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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.

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Trump invoked the Alien Enemies Act and The Supreme Court decided to lift temporary orders that had stopped deportations. The case, Trump v. J.G.G., rules on the jurisdiction district. This ruling means that if someone wants to challenge their removal under this law, they must do so in the district where they are being held, which in this case is Texas.

The decision was made by a group of justices, including Chief Justice John Roberts and Justices Clarence Thomas, Samuel Alito, Neil Gorsuch, and Brett Kavanaugh. They all agreed on this point, while Justices Sonia Sotomayor and Ketanji Brown Jackson voiced their disagreement, joined by Justices Elena Kagan and Amy Coney Barrett.

This case highlights the nuances of how legal challenges are handled, especially when it comes to immigration and detention. It emphasizes the importance of where and how these challenges can be made, shaping the landscape of legal rights for those affected.

Summary of the Case

The case of Trump v. J. G. G. arose from the detention and removal of Venezuelan nationals believed to be affiliated with Tren de Aragua (TdA), a group designated as a foreign terrorist organization by the U.S. State Department. President Trump invoked the Alien Enemies Act (AEA) to detain and remove these individuals. In response, five detainees and a putative class sought injunctive and declaratory relief against their removal, arguing that they were not removable under the AEA. The District Court issued temporary restraining orders (TROs) to prevent their removal, which the government sought to vacate, leading to the Supreme Court's involvement.

Opinion of the Court

The Supreme Court, in a per curiam opinion, vacated the District Court's TROs, asserting that challenges to removal under the AEA must be brought through habeas corpus proceedings. The Court emphasized that the detainees' claims implied the invalidity of their confinement, thus falling within the "core" of habeas corpus. The Court ruled that venue for such claims lies in the district of confinement, which in this case is Texas, not the District of Columbia. The Court acknowledged that while judicial review is limited under the AEA, detainees are entitled to notice and an opportunity to challenge their removal. The Court's decision was framed as a means to avoid unnecessary delays in the legal process.

Separate Opinions

Justice Kavanaugh concurred with the Court's opinion, emphasizing that the use of habeas corpus for transfer claims is consistent with historical precedent. He noted that the Court's disagreement with the dissenters was not about the availability of judicial review but rather about the appropriate venue for such review.

Dissenting Opinions

Justice Sotomayor, joined by Justices Kagan and Jackson, dissented, arguing that the Court's decision undermined due process protections for the detainees. She criticized the majority for intervening hastily and for failing to consider the potential harm to individuals being deported without adequate legal recourse. Justice Jackson also dissented, expressing concern over the Court's rushed decision-making process and the implications of using a wartime statute in a peacetime context.

Appropriate Use of Habeas Corpus

The case highlights the complexities surrounding the Alien Enemies Act, a law originally enacted in 1798 for wartime scenarios. The majority opinion underscored that the AEA precludes judicial review in many instances, yet it also allows for judicial scrutiny regarding the interpretation and constitutionality of the Act. The Court's ruling that habeas corpus is the appropriate vehicle for challenging removal under the AEA reflects a nuanced understanding of the interplay between statutory interpretation and constitutional rights. The dissenters raised critical concerns about the implications of applying a wartime statute in a peacetime context, emphasizing the need for careful judicial oversight to protect individual rights against potential government overreach.

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Who has the power to decide when government money gets paid out? In the case of Department of Education v. California, the Supreme Court looked at whether a lower court could stop the government from ending certain education grants and force it to keep paying. The lower court had put a temporary hold on the government’s decision, but the Supreme Court stepped in and said that the government was likely right: the lower court probably didn’t have the authority to order those payments in the first place.

The heart of the matter was whether the Administrative Procedure Act, a law that lets people challenge government actions, actually allows courts to order the government to pay money. The Supreme Court said that, because of rules about when you can sue the government—what’s called “sovereign immunity”—the lower court likely went too far. This means the government can move forward with its plan to end those grants, at least for now.

Summary of the Case

This case, Department of Education v. California, arose when the U.S. Department of Education abruptly terminated over 100 education-related grants awarded to public schools and universities under the Teacher Quality Partnership (TQP) and Supporting Effective Educator Development (SEED) programs. These grants, authorized by Congress, were intended to address teacher shortages and improve teacher quality, particularly in underserved areas. Eight states sued the Department, alleging that the mass termination was arbitrary, capricious, and violated the Administrative Procedure Act (APA). The District Court issued a temporary restraining order (TRO) to halt the terminations and restore the status quo while considering a preliminary injunction. The Department of Education sought emergency relief from the Supreme Court to stay the TRO, arguing that the District Court lacked jurisdiction to order the payment of money under the APA and that the proper forum for such claims was the Court of Federal Claims.

