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Learning Resources, Inc. v. Trump, Docket No. 24-1287

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Sometimes the hardest part of the law is what a law does not say. That’s the key to this Supreme Court ruling about whether a president can slap tariffs on imported goods during a declared national emergency under a law called the International Emergency Economic Powers Act, or IEEPA.

In a majority opinion written by Chief Justice John Roberts, the Court said IEEPA does not give the president the power to impose tariffs. The justices said that even though the law uses broad language and talks about the power to “regulate” importation, that doesn’t clearly include the power to add tariffs.

This case combined two disputes: Learning Resources, Inc. v. Trump and Trump v. V.O.S. Selections. The Court affirmed the lower court’s decision in the V.O.S. Selections case. In the Learning Resources case, the Court wiped out the lower court ruling and sent it back with instructions to dismiss it because that court did not have jurisdiction.

The majority included Roberts along with Justices Sotomayor, Kagan, Gorsuch, Barrett, and Jackson. Justices Thomas and Kavanaugh dissented, and Kavanaugh’s dissent was joined by Thomas and Alito.

Summary of the Case

The Supreme Court has ruled that the International Emergency Economic Powers Act does not give the President the power to impose tariffs on imported goods. This decision places a significant limit on presidential power during national emergencies.

In 2025, President Trump declared two national emergencies. One related to drug trafficking, and the other addressed trade deficits. He then tried to impose substantial tariffs as part of his response to these emergencies. Small importers challenged these tariffs, arguing that the President exceeded his legal authority. The Court agreed with the challengers in a 6 to 3 decision. While the majority was divided on their reasoning, they were united on the outcome.

Arguments Made By Counsel

The Government's Position

The government argued that the emergency powers law clearly allows the President to regulate importation, and tariffs are a classic way to regulate imports. The government made several key points.

First, they pointed to dictionary definitions. The word regulate has long meant to control or adjust by rule. Tariffs are a classic tool for controlling imports. From the founding era onward, this term has included tariffs as a regulatory mechanism.

Second, they cited historical precedent. President Nixon imposed 10 percent tariffs in 1971 under the predecessor to this law. These tariffs were upheld by federal courts. When Congress passed the current law just two years later in 1977, Congress clearly understood that the same language included tariffs.

Third, they referenced a Supreme Court case from one year before the law was enacted. In that case, the Court unanimously upheld the President's tariffs under a different trade law. That law authorized the President to adjust imports. The Court held this language included monetary charges like tariffs, not just quotas. The phrase regulate importation is even broader than adjust imports.

Fourth, they argued that the major questions doctrine should not apply to foreign affairs statutes. Congress regularly gives broad discretion to the President in foreign affairs.

Finally, they made a practical argument. The law clearly allows quotas and embargoes, which are complete blockages of imports. It would make no sense for Congress to allow the President to block all Chinese imports entirely but not impose even a one dollar tariff on those imports.

The Challengers' Position

The challengers mounted several arguments against the tariffs.

First, they argued that tariffs are fundamentally taxes, not regulatory tools. Tariffs raise revenue. The Constitution assigns taxation exclusively to Congress. The word regulate appears in hundreds of statutes, yet government lawyers could not identify a single instance where regulate included the power to tax.

Second, they pointed to congressional practice. When Congress intends to authorize tariffs, it uses explicit language like duty, tariff, or surcharge. These words do not appear in the emergency powers law. The trade code contains multiple tariff statutes, all of which expressly reference tariffs and include specific caps on rates, time limits, and procedural requirements. The emergency powers law contains none of these constraints.

Third, they raised a constitutional problem. The emergency powers law authorizes regulation of both importation and exportation. But the Constitution expressly forbids taxing exports. If regulate included tariffs, it would make part of the law unconstitutional.

Fourth, they invoked the major questions doctrine. This involves an extraordinary power: unlimited tariffs on any product from any country for unlimited duration. No President has claimed this power before. This exercise of power requires clear congressional authorization.

Fifth, they distinguished the Nixon tariffs. President Nixon did not initially cite the old emergency law when imposing tariffs. He relied on other statutes. He only invoked the emergency law later in litigation as a defensive position. The court decision supporting him was a single intermediate appellate court opinion, hardly a well settled interpretation Congress would incorporate by reference.

