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Chatrie v. United States, Docket No. 25-112

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Your phone's location history is now legally protected, and police cannot access it without convincing a judge they have good reason. Even just a couple of hours worth of data. The decision protects millions of Americans who use Google's location tracking feature without realizing how precisely it records their movements. It's a significant win for privacy rights in the digital age, though questions remain about exactly how police can use location data going forward.

How Police Used Location Data to Solve a Crime

In 2021, someone robbed a credit union in Virginia while apparently talking on a cell phone. Police didn't know who did it, but they asked Google to tell them which phones were near the crime scene at the time of the robbery.

Here's how it worked. Police drew an invisible circle around the credit union and asked Google to hand over location data for any phone inside that boundary during the robbery. Google gave them anonymized information about 19 devices. Police then narrowed the list by looking at which phones stayed in the area long enough to be suspicious. Eventually, they got Google to reveal the names of three people, including Okello Chatrie. He was arrested and charged with robbery and firearms offenses.

The lower courts allowed the evidence to be used against Chatrie, even though they had doubts about whether police had followed the rules. But Chatrie appealed all the way to the Supreme Court, arguing that accessing his location data without his knowledge violated his constitutional right to privacy.

What the Supreme Court Decided

In a 6-3 decision, the Supreme Court agreed with Chatrie. Justice Elena Kagan, writing for the majority, said that accessing someone's location history is a "search" under the Fourth Amendment, which protects Americans from unreasonable searches by police.

The Court pointed to three reasons why your location data deserves protection. First, Google Location History is incredibly precise. It pinpoints your phone's location within about 65 feet and records it roughly 720 times per day. Second, it creates a permanent record that police can examine anytime, long after events happen. Third, the data reveals deeply personal information about where you go, who you see, and what you believe in.

The Court rejected the government's main argument that Chatrie had given up his privacy rights by voluntarily turning on Location History. The majority noted that Google repeatedly pushes users to enable the feature, warns that phones may not work properly without it, and never clearly explains how detailed or legally accessible the data is. In other words, turning on a feature because your phone practically demands it is not the same as knowingly giving up your rights.

Why Some Justices Wanted to Go Further

Justice Ketanji Brown Jackson agreed the police needed a warrant, but she thought the warrant itself was unconstitutional. She pointed out that the warrant allowed police to gradually expand their search, accessing more sensitive information at each step, without having to prove to a judge that each new step was justified. Police started by looking at 19 phones and only narrowed the list because Google objected, not because the warrant required it.

Justice Neil Gorsuch also sided with Chatrie but for a different reason. Rather than focusing on privacy expectations, he argued that your location data is your property, similar to your car or your wallet. Just because you store it with Google doesn't mean you've given it away, any more than handing your keys to a valet means you no longer own your car.

What the Dissenters Said

Justice Samuel Alito, joined by Justices Clarence Thomas and Amy Coney Barrett, disagreed. Alito argued the Court should not have taken the case at all, since the evidence was already allowed in under an exception for good-faith police mistakes. He also noted that Google has since changed how it stores location data, making the ruling less practically important.

On the merits, Alito contended the majority stretched an earlier privacy decision too far. He pointed out that only two hours of data were involved here, not the weeks of data in the earlier case. He worried the ruling creates a rule with no clear limits, potentially requiring warrants for online shopping histories or search logs.

Cell Phone Location Data

The Supreme Court sent the case back to the lower court to decide whether the specific warrant police used actually met constitutional requirements. This means Chatrie's case is not over. But the bigger picture is police now need a warrant before accessing any amount of location data from tech companies, no matter how brief the time period.

The decision does not resolve every question. It focuses specifically on cell phone location information, though the reasoning could extend to other location data from apps. It also leaves open the question of whether the third-party doctrine, the old legal rule that you lose privacy rights when you share information with companies, still applies to digital data. Justice Gorsuch's approach, treating data as property rather than private information, offers a different path forward that future courts might follow.

Hunter v. United States, Docket No. 24-1063

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A man facing 300 years in prison made a deal with the government: plead guilty to one crime, drop nine others, and give up the right to appeal. But the Supreme Court just said there are limits to how far that deal can go. In a decision that affects thousands of criminal cases every year, the justices ruled that defendants cannot be forced to accept sentences that are so fundamentally unfair they shake public confidence in the courts, even if they signed away their appeal rights.

The Case: A Deal Gone Wrong

Munson Hunter III faced ten counts of bank and wire fraud. Rather than risk a 300-year sentence, he took a plea deal to admit guilt to one count, and have the rest disappear. As part of the agreement, he gave up his right to appeal, with one exception for cases where his lawyer failed him.

