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Smith & Wesson Brands, Inc. v. Estados Unidos Mexicanos, Docket No. 23-1141

The Supreme Court had to decide just how far a federal law shields gun makers from lawsuits when their products end up in the wrong hands. That law, known as the Protection of Lawful Commerce in Arms Act, bars most claims against firearm manufacturers—unless a plaintiff can show the makers knowingly helped illegal dealers break the law.

On June 5th, Justice Elena Kagan wrote for a unanimous Court in Smith & Wesson Brands v. Estados Unidos Mexicanos. Mexico sued seven U.S. gun makers, saying they aided and abetted dealers who sold weapons to traffickers. But the justices found that the complaint didn’t show the manufacturers consciously joined any criminal scheme. Knowing a few dealers slipped guns across the border or choosing to market certain products, the Court said, falls short of the “helping hand” needed to open the door to a lawsuit under the law. With that requirement unmet, the Court ended the case. So Mexico’s challenge is off the table for now. What happens next—and whether other efforts can succeed—remains to be seen.

Supreme Court Blocks Mexico's Lawsuit Against U.S. Gun Manufacturers

The Government of Mexico filed a lawsuit in U.S. District Court against seven American firearms manufacturers under the Protection of Lawful Commerce in Arms Act (PLCAA). Mexico claimed that its widespread gun violence problem is fueled by weapons trafficked from the United States to Mexican drug cartels, and it sought to hold the manufacturers civilly liable for harms resulting from criminal misuse by these third parties.

Since the PLCAA generally shields gun manufacturers from lawsuits based on such downstream misuse, Mexico tried to use the law's "predicate exception," which allows lawsuits when a manufacturer knowingly violated a law related to the sale or marketing of firearms, and that violation directly caused harm. Mexico alleged that the manufacturers aided and abetted unlawful sales by: (1) continuing to supply dealers known to traffic guns to Mexico; (2) failing to implement distribution controls; and (3) designing and marketing weapons (like military-style rifles or models with Spanish names) intended to appeal to cartel members.

Opinion of the Court

Justice Kagan, writing for a unanimous Court, reversed the lower court's decision and ruled that Mexico's complaint did not convincingly allege the level of conscious, affirmative participation needed for aiding-and-abetting liability under federal law. The Court emphasized three key principles:

• Aiding and abetting typically requires involvement in a specific wrongful act, not just general industry practices, unless participation is "pervasive, systemic, and culpable."
• Liability usually requires affirmative actions rather than failures to act or omissions.
• Routine, generally legal business conduct that "incidentally" helps criminals doesn't qualify.

Mexico's allegations about industry-wide knowledge, passive distribution policies, or legal design and marketing choices showed mere "indifference" rather than the active joining of "mind and hand" required for aiding and abetting. Since no plausible violation was alleged, the PLCAA's protection remains in force and the lawsuit is barred.

Separate Opinions

• Justice Thomas (concurring): Highlighted that the PLCAA's requirement of a "violation" might itself require a prior finding of a statutory breach, so civil plaintiffs can't effectively determine criminal guilt without proper criminal-law protections.

• Justice Jackson (concurring): Emphasized that Mexico's complaint never identified any specific violation of a firearms statute; the PLCAA's exception requires actual statutory violations, not just questionable business practices.

How Gun Manufacturer Liability Shields Work Under Federal Law

The PLCAA was created to protect firearms manufacturers and sellers from being sued when their legally sold products are later misused by criminals. However, Congress included a narrow exception that allows lawsuits when a gun manufacturer knowingly breaks a law related to selling or marketing firearms, and that violation directly causes someone's injury.

Congress provided examples of what might qualify, such as falsifying transfer paperwork or knowingly selling to prohibited persons, but broadly tied the exception to "any" applicable statute. This reflects a careful legislative compromise: blocking lawsuits based on how criminals later use firearms, while still allowing claims when gun makers themselves break clear legal duties.

The Court's ruling clarifies that to overcome this immunity, plaintiffs must show that manufacturers actively participated in illegal activity with the specific intent to further crimes—not just that they conducted business in ways that might indirectly enable criminal activity.

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CC/Devas (Mauritius) Ltd. v. Antrix Corp., Docket No. 23-1201

The Supreme Court has waded into a subtle wrinkle in a law that decides when you can take a foreign government to court here in the United States. Under the Foreign Sovereign Immunities Act, a country generally can’t claim immunity when the law itself lists clear exceptions—and when the papers are served properly. The question before the justices was whether you also had to prove some extra connection, or “minimum contacts,” as a separate step.

In a unanimous opinion, the Court said no. Once an exception in the law applies and service of process is done right, courts don’t get to add another hurdle. The decision removes the extra test the Ninth Circuit had imposed and sends the case back for proceedings under the straightforward rule Congress wrote.