Finally, they argued that Congress enacted the emergency powers law in 1977 specifically to constrain emergency powers after Watergate and Vietnam. The statute's careful procedural requirements and emergency declaration requirements suggest Congress intended to limit, not expand, executive authority. Using a vaguely worded emergency statute to claim unlimited tariff power contradicts this legislative purpose.

Opinion of the Court

Chief Justice Roberts delivered the lead opinion. Six Justices join parts of it, while only three Justices join other parts.

Article One of the Constitution vests the power to lay and collect taxes, duties, imposts and excises exclusively in Congress. The Framers deliberately withheld this power from the Executive Branch. As Roberts emphasizes, the Framers gave Congress alone access to the pockets of the people. This reflects hard won principles from the American Revolution against taxation without representation. Tariffs are unquestionably a branch of the taxing power.

For foreign affairs, the Framers gave Congress, not the President, the tariff power notwithstanding the obvious foreign affairs implications of tariffs. While the President enjoys some independent constitutional authority in foreign affairs, tariffs present no overlap with any such independent power. The government concedes the President has no inherent peacetime authority to impose tariffs. When core congressional powers are at stake, the fact that they implicate foreign affairs does not license ambiguous delegation. When Congress has delegated tariff powers, it has done so in explicit terms and with strict limits.

The President has no inherent authority to impose tariffs during peacetime and seeks authority purely from the emergency powers law. The government cannot identify any statute in the entire U.S. Code in which the definition of regulate includes the power to tax. When Congress addresses both regulatory and taxing powers, it treats them separately and expressly. The Court also identified an export clause problem. Because the emergency law authorizes regulating both importation and exportation, reading regulate to include tariffs would render the statute partly unconstitutional. The Constitution explicitly forbids taxing exports.

In the emergency law's nearly 50 year existence, no President until Trump invoked the statute to impose tariffs. Presidents regularly invoked the law for other purposes but consistently looked to other statutes for tariff authority. This lack of historical precedent, combined with the breadth of authority claimed, indicates the power exceeds the President's legitimate reach. Emergency powers tend to kindle emergencies, and the Framers understood emergencies could afford a ready pretext for usurpation of congressional power.

The Nixon and Ford Tariffs Distinguished

The Court rejected the government's reliance on President Nixon's 1971 tariffs and President Ford's 1975 tariffs. For the Nixon tariffs, the Court noted that a single, expressly limited opinion from one specialized intermediate appellate court does not establish a well-settled meaning that Congress would have incorporated into later legislation. Nixon did not initially invoke the emergency law to justify the tariffs; he relied on other statutes and only cited it later as a litigation defense.

For the Ford tariffs, the Court found a similar lack of precedent. The 1977 legislative history itself acknowledged that earlier Presidents had exploited the open-ended nature of the old law, transforming it far beyond its original purpose of sanctioning foreign belligerents. Congress enacted IEEPA specifically to rein in these overreaches. Reading the new law as silently preserving unlimited tariff authority would contradict the very reform Congress intended.

Does a National Emergency Unlock Unlimited Tariff Power?

This decision establishes that broad emergency language does not automatically encompass the power to tax. The Court drew a firm line: even sweeping terms like "regulate importation" do not include tariffs absent clear congressional authorization, particularly when core Article I taxing powers are at stake.

The ruling preserves presidential flexibility in other respects. The Court did not disturb the President's ability to impose sanctions, block transactions, or freeze assets under IEEPA. It also did not question the validity of tariffs imposed under other statutes that expressly grant that authority with specific procedural limits and rate caps.

However, the 6–3 split reveals a significant fault line. The dissenters argued that the plain meaning of "regulate" naturally encompasses tariffs, and that the majority imposed an artificially narrow reading on a foreign affairs statute. Justice Kavanaugh's dissent warned that the decision hamstrings presidential responses to genuine emergencies. This tension suggests future disputes over how broadly courts should read delegations of power in foreign affairs and emergency contexts.

The practical impact is immediate: tariffs imposed solely under IEEPA authority lack legal basis, and importers who paid those tariffs may seek refunds.

