District of Columbia Circuit, which held that the Board’s ruling was invalid because not enough members of the Board were present. The panel that heard the Noel Canning case consisted of one member who was appointed by President Barack Obama and confirmed by the Senate in 2010 and two members whom President Obama appointed without Senate confirmation in January 2012. Although the Recess Appointments Clause allows the president to fill vacancies that occur while Congress is in recess, between December 2011 and the end of January 2012, the Senate met in pro forma meetings every three business days. Therefore, the Court of Appeals determined that the Senate was not in recess on the days the Senate did not meet because, for the purpose of the Recess Appointments Clause, recess is defined as the time in between sessions of Congress.

Justice Stephen G. Breyer delivered the opinion for the 9-0 majority. The Court held that a pro forma session does not create a recess long enough to trigger the Recess Appointments Clause. While the term “recess” in the Clause refers both to inter- and intra-session recesses, its legislative history and historical context indicate that the term should be presumed to mean a recess of substantial length. The Court held that the three-day break that occurs during pro forma sessions does not represent a significant interruption of legislative business and therefore cannot justify the exercise of the Clause. Additionally, a pro forma session cannot be viewed as a single, long recess because the Senate retains its capacity to conduct business during such sessions. Because recess appointments made during a recess that was shorter than ten days have been so historically rare, the Court held that ten days was the appropriate presumptive lower limit to place on the exercise of the Clause. The Court also held that the Clause applies to vacancies that occur during a recess as well as those that originally occur before a recess but continue to exist at the time of the recess. Although a plain reading of the Clause does not require such an interpretation, the historical context of the wording favors the more broad reading because a vacancy can be considered a continuing state.

Justice Antonin Scalia wrote a concurrence in judgment in which he argued that the Recess Appointments Clause was only meant to cover breaks between congressional sessions rather than breaks within them. Therefore, the appointments in question are invalid because they were made during the session. Justice Scalia argued that a plain reading of the text as well as the historical meaning of the term “recess” clearly places it in opposition to the term “session,” and it is therefore illogical to interpret the Clause as allowing appointments while Congress is in session. In offering a broader reading of the Clause, the majority opinion disregards the Clause’s purpose: to preserve the balance of power between the President and the Senate regarding appointments. Justice Scalia also argued that the majority’s ten-day rule cannot stand because it is based purely on judicial interpretation of historical practices without any textual basis. For these same reasons, the Clause should be read as only granting the President the power to fill vacancies that originally occurred during a recess. Chief Justice John G. Roberts, Jr., Justice Clarence Thomas, and Justice Samuel A. Alito, Jr. joined in the concurrence in judgment.

Sources: NATIONAL LABOR RELATIONS BOARD v. NOEL CANNING. The Oyez Project at IIT Chicago-Kent College of Law. 15 September 2014. <http://www.oyez.org/cases/2010-2019/2013/2013_12_1281>.

Decision On: Riley v. California

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David Leon Riley belonged to the Lincoln Park gang of San Diego, California. On August 2, 2009, he and others opened fire on a rival gang member driving past them. The shooters then got into Riley’s Oldsmobile and drove away. On August 22, 2009, the police pulled Riley over driving a different car; he was driving on expired license registration tags. Because Riley’s driver’s license was suspended, police policy required that the car be impounded. Before a car is impounded, police are required to perform an inventory search to confirm that the vehicle has all its components at the time of seizure, to protect against liability claims in the future, and to discover hidden contraband. During the search, police located two guns and subsequently arrested Riley for possession of the firearms. Riley had his cell phone in his pocket when he was arrested, so a gang unit detective analyzed videos and photographs of Riley making gang signs and other gang indicia that were stored on the phone to determine whether Riley was gang affiliated. Riley was subsequently tied to the shooting on August 2 via ballistics tests, and separate charges were brought to include shooting at an occupied vehicle, attempted murder, and assault with a semi-automatic firearm.

Before trial, Riley moved to suppress the evidence regarding his gang affiliation that had been acquired through his cell phone. His motion was denied. At trial, a gang expert testified to Riley’s membership in the Lincoln Park gang, the rivalry between the gangs involved, and why the shooting could have been gang-related. The jury convicted Riley on all three counts and sentenced to fifteen years to life in prison. The California Court of Appeal, Fourth District, Division 1, affirmed.

