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With a sharp focus on where law meets medicine, the Supreme Court upheld Tennessee’s ban on puberty blockers and hormones for minors seeking care for gender dysphoria or to live as a gender different from their birth sex. The justices said this law doesn’t single out transgender kids but sets rules based on age and medical treatment. Chief Justice Roberts wrote that, in situations where scientists and doctors still debate, courts should give room for states to protect young people’s health.

Several justices added separate notes to explain parts of their agreement, while Justices Sotomayor and Kagan issued a strong dissent, warning that this ban risks harming vulnerable children and cutting off their access to care.

Summary of the Case

In 2023, Tennessee passed a law called SB1, which prohibits healthcare providers from giving puberty blockers or hormones to minors for gender-affirming care. The law specifically bans these treatments when used to help minors identify with a gender different from their birth sex or to treat distress from gender incongruence. However, the same medications remain available for adults and for minors with other medical conditions like precocious puberty or certain diseases.

Three transgender minors, their parents, and a physician challenged the law as unconstitutional under the Equal Protection Clause, and the U.S. government joined their case. Initially, a federal district court blocked the law, ruling that it discriminated based on sex and transgender status. However, the Sixth Circuit Court of Appeals reversed this decision, accepting Tennessee's argument that medical uncertainty provided a rational basis for the law.

The Supreme Court then took up the case to determine whether Tennessee's law violates equal protection rights.

How the Supreme Court Ruled on Gender-Affirming Care Restrictions

In a 5-4 decision, the Supreme Court upheld Tennessee's law. Chief Justice Roberts wrote the majority opinion, joined by Justices Thomas, Gorsuch, Kavanaugh, Barrett, and partially by Justice Alito.

The majority ruled that the law doesn't trigger heightened scrutiny because it classifies people based on two non-suspect grounds: age (adults versus minors) and medical purpose (gender dysphoria treatment versus other medical conditions). The Court determined that the law doesn't discriminate based on sex or transgender status.

According to the majority, merely referring to sex in defining a medical procedure doesn't automatically require intermediate scrutiny. They found that the law applies equally to all minors regardless of sex and doesn't reveal any discriminatory intent.

The Court also rejected the argument that the law classifies based on transgender status, stating that it excludes certain diagnoses from covered medical conditions rather than targeting transgender people themselves. The majority distinguished this case from Bostock v. Clayton County (an employment discrimination case), saying that changing a patient's sex wouldn't alter how the law operates since it focuses on diagnosis, not identity.

Under the less stringent rational-basis review, the Court found that Tennessee's concerns about medical risks, minors' maturity, potential regret, and alternative treatments provided sufficient justification for the law's restrictions.

Separate Opinions

Several justices wrote separate opinions:

Justice Thomas concurred but declined to extend the reasoning from Bostock beyond employment discrimination cases. He also warned against excessive deference to medical experts in constitutional cases.

Justice Barrett agreed that transgender status is not a suspect class warranting heightened scrutiny.

Justice Alito joined parts of the majority opinion but wrote separately to say he would have upheld the law even under heightened scrutiny.

In dissent, Justice Sotomayor (joined by Justices Jackson and Kagan) argued that the law clearly classifies based on sex and transgender status because it allows these medications only when they align with birth sex. She contended that intermediate scrutiny should apply, and under that standard, Tennessee failed to show its ban was substantially related to protecting minors' health.

Justice Kagan wrote a separate dissent (joined by Justices Jackson and Sotomayor) agreeing that intermediate scrutiny should apply.

The Medical and Legal Debate Behind Gender-Affirming Care Bans

Tennessee's law reflects the legislature's concerns about the growing use of puberty blockers and hormones for treating gender dysphoria in minors. The state cited worries about potential irreversible effects, including sterility, health risks, and psychological consequences. The law also referenced minors' limited capacity to fully understand long-term outcomes and reports of regret.

The law makes a critical distinction: it permits these medications for traditional medical conditions but prohibits them when used to facilitate gender identity different from birth sex or to treat distress related to gender dysphoria.

The dissenting justices argued that this distinction itself reveals the sex-based nature of the law, as the same treatment is allowed or banned depending on whether it preserves or challenges birth sex alignment. This fundamental disagreement about how to classify the law's restrictions formed the core of the Court's split decision.

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Here’s a twist in the way the law works: when a prisoner sues under the rule that says you must try every step inside prison before going to court, who decides if those steps really happened — a judge or a jury? The Supreme Court says that when those questions get mixed up with the heart of the case, a jury must decide. That’s because the law on prisoner complaints doesn’t spell out who sorts that out, and normally any factual fight tied to the main claim goes to a jury. This ruling settles a fight where different appeals courts had different answers. Chief Justice Roberts wrote for the five-justice majority, joined by Justices Sotomayor, Kagan, Gorsuch, and Jackson. Justice Barrett, joined by three colleagues, disagreed and would have left those decisions to judges.