Bost v. Illinois Bd. of Elections, Docket No. 24-568

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The Supreme Court said Congressman Michael Bost, as a candidate for office, can bring a lawsuit over Illinois’s way of counting certain mail-in ballots. Illinois allows ballots that are postmarked or certified by Election Day to still be counted if they arrive within two weeks after Election Day. A lower court had thrown the case out, saying Bost didn’t have the right to sue.

The Supreme Court disagreed and sent the case back to the lower courts to keep going. Chief Justice John Roberts wrote for the Court. The majority said candidates have a real, personal stake in the rules used to count votes in their own elections—even if they can’t prove the rule will make them lose, or even if it doesn’t drive up their campaign costs. The Court said this is about the integrity of the election and the democratic process itself.

Justice Ketanji Brown Jackson dissented, joined by Justice Sonia Sotomayor. Justice Amy Coney Barrett agreed with the result in a separate opinion, and Justice Elena Kagan joined that.

Supreme Court Rules Candidates Can Challenge Election Procedures Without Proving They'll Lose

Congressman Michael Bost and other political candidates sued over an Illinois election rule that allows mail-in ballots to be counted if they're postmarked by Election Day but arrive up to two weeks later. The candidates argued this violates federal law, which sets a single, uniform Election Day for congressional and presidential elections across the country.

Lower courts threw out the case. Not because the candidates were wrong about election law, but because the judges said the candidates hadn't proven they were harmed enough to even bring the lawsuit in the first place. This is called "standing," and it's a fundamental requirement before any federal court can hear a case.

The Supreme Court took up the case to answer one key question: Do candidates have the right to challenge election rules in court, or must they first prove those rules will cause them to lose?

The Supreme Court's Decision

Chief Justice Roberts, writing for the Court's majority, ruled that Congressman Bost does have standing to challenge the vote-counting rules. The Court sent the case back to the lower courts to actually decide whether Illinois's rule violates federal election law.

The Court's reasoning centered on what it means to be a candidate in an election. According to the majority, candidates have more at stake than just winning or losing. They have a personal interest in making sure the election is run lawfully and fairly, and in ensuring the results are seen as legitimate by the public.

The Court rejected the idea that candidates must show a "substantial risk" of losing their election before they can challenge election rules in court. The justices warned that requiring this kind of proof would create serious problems. It would force candidates to wait until right before an election, or even after votes are counted, to file lawsuits. The Court has repeatedly cautioned against last-minute court battles over election rules because they create chaos and confusion for voters and election officials alike.

The majority also pointed out that asking judges to predict election outcomes would put courts in an impossible position. Judges aren't political analysts, and making them guess who's likely to win an election would look more like partisan forecasting than legal analysis.

Justice Barrett's Middle-Ground Approach

Justice Barrett, joined by Justice Kagan, agreed that Congressman Bost should be allowed to sue, but for different reasons. She criticized the majority for creating what she called a "novel" special standing rule just for candidates.

Instead, Barrett argued that Bost has standing based on a more traditional legal concept: financial harm. According to Barrett, campaigns have to spend money on poll watchers and monitoring systems to protect against problems that might arise from counting ballots that arrive late. These are real, out-of-pocket costs that campaigns wouldn't have to pay if the rule didn't exist.

Barrett worried that the majority's approach strays too far from established legal principles. She emphasized that all people who sue in federal court, including political candidates, should have to meet the same basic requirements to prove they've been harmed.

Justice Jackson's Strong Dissent

Justice Jackson, joined by Justice Sotomayor, disagreed entirely. She argued that Congressman Bost hasn't suffered any real, concrete injury and therefore shouldn't be allowed to sue at all.

Jackson's main concern is that the majority is turning standing from a requirement to prove actual harm into an automatic right based on someone's status as a candidate. She pointed out that everyone cares about fair elections and legitimate results. If caring about election integrity is enough to sue, then anyone could challenge any election rule, which would overwhelm the courts with lawsuits.

Jackson also rejected Justice Barrett's financial-harm theory. She argued that spending money to monitor an election doesn't create standing if the underlying harm you're worried about is too speculative. In her view, Bost is spending money to guard against problems that might never happen, which isn't enough to justify a federal lawsuit.

