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In the case of Corner Post, Inc. versus the Board of Governors of the Federal Reserve System, the Court clarified that the clock for filing a claim doesn’t start ticking until a person or business is actually harmed by a final decision made by an agency.

This ruling is particularly interesting because it allowed Corner Post to challenge a regulation from the Federal Reserve Board that was issued back in 2011, even though they filed their complaint more than six years later. Why? Because Corner Post didn’t even exist as a company until 2018. So, the Court decided that they couldn’t have been harmed by a regulation that came out before they were even in business.

Justice Amy Coney Barrett wrote the majority opinion, and she was joined by several other justices, including John Roberts and Clarence Thomas. However, there was a dissenting opinion from Justice Ketanji Brown Jackson, supported by Justices Sonia Sotomayor and Elena Kagan.

This case highlights the importance of understanding when a legal claim can be made, especially for new businesses navigating regulations that may have been established long before they came into existence.

Summary of the Case

The case of Corner Post, Inc. v. Board of Governors of the Federal Reserve System arose from a challenge by Corner Post, a North Dakota truck stop and convenience store, against the Federal Reserve Board's Regulation II, which set interchange fees for debit card transactions. Corner Post argued that the regulation allowed fees exceeding what was permitted by the Durbin Amendment to the Dodd-Frank Act. The case was brought under the Administrative Procedure Act (APA), but the lower courts dismissed it as time-barred under the six-year statute of limitations outlined in 28 U.S.C. §2401(a). The Eighth Circuit affirmed this dismissal, leading Corner Post to seek review from the Supreme Court to resolve a circuit split regarding when an APA claim accrues.

Opinion of the Court

The Supreme Court, in a decision authored by Justice Barrett, reversed the Eighth Circuit's ruling. The Court held that an APA claim does not accrue until the plaintiff suffers an injury from final agency action. The Court interpreted §2401(a) to mean that the statute of limitations begins when the right of action first accrues, which occurs when the plaintiff has a complete and present cause of action—specifically, when they are injured by the agency's action. The Court emphasized that the traditional rule for limitations periods is that they commence when the plaintiff can file suit and obtain relief, not when the agency action is finalized. The Court's ruling underscored the importance of allowing parties injured by agency actions to seek judicial review, thereby reinforcing the APA's presumption of access to the courts.

Separate Opinions

Justice Kavanaugh filed a concurring opinion, agreeing with the Court's conclusion that an APA claim accrues upon injury from the agency's action. He emphasized that Corner Post's ability to obtain relief hinges on the APA's authorization for vacatur of agency rules, which is crucial for unregulated plaintiffs adversely affected by agency regulations.

Dissenting Opinions

Justice Jackson, joined by Justices Sotomayor and Kagan, dissented. The dissent argued that the majority's ruling undermines the established understanding that the limitations period for facial challenges to agency regulations begins when the regulation is published. Jackson contended that the majority's interpretation invites gamesmanship by allowing new entities to challenge long-standing regulations, effectively eliminating any meaningful statute of limitations for such claims. The dissent expressed concern that this ruling destabilizes the regulatory framework and creates uncertainty for both agencies and businesses.

Statute of Limitations

The case highlights the nuanced interpretation of the accrual of claims under the APA and the implications of the statute of limitations in administrative law. The majority's ruling reflects a plaintiff-centric approach, emphasizing that a claim accrues only when the plaintiff suffers an injury, which aligns with the traditional understanding of when a cause of action becomes actionable. This contrasts with the dissent's view that the limitations period should start at the time of final agency action, a perspective supported by historical practices in administrative law. The decision underscores the balance between ensuring timely challenges to agency actions and maintaining stability in regulatory frameworks, illustrating the complexities inherent in statutory interpretation and the evolving landscape of administrative law.

The Supreme Court dives into the nuances of legal standing in Murthy v Missouri. The justices looked at whether certain plaintiffs had the right to ask for an injunction against government officials. The Court found that neither the individuals nor the state could prove they had been harmed in a way that was directly linked to the actions of the government.

This means that the plaintiffs did not show a clear risk of future injury that could be fixed by the court's intervention. The ruling reversed a lower court's decision that had initially granted a preliminary injunction. Justice Amy Coney Barrett wrote the majority opinion, which was supported by several other justices, including John Roberts and Sonia Sotomayor.