Opinion of the Court

The Supreme Court, in a per curiam opinion, granted the Department of Education’s application to stay the District Court’s TRO pending appeal. The Court reasoned that, although TROs are generally not appealable, the District Court’s order functioned as a preliminary injunction and thus was reviewable. The Court found that the government was likely to succeed in showing that the District Court lacked jurisdiction under the APA to order the payment of money, citing the APA’s limited waiver of sovereign immunity, which does not extend to claims seeking money damages or to enforce contractual obligations to pay money (see 5 U.S.C. §702; Great-West Life & Annuity Ins. Co. v. Knudson, 534 U.S. 204 (2002)). The Court also found that the government would be unlikely to recover disbursed funds if the TRO remained in effect, while the respondents (the states) would not suffer irreparable harm because they could recover any wrongfully withheld funds through other legal means. The stay will remain in effect pending the outcome of the appeal and any petition for certiorari.

Separate Opinions

The Chief Justice (John Roberts) would have denied the application for a stay, but did not write a separate opinion.

Dissenting Opinions

Justice Kagan dissented, arguing that the Court’s intervention was unwarranted and premature. She emphasized that the government did not defend the legality of the grant cancellations and that the states had shown concrete harm from the loss of funding. Kagan contended that the APA generally allows district courts to review agency actions, even when monetary relief may result, and that the majority’s reliance on Great-West was misplaced because that case did not involve the APA. She criticized the Court for acting on an emergency basis without full briefing or argument, suggesting that the dispute should have proceeded in the ordinary course.

Justice Jackson, joined by Justice Sotomayor, also dissented. She argued that the TRO was a standard, time-limited order preserving the status quo and causing no concrete harm to the government, while the grant terminations would inflict significant harm on grantees. Jackson maintained that the government’s claims of irreparable harm were speculative and that the lower courts were better positioned to resolve the merits. She further argued that the Department’s mass termination of grants was likely arbitrary and capricious under the APA, as it lacked individualized reasoning and failed to follow required procedures. Jackson criticized the majority for intervening on technical jurisdictional grounds and for potentially shifting the forum for such disputes from district courts to the Court of Federal Claims.

Sovereign Immunity

The legal nuance in this case centers on the scope of the APA’s waiver of sovereign immunity and the proper forum for challenging agency actions involving monetary relief. The APA allows for judicial review of agency actions and waives sovereign immunity for certain claims, but this waiver does not apply if another statute “forbids the relief which is sought” or if the claim seeks “money damages” (5 U.S.C. §702). The Supreme Court has distinguished between claims for specific relief (such as setting aside agency action) and claims for money damages, with the latter generally falling under the jurisdiction of the Court of Federal Claims via the Tucker Act (28 U.S.C. §1491(a)(1)). In Bowen v. Massachusetts, 487 U.S. 879 (1988), the Court held that district courts could order the release of funds wrongfully withheld by an agency, but not to enforce a contractual obligation to pay money. The majority here interpreted the District Court’s order as effectively enforcing a contractual obligation, thus exceeding the APA’s waiver and requiring the case to be heard in the Court of Federal Claims. The dissenters, however, viewed the relief as within the APA’s scope, emphasizing the need for reasoned agency decision-making and the appropriateness of district court review. This case thus highlights the complex interplay between administrative law, sovereign immunity, and the allocation of judicial authority between district courts and the Court of Federal Claims.

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In the case of Medical Marijuana, Inc. v. Horn, the Supreme Court looked at whether people can get extra damages for business or property losses, even if those losses started with a personal injury. The law in question is called RICO, which is usually used to fight organized crime, but it can also be used in civil lawsuits.

The Court decided that if someone loses money or property because of something that started as a personal injury, they can still ask for triple damages under RICO. This goes against what some lower courts had said before, which was that you couldn’t get these damages if your business or property loss was tied to a personal injury. This decision could change how some lawsuits are handled, especially when business losses are connected to personal injuries.

Summary of the Case

Douglas Horn, a long-haul truck driver, began using “Dixie X,” a cannabidiol (CBD) tincture marketed as THC-free by Medical Marijuana, Inc., to treat chronic pain. After a workplace drug test detected THC, Horn was fired and sued under the Racketeer Influenced and Corrupt Organizations Act (RICO), alleging that Medical Marijuana’s misrepresentations constituted mail and wire fraud predicates. The District Court granted summary judgment for Medical Marijuana, holding that Horn’s lost employment flowed from a personal injury (the ingestion of THC) and that §1964(c) forecloses recovery for personal injuries or for business or property losses derived from them. The Second Circuit reversed (80 F.4th 130 (2023)), holding that §1964(c) authorizes treble-damages suits for business or property losses even if they “derive from a personal injury,” and adopting a broad definition of “business” to include employment. The Supreme Court granted certiorari to resolve a split among the Circuits over whether RICO bars suit for business or property harms that result from personal injury.