Finally, Jackson warned that the majority's decision could "open the floodgates" to candidate lawsuits about all sorts of election procedures even when candidates can't point to any specific harm those rules cause them. Candidate lawsuits like how ballots are designed to how they're transported and stored could arise.

The Core Legal Question: What Does It Take to Sue Over Election Rules?

The real legal debate in this case isn't about whether Illinois's mail-in ballot rule is legal. The Supreme Court didn't decide that question. Instead, the justices disagreed about a more fundamental issue: What does someone have to prove before they can challenge election procedures in federal court?

The majority's view: Being a candidate gives you a concrete, personal stake in how elections are run. Candidates have a unique interest in making sure the process is lawful and the results are seen as legitimate. This interest is specific enough to allow candidates to sue without having to prove they'll lose because of the rule they're challenging.

Justice Barrett's view: Candidates should have to meet the same standing requirements as everyone else, but they can do so by pointing to the real money they spend responding to potentially problematic election rules. You don't need a special "candidate standing" rule. Traditional legal principles work just fine.

The timing dilemma: The majority emphasized a practical problem: if candidates have to wait until they can prove a rule will cause them to lose, they'll file lawsuits at the last minute, creating chaos right before elections. But Jackson countered that practical concerns can't override the Constitution's limits on federal court power.

The "manufactured standing" debate: Barrett argued that campaign spending on poll watchers is a real cost that creates standing. Jackson called this "manufactured standing"arguing that voluntarily spending money in response to speculative harms shouldn't give you the right to sue.

These competing views reveal a fundamental disagreement about election cases. Should courts recognize that candidates have special, process-based injuries that allow them to challenge election rules? Or does doing so water down the requirements for bringing a lawsuit and open the door to endless political litigation?

The majority believes candidates need a meaningful way to challenge potentially unlawful election rules before it's too late. The dissenters worry this approach gives candidates—and by extension, political parties—too much power to drag election procedures into federal court without proving real harm.

Fuld v. Palestine Liberation Organization, Docket No. 24-20

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When does sending legal papers by email count as proper notice? The Supreme Court has now answered that in the Fuld v. Palestine Liberation Organization case. A family in Washington, D.C., sued the PLO over the tragic death of a loved one in a terror attack. They tried handing the complaint to the PLO’s U.S. office but came up empty. So the judge said, “Okay, you can mail it and even email it to their New York representative.” The PLO argued that wasn’t a real way to serve papers, but the Supreme Court disagreed. It said that under the law governing suits against foreign entities, courts can allow these alternate methods when personal service isn’t possible.

This ruling sends the case back to lower court and means the family’s lawsuit can move forward. It also sheds light on how judges balance the right to fair notice against victims’ need for access to justice.

Summary of the Case

American citizens (and their estates) who were injured or killed in terrorist attacks abroad sued the Palestine Liberation Organization (PLO) and Palestinian Authority (PA) under the Anti-Terrorism Act of 1990. After winning jury verdicts worth over $650 million in one case, the Second Circuit Court of Appeals overturned these victories, ruling that US courts lacked personal jurisdiction over these organizations because their alleged support for terrorism occurred overseas and didn't create sufficient connection to the United States.

In response, Congress passed the Promoting Security and Justice for Victims of Terrorism Act of 2019 (PSJVTA). This law specifically names the PA and PLO and establishes that they are considered to have consented to US court jurisdiction in terrorism cases if they either: (1) pay salaries or death benefits to convicted terrorists or their families, or (2) maintain any offices, facilities, or conduct any activities in the United States.

Lower courts found this law unconstitutional under the Fifth Amendment's Due Process Clause, but the Supreme Court has now reversed that decision.

Opinion of the Court

Chief Justice Roberts, writing for a unanimous Court in judgment, made three key rulings:

First, the Fifth Amendment's Due Process Clause (which applies to federal power) doesn't incorporate the same "minimum contacts" test used for state courts under the Fourteenth Amendment. This is because the Fourteenth Amendment concerns relationships between states, while the Fifth Amendment deals with federal authority, which can extend beyond US borders.