Summary of the Case

Kyle Richards, a Michigan state inmate, sued prison officer Thomas Perttu, alleging that Perttu had sexually harassed him and other inmates and then destroyed Richards's grievance forms when he tried to complain. Perttu moved for summary judgment, arguing that Richards failed to exhaust available administrative remedies as required by the Prison Litigation Reform Act (PLRA). The Magistrate Judge held an evidentiary hearing, found Richards's witnesses not credible, and recommended dismissal without prejudice for failure to exhaust. The District Court adopted that recommendation. On appeal, a three-judge Sixth Circuit panel reversed, holding that the Seventh Amendment guarantees a jury trial whenever resolution of a PLRA-exhaustion dispute is "intertwined" with a claim that itself entitles the plaintiff to a jury. That decision conflicted with other circuit court precedent. The Supreme Court granted review to resolve whether prisoners have a right to jury trial on PLRA exhaustion when that question overlaps with the merits of their claim.

Opinion of the Court

Chief Justice Roberts, writing for the 5–4 majority (joined by Justices Sotomayor, Kagan, Gorsuch, and Jackson), affirmed the Sixth Circuit. The Court first applied the constitutional-avoidance principle, asking whether the PLRA can be read to confer a jury trial right and thereby avoid resolving whether Congress could have required judge-only factfinding without violating the Seventh Amendment. The majority held that PLRA exhaustion is an affirmative defense subject to the "usual practice" under the Federal Rules of Civil Procedure, and that under that background practice, courts send factual disputes intertwined with the merits to a jury. The PLRA is "silent" on whether a judge or jury must decide exhaustion and contains no indication that Congress intended to change these common-law principles. Nor does the PLRA's purpose of conserving judicial resources overcome the weight of this usual practice. Historical precedents confirm that factual questions intertwined with the merits belong before a jury. Accordingly, the Court interpreted the PLRA to require a jury trial on exhaustion when it overlaps with a claim that carries a Seventh Amendment right.

Dissenting Opinions

Justice Barrett, joined by Justices Thomas, Alito, and Kavanaugh, dissented. She argued that the Court improperly reframed a purely constitutional question as a statutory one, creating out of thin air a rule that the PLRA "implicitly" confers a jury right. She maintained that neither the text nor the history of the PLRA supports such an inference, and that the majority misapplied precedents designed only to guide judicial sequencing of legal and equitable claims, not to expand the jury-trial right itself.

When Prison Grievances and Jury Rights Collide: The Supreme Court's PLRA Decision

The Prison Litigation Reform Act requires inmates to exhaust all available administrative remedies before filing lawsuits. But what happens when the very person an inmate is suing allegedly prevented them from filing grievances? This case addressed exactly that situation. The Court determined that when factual disputes about whether an inmate properly exhausted administrative remedies overlap with the merits of their underlying claim, those disputes must be decided by a jury rather than a judge.

This ruling is significant because it recognizes that in cases where the same facts are central to both whether an inmate followed proper grievance procedures and whether their rights were violated, those factual questions should be decided together by a jury. The Court interpreted the PLRA's silence on who decides exhaustion disputes as incorporating the traditional legal practice of having juries resolve factual issues when those issues are intertwined with claims that carry a constitutional right to jury trial.

By ruling this way, the Court avoided directly addressing whether Congress could have required judges to decide these factual disputes without violating the Seventh Amendment's guarantee of jury trials. Instead, the Court found that the PLRA itself, properly interpreted, preserves the jury's traditional role in resolving factual disputes central to the merits of a case.

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Here’s the twist in the law: if you never joined the conversation when a federal agency made its decision, you can’t show up later in court to complain. In this case, the Nuclear Regulatory Commission approved a plan to store spent nuclear fuel in West Texas. The state of Texas and a landowner group weren’t in the room when that license was granted, so the Supreme Court said they have no right to challenge it now. By reversing the lower court, the Justices kept the license in place but left a big question open—did the agency even have the power to issue that permit in the first place? Stay with us—there’s more coming up that dives into why this door was left ajar.

Summary of the Case

In 2016 Interim Storage Partners (ISP) applied to the Nuclear Regulatory Commission (NRC) for a 40-year license to build and operate an off-site spent nuclear-fuel storage facility in Andrews County, Texas. During the ensuing administrative proceeding the NRC undertook (1) a full safety review, (2) a draft and final environmental impact statement under the National Environmental Policy Act, and (3) a hearing on license "intervention." The State of Texas and a nearby landowner, Fasken Land and Minerals, submitted extensive comments on the draft environmental impact statement and repeatedly sought—and were denied—party status in the NRC hearing. In September 2021 the NRC granted ISP's license. Texas and Fasken then sued in the Fifth Circuit, claiming the agency lacked statutory authority to license private, off-site storage. The Fifth Circuit held Texas and Fasken could challenge the order as "parties aggrieved" and invalidated the license. The NRC and ISP sought review from the Supreme Court.