On the other side, Justice Samuel Alito dissented, joined by Justices Clarence Thomas and Neil Gorsuch. This case highlights how important it is for plaintiffs to clearly demonstrate their standing in court, as the justices emphasized that without a direct connection to the alleged harm, the case simply cannot move forward.

Summary of the Case

The case of Murthy v. Missouri arose from a lawsuit filed by two states and five individual social media users against various federal officials and agencies. The plaintiffs alleged that these officials pressured social media platforms to censor their speech regarding COVID-19 and election-related misinformation, thereby violating their First Amendment rights. The plaintiffs sought a preliminary injunction to prevent the government from coercing or encouraging platforms to suppress protected speech. The District Court initially granted the injunction, but the Fifth Circuit Court of Appeals affirmed in part and reversed in part, leading to the Supreme Court's review.

Opinion of the Court

The Supreme Court, in a decision delivered by Justice Barrett, reversed the Fifth Circuit's ruling, concluding that neither the individual nor state plaintiffs had established standing to seek an injunction against the government defendants. The Court emphasized that Article III's "case or controversy" requirement necessitates that a plaintiff demonstrate a concrete, particularized injury that is traceable to the defendant's actions and redressable by a favorable ruling. The Court found that the plaintiffs' claims were too speculative, as they did not seek to enjoin the platforms directly but rather the government's influence over them. The Court noted that the plaintiffs failed to show a substantial risk of future injury that could be traced to the government defendants, particularly given the platforms' independent content moderation policies. The Court ultimately held that the plaintiffs did not meet the burden of proof required for standing.

Separate Opinions

Justice Alito, joined by Justices Thomas and Gorsuch, dissented from the majority opinion. Alito argued that the evidence presented indicated a significant campaign of coercion by federal officials against social media platforms, which resulted in the suppression of the plaintiffs' speech. He contended that the plaintiffs, particularly Jill Hines, had established standing due to the direct and traceable nature of their injuries stemming from government actions. Alito believed that the majority's decision failed to address the serious implications for free speech rights.

Dissenting Opinions

Justice Alito's dissent highlighted the coercive nature of the government's interactions with social media platforms, arguing that the officials' actions constituted a violation of the First Amendment. He asserted that the plaintiffs had shown a likelihood of success on the merits of their claims and that the majority's ruling set a dangerous precedent by allowing government officials to exert pressure on private entities to suppress speech. Alito emphasized the importance of protecting dissenting views, especially in the context of public health and safety.

Direct Causal Link in Free Speech

The legal nuance in this case revolves around the interpretation of standing under Article III of the Constitution, particularly in cases involving alleged First Amendment violations. The Court underscored the necessity for plaintiffs to demonstrate a direct causal link between their injuries and the actions of the government defendants. The majority opinion emphasized that standing cannot be established through speculative claims about future harm resulting from third-party actions. This case illustrates the complexities of balancing government interests in regulating misinformation with the constitutional protections afforded to free speech. The dissenting opinion, however, argued for a broader interpretation of standing that recognizes the potential for government overreach in influencing private platforms' content moderation practices. This divergence reflects ongoing debates about the role of government in regulating speech in the digital age and the implications for First Amendment rights.

The Supreme Court published their opinion on Sheetz v. County of El Dorado, California. In this decision, the Court clarified how the Takings Clause applies to land-use permits. They determined that there is no difference between legislative and administrative conditions when it comes to these permits.

The Court specifically looked at a traffic impact fee that was required for a building permit. They decided that this fee must be carefully examined to ensure it has a clear connection to the impact of the development and that it is roughly proportional to that impact. This means that if a fee is imposed, it should directly relate to the effects the new building will have on traffic.

The ruling overturned a previous decision made by the California Court of Appeal and sent the case back for further review. Justice Amy Coney Barrett wrote the majority opinion, and she was joined by several other justices, including John Roberts and Sonia Sotomayor.

This case is important because it sets a standard for how local governments can impose fees on developers, ensuring that these fees are fair and justified based on the actual impact of their projects.

Summary of the Case

The case of Sheetz v. County of El Dorado arose when George Sheetz sought a residential building permit from El Dorado County, California. As a condition for the permit, the County required Sheetz to pay a traffic impact fee of $23,420, which was part of a broader legislative framework aimed at addressing public service demands due to new developments. Sheetz contested the fee, arguing that it constituted an unlawful "exaction" under the Takings Clause of the Fifth Amendment, as it was not based on an individualized assessment of the traffic impacts attributable to his specific project. The lower courts ruled against Sheetz, asserting that the Nollan and Dolan precedents, which require a connection between permit conditions and the impacts of a specific development, did not apply to fees imposed by legislative action.