Second, Congress acted within its constitutional authority when creating the PSJVTA, which links jurisdiction over the PLO and PA to conduct that meaningfully relates to the United States and involves critical foreign policy decisions made by the political branches of government.

Third, even if applying a "reasonableness" standard from Fourteenth Amendment cases, the PSJVTA easily passes constitutional muster. The Court noted the strong interest of American victims in having a US forum, the nation's compelling interest in fighting terrorism, and the absence of any unfair burden on the defendants.

The Court reversed the lower court's decision and sent the cases back for further proceedings.

Separate Opinions

Justice Thomas (joined partly by Justice Gorsuch) agreed with the outcome but offered different reasoning. He argued that the Fifth Amendment, as originally understood, places no territorial limit on Congress's power to extend federal jurisdiction. In his view, the Due Process Clause never imposed substantive restrictions on extraterritorial federal jurisdiction in the first place.

How Congress Tailored the Law to Combat Terrorism Financing

The PSJVTA carefully amends the Anti-Terrorism Act's jurisdictional rules in two specific ways.

First, it targets "incentive" programs like salaries paid to terrorists serving prison terms in Israel and benefits paid to families of terrorists killed while carrying out attacks. Congress had previously condemned these payments in the Taylor Force Act.

Second, the law subjects the PLO and PA to US court jurisdiction if they maintain any offices, facilities, or physical presence in the United States. This provision builds on existing restrictions on PLO/PA operations on American soil.

Importantly, the law applies only to terrorism claims and specifically excludes the Palestinian mission to the United Nations. Unlike broader jurisdictional provisions, Congress crafted the PSJVTA to target two specific non-sovereign organizations already involved in US counter-terrorism policy. The law gives clear notice that continuing these specific activities will be treated as consent to being sued in American courts.

The statute reflects a careful legislative balance between deterring support for terrorism, respecting diplomatic and foreign policy concerns, and ensuring fairness to defendants who have known connections to the United States.

United States v. Skrmetti, Docket No. 23-477

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

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

Summary of the Case

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

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

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

How the Supreme Court Ruled on Gender-Affirming Care Restrictions

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

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

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

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

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

Separate Opinions

Several justices wrote separate opinions:

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

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

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

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

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

The Medical and Legal Debate Behind Gender-Affirming Care Bans

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

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

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

Perttu v. Richards, Docket No. 23-1324

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

Summary of the Case

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

Opinion of the Court

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

Dissenting Opinions

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

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

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

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

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

A. J. T. v. Osseo Area Schools, Independent School Dist. No. 279, Docket No. 24-249

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

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

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

Summary of the Case

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

Opinion of the Court

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

Separate Opinions

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

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

How Disability Discrimination Standards Apply in Education Settings

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

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

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

Thompson v. United States, Docket No. 23-1095

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When does a half‐truth cross the line into a punishable lie? That’s what the Supreme Court asked when it looked at a law banning “knowingly mak[ing] any false statement” on loan documents. The justices unanimously agreed that a statement can be misleading yet still be true, and the law only reaches statements that are actually false.

Because of that narrow reading, the Court sent the case back to the lower court to decide whether Thompson’s statements were outright lies or just clever ways to spin the facts.

Summary of the Case

Patrick Thompson borrowed three sums from Washington Federal Bank. $110,000 in 2011, $20,000 in 2013 and $89,000 in 2014 — totaling $219,000. When the bank failed in 2017, the FDIC, as receiver, sought repayment. During two debt-collection calls, Thompson disputed an invoice showing a $269,120.58 balance, telling FDIC contractors that he “had no idea where the 269 number comes from” and that he “borrowed . . . $110,000”. The Government indicted him under 18 U.S.C. § 1014 for “knowingly mak[ing] any false statement” to influence the FDIC’s handling of a loan. A jury convicted, and Thompson moved for acquittal, arguing his statements were literally true. He had in fact borrowed $110,000, albeit misleading by omitting subsequent borrowings. Both the District Court and the Seventh Circuit held that § 1014 also covers misleading statements, affirmed the convictions, and rejected the claim of literal truth. The Supreme Court granted certiorari to decide whether § 1014 reaches misleading but true statements.