Summary of the Case

In January 2005 Devas Multimedia Private Ltd., an Indian‐incorporated company, entered into a satellite‐leasing agreement with Antrix Corporation Ltd., the commercial arm of India's Department of Space, to obtain capacity on two new S-band satellites. When the Government of India later reallocated that spectrum for its own use, Antrix invoked a force-majeure clause and terminated the contract. Devas initiated arbitration in India; the panel unanimously found that Antrix had wrongfully repudiated the agreement and awarded Devas $562.5 million plus interest. After obtaining enforcement in France and the United Kingdom, Devas sought confirmation of the award in the U.S. District Court for the Western District of Washington under the Foreign Sovereign Immunities Act's arbitration exception. The District Court confirmed the award and entered a $1.29 billion judgment. A Ninth Circuit panel reversed, ruling that Antrix lacked sufficient connections to the United States. Devas petitioned the Supreme Court to resolve whether the FSIA requires such connections for jurisdiction.

Opinion of the Court

Justice Alito, writing for a unanimous Court, held that the Foreign Sovereign Immunities Act grants personal jurisdiction over a foreign state "whenever an immunity exception applies and service of process has been accomplished," without any additional due-process or minimum-contacts inquiry. The Court reasoned that the law imposes just two prerequisites—(1) an applicable exception to sovereign immunity and (2) proper service—and then mandates jurisdiction by the unambiguous "shall exist" language. Although the immunity exceptions themselves require certain connections to the United States, there is no textual basis to read the law as requiring a separate contacts test. To do so would undermine the FSIA's "comprehensive framework" linking immunity waivers and jurisdictional grants. Legislative history confirms that Congress viewed the exceptions as meeting due-process norms. The Court reversed and remanded.

How Foreign Sovereign Immunity Works in US Courts: No Extra Hurdles Required

The Foreign Sovereign Immunities Act created a clear system for determining when foreign governments can be sued in American courts. It replaced the previous case-by-case diplomatic determinations with specific exceptions to immunity (such as commercial activity, tort, property seizure, and arbitration) and gave federal courts jurisdiction when these exceptions apply and proper service is made.

The Supreme Court clarified that while traditional personal jurisdiction rules require showing "minimum contacts" with the United States, the FSIA doesn't add this as a separate requirement. Instead, the immunity exceptions themselves already define what connections to the US are necessary. The Court found that adding an extra, judge-made contacts test would disrupt the carefully designed system Congress created.

This decision respects both the law's goal of providing clear standards and the principle of international courtesy that underlies sovereign immunity. By letting the statutory exceptions themselves define when jurisdiction exists, the Court preserved the straightforward framework Congress intended.

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The Supreme Court’s decision turns on a fine point of environmental law: when a federal agency studies a project’s effects, it only has to look at the project itself. Seven County Infrastructure Coalition v Eagle County involved an 88-mile railroad line in Utah’s Uinta Basin. The Surface Transportation Board wrote its environmental report on that rail project and chose not to analyze separate oil drilling or refining plans. The Court said that was enough and sent the case back, reversing the lower court.

Under the law at issue—the rule that makes federal agencies study environmental impacts—courts are meant to trust agencies when they stick to the work Congress set out. Agencies don’t have to guess at every possible side project beyond their control.

Summary of the Case

The Seven County Infrastructure Coalition applied to the Surface Transportation Board (STB) in 2020 to build an 88-mile freight railroad from Utah's oil-rich Uinta Basin to the national rail network, thereby easing crude-oil transport to Gulf-Coast refineries. As required by NEPA, the Board prepared a 3,600-page Environmental Impact Statement (EIS) analyzing the line's construction and operation—wetlands, wildlife, noise, air quality, and local land-use effects—but declined to "detailed[ly]" assess two categories of indirect impacts: (1) additional upstream oil drilling in the Basin and (2) increased downstream refining along the Gulf Coast. In December 2021, the Board approved the line, finding its transportation and economic benefits outweighed its environmental costs. Petitioners in the D.C. Circuit—Eagle County and environmental organizations—argued that NEPA's "hard look" mandate required fuller analysis of those foreseeable upstream and downstream effects. The D.C. Circuit agreed, vacating both the EIS and the Board's approval. The Supreme Court granted certiorari to decide whether NEPA compels an agency to analyze the environmental impacts of separate projects that are distinct in time, place, or regulatory authority from the "proposed action."