Opinion of the Court

The Supreme Court, in a unanimous opinion delivered by Justice Barrett, held that the Takings Clause does not differentiate between legislative and administrative conditions on land-use permits. The Court emphasized that when the government imposes conditions on property use, it must adhere to the principles established in Nollan v. California Coastal Commission and Dolan v. City of Tigard, which require an "essential nexus" and "rough proportionality" between the condition imposed and the impact of the proposed development. The Court found that the California Court of Appeal erred in exempting legislative actions from this scrutiny, as the Constitution does not provide a basis for treating legislative takings differently from administrative ones. The Court vacated the lower court's decision and remanded the case for further proceedings consistent with its opinion.

Separate Opinions

Justice Sotomayor, joined by Justice Jackson, filed a concurring opinion emphasizing that the application of the Nollan/Dolan scrutiny hinges on whether the permit condition would constitute a compensable taking if imposed outside the permitting context. Justice Gorsuch also concurred, reinforcing that the constitutional rules apply uniformly regardless of whether the government acts through legislation or administration. He noted that the Court's decision does not address whether the Nollan/Dolan test operates differently for conditions affecting a class of properties versus a specific development.

Dissenting Opinions

There were no dissenting opinions in this case. The ruling was unanimous, with all justices agreeing on the core principles regarding the application of the Takings Clause.

Takings Clause Nuance

The law surrounding the Takings Clause is nuanced, particularly in distinguishing between legislative and administrative actions. The Court's decision clarifies that the constitutional protections against uncompensated takings apply equally to both forms of government action. The historical context of the Takings Clause indicates that it was designed to protect property owners from arbitrary government actions, regardless of whether those actions are legislative or administrative. The Court's reliance on precedents like Nollan and Dolan establishes a framework that requires a clear connection between the imposed conditions and the impacts of the development, thereby preventing potential abuses of power by government entities. This ruling underscores the importance of ensuring that property rights are uniformly protected under the Constitution, reinforcing the principle that the government cannot impose conditions that effectively amount to extortion, regardless of the method of imposition.

The Supreme Court case Lindke v. Freed centers around a public official, James Freed, and his actions on social media. The Court ruled that a public official's social media posts only count as official state actions if they have the real authority to speak for the State and are using that authority in their posts.

In this case, Freed blocked comments and deleted posts, but the Court found that he was acting in his private capacity, not as a representative of the State. This means he did not violate the First Amendment rights of Kevin Lindke, the plaintiff in this case.

The decision was issued on March 15, 2024, and was written by Justice Amy Coney Barrett. The majority of justices agreed with this opinion, which means they believe Freed's actions were not state actions under the law. The Court also sent the case back to the lower court for further proceedings based on this ruling.

This case highlights the ongoing conversation about how public officials interact with the public on social media and what that means for our rights.

Summary of the Case

The case of Lindke v. Freed arose when Kevin Lindke, a Facebook user, sued James Freed, the city manager of Port Huron, Michigan, under 42 U.S.C. section 1983, claiming that Freed violated his First Amendment rights by blocking him from commenting on Freed's Facebook posts. Lindke argued that Freed's Facebook page functioned as a public forum, and thus, Freed's actions constituted viewpoint discrimination. The District Court ruled in favor of Freed, determining that he acted in a private capacity when managing his Facebook page, and the Sixth Circuit affirmed this decision. The case was brought before the Supreme Court to clarify the standards for determining when a public official's social media activity constitutes state action under section 1983.

Opinion of the Court

The Supreme Court, in a unanimous opinion delivered by Justice Barrett, held that a public official's social media activity constitutes state action under section 1983 only if the official (1) possesses actual authority to speak on behalf of the State and (2) purports to exercise that authority in the relevant social media posts. The Court emphasized that the distinction between private conduct and state action is based on substance rather than labels. In Freed's case, the Court found that he did not act in his official capacity when blocking Lindke and deleting his comments, as Freed's Facebook page was primarily personal and did not clearly indicate that he was acting as a city official. The Court vacated the Sixth Circuit's judgment and remanded the case for further proceedings consistent with its opinion.