At sentencing, the judge ordered 51 months in prison plus three years of supervised release. One condition required Hunter to take any mental health medications his doctor prescribed. Hunter objected. Then the judge mistakenly told Hunter he could appeal anyway. The prosecutor heard this but said nothing.

Hunter appealed the medication requirement, claiming it violated his rights. The lower court rejected his appeal, saying his waiver was binding. The Supreme Court took the case to settle conflicting rulings across the country about when these waivers should actually hold up.

What Each Side Argued

Hunter's lawyers said appeal waivers should not apply when a sentence violates fundamental constitutional rights. They also argued the judge's mistake, combined with the prosecutor staying silent, changed the deal. The government disagreed completely. They said any knowing and voluntary waiver should always be enforced, no exceptions. When justices asked about extreme scenarios during oral arguments, the government refused to budge.

The Court's Decision

Justice Kagan wrote the opinion for eight of nine justices. The Court ruled the judge's mistake did not change Hunter's plea agreement. The original deal required any changes in writing and signed by everyone. The prosecutor's silence did not count as giving up the waiver either.

On the bigger question, the Court said appeal waivers cannot be enforced when doing so would be a "miscarriage of justice." This is a very high bar. The error must be obvious and so serious that it damages public trust in courts. It's also a narrow exception. Routine sentencing mistakes do not qualify.

The Court gave three examples of situations that might qualify: a sentence exceeding the legal maximum, a sentence tainted by racial bias, and a sentence handed down without basic fair procedures. The Court sent Hunter's case back to the lower court to decide whether his medication condition meets this standard.

What This Actually Means for Real People

This decision creates a safety valve for extreme cases, not a wide-open door. Most sentencing errors will not overcome a waiver. The Court deliberately left the exact boundaries fuzzy, offering only examples rather than a precise rulebook.

The justices who voted together disagreed on how broad this exception should be. Justice Gorsuch suggested it should cover unreasonable sentences and unfair conditions. Justice Kavanaugh warned against reading it too broadly, signaling that at least five justices want to keep the exception truly rare. Lower courts will now navigate this tension, likely erring on the side of caution.

Justice Thomas dissented, arguing that appeal rights are a modern invention, that defendants already give up more important rights in plea deals, and that even a high bar is easy to claim. With tens of thousands of guilty pleas entered yearly, he warned this decision could trigger waves of new litigation.

Tension in Criminal Law

This decision reflects a genuine tension in criminal law that weighs respecting the deals defendants make versus protecting the basic fairness of the justice system. The Court sided with fairness, but only in the most extreme situations. If you plead guilty and waive your appeal rights, that waiver will almost certainly hold. But if your sentence is so fundamentally broken that it threatens the integrity of the courts themselves, you may get a second chance.

Abouammo v. United States, Docket No. 25-5146

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This case reveals how the Constitution still protects one of the rights the Founders fought hardest to preserve. Ahmad Abouammo sold his employer's secrets to a Saudi official for $300,000. When the FBI showed up at his Seattle home to question him, he panicked. He went upstairs, created a fake invoice on his computer, and emailed it to an agent. The Supreme Court has ruled unanimously that the government cannot drag you across the country to stand trial for a crime you committed at home.

What Happened

Abouammo, a former Twitter employee, handed over confidential user information to a Saudi official in exchange for cash. When FBI agents came to his Seattle home to interview him, he created a fraudulent invoice and emailed it to one of the agents, hoping to cover his tracks.

The government charged him with falsifying a document to obstruct a federal investigation. But instead of trying him in Seattle, where he actually created the fake document, prosecutors brought the case in Northern California, where the FBI investigation was based. Abouammo's lawyers said that was unconstitutional. The Supreme Court agreed, unanimously.

The Two Sides of the Argument

Abouammo's defense was straightforward: he falsified a document in Seattle. That is the crime. The trial should happen where the crime happened.

The government offered two counterarguments. First, it said that because the law requires proving Abouammo intended to obstruct an investigation, the trial could be held wherever that investigation was taking place. Second, prosecutors compared document falsification to conspiracy, a crime that can be prosecuted anywhere any part of the criminal plan occurred. They pointed out that Abouammo emailed the fake invoice to an FBI agent in San Francisco, creating a connection to California.

Why the Court Sided With the Defendant

Justice Elena Kagan wrote for the entire Court, and she began with history. The Founders despised the British practice of shipping colonists across the ocean for trial. This abuse was so hated that it appears in the Declaration of Independence. The Constitution protects the right to a local trial in two separate places, showing how seriously the Founders took this principle.