Opinion of the Court

Justice Kavanaugh, writing for a 5-4 majority, reversed. He first reiterated that NEPA is a purely procedural statute: it requires agencies to prepare an adequate EIS but does not prescribe substantive results. Courts reviewing NEPA claims must defer to agencies' fact-intensive judgments—on the scope, detail, and breadth of an EIS—so long as those choices fall within a "broad zone of reasonableness." Under NEPA's text, the focus is the "proposed action," here the 88-mile rail line, not separate upstream wells or downstream refineries. Even if those indirect effects are foreseeable, the causal chain is too attenuated when another agency controls drilling or refining. Moreover, courts must not, "under the guise of judicial review," delay or block projects by importing into NEPA the environmental assessment of unrelated undertakings. The Board's EIS adequately addressed the environmental consequences of the railway itself; it was neither arbitrary nor capricious to omit a second-order inquiry into separate oil-industry projects.

Separate Opinions

Justice Sotomayor concurred in the judgment. She agreed that the Board need not analyze effects of drilling and refining because its organic statute gives it no authority to deny or condition rail approval on those consequences. In her view, the majority's broad deference framework risks understating NEPA's information-forcing purpose; yet this case's outcome follows inexorably from the Board's lack of power over oil development. Justices Kagan and Jackson joined her concurrence.

How Far Does Environmental Review Extend? The Limits of NEPA's Reach

NEPA requires federal agencies to prepare an Environmental Impact Statement for major actions affecting the environment. But there's an important boundary: agencies only need to analyze environmental impacts they have the power to address. The law functions as a transparency tool, making agencies consider environmental concerns before proceeding with projects.

When courts review these environmental statements, they must give substantial deference to agencies' decisions about what to include and at what level of detail. The focus must remain on the specific project being proposed—in this case, the railway itself—not on separate projects that might be connected but are different in time, location, or under different regulatory authority.

This approach maintains NEPA's original purpose: ensuring informed decision-making without allowing judges to substitute their own policy preferences for the expertise and discretion of government agencies. The law requires thorough environmental analysis of the proposed action, but doesn't force agencies to analyze impacts beyond their control or authority to mitigate.

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You might think fraud only matters if someone loses money, but the Supreme Court dug into a finer point of the law. In this case, a painting company and its owner, Stamatios Kousisis, were tried for wire fraud after they persuaded a customer to start a deal with false promises. The Court said it doesn’t matter whether the customer ended up losing cash. What counts is that important lies were used to get them into the deal.

Justice Amy Coney Barrett and six other justices agreed that tricking someone into a transaction itself meets the federal fraud law. They said it’s enough that the lie was “material,” meaning it was big enough to matter to the deal. No proof of real financial harm is required.

Summary of the Case

In December 2024, the U.S. Supreme Court agreed to hear Kousisis v. United States to resolve a disagreement among federal courts about wire fraud convictions. The key question: Can someone be convicted of wire fraud when they trick a government agency into paying them money, even if the agency doesn't suffer a financial loss?

The case involves Stamatios Kousisis and his company, Alpha Painting and Construction. They won two Pennsylvania Department of Transportation (PennDOT) contracts worth about $86 million. These contracts, funded with federal money, required subcontracting with disadvantaged business enterprises (DBEs). When bidding, Kousisis falsely claimed that a qualified DBE called Markias would supply over $6 million in paint. In reality, Markias was just a "pass-through" for Alpha's non-DBE suppliers, violating both regulations and a material contract term.

After completing the work and making $20 million in profit, Kousisis and his company were convicted of wire fraud and conspiracy under a "fraudulent-inducement" theory. They argued for acquittal, claiming PennDOT suffered no financial loss and therefore couldn't have been defrauded "of money or property." The Third Circuit rejected this argument, and the Supreme Court agreed to review the case.

Opinion of the Court

Justice Barrett, writing for a 7-Justice majority, affirmed the conviction. The wire fraud statute punishes any "scheme for obtaining money or property by means of false or fraudulent pretenses." The Court found that the law's text doesn't require proof of net economic loss. To "obtain" simply means "to gain or attain possession," even if the victim receives something in return.

The Court noted that common law didn't generally require pecuniary loss in all fraud actions. Some fraud remedies focused on whether the victim received "property of a different character or condition than promised," not whether they suffered a net loss. The wire fraud statute's "money-or-property" requirement therefore covers fraudulent-inducement schemes as long as money or property was an object of the fraud.

Previous Supreme Court cases like Carpenter v. United States and Shaw v. United States confirm that wire fraud liability doesn't depend on causing economic loss. False statements that induce payment—even if the victim receives value—fall within the statute, provided they are "material" (meaning important to the transaction). The Court emphasized that materiality remains a "demanding" element and held that the Third Circuit correctly applied the law in affirming the convictions.

Separate Opinions

Justice Thomas concurred in the judgment, agreeing that a net loss isn't required but taking no position on the case's outcome under a more demanding materiality test. He wrote separately to emphasize that materiality deserves rigorous analysis but declined to define its exact boundaries here.

Justice Gorsuch also concurred in part and in the judgment. He agreed that the statute doesn't require victim economic loss but objected to the majority's suggestion that any "obtaining" of money or property is sufficient regardless of whether the victim received what they bargained for. He urged adherence to the common-law rule that fraud requires proof that the victim lost "what he bargained for."