Opinion of the Court

Justice Barrett, for a 5–3 majority, addressed “whether civil RICO categorically bars recovery for business or property losses that derive from a personal injury”. Relying on the ordinary meaning of “injure” (“to cause harm or damage to”), she held that §1964(c) plainly authorizes suits by any person “injured in his business or property,” implicitly excluding personal injuries but not business or property harms that stem from them. The majority rejected petitioners’ term-of-art argument that “injured” requires invasion of a “legal right” in business or property, observing that context favors the ordinary definition and that “damages” must mean monetary redress, not “harm”. It found support in civil RICO precedent to import a common-law “situs” rule into §1964(c). Antitrust precedents construing identical language in the Clayton Act (§4, 38 Stat. 731) do not govern RICO. Finally, the majority stressed that RICO’s other limits — its proximate-cause requirement and “pattern” element — mitigate any over-federalization, and it left further policy refinements to Congress.

Separate Opinions

Justice Jackson concurred, emphasizing that Congress directed in §904(a), 84 Stat. 947, that RICO “shall be liberally construed to effectuate its remedial purposes.” She argued that a broad reading of the statute’s private-action provision is especially warranted given RICO’s “remedial” design and its civil provision’s purpose of enabling private enforcement of racketeering prohibitions.

Dissenting Opinions

Justice Thomas, joined by no other Justice, would have dismissed the writ as improvidently granted. He argued that we cannot know whether Horn suffered a personal injury because the District Court and parties disagreed below. He urged resolution of that threshold issue first and contended that no party fully briefed the definition of “injured in his business or property.”

Justice Kavanaugh, joined by Chief Justice Roberts and Justice Alito, dissented on the merits. He maintained that “injured” is a term of art importing the tort-law definition—“the invasion of any legally protected interest”—and that RICO’s text, modeled on the Clayton Act, precludes personal-injury suits. Lost wages and medical costs, in his view, are merely damages flowing from a personal injury, not distinct business or property invasions.

RICO and Definition of Injury

When Congress added §1964(c) in 1970, it deliberately limited private RICO actions to persons “injured in [their] business or property,” implicitly excluding personal injuries. In American tort law, “injury” denotes the invasion of a legal right—personal, property, or business—distinct from the economic “damages” a victim sustains. By contrast, the majority reads “injured” in its ordinary sense (“harmed or damaged”), allowing recovery for business or property harm regardless of its source. This interpretation subverts RICO’s text and historic tort categories, which this Court and earlier antitrust decisions recognized when construing the identical “injured in his business or property” language. The statutory choice of the disjunctive “business or property” (not “and”), its modeling on Clayton Act §4, and the placement of “damages” as separate relief for a proved “injury” all underscore that Congress did not intend to federalize garden-variety personal-injury torts simply because they yield lost-wages or medical-expense damages.

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The Supreme Court looked at a case involving the Food and Drug Administration and a company that wanted to sell flavored e-cigarettes. The lower court had said the FDA was wrong to deny the company’s request to sell these products, calling the agency’s actions unfair and inconsistent. But the Supreme Court disagreed, saying the FDA had actually followed its own rules and guidance when it made its decision.

The justices explained that the FDA’s process for reviewing these e-cigarette products was in line with what it had told companies to expect, especially when it came to the kind of scientific evidence and comparisons it wanted to see. The Court also said that the FDA didn’t break any rules by sticking to its earlier positions. However, the Supreme Court didn’t end the case there. Instead, it sent the case back to the lower court to take another look at whether the FDA made a harmless mistake by not reviewing the company’s marketing plans. This case shows how the courts look closely at whether government agencies are following their own guidelines, and what happens if they don’t.

Summary of the Case

In FDA v. Wages and White Lion Investments, LLC (No. 23-1038), the Food and Drug Administration (FDA) denied premarket tobacco product applications (PMTAs) submitted by two e-liquid manufacturers, Wages and White Lion (dba Triton) and Vapetasia. Under the Tobacco Control Act of 2009 (TCA), any “new tobacco product”—including most flavored e-liquids sold after February 15, 2007—may not be marketed absent FDA authorization, which must be granted only if the product “would be appropriate for the protection of the public health.” 21 U.S.C. § 387j(c)(2)(A). The FDA concluded the applicants had not submitted sufficient scientific evidence—including randomized controlled trials or longitudinal cohort studies—to demonstrate benefits for adult smokers that would outweigh youth-initiation risks, nor did it review their marketing-plan commitments (Syllabus, pp. 2–3; App. 177a, 285a).