Opinion of the Court

Justice Kavanaugh, writing for a 6-justice majority, held that under the relevant laws, only a license applicant or someone who has successfully intervened and become "a party" to the NRC's licensing proceeding may obtain judicial review of the final order. Texas never applied for the license, and Fasken's petition to intervene was denied and that denial upheld by the D.C. Circuit. Merely commenting on an environmental impact statement or unsuccessfully seeking intervention does not suffice to become a "party" entitled to sue. Nor may Fasken relitigate its challenge to the intervention ruling—the D.C. Circuit's decision is final. The Fifth Circuit's theory that courts can review clearly unauthorized agency actions likewise fails where a statutory review scheme provides an adequate alternative. Accordingly, the petitions must be dismissed for want of party status; the Court therefore does not decide whether the NRC exceeded its statutory authority.

Dissenting Opinions

Justice Gorsuch, joined by Justices Thomas and Alito, would reach the merits and hold the NRC's license unlawful. He emphasizes that the Nuclear Waste Policy Act of 1982 permits interim storage only "at the site of each civilian nuclear reactor" or at "facilities owned by the Federal Government," forbidding private, off-site storage. He argues neither the Atomic Energy Act of 1954 nor its regulations may override that express Congressional command. He further contends Texas and Fasken were parties aggrieved because they actively participated in the NRC's environmental review—statutorily required and incorporated into the license—and so qualify for judicial review.

Who Can Challenge Nuclear Waste Storage Decisions? The Legal Standing Dilemma

The legal framework for nuclear waste storage has evolved over time. The Atomic Energy Act of 1954 did not address spent-fuel storage, as it anticipated reprocessing rather than storage. Congress first tackled storage in the Nuclear Waste Policy Act of 1982, which directs that interim storage occur only at reactors or on federal land and states that nothing in the Act should be construed to encourage or authorize private off-site storage.

NRC's regulations from 1980 predated this Act and contemplated "away-from-reactor" facilities, but regulations cannot override clear statutory directives. The various licensing provisions in existing law authorize specific uses—research, industrial, medical—not long-term passive storage. General provisions in older laws must be read in context and cannot override a later, more specific statute.

The case also highlights an important distinction in who can challenge agency decisions. The standard of being a "party aggrieved" differs from simply being a "person aggrieved," as it requires formal party status in the agency proceeding—whether by intervention or otherwise. Courts can review clearly unauthorized agency actions only in narrow circumstances, and this exception is unavailable when the law already provides adequate judicial review procedures.

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A little-known detail about how one law can push another out of the way is the subject of this case. The Supreme Court looked at two rules for paying special combat benefits to veterans. One law, the Combat-Related Special Compensation statute, says the Secretary of Defense gets to decide who qualifies and how much they receive. An older law, called the Barring Act, set up its own claim process and a six-year deadline.

The justices, speaking through Justice Thomas in a unanimous opinion, said the CRSC rule stands on its own. Because it’s a separate law, it replaces the Barring Act’s steps and time limit. In plain terms, veterans seeking these extra payments will follow the newer CRSC path and won’t be blocked by the old six-year window.

Summary of the Case

Petitioner Simon Soto, a Marine Corps veteran medically retired in 2006 with a 100 percent VA disability rating for post-traumatic stress disorder, applied in 2016 for "combat-related special compensation" (CRSC). Although the Navy approved his CRSC status, it limited retroactive payments to six years, citing the six-year statute of limitations in the "Barring Act." Soto filed a nationwide class-action suit arguing that the CRSC law itself provides authority to settle claims, thereby displacing the Barring Act's default procedures and time limits. The district court ruled in favor of Soto's class, but the Federal Circuit reversed. The Supreme Court then agreed to hear the case to resolve whether the CRSC law displaces the Barring Act.

Opinion of the Court

Justice Thomas, writing for a unanimous Court, affirmed that the CRSC law provides an independent settlement mechanism and thus displaces the Barring Act. The Court defined "settlement" of Government claims as involving two key powers: determining if a claim is valid and calculating the amount owed. The Court emphasized that Congress doesn't need to use the specific word "settle" to grant settlement authority.

The CRSC law gives military department Secretaries authority to administer these benefits: it directs them to consider whether each applicant is eligible (resolving claim validity) and prescribes how to determine the monthly amount payable. Read as a whole, the CRSC law establishes a "self-contained, comprehensive compensation scheme" that authorizes the Secretary to perform both settlement functions, thereby displacing the six-year limitation period.