Opinion of the Court

Chief Justice Roberts, for a unanimous Court, held that § 1014’s reference to “false statement[s]” does not encompass statements that are merely misleading. First, the statute’s text uses only the adjective “false,” which unambiguously means “not true,” and omits the word “misleading”. A misleading statement can be true, and a true statement is not false; “any false statement” does not expand the category to include all misleading statements. Second, context confirms this narrow reading: other federal criminal and regulatory provisions in Title 18 expressly prohibit “false or misleading” statements, so interpreting § 1014 to cover all misleading statements would render that language superfluous. Third, precedent is in accord: in United States v. Wells, the Court declined to graft a materiality requirement into § 1014 because Congress omitted it; similarly, Williams v. United States, held that a check cannot be a “false statement” at all. Kay v. United States does not aid the Government, as its references to “misleading” describe intent, not substantive scope. Finally, the Court recognized that context is relevant to determining whether a given statement is false, and remanded for the Seventh Circuit to assess whether a reasonable jury could find Thompson’s statements false in their factual setting.

Separate Opinions

Justice Alito concurred to emphasize five key takeaways: (1) § 1014 reaches only untrue statements; (2) “false” bears its ordinary meaning of “not true”; (3) falsity must be assessed in context; (4) overlap between “false” and “misleading” does not require reference to “misleading” in jury instructions; and (5) on remand, the Seventh Circuit should apply the Jackson v. Virginia sufficiency-of-the-evidence standard. Justice Jackson also concurred, noting that because the jury was correctly instructed to find only false statements, the Seventh Circuit should simply affirm the verdict if a rational factfinder could find falsity.

False Vs. Misleading

When Congress recodified the federal criminal statutes in 1948, it consolidated eleven predecessor provisions into § 1014—all penalizing “false statements” without mentioning “misleading.” By contrast, contemporaneous statutes that targeted misleading or deceptive conduct patently used the phrase “false or misleading”. The omission of “misleading” in § 1014 is thus deliberate, not inadvertent. Further, adding “any” before “false statement” broadens only within the class of untrue statements, not to encompass true but misleading assertions. Precedents like Wells, declining to import materiality, and Williams, limiting § 1014 to assertions analyzable as true or false, reinforce that § 1014’s ambit is confined to statements that can legitimately be called false. Although contextual nuance informs whether particular words are untrue, the statute itself turns solely on falsity, not misleadingness.

Trump v. United States, Docket No. 23-939

You've heard this case in the news and all over social media. Trump v. United States dissects the complexities of legal protections for former presidents. This case forges new law for immunity from criminal presection for actions taken while they were in office. So long as the president is acting within their official duties, they have a defined curtain of protection from being charged with a crime. This case is complex and riddled with important detail. Stay tuned as we dig in to the facts of this case and the implications for future U.S. presidents.

The Court made it clear that this immunity is absolute for actions that fall under the president's exclusive constitutional powers. For other official acts, there is at least a presumption of immunity. However, if a president engages in unofficial actions, they do not enjoy this protection. The case has now been sent back to lower courts to figure out the specifics of the conduct mentioned in the indictment.

This decision has sparked a lot of discussion, especially with dissenting opinions from some justices who believe that this level of immunity could set a concerning precedent. As we continue to follow this case, it raises important questions about accountability and the limits of presidential power.

Summary of the Case

The case of Trump v. United States arose from a federal grand jury indictment against former President Donald J. Trump, who faced four counts related to actions taken during his presidency following the November 2020 election. The indictment alleged that Trump conspired to overturn the election results by spreading false claims of election fraud, thereby obstructing the collection, counting, and certification of the election results. Trump sought to dismiss the indictment, claiming absolute presidential immunity for actions taken within the scope of his official duties. The District Court and the D.C. Circuit Court both denied this motion, leading to the Supreme Court's review of the extent of presidential immunity from criminal prosecution.

Opinion of the Court

The Supreme Court held that a former President is entitled to some degree of immunity from criminal prosecution for actions taken within the scope of his official duties. The Court established that while a President has absolute immunity for conduct that falls within his exclusive constitutional authority, he is entitled to at least presumptive immunity for other official acts. The Court emphasized that not all presidential actions are immune; unofficial acts do not enjoy such protection. The Court remanded the case to the District Court to determine which specific actions alleged in the indictment were official or unofficial, thus requiring a careful analysis of the conduct in question. The ruling underscored the importance of maintaining the separation of powers and the need for the President to perform his duties without the fear of criminal prosecution for official acts.