Chief Justice John G. Roberts, Jr. wrote the opinion for the unanimous Court. The Court held that the warrantless search exception following an arrest exists for the purposes of protecting officer safety and preserving evidence, neither of which is at issue in the search of digital data. The digital data cannot be used as a weapon to harm an arresting officer, and police officers have the ability to preserve evidence while awaiting a warrant by disconnecting the phone from the network and placing the phone in a “Faraday bag.” The Court characterized cell phones as minicomputers filled with massive amounts of private information, which distinguished them from the traditional items that can be seized from an arrestee’s person, such as a wallet. The Court also held that information accessible via the phone but stored using “cloud computing” is not even “on the arrestee’s person.” Nonetheless, the Court held that some warrantless searches of cell phones might be permitted in an emergency: when the government’s interests are so compelling that a search would be reasonable.

Justice Samuel A. Alito, Jr. wrote an opinion concurring in part and concurring in the judgment in which he expressed doubt that the warrantless search exception following an arrest exists for the sole or primary purposes of protecting officer safety and preserving evidence. In light of the privacy interests at stake, however, he agreed that the majority’s conclusion was the best solution. Justice Alito also suggested that the legislature enact laws that draw reasonable distinctions regarding when and what information within a phone can be reasonably searched following an arrest.

Sources: RILEY v. CALIFORNIA. The Oyez Project at IIT Chicago-Kent College of Law. 17 September 2014. <http://www.oyez.org/cases/2010-2019/2013/2013_13_132>.

Decision On: Fifth Third Bancorp v. Dudenhoeffer

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John Dudenhoeffer and Alireza Partivopanah are former employees of Fifth Third Bank and are participants in the Fifth Third Bancorp Master Profit Sharing Plan, an employee stock ownership plan (ESOP), which is a defined contribution retirement fund for employees with Fifth Third as a trustee. Participants make voluntary contributions to the ESOP from their salaries and Fifth Third matches the contributions by purchasing Fifth Third stock for their individual accounts. During the time period in question, a large amount of the ESOP’s assets were invested in Fifth Third stock. Also during this period, Fifth Third switched from being a conservative lender to a subprime lender and the portfolio became increasingly vulnerable to risk, which it failed to disclose. The price of the stock declined drastically and caused the ESOP to lose tens of millions of dollars. The respondents sued Fifth Third and argued that Fifth Third breached its fiduciary duty as imposed by the Employee Retirement Income Security Act (ERISA) by continuing to invest in Fifth Third stock despite having knowledge of its increasingly precarious value. The federal district court granted Fifth Third’s motion to dismiss and held that the plaintiffs failed to state a claim for which relief could be granted because under ERISA, the investment decisions made by ESOP fiduciaries are presumed to be prudent. The U.S. Court of Appeals for the Sixth Circuit reversed and held that, while ESOP fiduciaries have a presumption of prudence, this presumption was an evidentiary matter and thus not grounds for a motion to dismiss.

Justice Stephen Breyer delivered the opinion for the unanimous Court. The Court held that the presumption of prudence found by the lower courts is not included in ERISA’s language; instead, the presumption is a court-made response to the different fiduciary duties of an ESOP fiduciary rather than fiduciaries of other eligible retirement plans under ERISA. Unlike other plans, ESOP plans prioritize buying a company’s own stock, as opposed to diversifying retirement funds across a number of different investments. For non-ESOP retirement funds, normal prudence requires fiduciaries to spread the investment risk out across multiple investments, which is a prudential standard that cannot be applied to ESOP. Therefore, some courts had held that ESOP fiduciaries were entitled to a presumption of prudence regarding their choice of whether to purchase their own company stock or not. The Supreme Court, however, held that these differing requirements did not amount to a presumption of prudence for ESOP fiduciaries. Instead, the Court found that ESOP fiduciaries have the same fiduciary duty as non-ESOP fiduciaries, except as it applies to diversification of investments. The Court remanded the case back to the district court, instructing the lower court to analyze Fifth Third’s motion to dismiss under the pleading standards set forth in Ashcroft v. Iqbal and Bell Atlantic Corp. v. Twombly, requiring a plaintiff’s pleadings contain enough facts to give rise to a plausible entitlement to relief.

Sources: FIFTH THIRD BANCORP v. DUDENHOEFFER. The Oyez Project at IIT Chicago-Kent College of Law. 17 September 2014. <http://www.oyez.org/cases/2010-2019/2013/2013_12_751>.

Decision On: American Broadcasting Cos. v. Aereo, Inc.