The Court rejected the Federal Circuit's insistence on requiring explicit settlement language or a specific limitations period. Congress can create a compensation scheme without including a time limit; the absence of such a period reflects a deliberate choice appropriate for a narrowly defined class of beneficiaries. The Court also dismissed the Government's policy concerns, finding that the statutory text and structure were sufficient to resolve the case.

How Veterans' Benefits Laws Override General Time Limits

At the heart of this case is the relationship between the Barring Act's default claims-settlement system and the special law Congress created for combat-related compensation. The Barring Act serves as a fallback—authorizing government agencies to "settle" certain military-pay claims and imposing a six-year deadline—unless "another law" provides settlement authority.

Congress doesn't need to explicitly label a statute as a "settlement" law. Instead, courts look at whether the law assigns an agency to (1) evaluate if claims are valid and (2) calculate how much is owed. The CRSC law includes both elements: it directs the Secretary to "consider" eligibility and instructs how to "determine" the monthly payment amount.

The absence of a time limit in the CRSC law is significant: it shows Congress chose not to impose deadlines for this special category of combat-disabled veterans. This structure indicates a legislative decision to completely replace the Barring Act's framework, even without using the word "settle" or specifying an alternative time limit.

The Court's analysis highlights an important principle of statutory interpretation: when Congress creates a specific, self-contained benefits system that includes both elements of settlement authority, that law governs—regardless of whether it contains traditional legal terminology or deadlines. The Soto decision reinforces that a law's effect comes from its text, context, and structure, not from specific magic words.

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When a door closes only to be cracked open again, does your first knock still count? In Parrish v. United States, the Court said it does. A man filed his notice of appeal after the official deadline but before a judge agreed to reopen the time limit. He never filed a second notice. The Fourth Circuit said that meant his case was off the table. But the Supreme Court, in an opinion by Justice Sonia Sotomayor, held that the original notice reaches forward to the moment the court reopens the clock, so no new filing is needed. Chief Justice Roberts and four others agreed, while Justice Neil Gorsuch disagreed in dissent. This subtle shift in timing rules shows how a small wrinkle in court procedures can make all the difference.

Supreme Court Rules in Favor of Inmate's Appeal Rights

Donte Parrish, a federal inmate, spent 23 months in segregated confinement based on suspicions of involvement in another prisoner's death. After administrative hearings cleared him of misconduct, Parrish sued the United States under the Federal Tort Claims Act for wrongful disciplinary confinement. The District Court dismissed portions of his suit on March 23, 2020. Parrish, by then transferred to state custody, did not receive that judgment until June 25, 2020, and filed a notice of appeal immediately upon receipt—well after the standard 60-day deadline. The Fourth Circuit recharacterized his late filing as a motion to reopen the appeal window, which the District Court granted for 14 days. However, Parrish did not file a new notice during this reopened period. The Fourth Circuit held it lacked jurisdiction and dismissed his appeal.

Opinion of the Court

Justice Sotomayor, joined by Chief Justice Roberts and Justices Alito, Kagan, Kavanaugh, and Barrett, reversed the Fourth Circuit's decision. The Court held that a notice of appeal filed after the original window but before a reopening order is not "late" with respect to the reopened period but merely "premature." Under long-standing legal precedent dating back to the 1800s, a premature but adequate notice "relates forward" to the date the court makes the appeal possible. The Court observed that the Federal Rules of Appellate Procedure codify this principle and that nothing in the rules or their purpose of ensuring "just, speedy, and inexpensive determination" suggests otherwise. Accordingly, Parrish's single filing was sufficient to establish jurisdiction for his appeal.

Separate Opinions

Justice Jackson, joined by Justice Thomas, concurred only in the judgment. They agreed that Parrish's appeal should proceed but based their reasoning on different grounds. In their view, Parrish's original submission functioned simultaneously as a reopening motion and as the proposed notice of appeal. Once the District Court granted reopening, that filing should simply have been docketed as a timely notice, eliminating the need for any second filing.

Dissenting Opinions

Justice Gorsuch dissented, arguing that the Supreme Court should not have decided the case at all. He would have dismissed the petition, noting that the Advisory Committee on Appellate Rules has already begun studying potential amendments to the relevant rule. In his view, resolving this question through the rulemaking process—rather than judicial decision—would better respect the separation of powers and avoid interfering with the Committee's work.