Wire Fraud and the "Fraudulent Inducement" Theory Explained

The wire fraud statute prohibits schemes to "obtain money or property by means of false pretenses." It has three key elements: (1) a scheme to defraud; (2) an objective to obtain money or property; and (3) use of interstate wires to further the scheme.

Under the "fraudulent-inducement" theory upheld by the Court, a person violates the law by making important misrepresentations to induce someone to pay them—even if they deliver value and don't intend to cause financial loss. The Court clarified that "obtain" simply means "gain possession," without considering exchange value.

Historical context supports this interpretation. At common law, certain fraud prosecutions and contract cancellations focused on schemes that deprived victims of promised property, not on proving financial loss. The only common-law fraud action requiring economic loss was the tort of misrepresentation, not the criminal offense of false pretenses.

The Court's decision, consistent with previous cases, rejects requiring proof of net financial loss in wire fraud cases. However, the "materiality" requirement remains important—it distinguishes actionable misrepresentations from minor ones. The fraudulent inducement theory doesn't extend to mere interference with regulatory power, nor does it blur distinctions with other federal fraud statutes. It protects only money or property, not intangible interests.

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The justices put a hold on the removal of several Venezuelan nationals linked to a group called Tren de Aragua. They ruled these detainees have to receive clear and timely notice so they can ask a court to review their status. The high court sent the case back down and told the lower courts to figure out exactly how much notice is fair and then to dive into the deeper challenges those detainees have raised. This isn’t a final decision on whether they’ll stay or go, but it does pause the process and forces the government to spell out the reasons against each person. What happens next could shape how far the government must go in giving notice to anyone it wants to remove under national security laws.

Summary of the Case

Two Venezuelan nationals were detained in Texas and identified as members of Tren de Aragua, a designated terrorist group. Using the Alien Enemies Act, the President issued an order for their immediate removal from the United States. The detainees sought emergency relief in court, arguing they were given only about 24 hours' notice with no real chance to consult lawyers or challenge their removal. When the trial court failed to rule for over 14 hours, they appealed to a higher court and also directly to the Supreme Court. The appeals court dismissed their case, claiming it lacked jurisdiction because the trial judge had been given only 42 minutes to act. The detainees then brought their case directly to the Supreme Court.

Opinion of the Court

In the court's decision, the Supreme Court granted temporary protection for the detainees, overturned the appeals court's judgment, and sent the case back for further proceedings. First, the Court ruled that the appeals court was wrong: higher courts do have authority to review cases when a lower court's inaction effectively denies emergency relief, which is what happened here.

Second, applying constitutional principles, the Court reaffirmed that "no person shall be removed from the United States without opportunity, at some time, to be heard." The Court emphasized that people detained under the Alien Enemies Act must receive notice that reasonably informs them about their removal and actually allows them to challenge it. Notice given roughly a day in advance, without information about legal counsel or procedures, clearly failed to meet constitutional requirements. The Court therefore blocked removals under the Alien Enemies Act while lower courts determine exactly what kind of notice is required, stressing that national security must be pursued in "a manner consistent with the Constitution."

Separate Opinions

Justice Kavanaugh agreed that temporary relief was warranted to preserve the courts' role, but he argued against sending the case back to lower courts. Instead, he urged the Supreme Court to fast-track the case and resolve two key questions now: whether the Alien Enemies Act authorizes removal of these particular detainees, and what legal process the Act requires.

Dissenting Opinions

Justice Alito, joined by Justice Thomas, fully disagreed with the majority. He first argued the Court lacked jurisdiction: the trial court had been working diligently, the 42-minute deadline imposed by the detainees was unfair, and there was no effective denial of relief. Second, he maintained that the detainees failed to show they would likely win their case on its merits. Third, he criticized the Court for bypassing normal judicial procedures, stating: "we are a Court of review, not first view."

The Tension Between Ancient Laws and Modern Rights

At the heart of this case is the Alien Enemies Act, a law dating back to 1798 that gives the President power to remove citizens of countries at war with the United States. The law itself is remarkably brief and says nothing about procedural protections. However, over more than a century, the Supreme Court has established fundamental due process limits on this executive power. Past cases have established that removal without "opportunity, at some time, to be heard" is unconstitutional, and that people facing removal must receive notice "reasonably calculated under all the circumstances" to inform them and give "a reasonable time" to respond. In a recent 2025 case, the Court unanimously confirmed that people detained under the Alien Enemies Act must receive adequate notice and an opportunity to challenge their detention before being summarily removed. Lower courts must now determine exactly what form and timing of legal process the Constitution requires before someone can be removed under this Act. This case highlights the ongoing tension between an old statutory power and evolving constitutional protections—showing how our legal system balances legislative authority with constitutional rights.

