Supreme Court of the United States, 2016

The Court held that the bank‑fraud statute’s phrase “scheme to defraud a financial institution” covers schemes that obtain money from a depositor’s account because the bank holds a property interest in the deposits, and that the required mental state is knowledge, not purpose, with no need to show actual loss.

The Supreme Court held that a violation of the False Claims Act seal requirement does not mandate automatic dismissal of a relator’s complaint and that the district court did not abuse its discretion in refusing to dismiss the suit. The Court affirmed the Fifth Circuit’s judgment.

The Court affirmed the Ninth Circuit’s judgment, holding that a tipper’s gift of confidential information to a trading relative satisfies the personal‑benefit requirement for tippee liability under §10(b) and Rule 10b‑5, and that the Dirks personal‑benefit test is not unconstitutionally vague or overbroad.

Justice Sotomayor delivered the opinion of the Court, holding that an “article of manufacture” under 35 U.S.C. § 289 can be a component of a multicomponent product, even if that component is not sold separately to consumers.

Justice Thomas concurs with the Court’s decision that a vacated conviction does not erase the preclusive effect of an earlier acquittal, and argues that the Court should not extend the holdings of Ashe and Yeager, emphasizing the original meaning of the Double Jeopardy Clause.

The Supreme Court granted review, vacated, and remanded five Arizona juvenile life‑without‑parole cases, directing the lower courts to reconsider the sentences in light of Montgomery’s requirement that a sentencer determine whether a juvenile offender is among the rare offenders whose crimes reflect irreparable…

In a dissent, the Justice argues that the petition for certiorari should be granted because trial counsel’s performance was constitutionally deficient under the Sixth Amendment, violating Strickland’s standards, and that the Washington Supreme Court’s application of those standards was unreasonable.

The Supreme Court held that using prior uncounseled tribal-court convictions to establish a defendant as a habitual offender under 18 U.S.C. §117(a) does not violate the Sixth Amendment, as these convictions were valid when entered and comply with the Indian Civil Rights Act. Citing Nichols v.

The Supreme Court held that misdemeanor assault convictions for reckless conduct qualify as 'misdemeanor crimes of domestic violence' under 18 U.S.C. § 922(g)(9), triggering the federal firearms ban.

The Court reversed the Fifth Circuit, holding that res judicata did not bar challenges to Texas' HB2 provisions and that both the admitting-privileges and surgical-center requirements imposed an undue burden on abortion access because they provided no medical benefits while substantially obstructing access.

Justice Thomas dissents, arguing that the majority’s decision to strike down Texas’s admitting‑privileges and ambulatory‑surgical‑center requirements misapplies res judicata, the undue‑burden test, and third‑party standing doctrine.

The Supreme Court held that the Fourth Amendment permits warrantless breath tests incident to lawful arrests for drunk driving but does not permit warrantless blood draws in that circumstance, and that implied consent cannot extend to criminal punishment for refusing a blood test.

Justice Alito dissents, arguing that the Court's majority improperly excludes many burglary convictions from counting as predicate offenses under the Armed Career Criminal Act by focusing on a formal distinction between "elements" and "means" rather than the actual conduct, and that this approach is impractical…

Justice Thomas concurs with the Court’s opinion, agreeing that the modified categorical approach cannot be used to determine the specific means by which a defendant committed a prior burglary for ACCA sentencing.

Justice Kennedy joins the Court's opinion but expresses reservation regarding its reliance on Apprendi v. New Jersey, which he views as incorrect and not compelling the elements-based approach. He acknowledges the arbitrary results of current ACCA precedents but suggests Congress should amend the statute.

The Supreme Court held that the Armed Career Criminal Act's elements-only categorical approach admits no exception for statutes that define a single crime with one set of elements but list alternative factual means of satisfying an element: because Iowa's burglary statute reaches land, water, and air vehicles in…

The Court held that evidence seized incident to arrest is admissible because the discovery of a pre‑existing valid arrest warrant attenuates the causal link between an unlawful investigatory stop and the contraband found, reversing the Utah Supreme Court’s suppression ruling.

The Court held that RICO’s substantive prohibitions can reach foreign racketeering activity when the relevant foreign predicate offenses are themselves covered extraterritorially, and that RICO does not require the enterprise to be domestic if it has a significant connection to U.S. commerce.

The Supreme Court held that RICO applies extraterritorially to substantive prohibitions only when underlying predicate statutes do so, and private RICO plaintiffs must allege domestic injury for recovery. The Court reversed the Second Circuit's contrary ruling.

Justice Thomas dissents, arguing that the Hobbs Act should require proof that a robbery itself affected interstate commerce and that Congress lacks authority under the Commerce Clause to criminalize robberies affecting only intrastate activity.