When Early Appeal Notices Can Still Be Valid

At the heart of this case is whether an appeal notice filed too early can automatically become valid when a court reopens the appeal window. The Court ruled that when someone files an appeal notice before a court officially reopens the appeal period, that early filing isn't invalid—it simply "ripens" once the court grants the extension. This builds on a well-established legal tradition that premature notices can "relate forward" to the moment they become proper, as long as no party is harmed by this approach. The Court found that federal rules support this principle and that requiring a duplicate filing would create unnecessary procedural hurdles, particularly for those without legal representation. This ruling ensures that technical timing issues won't prevent people from having their appeals heard, especially when delays in receiving court decisions are beyond their control.

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At the center of a subtle change in disability law, the Supreme Court has said that students claiming their schools discriminated against them don’t have to prove that officials acted in “bad faith or gross misjudgment.” Instead, those students use the same straightforward rules that apply to other cases of disability discrimination.

This ruling overturns a higher bar set by the Eighth Circuit, which had made it tougher for students to bring their claims forward. Now the Supreme Court sent the case back to that court to be handled under the usual standards.

With this decision, families will face a clearer path when they say their children were denied equal access in the classroom. Stay tuned—we’ll break down what this means for schools and for kids across the country.

Summary of the Case

A. J. T. is a teenage student with a severe form of epilepsy whose seizures preclude her from attending school before noon but leave her able to learn from noon to 6 p.m. After moving to Osseo Area Schools (Dist. No. 279), her parents twice sought to include evening instruction in her IEP; the district denied those requests, cutting her instructional day to 4.25 hours versus 6.5 for nondisabled peers. They prevailed on an IDEA administrative complaint and in federal court, securing compensatory education and after-hours instruction. They then sued under Title II of the ADA and § 504 of the Rehabilitation Act. The Eighth Circuit affirmed summary judgment for the district on the ground that educational discrimination claims require a heightened showing of "bad faith or gross misjudgment" (Monahan v. Nebraska), which A. J. T. had not made. The Supreme Court granted certiorari to resolve the circuit split over whether ADA/§ 504 claims involving public-school services must satisfy that elevated standard.

Opinion of the Court

Chief Justice Roberts, writing for a unanimous Court, held that Title II and § 504 claimants relating to educational services are subject to the same requirements applied elsewhere under those statutes—no showing of intent to discriminate is required to obtain injunctive relief, and intentional discrimination (often shown by "deliberate indifference") is required only for compensatory damages. The Court observed that both statutes prohibit discrimination "by reason of" disability and confer remedies on "any person." It rejected the Eighth Circuit's Monahan-derived "bad faith or gross misjudgment" rule as incompatible with IDEA's non-exclusivity provision, and vacated and remanded the judgment.

Separate Opinions

Justice Thomas (joined by Justice Kavanaugh) concurred in full but stated that, in a future case properly presented, he would revisit whether ADA/§ 504 should uniformly require intent to discriminate—contending that "discrimination" necessarily implies intent and that Title II's prescriptions on States implicate Spending- and Fourteenth-Amendment limits.

Justice Sotomayor (joined by Justice Jackson) emphasized that the statutes' text and legislative history refute any improper-purpose gloss, underscoring that discrimination "most often" stems from "benign neglect" and that passive-voice drafting and affirmative-accommodation duties confirm no animus requirement.

How Disability Discrimination Standards Apply in Education Settings

The relationship between different disability laws is crucial to understanding this case. The Americans with Disabilities Act (ADA) and the Rehabilitation Act broadly prohibit discrimination based on disability and allow for both injunctive relief and monetary damages. Meanwhile, the Individuals with Disabilities Education Act (IDEA) specifically ensures appropriate education through individualized programs.

After a previous Supreme Court case limited disability rights, Congress clarified that IDEA procedures don't restrict rights available under the ADA or Rehabilitation Act. The Eighth Circuit's requirement for showing "bad faith or gross misjudgment" in education cases improperly narrowed the protections that should be available under disability discrimination laws.

The Court's ruling confirms that the standards for proving discrimination should be consistent across different contexts - whether in schools, workplaces, or public services. For injunctive relief (like ordering a school to provide evening instruction), no proof of discriminatory intent is needed. Only when seeking monetary damages must a plaintiff show intentional discrimination, typically through evidence of "deliberate indifference" to their rights.

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Every so often, the Court takes a magnifying glass to a small but powerful part of a law. In Martin v. United States, the justices looked at one section of the Federal Tort Claims Act—the rule about when someone can sue the federal government. They said the special “law enforcement” safety net only applies if an officer meant to do harm. It doesn’t wipe out other rules that protect government choices or other exceptions. They also made clear that the Supremacy Clause—often used to shield federal actions—can’t be used here to block claims. The case goes back to the Eleventh Circuit to sort out whether government decisions or mistakes can still be challenged under state law.