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Aereo, Inc. (Aereo) provides a service that allows its subscribers to watch programs that are currently airing on network television or record programs that will air in the future over the Internet. By allowing subscribers to watch live television as well as record and watch shows on Internet-enabled devices including mobile phones, Aereo serves three functions: that of a regular television antenna, a recording device, and an application that makes these services work on devices other than televisions and computers. Aereo is currently only available to subscribers in the New York City area and offers only New York City local channels. Aereo does not have a license from the copyright holders of the programs to record or transmit their programs.

Two groups of plaintiffs filed separate copyright infringement suits against Aereo and moved for a preliminary injunction to prevent Aereo from transmitting programs to its subscribers while the programs were still being broadcast. The plaintiffs claimed that the transmission of the programs violated their right to “publicly perform” their copyrighted works. The district court denied the motion and held that Aereo’s system was not substantially different from another that had been determined non-violative of the rights of copyright holders and that, while the injunction might prevent harm for the plaintiffs’ businesses, it would irreparably harm Aereo’s. The U.S. Court of Appeals for the Second Circuit affirmed the lower court’s ruling to deny the motion.

Justice Stephen G. Breyer delivered the opinion for the 6-3 majority. The Court held that, because Aereo is functionally similar to community antenna television (CATV), which Congress specifically amended the Copyright Act to cover, the Copyright Act regulates Aereo’s actions in a similar manner. Under the definitions Congress established in the Copyright Act, Aereo performs work because it shows images in sequence with the accompanying audio, and it does so publicly because those images and sounds are received beyond the place from where they were sent by a large number of unrelated people. Therefore, Aereo, like CATV, is not just an equipment provider but rather a broadcaster.

Justice Antonin Scalia wrote a dissent in which he argued that Aereo merely provides a platform for the customer to use as he sees fit. Because Aereo plays no role in the selection of content, it does not “perform” in any meaningful sense and cannot be held liable for the customer’s choice of transmission content. Justice Scalia wrote that the majority opinion was based on the faulty assumption that Aereo’s services resembled CATV, which creates a rule so broad as to be useless. Instead, Justice Scalia argued that the question of volitional conduct is the appropriate bright-line test to use in such cases. Justice Clarence Thomas and Justice Samuel A. Alito, Jr. joined in the dissent.

Sources: ABC, INC. v. AEREO, INC.. The Oyez Project at IIT Chicago-Kent College of Law. 16 September 2014. <http://www.oyez.org/cases/2010-2019/2013/2013_13_461>.

Decision On: Halliburton Co. v. Erica P. John Fund, Inc.

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“Former shareholders of Halliburton Company (Halliburton) filed a class action lawsuit against the company and argued that Halliburton falsified its financial statements and misrepresented projected earnings between 1999 and 2001. In their petition for class certification, the shareholders invoked the “fraud on the market” presumption to demonstrate their class-wide reliance on Halliburton’s statements. The “fraud on the market” theory assumes that, in an efficient market, the price of a security reflects any material, public representation affecting that security. Therefore, under this theory, the law presumes that investors have relied on a material misstatement when they purchase a security at an artificially high or low price. The federal district court certified the shareholders as a class and prevented Halliburton from introducing evidence that the statements did not impact its stock prices at all. The U.S. Court of Appeals for the Fifth Circuit affirmed and held that Halliburton could not rebut the presumption that the plaintiffs relied on the statements until a trial on the merits of the plaintiffs’ claims.”

Chief Justice John G. Roberts, Jr. delivered the opinion for the 6-3 majority. The Court held that there was no reason to prevent defendants in a securities fraud case from presenting evidence regarding the impact of alleged misinformation on stock prices during the class certification stage. The Court also held that Halliburton was unable to provide adequate justification to overrule the established precedent that plaintiffs in securities fraud cases only need to prove a presumption of reliance on fraudulent information. The presumption standard is based on the generally agreed-upon principle that public information affects stock prices. Without any evidence that this principle was misunderstood or no longer reflects current economic realities, the presumption standard should remain. Additionally, because Congress had the opportunity to pass a law that created a new standard and chose not to do so, Congress clearly intended the presumption to stand.

In her concurring opinion, Justice Ruth Bader Ginsburg wrote that, while allowing the defendants to present price-impact evidence at the class certification stage may broaden the scope of those proceedings, it should not present an undue burden to plaintiffs with legitimate claims. Justice Stephen G. Breyer and Justice Sonia Sotomayor joined in the concurrence.