The Court identified the critical fact that the crime of falsifying a document is complete the moment you create it with intent to obstruct. Nothing else needs to happen. No email needs to arrive. No investigation needs to be disrupted. The crime is finished in Seattle, where Abouammo sat at his computer.

This distinction between what someone does and what they intend matters enormously. The government wanted to use Abouammo's intent to obstruct an investigation as a reason to move the trial to California. The Court rejected this. Where a crime is prosecuted depends on where the defendant acted, not on what was happening in their mind or what they hoped would happen elsewhere. Falsifying a document happens in the same place regardless of why you are doing it.

The Court also rejected the conspiracy comparison. Conspiracy requires multiple steps and coordination. Document falsification under this law does not. You break the law the moment you create the false document, even if you never send it or show it to anyone. That makes it a complete crime on its own, not an incomplete one that can be prosecuted anywhere the effects might be felt.

The Fundamental Right to Be Tried Near Home

This decision protects something fundamental: your right to be tried near home is fundamental. The government cannot use vague intent requirements to drag defendants across the country. What matters is where you acted.

The Court left one opening. Congress can write specific rules about where certain crimes can be prosecuted if it chooses to do so. This ruling only addresses the default rule when Congress has said nothing. The practical result is a tradeoff: if the government wants a law that is easy to prove, it has to accept that trials must happen where the defendant actually committed the crime.

The framers of the Constitution were explicit to protect your right to be tried in your own community, not in some distant courthouse chosen by prosecutors for their convenience. That protection matters because trials are easier to defend when they happen close to home, where your community knows you and where witnesses live.

Oliver Vs. City of Brandon, Docket # 24-993

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Gabriel Olivier is a street preacher in Brandon, Mississippi, who was arrested in 2021 for violating a city ordinance that restricted protests and demonstrations near a public amphitheater to a designated area. He pleaded no contest and received a fine of $304, one year of probation, and a suspended ten-day jail sentence. Rather than appeal his conviction, Olivier filed a federal lawsuit seeking a declaration that the ordinance violates the First Amendment and an order barring the city from enforcing it against him in the future. He was not trying to overturn his conviction or get money from the city. The Fifth Circuit Court of Appeals ruled that his lawsuit was blocked by a legal doctrine from a 1994 Supreme Court case called Heck v. Humphrey, which said that winning his federal case would essentially mean his conviction was wrong. The Supreme Court unanimously disagreed and reversed that decision.

Arguments Made By Counsel

Olivier's attorney argued that this was a straightforward case about protecting someone from future prosecutions, not about undoing a past conviction. She pointed to a 1977 Supreme Court case called Wooley v. Maynard, where the Court allowed a previously convicted person to sue for protection against future enforcement of the very law he had been convicted under. She argued that the Heck doctrine was designed to stop prisoners from sneaking around the rules for challenging their convictions, and that concern simply does not apply here.

The federal government stepped in to support Olivier and suggested a clear rule: people who are no longer in custody should be allowed to bring forward-looking lawsuits like this one, while lawsuits that are really about attacking a past conviction should remain blocked. The city's attorney pushed back, arguing that because a ruling in Olivier's favor would imply his conviction was wrong, the lawsuit should be blocked regardless of what kind of relief he was asking for. He also pointed out that Olivier had other options available to him, like appealing his conviction or seeking a pardon.

During arguments, Justice Thomas pointed out a significant problem with the city's position: a person who had never been convicted could bring the exact same lawsuit without any issue, so why should Olivier be treated worse simply because he had been prosecuted before? Justice Kagan pressed the city's attorney on whether the Court's own prior ruling in Wooley already answered the question against him. Justices Gorsuch and Sotomayor raised concerns about what happens to people on probation and whether the city's rule could leave some people with no way to challenge an unconstitutional law at all.

Opinion of the Court

Justice Kagan wrote the opinion for a unanimous Court, holding that the Heck doctrine does not block Olivier's lawsuit because he is only asking for protection going forward. The Court walked through its reasoning in three steps. First, it said that the Wooley case from 1977 would resolve this case on its own, because that decision already established that a previously convicted person can use a federal civil rights lawsuit to seek protection from future prosecutions under the same law.

Second, the Court explained that Heck does not change that conclusion. The Heck doctrine was designed to stop prisoners from using civil rights lawsuits to effectively challenge their convictions while bypassing the proper legal process for doing so. Later cases made clear that lawsuits seeking only forward-looking relief fall outside that concern entirely, and Olivier's lawsuit fits squarely in that category.