The Fifth Circuit, sitting en banc, held the FDA acted arbitrarily and capriciously by applying standards different from those announced in pre-decision guidance concerning (1) types of scientific evidence, (2) cross-flavor comparisons, (3) device types, and (4) marketing plans, and it rejected the agency’s harmless-error defense (90 F. 4th 357, 376–384). The Supreme Court granted certiorari to resolve conflicts among the circuits and to clarify whether the FDA’s denials complied with the Administrative Procedure Act (APA), 5 U.S.C. § 706(2)(A).

Opinion of the Court

Justice Alito, writing for a unanimous Court, vacated the Fifth Circuit’s judgment and remanded. The Court first declined to decide whether the FDA was required to issue notice-and-comment regulations rather than guidance. It then applied the “change-in-position” doctrine, under which an agency may change policy so long as it “provide[s] a reasoned explanation,” “display[s] awareness that it is changing position,” and considers “serious reliance interests.”

1. Scientific Evidence
   The TCA contemplates both “well-controlled investigations” and “other valid scientific evidence.” The FDA’s guidance made clear that, absent randomized trials or cohort studies, manufacturers must submit “robust” alternative evidence bridged to their specific products. The Court held the agency’s denial orders simply applied that approach: respondents offered literature reviews and surveys, but not evidence sufficiently tied to their flavored products. No unacknowledged “change” occurred.

2. Comparative Efficacy
   The TCA requires comparisons of new products to other tobacco products and the FDA’s guidance recommended comparing health risks “within the same category and … different categories as appropriate”. Its later emphasis on dessert-, candy-, and fruit-flavors over tobacco flavors naturally flowed from data showing those flavors disproportionately appeal to youth. The denial orders tracked that guidance, not a repudiation of it.

3. Device Type
   A 2020 guidance prioritized enforcement against flavored, cartridge-based products, but it also covered any products “targeted to, or whose marketing is likely to promote use by, minors”. The FDA reasonably concluded youth demand shifted from disposable cartridges to other flavored devices, justifying scrutiny of all flavored products regardless of cartridge status.

4. Harmless Error and Marketing Plans
   Although the FDA admitted it did not review marketing plans—contrary to its guidance—it did not seek plenary review of that finding. Instead, the agency asked the Court to clarify the proper harmless-error standard. Noting tension between the remand rule of SEC v. Chenery Corp. and the APA’s harmless-error directive the Court held the Fifth Circuit misread Calcutt v. FDIC by treating its sole exception to the remand rule as universal. The Court vacated and remanded for the Fifth Circuit to apply a proper blend of remand-and-harmless-error principles.

Separate Opinions

Justice Sotomayor filed a brief concurrence emphasizing that the record shows the FDA provided consistent, clear guidance on the need for rigorous product-specific evidence that benefits to adult smokers outweigh youth risks. She stressed that e-cigarette regulation under the TCA served a core public-health purpose and did not support any suggestion that the FDA “was unable or unwilling to say in clear and specific terms precisely what applicants would have to provide.”

Nuance of the Law

The Family Smoking Prevention and Tobacco Control Act of 2009 (TCA) brought tobacco products within the FDA’s ambit for the first time while preserving the FDCA’s existing premarket approval scheme for “new drugs”. A “new tobacco product” is any tobacco product not marketed in the U.S. before February 15, 2007 and the TCA mandates FDA authorization before sale. To approve a PMTA, the agency must find the product “appropriate for the protection of the public health,” weighing “risks and benefits to the population as a whole” and the likelihood of adult cessation versus youth initiation. Those findings “when appropriate” rely on “well-controlled investigations” or “other valid scientific evidence,” but the statute leaves to the FDA’s discretion what studies or data suffice.

This delegation reflects Congress’s judgment that tobacco products pose unique, shifting risks—particularly because of rapidly proliferating flavors and devices—requiring individualized review rather than blanket standards. At the same time, Congress bounded the FDA’s power by insisting on a public-health test rather than an outright ban and by providing judicial review under 5 U.S.C. § 706 via the TCA’s review provision. In turn, the APA’s arbitrary-and-capricious standard demands agency consistency or, if it changes course, “a reasoned explanation,” awareness of reliance interests, and consideration of serious reliance. Finally, the remand rule of SEC v. Chenery must be harmonized with the APA’s harmless-error directive to permit courts to remand when an agency “rested decision on an unsustainable reason,” but also to excuse harmless errors that “had no bearing” on the outcome.