Summary of the Case

On October 18, 2017, FBI agents made a serious mistake. Intending to execute warrants at 3741 Landau Lane, they instead raided 3756 Denville Trace in suburban Atlanta. The agents deployed a SWAT team, detonated a flash-bang grenade, handcuffed the occupants, and assaulted them before realizing they were at the wrong address. Curtrina Martin, Hilliard Toi Cliatt, and their child sued the United States under the Federal Tort Claims Act (FTCA), alleging both negligent and intentional wrongdoing.

The district court granted summary judgment for the Government, and the Eleventh Circuit affirmed using a unique approach. The Supreme Court then agreed to hear the case to decide two key questions: (1) whether the FTCA's "law enforcement proviso" applies beyond just intentional torts, and (2) whether the Supremacy Clause gives the Government any defense in these types of lawsuits.

Opinion of the Court

Justice Gorsuch, writing for a unanimous Court, held:

1. The law enforcement proviso in the FTCA only limits the intentional-tort exception in that same subsection, not the discretionary-function exception or any other exceptions. The proviso appears in the same sentence as the intentional-tort clause, refers only to "this subsection," and specifically addresses claims for assault, battery, false imprisonment, false arrest, abuse of process, or malicious prosecution by "investigative or law enforcement officers."

2. The Supremacy Clause does not provide the United States a defense under the FTCA. The FTCA itself is the "supreme" federal law on tort liability for federal employees, making the Government liable under state law on the same terms as private individuals. No federal statute or constitutional provision displaces Georgia tort law in this case.

The Court vacated the lower court's decision and sent the case back to the Eleventh Circuit to determine which claims survive without reference to the law enforcement proviso, and for remaining claims, whether Georgia law would impose liability on a private person "under like circumstances."

Separate Opinions

Justice Sotomayor (joined by Justice Jackson) filed a concurrence emphasizing that the Eleventh Circuit must apply a two-step test when reevaluating the discretionary-function exception. First, ask whether the acts involve "judgment or choice" not limited by specific federal directives; second, determine whether the judgment involved "public policy" considerations that Congress intended to shield. She highlighted the ambiguity in lower courts over whether careless conduct or constitutional violations fall outside the exception and urged the court to consider the FTCA's legislative history—especially its enactment in response to "wrong-house" raids—to ensure victims of law enforcement misconduct have proper remedies.

Understanding When the Government Can Be Sued for Law Enforcement Mistakes

The Federal Tort Claims Act (FTCA) allows people to sue the federal government for wrongdoing by its employees, but with important limitations. The Act contains several exceptions that protect the government from liability in certain situations.

At issue in this case was how two of these exceptions interact. The "intentional-tort exception" normally prevents lawsuits against the government for intentional wrongdoing like assault or false imprisonment. However, a special provision (the "law enforcement proviso") creates an exception to this exception, allowing people to sue when law enforcement officers commit these specific acts.

Separately, the "discretionary-function exception" protects the government from liability when employees exercise judgment in their official duties.

The Court clarified that the law enforcement proviso only modifies the intentional-tort exception, not the discretionary-function exception. This means that while victims can sue for intentional misconduct by law enforcement officers, the government might still be protected if the actions involved discretionary judgment.

The Court also rejected the government's argument that the Supremacy Clause provides additional protection beyond what's specifically listed in the FTCA. Instead, the government is subject to the same liability standards as private individuals under state law, with only limited defenses specifically provided in the law.

This framework preserves both the right of victims to sue individual officers and their right to recover damages from the United States under state law standards that Congress chose to adopt in the FTCA.

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This case shines a light on a small but important twist in the rules for people challenging their convictions in federal court. The Supreme Court said that as soon as a judge has made a final decision on a first petition, any new petition on the same issue counts as a “second or successive” filing.

That means a second petition faces extra hurdles, even if the first one is still on appeal. The Court made clear you can’t sidestep these gatekeeping rules just because your first appeal hasn’t wrapped up.

Summary of the Case

Danny Rivers was convicted in a Texas state court of continuous sexual abuse of a child, indecency with a child, and possession of child pornography. After unsuccessful direct review and state habeas proceedings, Rivers filed his first federal habeas corpus petition in August 2017, raising claims of prosecutorial misconduct, ineffective assistance of counsel, and other constitutional violations. The District Court denied relief in September 2018. On appeal, the Fifth Circuit granted a certificate of appealability solely on his ineffective-assistance claim.

While that appeal remained pending, Rivers discovered exculpatory material in his trial counsel's file and moved in the Fifth Circuit to supplement the record or remand for consideration of the new evidence. When that effort failed, Rivers filed a second habeas petition in the District Court based on the newly uncovered report. The District Court deemed this second-in-time petition a "second or successive application" for habeas relief and transferred it to the Fifth Circuit for authorization. Rivers challenged that transfer, arguing that because his first petition was still on appeal, the new filing should be treated as an amendment, not a successive application. The Fifth Circuit affirmed, and the Supreme Court granted certiorari to resolve a split over when the "second or successive" rule applies.