Third, the Court addressed the city's argument that winning the case would still imply the conviction was wrong. The Court acknowledged that this was technically true, but said that broad legal language from past opinions should be read in the context of the situations those opinions were actually addressing. The Heck doctrine was meant to catch lawsuits that are really disguised attacks on past convictions, not genuine challenges to whether a law can be enforced in the future. The Court also noted that it was not deciding whether someone currently in custody could bring the same kind of forward-looking lawsuit, leaving that question for another day.

How Courts Decide Whether a Civil Rights Lawsuit Is a Disguised Attack on a Prior Conviction

The most important analytical move in this opinion is a simple hypothetical. The Court imagined a person named Laurence who has never been convicted of anything but wants to challenge the same ordinance in federal court. No one would argue that Heck blocks Laurence's lawsuit. But if Laurence wins, the result would equally imply that Olivier's conviction was based on an unconstitutional law. That means the mere fact of a prior conviction cannot be what triggers the Heck barrier, because the logical consequence of winning is the same either way.

This hypothetical exposes the core principle the Court is applying. The Heck doctrine exists to prevent civil rights lawsuits from becoming a back door for prisoners to challenge their convictions without following the proper legal process. When a lawsuit is genuinely about stopping future enforcement of a law, it is a fundamentally different kind of case than one that is really about proving a past conviction was wrong. The first looks forward and asks whether a law is constitutional. The second looks backward and asks whether something went wrong in a prior case.

The practical consequence of the Fifth Circuit's approach was deeply counterintuitive. Under that rule, the person with the most direct and proven experience of being harmed by an unconstitutional law had less access to federal court than someone who had never been prosecuted at all. The Supreme Court's decision corrects that imbalance, at least for people who are no longer serving a sentence or on probation. The question of what happens to someone who is still in custody when they bring a forward-looking challenge remains open, and the Court's careful reservation of that issue signals that the boundaries of the Heck doctrine are not yet fully settled.

Geo Group, Inc. v. Menocal, Docket No. 24-758

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In a case called GEO Group v. Menocal, the Supreme Court focused on that timing question for federal contractors who say they were just following lawful government authorization.

Justice Elena Kagan wrote for the Court that the rule from an older case, Yearsley, gives contractors a defense they can use to fight liability on the merits. But it is not a free pass that shields them from having to stay in the case at all. And that matters, because the Court said if a trial judge rejects that Yearsley protection before trial, the contractor usually cannot take an immediate appeal right then.

Instead, the Court said that kind of denial is not one of those rare “appeal-now” orders under federal law and the collateral-order doctrine. It can be reviewed after the case reaches a final judgment.

The Chief Justice and Justices Sotomayor, Gorsuch, Kavanaugh, Barrett, and Jackson joined Justice Kagan’s opinion. Justice Thomas agreed with parts of it and the final result, and Justice Alito agreed with the result.

Summary of the Case

The Supreme Court recently tackled a question that sounds simple but has major legal consequences. When a federal contractor like GEO Group claims it should be dismissed from a lawsuit because it was just following government orders, and the trial judge says no, can the contractor appeal right away? Or does it have to wait until the entire trial is finished?

The Court's answer was clear: wait until trial. Justice Kagan, writing for six justices, explained that the legal protection contractors claim, known as the Yearsley doctrine, is a defense against being found liable. It is not immunity from being sued in the first place. This distinction matters a lot when deciding whether someone can appeal immediately.

Here's what happened. GEO operated a detention facility for Immigration and Customs Enforcement in Colorado. People detained there filed a lawsuit. They claimed GEO's work policies violated federal laws against forced labor. These policies included unpaid cleaning duties and a so-called voluntary work program that paid just one cent per day. GEO argued it should be protected because ICE had authorized these policies. The trial court disagreed, finding that GEO's contract didn't actually require these specific policies. GEO tried to appeal immediately. The Tenth Circuit said it didn't have jurisdiction to hear the appeal yet. The Supreme Court agreed with that decision.

Arguments Made By Counsel

The oral arguments showed the real tension in this case. Dominic Draye, representing GEO, made an argument about fairness that got several justices thinking. He asked: Why should GEO, doing exactly the same work as ICE employees in the same facility, be unable to appeal immediately when those ICE employees could appeal right away if they claimed qualified immunity? This practical unfairness particularly resonated with Justices Alito and Kavanaugh.

Draye pointed to a long tradition in common law. He said that agents acting under valid government authority have always enjoyed immunity from being sued. He made a distinction between whether Congress has the constitutional power to authorize something and whether a specific authorization was lawful under existing statutes. Under his reading, a contractor could have immunity even if it violated a statute, as long as Congress had the constitutional power to authorize the underlying activity. This proved controversial.