The Court affirmed the Federal Circuit's judgment, holding that 35 U.S.C. § 314(d) bars judicial review of the Patent Office's decision to institute inter partes review, and that 35 U.S.C. § 316(a)(4) authorizes the agency to use the broadest reasonable construction standard.

The Court, in an opinion by Justice Breyer, affirmed the Federal Circuit. It held that 35 U.S.C. §314(d) bars Cuozzo’s challenge to the institution of inter partes review based on the petition’s alleged failure to identify its grounds with particularity.

The Court held that a Hobbs Act prosecution satisfies the commerce element by showing the defendant robbed or attempted to rob a drug dealer of drugs or proceeds, relying on Gonzales v. Raich. The Fourth Circuit’s judgment was affirmed.

The Supreme Court held that the Department of Labor's 2011 regulation interpreting the FLSA automobile-dealership overtime exemption, 29 U.S.C. § 213(b)(10)(A), is not entitled to Chevron deference because the Department offered barely any reasoned explanation for reversing its longstanding position that service…

The Court held that the Hobbs Act's commerce element is satisfied when a defendant robs a drug dealer of drugs or proceeds, without needing to prove the drugs traveled in interstate commerce, relying on Gonzales v. Raich.

The Supreme Court granted the petition for a writ of certiorari, vacated the judgment, and remanded the case to the Louisiana Court of Appeal for further consideration in light of Foster v. Chatman.

The Court affirmed the Federal Circuit’s judgment, with Justice Thomas concurring and Justice Alito concurring in part and dissenting in part, focusing on whether 35 U.S.C. § 314(d) bars judicial review of the Patent Office’s decision to institute inter partes review.

The Supreme Court held that the implied false certification theory can support False Claims Act liability when a claim makes specific representations about the goods or services provided and the submitter's failure to disclose noncompliance with material statutory, regulatory, or contractual requirements renders those…

The Supreme Court held that 38 U.S.C. § 8127(d) — the 'Rule of Two' — unambiguously requires the Department of Veterans Affairs to restrict competition to veteran-owned small businesses in all contracting determinations, including orders placed under the Federal Supply Schedule, and not merely to the extent necessary…

The Court held that district courts must give substantial weight to the objective reasonableness of a losing party’s position when applying 17 U.S.C. §505, but must also consider all other relevant circumstances, and therefore vacated the Second Circuit’s judgment and remanded for further consideration of the fee…

The Court held that uncounseled tribal-court convictions compliant with the Indian Civil Rights Act may be used as predicate offenses in a prosecution under 18 U.S.C. § 117(a). Because the Sixth Amendment does not apply to tribal courts, these convictions were valid when entered and remain valid when invoked later.

Justice Thomas concurs in the judgment that the Sixth Amendment and the Fifth Amendment’s Due Process Clause do not prohibit the government from using Michael Bryant’s uncounseled tribal‑court convictions as predicates for a federal domestic‑assault charge, but he critiques the underlying assumptions about tribal…

The Court held that the Bankruptcy Code's pre-emption provision bars Puerto Rico from enacting its own municipal bankruptcy law. The Court reasoned that the Code's definition of 'State' excludes Puerto Rico only for the purpose of authorizing municipalities to file under Chapter 9, not for pre-emption purposes.

Justice Sotomayor, joined by Justice Ginsburg, dissents from the Court’s decision that Puerto Rico’s Recovery Act is pre‑empted by § 903(1) of the Bankruptcy Code. She argues that because Puerto Rico’s municipalities are excluded from Chapter 9, the pre‑emption provision does not apply, and the Act should be upheld as…

The Court held that the Federal Bankruptcy Code preempts Puerto Rico's Recovery Act, a state bankruptcy law for insolvent municipalities, because Puerto Rico remains a "State" under the Code's preemption provision despite being excluded from the definition of "State" for Chapter 9 debtor eligibility.

The Court unanimously held that Seagate's framework improperly restricted district courts' discretion to award enhanced patent damages under 35 U.S.C. § 284. Objective recklessness is not a prerequisite; subjective willfulness may justify enhancement, assessed against the infringer's knowledge when it acted.

Justice Thomas dissents from the majority's holding that the Due Process Clause was violated when the Chief Justice of the Pennsylvania Supreme Court reviewed the petitioner's post-conviction petition after having served as district attorney in the petitioner's criminal trial.

The Supreme Court held that a federal district court has a limited inherent power, in civil cases, to rescind a jury discharge order and recall the jury for further deliberations after discovering an error in its verdict, because the power is a reasonable response to correcting error and contravenes no rule or…

The Supreme Court held that the Due Process Clause of the Fourteenth Amendment is violated when a judge who earlier had significant, personal involvement as a prosecutor in a critical decision in the defendant's case denies recusal and later participates in adjudication; former Philadelphia District Attorney Ronald…