State-Action Doctrine

The Court's opinion highlights the complexity of distinguishing between a public official's private and official actions, particularly in the context of social media. The ruling clarifies that the state-action doctrine requires a two-pronged test: the official must have actual authority to speak on behalf of the State, and the official must purport to exercise that authority in the relevant posts. This nuanced approach recognizes that public officials retain their First Amendment rights and can engage in personal speech without it being construed as state action. The decision underscores the importance of context in social media interactions, suggesting that the appearance and function of posts must be carefully analyzed to determine their nature. The ruling also indicates that public officials must be cautious in managing their social media accounts to avoid potential liability for actions taken in a personal capacity that may inadvertently affect their official duties.

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The Court vacated the judgment of the Court of Appeals and remanded with instructions to dismiss the case as moot, after Laufer voluntarily dismissed her ADA lawsuit against Acheson Hotels following revelations of misconduct by her attorney in other cases.

Overview

The case of Acheson Hotels, LLC v. Laufer was brought before the Supreme Court to address whether Deborah Laufer had Article III standing to sue hotels for failing to provide information about accessible rooms on their websites, as mandated by the Americans with Disabilities Act (ADA) of 1990. Laufer, who systematically filed lawsuits against numerous hotels without any intention of staying at them, argued that the lack of accessibility information constituted a violation of her rights under the ADA. The case arose amidst a circuit split, with some circuits ruling that Laufer lacked standing while others found she had it. After Laufer's attorney faced sanctions for misconduct, she voluntarily dismissed her pending lawsuits, including the one against Acheson Hotels, leading to a suggestion of mootness in the Supreme Court.

Legal mootness is when a court case no longer needs a decision because the issue has already been resolved or can't be affected by the court's ruling. For example, if two people are arguing over who owns a bike and they both decide to give up the bike, the case is moot because there's no longer a problem to solve.

The issue of vacatur came up in this case too. Vacatur is when a court cancels or sets aside a previous legal judgment or decision. It’s like erasing the court's previous decision as if it never happened. This can occur if the court finds that there was a mistake or if both parties agree to drop the case.

Opinion of the Court

The Supreme Court, in a decision delivered by Justice Barrett, vacated the case as moot. The Court acknowledged its authority to address jurisdictional issues in any order and noted that while Acheson Hotels expressed concern about potential manipulation of the Court's jurisdiction, it was not convinced that Laufer's dismissal was a tactic to evade review. The Court emphasized that Laufer's case was indeed moot due to her voluntary dismissal and that the underlying circuit split on the standing issue remained unresolved. The judgment was remanded to the First Circuit with instructions to dismiss the case as moot, following the precedent established in United States v. Munsingwear, Inc. (1950).

Concurring Opinions

Justice Thomas concurred in the judgment but expressed a desire to address the standing issue directly, arguing that Laufer lacked standing to sue under the ADA. He contended that Laufer's claims did not assert a violation of her rights, as the ADA prohibits discrimination based on disability but does not create a right to information. He criticized Laufer's role as a "tester" of compliance, suggesting that her actions were more aligned with enforcing the law rather than seeking redress for personal harm.

Justice Jackson also concurred in the judgment, agreeing that the case was moot but critiqued the majority's decision to vacate the lower court's judgment. She argued that mootness and vacatur are distinct concepts and that vacatur should not automatically follow from mootness without a specific equitable justification.

Dissenting Opinions

There were no dissenting opinions in this case, but the concurring opinions highlighted differing views on the implications of the Court's decision regarding standing and the vacatur of lower court judgments.

Affected Doctrine

The legal nuance in this case revolves around the doctrine of standing, which requires a plaintiff to demonstrate a concrete injury to have the right to sue in federal court. The ADA allows individuals to sue for discrimination based on disability, but the Court emphasized that it does not create a right to information. Laufer's approach as a "tester" raised questions about whether her lawsuits were genuinely aimed at remedying personal harm or merely enforcing compliance with the law. The case also highlighted the complexities of mootness and vacatur, particularly in how the Court navigates jurisdictional issues and the implications of a party's voluntary dismissal of a case. The majority's decision to vacate the lower court's judgment reflects a longstanding practice aimed at preventing parties from benefiting from favorable judgments that are no longer live controversies, while the concurring opinions raised important considerations about the equitable application of this practice.