Jennifer Bennett represented Menocal and the other detainees. The government also supported her position. She argued that Yearsley simply lets contractors show they acted lawfully. That's a defense on the merits, not immunity. She walked through historical cases showing that agents have never had derivative sovereign immunity. The fact that the government opposed GEO, even though it acknowledged Yearsley's importance, carried substantial weight. As Justice Kavanaugh noted, this seemed like a big hurdle for GEO to overcome. If the government itself didn't believe immediate appeals were necessary, perhaps they weren't.

Bennett also highlighted a practical problem with GEO's theory. Figuring out what the government actually authorized and directed requires digging deep into the facts. You have to compare what the contractor actually did against what the contract said, what the regulations required, what emails instructed, and what verbal directions were given. Justice Sotomayor suggested this factual complexity provided a simple answer for denying immediate appeals without having to resolve deeper immunity questions.

The most revealing moment in oral argument came when Justice Jackson posed a logical puzzle. In the original Yearsley case, the government had waived sovereign immunity because takings require compensation. She asked, wouldn't we have a very odd scenario in which the contractor would somehow be given immunity, but the government itself wouldn't? This exposed a fundamental problem with the theory that contractors get immunity derived from the government.

Opinion of the Court

Justice Kagan's majority opinion builds a clean framework for distinguishing between defenses on the merits and immunities.

The Supreme Court's decision draws an important distinction between two different ways defendants can avoid liability. A defense on the merits argues that the defendant acted lawfully and therefore shouldn't be held responsible. An immunity, by contrast, is a shield that protects someone even if they did break the law. This distinction matters because it determines whether a defendant can appeal a court's decision right away or must wait until the case is fully resolved.

The timing of appeals depends on the type of protection at stake. With immunity, waiting for a full trial defeats the whole purpose—immunity is meant to avoid trial altogether. So when a court denies immunity, that decision can be appealed immediately. With a defense on the merits, however, there's no rush. If a defendant loses at trial but had a valid defense, an appeals court can simply overturn the verdict. The defendant's rights are fully protected even after the trial concludes, so waiting for final judgment doesn't cause any harm.

The Court concluded that the legal doctrine in question operates as a defense on the merits, not as immunity. The key reasons: the doctrine only protects conduct that was actually authorized and lawful; historical legal precedent doesn't support extending government immunity to private contractors; and an earlier court decision explicitly described similar protections as a defense rather than immunity. Because it's a defense on the merits—not immunity—the normal rules apply: defendants must wait for the case to conclude before appealing.

Separate Opinions

Justice Thomas's Separate View

Justice Thomas agreed with the outcome but objected to the Court's broader reasoning about when appeals can happen before a case is fully resolved. Thomas has long worried that judges are making too many exceptions to the rule requiring cases to finish before appeal. He believes Congress and not individual judges should decide when those exceptions apply. Congress has already established specific exceptions through law and authorized the Court to create more through formal rulemaking procedures. Allowing judges to create exceptions case-by-case through their written opinions, Thomas argues, bypasses the proper process. Since previous court decisions never allowed immediate appeals in situations like this one, Thomas would have kept the final judgment rule in place without exception.

Justice Alito's Different Approach

Justice Alito also disagreed with the majority's reasoning but agreed with the final decision. Rather than focusing on whether a defense requires proving lawful conduct, Alito suggested courts should ask whether delaying an appeal would harm an important public interest. For some protections, like qualified immunity for government officials, immediate appeals do serve the public interest. They ensure officials aren't overly cautious. But Alito saw no such compelling public interest for this particular doctrine. He noted that contractors already have qualified immunity, which offers even stronger protection. Since that broader protection already exists and doesn't require immediate appeals, there's no urgent reason to make exceptions for this narrower doctrine.

When Can Federal Contractors Appeal? The Supreme Court Draws a Clear Line

This case answers a narrow but important question: if you're a private company doing work for the federal government and you get sued, you can't immediately appeal to a higher court just because you say the government told you to do it. You have to go through the trial first, make your case there, and appeal afterward like everyone else.

The practical impact falls squarely on companies that run federal facilities, build federal projects, or carry out federal programs. These contractors may still argue they were following lawful government direction. They may win on that argument. But they don't get to treat that argument as a get-out-of-court-free card that lets them skip the trial process entirely. That privilege is reserved for true immunities, like the qualified immunity government employees themselves enjoy.

The deeper issue is about accountability. When the government outsources work to private companies, those companies step into a gray zone between public authority and private responsibility. The Court is saying that operating in that zone doesn't entitle you to the same legal shortcuts the government gets. If a contractor's conduct was lawful, the trial will bear that out. But the people bringing the lawsuit are entitled to their day in court first.