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Law can turn on a single moment, but the Supreme Court says it’s not enough just to stop the clock at that instant. In Barnes v. Felix, the Court looked at a rule that made judges evaluate police force only by what happened in the split second an officer felt threatened. The Justices all agreed that’s too narrow.

Instead, they said courts must look at the whole story—the moments leading up to the use of force, not just that final flash. In simple terms, it’s like watching the whole game, not just the winning play. By sending the case back to the lower court, the Supreme Court is making sure every part of the encounter gets its fair share of attention.

Summary of the Case

The family of Ashtian Barnes sued Officer Roberto Felix in Barnes v. Felix after he used deadly force during a traffic stop. Barnes was initially pulled over for toll violations. When he began searching through his car and then drove away after being ordered to exit, Officer Felix jumped onto the doorstep of the moving vehicle. Within two seconds, Felix fired two fatal shots. The trial court ruled in favor of the officer, applying a rule that only considered whether danger existed at the exact moment before the shooting. An appeals court agreed, stating that events before the "two-second window" weren't relevant. The Supreme Court then stepped in to decide whether this narrow time focus aligns with the Fourth Amendment's requirement that police actions be "objectively reasonable."

Opinion of the Court

Justice Kagan, writing for a unanimous Court, rejected this "moment-of-threat" approach as improperly limiting Fourth Amendment analysis. The Court reinforced that all excessive force claims must consider the "totality of the circumstances." Because prior events might explain why an officer reasonably perceived danger—or why a suspect's actions were actually harmless—courts cannot wear "chronological blinders" that only focus on the final moment before shots were fired. The Court noted that context, including events leading up to a shooting, can justify an officer's decision to use deadly force. It overturned the lower court's ruling and sent the case back for reconsideration using a complete timeline analysis.

Separate Opinions

Justice Kavanaugh, joined by Justices Thomas, Alito, and Barrett, wrote separately while agreeing with the outcome. He emphasized the dangers officers face during traffic stops and the split-second decisions they must make when drivers flee. While agreeing courts must consider all circumstances, he stressed that judges should recognize the risks to officers and the public, especially when a suspect's "flight could signal a larger danger."

The Timeline Matters in Police Use of Force Cases

The key issue in this case revolves around how much of the timeline courts should examine when judging police use of force. The Fourth Amendment protects people from "unreasonable seizures," including excessive police force. Previous Supreme Court decisions established that reasonableness must be judged from "the perspective of a reasonable officer on the scene," without applying a simplistic test. The Court clarified that while an officer's split-second decision at the moment of firing is crucial, earlier events—such as the suspect's actions, any warnings given, or how the officer approached the situation—are equally important in determining whether force was reasonable. A rule that artificially cuts off consideration of earlier events contradicts the fact-based, context-sensitive approach the law requires. Courts must evaluate the complete picture without arbitrarily limiting their view to just the final moments before force was used.

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Sometimes, the law comes down to the smallest details — like the exact timing of when someone is called to serve. In the case of Feliciano v. Department of Transportation, the Supreme Court looked at whether federal civilian employees who are also reservists should get extra pay when they’re called to active duty during a national emergency. The question was: does their service have to be directly tied to the specific emergency, or is it enough that their service just happens to overlap with a declared national emergency?

The Court decided that if a federal employee is called up under any law during a national emergency, they’re entitled to that extra pay, even if their service isn’t directly connected to the emergency itself. Justice Neil Gorsuch wrote the opinion, and he was joined by Chief Justice Roberts, as well as Justices Sotomayor, Kavanaugh, and Barrett. There was a dissent, led by Justice Thomas and joined by Justices Alito, Kagan, and Jackson. This case is a reminder of how the wording of a law, and the timing of events, can make a big difference in people's lives.

Summary of the Case

Feliciano v. Department of Transportation (No. 23–861) concerns the interpretation of federal statutes governing "differential pay" for federal civilian employees who are also military reservists. When reservists are called to active duty, they often earn less than in their civilian roles. Congress enacted a statute (5 U.S.C. §5538(a)) requiring the government to pay the difference in certain circumstances, including when reservists are called to active duty "during a national emergency." The dispute arose over whether this language entitles a reservist to differential pay simply because their service coincides with a declared national emergency, or whether there must be a substantive connection between the reservist’s service and the specific emergency. Nick Feliciano, a federal air traffic controller and Coast Guard reservist, was denied differential pay for his active duty service under 10 U.S.C. §12301(d) during a period of declared national emergency. After the Merit Systems Protection Board and the Federal Circuit denied his claim—holding that a substantive connection was required—Feliciano sought Supreme Court review.