Opinion of the Court

Justice Jackson, writing for a unanimous Court, held that once a district court enters final judgment on an initial federal habeas petition, any "second-in-time" filing asserting new or previously unlitigated claims qualifies as a "second or successive" application, regardless of whether the first petition remains under appellate review. The Court relied on its precedents establishing that:

• An amended petition filed before final judgment is not "second or successive" because the original proceeding has not concluded.
• A motion filed after judgment that attacks the merits of a prior resolution or adds new grounds for relief is treated as a successive petition.

Rivers's contention that the pendency of his first-petition appeal insulated his second filing was rejected. The Court explained that the gatekeeping provisions were designed to conserve judicial resources, prevent piecemeal litigation, and ensure finality of state-court judgments, goals best served by drawing the successive-petition line at entry of final judgment. Historical practices before the law's enactment yielded no clear contrary rule. Accordingly, the Fifth Circuit correctly classified and transferred Rivers's second petition.

When Habeas Petitions Become "Second or Successive": The Final Judgment Rule

The law establishes a specific meaning for "second or successive" habeas applications, distinct from mere chronological order. Under the law, relitigation of claims already denied is barred. A new claim is only allowed if it relies on a new, retroactive constitutional rule or alleges previously undiscoverable facts showing innocence. Before a district court may consider a successive petition, the petitioner must obtain approval from the court of appeals showing that one of these exceptions is met.

Critically, the distinction between first and successive applications hinges on finality of the initial proceeding. Motions filed before entry of judgment—such as amended petitions—are part of the original habeas action and don't trigger the restrictions. Motions to alter or amend judgment are likewise viewed as continuations of the initial proceeding because they "suspend finality" and merge into a single judgment. By contrast, any submission made after final judgment that seeks new substantive relief operates as a discrete application subject to strict limitations.

This interpretation balances the twin aims of allowing meaningful collateral review while safeguarding finality and judicial economy, preventing indefinite filings during appeal, and discouraging piecemeal litigation.

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At the heart of this decision is when the Tax Court can step in. Under federal law, the Tax Court can only review an IRS determination about whether it may seize assets to cover unpaid taxes — a process called a levy. In Commissioner v. Zuch, the IRS stopped its levy because the taxpayer’s debt was wiped out by earlier overpayments. The Supreme Court held there was no longer any “determination” for the Tax Court to review once the levy lost its basis.

That ruling reverses a Third Circuit decision that had sent the case back to the Tax Court. Now the dispute returns to the IRS without that extra layer of review. Stay with us to find out what this means for people who thought they still had a chance to challenge the IRS in Tax Court.

Summary of the Case

In 2012, Jennifer Zuch and her then-husband Patrick Gennardo each filed late tax returns for 2010. Gennardo submitted an offer-in-compromise to settle his tax debt, which prompted the IRS to apply $50,000 in estimated tax payments to his account. Later, Zuch amended her return to report additional income that generated $28,000 in tax liability. She claimed that the $50,000 should have been credited to her account instead, which would have entitled her to a $22,000 refund.

The IRS disagreed with Zuch's position and issued a levy to collect the unpaid taxes. Zuch requested a collection due process hearing, where the appeals officer rejected her argument about how the payments should be allocated and determined the levy could proceed. Zuch then appealed this decision to the Tax Court.

During the years-long legal proceedings that followed, Zuch overpaid her taxes in subsequent years. Rather than refunding these overpayments, the IRS repeatedly applied them against her 2010 tax liability. Once these offsets completely eliminated her 2010 balance, the IRS moved to dismiss the case as moot, arguing there was no longer any basis for a levy. The Tax Court agreed and dismissed the case for lack of jurisdiction. The Third Circuit reversed this decision, but the Supreme Court ultimately granted review to resolve disagreements among circuit courts.

Supreme Court Limits Tax Court's Authority in Levy Cases

In an 8-1 decision authored by Justice Barrett, the Supreme Court held that the Tax Court's jurisdiction in these cases is strictly limited to reviewing whether a levy may proceed. The Court explained that once Zuch's tax liability reached zero and there was no longer any levy to enforce, the Tax Court lost its jurisdiction over the case.

The majority emphasized that Congress established a default rule requiring taxpayers to pay their taxes first and then sue for a refund later. The special collection due process hearing provision is narrowly focused on issues related to proposed levies. The Court noted that the law doesn't authorize the Tax Court to award refunds or issue declaratory judgments beyond stopping a levy.

Because Zuch's liability had been paid in full through the IRS's application of her later overpayments, no levy remained at issue. The Court concluded that the Tax Court correctly dismissed the case, and that Zuch's proper remedy would be to file a separate refund lawsuit in a different court.