Case v. Montana, Docket No. 24-624

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When it comes to the Fourth Amendment, the hard part is drawing the line between privacy at home and a real emergency where someone might be hurt. In Case v. Montana, the Supreme Court took up that line again, and the Justices were unanimous in their agreement.

The Court said police can enter a home without a warrant to give emergency help when they have an “objectively reasonable basis” to believe someone inside is seriously injured, or about to be. The Justices rejected two other options: they said the standard is not as low as “reasonable suspicion,” but it also doesn’t require “probable cause,” either. Instead, the Court stuck with the rule it laid out before in a case called Brigham City v. Stuart.

In this case, officers were told William Case was threatening suicide and might have already shot himself. The Court said that was enough for the officers to reasonably believe there was an emergency, so the entry without a warrant was allowed. The Court affirmed the Montana Supreme Court’s decision.

When Police Enter Your Home Without a Warrant: The Supreme Court's Latest Guidance

William Trevor Case asked the U.S. Supreme Court to decide whether Montana police violated his constitutional rights when they entered his home without a warrant. The police had received a 9-1-1 call reporting that Case was threatening to kill himself and may have already shot himself. When officers entered the home, a confrontation occurred that resulted in an officer shooting Case. Police then found a handgun inside. Case was later charged and convicted of assaulting a police officer, but he argued that all evidence from the warrantless entry should be thrown out because the entry was unconstitutional.

The Montana Supreme Court had approved the police entry under what the state calls a "community caretaker doctrine." Under Montana's rule, police need "objective, specific and concrete facts" that lead an officer to "suspect" someone inside needs help. One judge disagreed, arguing that this standard was too weak for entering someone's home and that police should need stronger evidence—what lawyers call "probable cause"—before breaking down your door. The Supreme Court agreed to hear the case because courts across the country have been split on this question: how much evidence do police need before they can enter a home without a warrant to provide emergency aid?

The Court's Decision

Justice Kagan wrote the opinion for a unanimous Court. All nine justices agreed on the outcome. The Court held that the rule from an earlier case called Brigham City v. Stuart applies: police officers may enter a home without a warrant when they have "an objectively reasonable basis for believing" that someone inside is seriously injured or is about to be seriously injured.

Case had argued that the Court should require "probable cause"—a higher standard of evidence—before police can enter. The Court disagreed. Probable cause, the justices explained, is a concept that grew out of criminal investigations. It's designed to answer questions like "Is there probably evidence of a crime here?" or "Did this person probably commit a crime?" That framework doesn't fit well when police are responding to an emergency where someone might be hurt or dying. In those situations, officers aren't investigating a crime—they're trying to save a life. The Court said it would be awkward and inappropriate to force that criminal-investigation standard onto emergency situations.

Instead, the Brigham City rule asks a more direct question: Was it objectively reasonable for the officers to enter, given what they knew about the potential for serious harm?

Applying that standard to Case's situation, the Court found the entry was reasonable. Case's ex-girlfriend had called 9-1-1 and reported that Case had made explicit threats to kill himself, that she heard sounds consistent with a gun being cocked and possibly fired, and then silence. When officers arrived at the scene, they saw additional warning signs: an empty gun holster, what appeared to be a suicide note, and Case didn't respond when they called out. These facts, taken together, gave officers an objectively reasonable belief that Case had shot himself or was about to do so without immediate intervention. The Court therefore ruled in favor of the police and upheld Case's conviction.

The Court also criticized Montana's "community caretaker" label and its use of language that sounded too much like the lower "reasonable suspicion" standard used for brief street stops, not home entries.

Additional Perspectives from the Justices

Justice Sotomayor's Concerns: Justice Sotomayor agreed with the outcome but wrote separately to raise an important caution. She emphasized that when police respond to mental health crises, their entry can sometimes make things worse rather than better—especially when guns are involved. She stressed that courts should carefully consider the specific risks of each crisis situation when deciding whether police entry was reasonable. She also noted that not only does the decision to enter need to be reasonable, but also how police enter and what they do once inside must be reasonable too. These issues weren't argued in Case's appeal, so the Court didn't address them. Still, Justice Sotomayor agreed that the facts here—particularly the possibility that Case had already shot himself—supported the officers' decision to enter, even though some evidence might have suggested Case was trying to provoke police into shooting him.