Justice Clarence Thomas wrote an opinion concurring in the judgment in which he argued that the presumption of reliance standard should not be used because it is based on a flawed understanding of economics and effectively lowers the burden of proof for the plaintiffs. For these reasons, Justice Thomas argued that the decision in Basic v. Levinson—the decision that established the “fraud on the market” presumption standard—should be overruled. Justice Antonin Scalia and Justice Samuel A. Alito, Jr. joined in the concurrence in judgment.

Sources: HALLIBURTON CO. v. ERICA P. JOHN FUND, INC.. The Oyez Project at IIT Chicago-Kent College of Law. 16 September 2014. <http://www.oyez.org/cases/2010-2019/2013/2013_13_317>.

Decision On: Utility Air Regulatory Group v. EPA

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After the 2007 Supreme Court decision in Massachusetts v. EPA that determined that air pollution was subject to Environmental Protection Agency (EPA) regulation under the Clean Air Act, the EPA set out a series of standards governing greenhouse gas emissions. One of these benchmarks set emission standards for vehicles, while another one required stationary sources of greenhouse gases to obtain constructing and operating permits from the EPA. The petitioners, who include various state and industry groups, challenged these rules on the grounds that they were based on an improper construction of the Clean Air Act and are arbitrary and capricious because they are based on an inadequate scientific record. The U.S. Court of Appeals for the Federal Circuit dismissed the challenges.

Sources: UTILITY AIR REGULATORY GROUP v. ENVIRONMENTAL PROTECTION AGENCY. The Oyez Project at IIT Chicago-Kent College of Law. 16 September 2014. <http://www.oyez.org/cases/2010-2019/2013/2013_12_1146>.

Decision On: Loughrin v. United States

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Kevin Loughrin created a scheme to obtain cash by stealing checks from people’s outgoing mail, altering them to make purchases at Target, and returning the purchases for cash. When the scheme came to an end, he and Theresa Thongsarn were indicted on six counts of bank fraud, two counts of aggravated identity theft, and one count of possession of stolen mail. Loughrin moved to dismiss the case and alleged violations of the Speedy Trial Act; the district court denied the motion to dismiss. At trial, Loughrin requested that the jury instructions specify that the jury had to find that he had the intent to defraud a financial institution in order to find him guilty of bank fraud. The district court held that such an instruction was not necessary and declined to use it. Loughrin was convicted on all counts and sentenced to 36 months in prison. The U.S. Court of Appeals for the Tenth Circuit affirmed.

Justice Elena Kagan wrote the opinion for the unanimous Court. The Court held that, while one clause of the statute requires the intent to defraud a bank, the second clause does not require it. Instead, this second clause only requires that the defendant intend to obtain any property under the control of a bank. The Court held that requiring these two clauses to be read as having the same intent would render the second one meaningless; the structure of the statute indicated that the two clauses had different requirements. However, because the second clause should not apply to any and all fraud where the defrauder receives a check, the Court stated that the specific language limited its coverage to circumstances where the defendant’s false statement “naturally induces” the bank to part with money in its control, instead of where a bank is only tangentially involved.

Justice Antonin G. Scalia wrote an opinion concurring in part and concurring in the judgment in which he argued against the “natural inducement” test promoted by the Court. He argued that the dictionary definition of “by means of” language of the second clause included tangential involvement of a bank, although he agreed that the clause should not apply to all fraud where the defrauder receives a check. Justice Clarence Thomas joined the concurrence in part and concurrence in the judgment. In his separate opinion concurring in part and concurring in the judgment, Justice Samuel A. Alito, Jr. wrote that the second clause only requires that the defendant knowingly execute a scheme to obtain bank property, instead of intentionally doing so.

Sources: LOUGHRIN v. UNITED STATES. The Oyez Project at IIT Chicago-Kent College of Law. 17 September 2014. <http://www.oyez.org/cases/2010-2019/2013/2013_13_316>.

Decision On: POM Wonderful LLC v. Coca-Cola Co.

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Pom Wonderful, LLC (Pom Wonderful), a California-based beverage company, sold various types of juice, including a pomegranate blueberry juice blend. In 2007, Coca-Cola Company (Coca-Cola) announced its own version of a pomegranate blueberry juice. In 2008, Pom Wonderful sued Coca-Cola in federal district court and argued that Coca-Cola misled consumers into believing that Coca-Cola’s product contained pomegranate and blueberry juices when it actually contained 99% apple and grape juices and only 0.5% pomegranate and blueberry juice. Specifically, Pom Wonderful claimed that Coca-Cola violated provisions of the Lanham Act, a federal law prohibiting false advertising, as well as California’s false advertising and unfair competition laws. The lawsuit challenged the name, labeling, marketing, and advertising of Coca-Cola’s product.

