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

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

Summary of the Case

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

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

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

Opinion of the Court

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

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

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

Separate Opinions

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

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

Wire Fraud and the "Fraudulent Inducement" Theory Explained

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

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

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

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

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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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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.

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.