Justice Gorsuch's Historical View: Justice Gorsuch also agreed with the outcome but wanted to explain the deeper roots of the emergency-aid exception. He argued that this exception isn't just about what judges today think is "reasonable." Instead, it comes from old common-law rules—legal principles that go back centuries—that allowed people to enter another person's property to prevent serious harm. This was called the "necessity privilege." Justice Gorsuch believes grounding the rule in this historical tradition is important because those old common-law rules came with built-in limits: you could only enter to the extent reasonably necessary to address the emergency.

The Legal Question at the Heart of This Case

The Fourth Amendment to the Constitution protects Americans from "unreasonable" searches and seizures. Courts have long said that entering someone's home without a warrant is "presumptively unreasonable"—meaning it's generally not allowed. But the Supreme Court recognizes certain exceptions to this rule, and the emergency-aid exception is one of them.

The tricky question in this case was: what standard should trigger this exception? How much information do police need before they can enter your home without a warrant to provide emergency help?

Montana's rule used language that sounded a lot like "reasonable suspicion"—the standard police need for brief street stops and pat-downs. The Supreme Court said this was misleading. Reasonable suspicion is a relatively low bar designed for quick, less intrusive encounters on the street, not for entering the sanctity of someone's home.

But the Court also refused to require "probable cause," which is a higher standard. Probable cause is the amount of evidence police typically need to get a search warrant or make an arrest. But as the Court explained, probable cause developed specifically for criminal investigations. It's about determining the likelihood that evidence of a crime exists or that someone committed a crime. That framework doesn't translate well to emergency situations where police are making split-second decisions about whether someone is injured or in immediate danger.

So the Court created—or more accurately, reaffirmed—a middle path: a distinct reasonableness test specifically for emergencies. Police can enter when, looking at all the circumstances, they have an objectively reasonable basis to believe immediate aid is needed. And importantly, what police do once inside must be limited to what the emergency requires. They can't use an emergency as an excuse to search your whole house for evidence of crimes.

This isn't about making it easy for police to enter homes. The Fourth Amendment still strongly protects your home. But when someone's life is genuinely at risk, the Constitution allows officers to act—as long as their belief in that risk is objectively reasonable based on the facts they knew at the time.

FCC v. Consumers' Research, Docket No. 24-354

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The Supreme Court dug into a tricky question about who gets to set fees on phone and internet companies to pay for universal service programs. At issue was whether Congress handed too much lawmaking power to the Federal Communications Commission, and then whether the FCC handed too much of its power to a private group that crunches the numbers. Justice Kagan, writing for the Court’s majority, said Congress gave clear instructions on how to calculate those fees and that the FCC still calls the final shots. A few justices disagreed, but the Court rejected the idea that separate steps of delegation added up to an unconstitutional hand-off of power.

Summary of the Case

Congress's 1996 amendments to the Communications Act require every interstate telecommunications carrier to contribute to a Universal Service Fund (USF). This fund subsidizes basic phone and broadband service for low-income consumers, high-cost rural areas, schools, libraries, and rural hospitals. Each quarter, the FCC sets a "contribution factor" - the percentage of carriers' projected revenues to be paid into the USF. In December 2021, the FCC set this factor at 25.2 percent for the first quarter of 2022.

Consumers' Research (representing a carrier, a non-profit, and individual consumers) challenged this system, arguing it violates constitutional principles in two ways: first, that Congress improperly delegated its taxing power to the FCC without clear guidance, and second, that the FCC wrongfully passed that power to a private entity, the Universal Service Administrative Company. The Fifth Circuit agreed with these challenges, ruling the framework unconstitutionally gives legislative power to both the Executive Branch and private actors.

Opinion of the Court

Justice Kagan, writing for the majority (joined by Chief Justice Roberts and Justices Sotomayor, Kavanaugh, Barrett, and Jackson), reversed the Fifth Circuit's decision.

The Court found that Congress provided adequate guidance for the FCC. The law clearly defines universal-service policy, specifies who benefits (rural/high-cost areas, low-income consumers, schools/libraries, rural hospitals), and details what services should be funded (those essential to education/public health/safety, widely subscribed, and affordable). The term "sufficient" in the law imposes both minimum and maximum limits on revenue collection.

Regarding the use of a private administrator, the Court ruled this doesn't violate constitutional principles because the FCC maintains final control - it appoints the administrator's board, approves its budget, and reviews all revenue and expense projections before finalizing the contribution factor.

The Court also rejected the Fifth Circuit's novel "double-layer" theory, noting that public and private delegations involve different constitutional concerns and don't compound to exceed permissible bounds.

Separate Opinions

Justice Kavanaugh, while concurring with the majority, elaborated on the historical and textual foundations of the "intelligible-principle" test. He explained how Congress may delegate detailed administration to the Executive Branch but expressed concerns about delegations to independent agencies.