Opinion of the Court

Justice Gorsuch, writing for the majority, held that a federal civilian employee called to active duty under "any other provision of law... during a national emergency" is entitled to differential pay if their service temporally coincides with a declared national emergency, without needing to prove a substantive connection to a particular emergency. The Court emphasized the ordinary meaning of "during," which denotes a temporal, not substantive, link. The majority found that when Congress intends to require both temporal and substantive connections, it does so explicitly (e.g., "during and in relation to"). The Court also noted that requiring a substantive connection would create interpretive difficulties, as the statute provides no guidance on what such a connection would entail. The Court rejected arguments that a temporal-only reading would render the statute meaningless, pointing out that Congress sometimes uses temporal conditions even if they are often satisfied. The judgment of the Federal Circuit was reversed and remanded (Slip Op. at 4–16).

Separate Opinions

No separate concurring opinions were issued. All justices in the majority joined Justice Gorsuch’s opinion.

Dissenting Opinions

Justice Thomas, joined by Justices Alito, Kagan, and Jackson, dissented. The dissent argued that the statutory context and the ordinary meaning of "contingency operation" require a substantive connection between the reservist’s service and the national emergency. Justice Thomas emphasized that the term "contingency operation" in military parlance refers to operations responding to specific exigencies, not all military activity during a national emergency. He warned that the majority’s reading would render much of the statutory language superfluous, as national emergencies are almost always ongoing, and would have unintended consequences for other statutes that use the same definition. The dissent also pointed to legislative history and subsequent amendments as evidence that Congress intended a narrower reading (Thomas, J., dissenting, Slip Op. at 4–17).

Temporal and/or Substantive Connections

The legal nuance in this case centers on statutory interpretation, particularly the meaning of "during a national emergency" in 10 U.S.C. §101(a)(13)(B) as incorporated by 5 U.S.C. §5538(a). The majority applied a textualist approach, focusing on the ordinary, dictionary meaning of "during" as temporal, and found no evidence that Congress intended a specialized or substantive meaning. The Court contrasted this with other statutes where Congress explicitly requires a substantive connection (e.g., "during and in relation to"). The dissent, by contrast, relied on the context of the statutory scheme, the military’s use of "contingency operation," and the structure of the statute, arguing that the catchall provision should be read in harmony with the more specific enumerated provisions and the overall purpose of the law. The case thus illustrates the tension between plain meaning and contextual or purposive statutory interpretation, as well as the challenges of applying general statutory language to complex, real-world situations involving overlapping legal regimes and administrative practice.

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When it comes to the rules around Medicare and hospital funding, the details can get pretty tricky. In the case of Advocate Christ Medical Center v. Kennedy, the Supreme Court looked at how hospitals get extra money for treating low-income patients. The question was about who counts as "entitled" to certain government benefits—specifically, supplementary security income, or SSI—when hospitals figure out how much extra funding they should get.

The Court decided that a patient is only considered "entitled" to SSI benefits if they’re actually eligible to receive a cash payment during the month they’re in the hospital. This might sound like a small detail, but it changes which patients hospitals can count when they ask for more money to help cover the costs of caring for people with lower incomes. The decision means that only those patients who could get an SSI payment that month will be included in the hospital’s calculations for extra Medicare funding.

Summary of the Case

Advocate Christ Medical Center v. Kennedy concerns the calculation of the "disproportionate share hospital" (DSH) adjustment under Medicare, which provides additional funding to hospitals serving a high percentage of low-income patients. The DSH adjustment is determined by a formula that includes the "Medicare fraction," which counts the number of hospital patient days attributable to Medicare patients who are also "entitled to [Supplemental Security Income (SSI)] benefits." The Department of Health and Human Services (HHS) interpreted this to mean only those patients eligible to receive an SSI cash payment during the month of hospitalization. Over 200 hospitals challenged this interpretation, arguing that all patients enrolled in the SSI system at the time of hospitalization should be counted, even if they did not receive a payment that month. The hospitals claimed HHS’s approach undercounted low-income patients and led to underfunding from 2006 to 2009. The lower courts sided with HHS, and the Supreme Court granted certiorari to resolve the statutory interpretation of "entitled to [SSI] benefits" (see Syllabus, pp. 1–3).

Opinion of the Court

Justice Barrett, writing for the majority, held that for purposes of the Medicare fraction, an individual is "entitled to [SSI] benefits" only when eligible to receive an SSI cash payment during the month of hospitalization. The Court reasoned that SSI benefits, as defined by statute, are cash benefits determined on a monthly basis (42 U.S.C. §§1381a, 1382(b), 1382(c)). The Court rejected the hospitals’ broader reading, which would have included non-cash benefits or all SSI enrollees regardless of monthly eligibility. The majority emphasized that the statutory language and structure focus on monthly eligibility for cash payments, not broader program enrollment or ancillary benefits. The Court also distinguished this case from its prior decision in Becerra v. Empire Health Foundation, noting that the entitlement structure of SSI (monthly, means-tested, and not automatic) differs from Medicare Part A (automatic and ongoing). The Court concluded that Congress chose a specific, administrable formula, and the judiciary must respect that choice, even if it is imperfect (Opinion, pp. 6–16).