The district court held that Pom Wonderful’s claims regarding the name and label of the juice were barred by a separate law, the Food, Drug and Cosmetics Act (FDCA). The FDCA allows the Food and Drug Administration (FDA) to regulate the labels on, among other items, juices. Because the FDA has exclusive authority to file claims for violations of the FDCA, the court feared that a decision under the Lanham Act would undercut the FDA’s authority to regulate juice labels. After both parties gathered evidence, the court granted summary judgment in favor of Coca-Cola on the name and label issues. Although the court gave Pom Wonderful the opportunity to proceed to trial on the remaining issues, Pom Wonderful conceded that it could not win without the name and label issues. Pom Wonderful appealed.

The U.S. Court of Appeals for the Ninth Circuit affirmed the lower court’s decision to bar Pom Wonderful’s claim with respect to the name and labeling of Coca-Cola’s juice. It vacated the lower court’s ruling in favor of Coca-Cola, instead allowing Pom Wonderful’s case to proceed on the remaining claims.

 Justice Anthony M. Kennedy delivered the opinion for the 8-0 majority. The Court held that, while it is the duty of the courts to harmonize statutes, the best way to do that in this case does not entail barring POM Wonderful’s Lanham Act claims. Neither the Lanham Act nor the FDCA explicitly forbids or limits Lanham Act claims on labels that the FDCA regulates. The Court held that, because the Lanham Act and the FDCA have coexisted since the passage of the Lanham Act in 1946 without Congress addressing the issue, Congress has evidently not seen a problem with their potential interferences. Therefore, holding that the FDCA precludes the operation of the Lanham Act would represent a disregard for the legislative intent of having the two statutes complement one another.

Justice Stephen G. Breyer did not take part in the discussion or decision of this case.

Sources: POM WONDERFUL, LLC v. THE COCA-COLA COMPANY. The Oyez Project at IIT Chicago-Kent College of Law. 16 September 2014. <http://www.oyez.org/cases/2010-2019/2013/2013_12_761>

Decision On: Sprint Communications, Inc. v. Jacobs

Click here to read a PDF of the opinion of the court.

In January 2010, Sprint Communications Co. filed a complaint with the Iowa Utilities Board (“IUB”) asking for a declaration that it was proper to withhold certain VoIP call access charges from Windstream (formerly Iowa Telecom). Before IUB addressed the complaint, Sprint settled the dispute with Windstream and withdrew its complaint. However, IUB continued the proceeding so that it could decide a greater underlying issue of how VoIP communications should be classified under federal law. In February 2011, IUB issued an order with its own interpretation of VoIP’s classification under federal law along with a determination that Sprint was liable to Windstream for the access charges.

Sprint challenged IUB’s order by filing a complaint in both state court and federal district court, alleging that federal law preempts the IUB’s decision. In order to proceed with the federal complaint first, Sprint filed a motion to stay the state case until resolution of the federal case. In turn, the IUB filed a motion asking the federal court to abstain and dismiss the case under the doctrine of Younger v. Harris. Generally, this doctrine states that a federal court shall abstain from hearing a case if there is a threat of interference with a state court proceeding involving important state interests. The district court granted IUB’s motion and dismissed Sprint’s federal complaint. Sprint appealed to the United States Court of Appeals for the Eighth Circuit, which upheld the district court’s abstention, but determined that a stay on the federal proceedings was more appropriate than dismissal.

 Justice Ruth Bader Ginsburg delivered the opinion for a unanimous Court. The Court held that a federal court is not required to abstain from deciding a case simply because there is a case in state court that deals with the same subject matter. Because theYounger doctrine only required a court to abstain when there are parallel criminal cases in federal and state courts or when there are certain civil proceedings that are very similar to criminal ones, it is meant only for exceptional cases. The proceeding in question is civil, not criminal, and does not affect a state court’s ability to perform its judicial function, so none of the Younger exceptions are triggered in this case.

Sources:SPRINT COMMUNICATIONS CO. v. JACOBS. The Oyez Project at IIT Chicago-Kent College of Law. 16 September 2014. <http://www.oyez.org/cases/2010-2019/2013/2013_12_815>

Decision was made on Atlantic Marine Constr. Co. v. United States Dist. Court for Western Dist. of Tex.

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