Justice Jackson, also concurring, questioned whether the private-nondelegation doctrine (which limits delegation to private entities) has clear textual or historical support, suggesting it should be applied cautiously.

Dissenting Opinions

Justice Gorsuch (joined by Justices Thomas and Alito) dissented, arguing that the universal-service "contributions" are actually taxes, and that Congress delegated its taxing power without prescribing any rate or cap - an abdication of legislative responsibility. He contended that the law's qualitative constraints ("evolving service," "sufficient," and various competing "factors" and "principles") don't provide meaningful guidance to the FCC. He criticized the majority's interpretation as inconsistent with the law's language and warned about the separation-of-powers consequences of allowing an agency unfettered taxing authority.

How the FCC's Universal Service Fund Authority Balances Agency Discretion with Congressional Guidance

The 1996 Telecommunications Act restructures universal service funding by defining four specific beneficiary groups: rural and high-cost areas, low-income consumers, schools and libraries, and rural hospitals. The law directs the FCC to subsidize services that meet three key criteria: they must be "essential to education, public health, or safety," "subscribed to by a substantial majority of residential customers," and "affordable."

To guide funding decisions, Congress provided six mandatory principles and authorized additional principles consistent with the Act. To finance these programs, Congress empowered the FCC to require interstate telecommunications carriers to contribute "sufficient" revenue to "preserve and advance" universal service.

The FCC works with a private nonprofit—the Universal Service Administrative Company—to project fund disbursements and carrier revenues each quarter. While the FCC reviews and may revise these projections before setting the final "contribution factor" (the percentage of carrier revenues owed), the use of qualitative terms like "sufficient" and "evolving level," along with multiple factors and principles, gives the FCC considerable discretion. This broad authority is precisely what sparked the constitutional debate in this case.

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

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

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

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

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

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

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

Opinion of the Court

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

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

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

Separate Opinions

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

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

How Gun Manufacturer Liability Shields Work Under Federal Law

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

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

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

Barnes v. Felix, Docket No. 23-1239

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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.

Dewberry Group, Inc. v. Dewberry Engineers Inc., Docket No. 23-900

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When the law turns on a fine point in how companies are structured, the outcome can shift by millions of dollars. In Dewberry Group versus Dewberry Engineers, the Supreme Court looked at whether a court can award a trademark winner the profits of sister companies that weren’t named in the case. The justices said no: you can only get the money made by the company you sued, not by its separate affiliates.

That ruling wiped away a $43 million award and sent the case back to the district court. Justice Elena Kagan wrote for the court, and the decision makes clear that each corporation stands on its own when it comes to counting up profits. The Court left open questions about how judges should handle accounting details and whether they can ever pierce the corporate veil to include affiliate earnings.

Summary of the Case

Dewberry Engineers Inc. sued Dewberry Group, Inc. for trademark infringement under federal trademark law. While Dewberry Group itself reported operating losses, its sister companies—all owned by the same person, John Dewberry—made tens of millions in rental profits. The trial court treated all these companies as "a single corporate entity" and ordered Dewberry Group to pay nearly $43 million in profits. An appeals court upheld this decision. The Supreme Court then stepped in to determine whether "defendant's profits" can include profits from companies that weren't actually sued, and whether courts can ignore the boundaries between separate companies without specific legal justification.

Opinion of the Court

Justice Kagan, writing for a unanimous Court, ruled that "defendant's profits" means exactly what it sounds like—only the profits of the company that was actually named in the lawsuit. The Court emphasized the well-established principle that separately incorporated businesses are legally distinct entities. Since Engineers only sued Dewberry Group, the trial court made a mistake by including the sister companies' earnings without proper legal grounds. The Court canceled the $43 million award and sent the case back to calculate profits attributable only to Dewberry Group itself.

Separate Opinions

Justice Sotomayor agreed with the main opinion but wrote separately to emphasize that respecting corporate boundaries doesn't mean courts must ignore economic realities. She suggested that courts can still look behind artificial arrangements between related companies when calculating the defendant's true profits, as long as they focus on the profits of the company that was actually sued.

When Corporate Boundaries Matter in Trademark Cases

The Court clarified that "defendant's profits" refers only to profits earned by the specific entity being sued. This reflects the fundamental legal principle that each corporation has its own separate identity. Courts cannot disregard these boundaries without proper legal justification. The decision outlines how courts should first calculate only the named defendant's profits, and then they may adjust that amount if it seems unfair. While the Court didn't provide a complete roadmap for how courts should handle non-arm's-length transactions between related companies, it left open several legal approaches that lower courts can use in appropriate cases to determine a defendant's true profits.