Dissenting Opinions

Justice Jackson, joined by Justice Sotomayor, dissented. The dissent argued that the majority misunderstood the nature of SSI, which is designed as a safety net guaranteeing a minimum income for low-income individuals. Justice Jackson contended that "entitlement" to SSI should be understood as program enrollment, not just monthly payment eligibility, because the benefit is the security of coverage, not merely the receipt of a check. The dissent criticized the majority’s approach as arbitrary, noting that it could exclude low-income patients from the DSH calculation based on the timing of their income fluctuations, rather than their overall economic status. Justice Jackson also argued that the majority’s interpretation undermines Congress’s intent to support hospitals serving the neediest populations and is inconsistent with the Court’s prior reasoning in Empire Health, which focused on program eligibility rather than payment receipt (Dissent, pp. 2–18).

Determining Poverty Status

The legal nuance centers on the interpretation of "entitled to [SSI] benefits" in 42 U.S.C. §1395ww(d)(5)(F)(vi)(I). The statute’s language is technical and embedded in a complex reimbursement scheme. SSI is a means-tested program providing monthly cash payments to eligible individuals, with eligibility determined each month based on income and resources (42 U.S.C. §§1381a, 1382(a)-(c)). The DSH adjustment formula uses the Medicare fraction to approximate the share of low-income Medicare patients, but Congress chose to use monthly SSI payment eligibility as a proxy for poverty status. This choice reflects a legislative compromise balancing accuracy, administrability, and resource allocation. The majority’s interpretation adheres closely to the statutory text and structure, emphasizing the importance of monthly eligibility and the cash nature of SSI benefits. The dissent, by contrast, reads the statute in light of its broader remedial purpose and the practical realities of poverty, advocating for a more inclusive approach that would better capture the population Congress intended to benefit. This case illustrates the tension between textualist and purposivist statutory interpretation, especially in the context of complex social welfare legislation (see Opinion, pp. 6–16; Dissent, pp. 2–18).

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Trump's immigration policies are in the Supreme Court once again in the case of Velazquez v. Bondi. The case questions deadlines! The justices had to decide what happens when a deadline for voluntary departure falls on a weekend or a holiday. The Court ruled that if the deadline lands on one of those days, it actually extends to the next business day.

This decision overturned a previous ruling from the Tenth Circuit, which had treated the deadline as a strict calendar day. Justice Neil Gorsuch wrote the majority opinion, and he was joined by Justices Roberts, Sotomayor, Kagan, and Jackson. On the other side, Justices Thomas, Alito, and Barrett disagreed, with Kavanaugh joining parts of their dissent.

This ruling is important because it clarifies how deadlines are interpreted in immigration cases, ensuring that individuals have a fair chance to respond, especially when those deadlines coincide with weekends or holidays. The Court's decision means that people won't be unfairly penalized for timing that is out of their control.

Summary of the Case

The case of Monsalvo Velázquez v. Bondi arose from the federal government's initiation of removal proceedings against Monsalvo, who sought to suspend these efforts or to leave the United States voluntarily. An immigration judge found him removable but granted him a 60-day period for voluntary departure. After the Board of Immigration Appeals (BIA) rejected his appeal, it granted him a new 60-day period, which ended on a Saturday. Monsalvo filed a motion to reopen his case on the following Monday, which the BIA rejected as untimely, asserting that the deadline had expired on Saturday. The Tenth Circuit upheld the BIA's decision, leading to the Supreme Court's review of the interpretation of the statutory deadline under 8 U.S.C. §1229c(b)(2).

Opinion of the Court

The Supreme Court, in a decision authored by Justice Gorsuch, held that the Tenth Circuit erred in interpreting the voluntary departure deadline as strictly referring to calendar days without extending to the next business day when the deadline falls on a weekend or holiday. The Court reasoned that the term "days" in legal contexts often carries a specialized meaning that allows for such extensions. The Court emphasized that Congress enacted §1229c(b)(2) against a backdrop of longstanding administrative practices that recognized this interpretation. The Court reversed the Tenth Circuit's ruling, allowing for the possibility that Monsalvo's motion to reopen was timely filed.

Separate Opinions

Justice Kavanaugh joined the dissenting opinions of Justices Thomas and Alito, which focused on jurisdictional issues rather than the merits of the case. Justice Barrett also dissented, agreeing with Justice Thomas on jurisdiction but providing a different rationale. She argued that Monsalvo did not challenge any aspect of the final order of removal, thus the Tenth Circuit lacked jurisdiction to hear his case.