Justice Gorsuch was the lone dissenter. He argued that the Tax Court should have broader authority to review all aspects of the appeals officer's determination, including whether Zuch had any underlying tax liability at all. He warned that the majority's interpretation allows the IRS to escape judicial review simply by abandoning levies after receiving unfavorable determinations.

How Tax Collection Due Process Works Under Federal Law

The Supreme Court's decision clarifies the limited role Congress created for collection due process hearings. The law provides taxpayers with one hearing before the IRS can levy (seize) their property to satisfy unpaid taxes. These hearings are specifically focused on issues related to the proposed levy or, in certain cases, the existence or amount of the underlying tax if the taxpayer hasn't had a previous opportunity to dispute it.

Appeals officers must consider specific factors during these hearings—including whether the IRS followed proper procedures, any issues raised by the taxpayer, and whether the collection action is unnecessarily intrusive. After considering these factors, the officer makes a single determination: whether the levy may proceed.

The Tax Court can review this determination, but its power is limited to stopping the levy. It cannot transform these proceedings into refund cases or declaratory judgment actions. For taxpayers who want to dispute their tax liability outside the context of an ongoing levy, the traditional path remains: pay the tax first, then file a refund lawsuit.

This structure ensures that collection due process hearings remain focused on their intended purpose—providing taxpayers with procedural protections before the IRS seizes their property—rather than becoming an alternative route to challenge tax assessments more broadly.

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BLOM Bank SAL v. Honickman, Docket No. 23-1259

When the Supreme Court steps in to sort out a tight corner of court rules, it reminds us how every word counts. In Blom Bank v. Honickman, a bank asked to reopen a closed case so it could tweak its complaint. But there’s a rule that says you can only reopen a case for really rare, compelling reasons; so rare that they call them “extraordinary circumstances.”

The bank argued it should get a break because courts usually let you fix mistakes in your papers. The Second Circuit tried to balance that friendly approach with the strict reopening rule. The high court said no. Justice Thomas, writing for all nine justices, made clear you have to clear the high bar of "extraordinary circumstances" before you even think about making changes. Since the bank couldn’t show that kind of reason, its request stayed shut.

Summary of the Case

BLOM Bank SAL v. Honickman arose after victims of Hamas terrorist attacks (2001–2003) sued BLOM Bank under the Anti-Terrorism Act, alleging the bank "aided and abetted" Hamas by providing financial services to allegedly affiliated customers. The District Court dismissed the complaint with prejudice for failure to plead the required "general awareness" element of aiding-and-abetting liability and denied leave to amend when plaintiffs declined opportunities to replead. The Second Circuit affirmed the dismissal but granted relief to reopen and amend by "balancing" finality concerns against liberal amendment policy. The Supreme Court granted review to decide whether the "extraordinary circumstances" standard yields to more lenient amendment rules when a movant seeks to amend its complaint after final judgment.

Opinion of the Court

Justice Thomas, writing for an eight-Justice majority, held that relief to reopen a case remains governed by the "extraordinary circumstances" standard even when a party seeks to reopen for amendment. The Court emphasized that this relief provision is a narrow "catchall" only for grounds not covered by other specific provisions, and that a broad reading would undermine time limitations built into the rules. It rejected the Second Circuit's approach of "balancing" different procedural rules, explaining that the liberal amendment standard applies only to pre-trial amendments and cannot dilute the stringency of reopening requirements once judgment is final. The Court reversed the Second Circuit and reaffirmed that plaintiffs must demonstrate "extraordinary circumstances" before being allowed to reopen a case for repleading.

Separate Opinions

Justice Jackson concurred in part and in the judgment, joining the majority except for one section. She agreed that the "extraordinary circumstances" standard governs motions to reopen but cautioned against reading precedent to bar reopening whenever a plaintiff previously declined to amend. Jackson emphasized that exercising a right to appeal does not automatically disqualify a movant from seeking relief to reopen and stressed that "due diligence" must be assessed in context.

When Final Means Final: The High Bar for Reopening Closed Cases

The Court's ruling reinforces that reopening a closed case is designed to preserve finality by permitting relief only in "extraordinary circumstances"—a principle established in earlier Supreme Court cases. This strict standard cannot be used to evade the one-year limit on relief for mistake, new evidence, or fraud. The Court clarified that the instruction to "freely give leave" to amend applies to pre-judgment amendments, not to cases closed by final judgment. By requiring movants to satisfy the extraordinary circumstances test before seeking amendment, the Court maintained the integrity of the Federal Rules—ensuring that a party's desire to amend does not weaken the high standard for reopening cases or render other procedural safeguards meaningless. This decision provides important guidance on the balance between finality in litigation and opportunities to correct pleadings.