Dissenting Opinions

Justice Thomas, joined by Justices Alito, Kavanaugh, and Barrett, dissented on the grounds that the Court should have remanded the case to the Tenth Circuit to address a jurisdictional objection raised by the government. He contended that Monsalvo's petition did not seek judicial review of a final order of removal, as he did not contest his removability. Justice Alito's dissent emphasized that the ordinary meaning of "days" should apply, arguing that the statutory deadline was clear and that extending it would create inconsistencies. Justice Barrett's dissent focused on the lack of a challenge to the final order of removal, asserting that the Tenth Circuit lacked jurisdiction regardless of how broadly one interprets the final order.

Scrutinizing "Days" As a Legal Term

The case highlights the complexities of statutory interpretation within immigration law, particularly regarding deadlines. The Court's decision underscores the principle that statutory terms can carry specialized meanings in legal contexts, which may differ from their ordinary usage. The ruling also illustrates the importance of administrative practices and historical context in interpreting legislative provisions. The dissenting opinions raise critical questions about jurisdiction and the scope of judicial review under the Immigration and Nationality Act, emphasizing the need for clarity in how courts interpret "final orders of removal" and the implications of procedural deadlines. The case ultimately reflects the tension between strict statutory interpretation and the need for flexibility in legal proceedings, particularly in immigration contexts where individuals face significant consequences.

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The Supreme Court clarified an important aspect of the Employee Retirement Income Security Act, or ERISA, in the case of Cunningham et al. v. Cornell University. The justices decided that when someone wants to make a claim under a specific part of this law, they only need to show that their claim meets the basic requirements laid out in that section. They don’t have to worry about other exemptions that might apply.

This ruling overturned a previous decision from the Second Circuit Court, which had added extra steps for plaintiffs. They had to prove not only that their claim was valid but also that certain transactions were unnecessary or involved unreasonable compensation. The Supreme Court's decision simplifies the process for those bringing claims under this part of ERISA, making it easier for them to seek justice.

Justice Sonia Sotomayor wrote the majority opinion, and she was joined by several other justices. This case highlights how the law can evolve and adapt, ensuring that individuals have a fair chance to present their claims without unnecessary hurdles.

Summary of the Case

The case of Cunningham et al. v. Cornell University et al. arose from a group of current and former employees of Cornell University who participated in defined-contribution retirement plans. They alleged that Cornell and its fiduciaries engaged in prohibited transactions under the Employee Retirement Income Security Act of 1974 (ERISA) by paying excessive fees for recordkeeping services provided by parties in interest, specifically the Teachers Insurance and Annuity Association of America-College Retirement Equities Fund and Fidelity Investments Inc. The plaintiffs contended that the fees paid were significantly higher than what would be considered reasonable. The District Court dismissed their claims, and the Second Circuit affirmed this dismissal, ruling that plaintiffs must plead that the exemptions under §1108(b)(2)(A) do not apply to their claims under §1106(a)(1)(C).

Opinion of the Court

The Supreme Court, in a unanimous opinion delivered by Justice Sotomayor, reversed the Second Circuit's decision. The Court held that to state a claim under §1106(a)(1)(C), a plaintiff need only plausibly allege the elements contained in that provision itself, without needing to address potential exemptions under §1108. The Court reasoned that §1106(a)(1)(C) contains a categorical prohibition against certain transactions, and the exemptions in §1108 are structured as affirmative defenses that must be pleaded and proved by the defendants. The Court emphasized that requiring plaintiffs to negate these exemptions in their initial pleadings would be impractical and contrary to the statutory structure of ERISA.

Separate Opinions

Justice Alito filed a concurring opinion, joined by Justices Thomas and Kavanaugh. Alito agreed with the Court's conclusion that §1108 sets out affirmative defenses and that plaintiffs need not plead against them. However, he expressed concern that this ruling could lead to practical issues, as it may allow plaintiffs to survive motions to dismiss by merely alleging that a fiduciary engaged in transactions that are often necessary for plan administration, potentially leading to increased litigation costs for fiduciaries.

Dissenting Opinions

There were no dissenting opinions in this case; the ruling was unanimous.

ERISA and Exemptions

The case highlights a critical interpretation of ERISA, particularly the relationship between its prohibitory and exemptive provisions. The Court's decision clarifies that the burden of proving the applicability of exemptions under §1108 lies with the defendants, not the plaintiffs. This interpretation aligns with the general principle in statutory construction that exemptions are treated as affirmative defenses. The Court's ruling underscores the importance of maintaining a clear distinction between prohibited conduct and exemptions, thereby preventing the potential for overly burdensome pleading requirements that could stifle legitimate claims. The decision also reflects a broader concern about the balance between protecting plan participants and ensuring that fiduciaries can effectively manage retirement plans without facing undue litigation risks.