Separate Opinions

Justice Thomas filed a concurring opinion, emphasizing the dangers of criminally prosecuting a former President for official acts and suggesting that the Constitution does not permit such a course. He raised concerns about the legitimacy of the Special Counsel's appointment, questioning whether it was established by law as required by the Constitution.

Justice Barrett also concurred in part but did not join the section of the Court's opinion regarding the evidentiary treatment of official acts. She argued that the President should be able to challenge the constitutionality of criminal statutes as applied to official acts and that the Court should have addressed this issue directly.

Dissenting Opinions

Justice Sotomayor, joined by Justices Kagan and Jackson, dissented, arguing that the majority's decision effectively grants former Presidents immunity from criminal prosecution for their official acts, undermining the principle that no one is above the law. She contended that the majority's expansive interpretation of presidential immunity is unprecedented and dangerous, allowing for potential abuses of power without accountability.

Justice Jackson also dissented, echoing Sotomayor's concerns and emphasizing that the majority's ruling alters the accountability paradigm for Presidents, creating a new model that permits them to evade criminal liability for actions taken while in office. He criticized the majority for failing to provide clear standards for distinguishing between official and unofficial conduct, which could lead to significant legal ambiguities.

Presidential Immunity and Official Acts

The ruling in Trump v. United States highlights the complex interplay between presidential powers and accountability under the Constitution. The Court's decision reflects a nuanced understanding of the separation of powers, recognizing that while the President must be able to perform his duties without undue interference, this does not grant him carte blanche to act unlawfully. The distinction between official and unofficial acts is critical; while the President enjoys immunity for actions taken in the course of his official duties, this immunity does not extend to conduct that is deemed unofficial or outside the scope of his constitutional authority. The Court's approach necessitates a careful, fact-specific analysis of the actions in question, balancing the need for executive independence with the imperative of accountability under the law. This case sets a significant precedent regarding the limits of presidential immunity and the conditions under which a former President may be held accountable for actions taken while in office.


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Loper Bright Enterprises v. Raimondo, Docket No. 22-451

A fresh perspective on how courts interact with government agencies is at the fore in Loper Bright Enterprises v. Raimondo. The Supreme Court decided to overrule the Chevron doctrine, which previously allowed courts to defer to agency interpretations when laws were unclear. Instead, the Court emphasized that judges should use their own judgment to determine if an agency is acting within its legal boundaries.

This decision, led by Chief Justice John Roberts, signals a shift in how legal ambiguities will be handled in the future. The majority opinion was supported by several justices, including Clarence Thomas and Amy Coney Barrett. However, there was a dissenting opinion from Justice Elena Kagan, joined by Justices Sonia Sotomayor and Ketanji Brown Jackson, who expressed concerns about this new approach.

In essence, this ruling means that courts will no longer automatically side with agency interpretations just because a law is vague. Instead, they will take a closer look at whether the agency is truly following the law as it was intended. This could have significant implications for how laws are enforced and interpreted across various government agencies.

Summary of the Case

The case of Loper Bright Enterprises et al. v. Raimondo arose from challenges to a rule promulgated by the National Marine Fisheries Service (NMFS) under the Magnuson-Stevens Fishery Conservation and Management Act. Petitioners, who are operators in the Atlantic herring fishery, contested the legality of a rule requiring them to pay for observer services mandated by the NMFS. They argued that the Magnuson-Stevens Act did not authorize such a requirement. The case was brought before the Supreme Court to determine whether the Chevron deference doctrine, which requires courts to defer to reasonable agency interpretations of ambiguous statutes, should be overruled or clarified.

Opinion of the Court

The Supreme Court, in a decision delivered by Chief Justice Roberts, overruled the Chevron doctrine, asserting that the Administrative Procedure Act (APA) mandates that courts exercise independent judgment in determining whether an agency has acted within its statutory authority. The Court emphasized that courts should not defer to agency interpretations simply because a statute is ambiguous. The opinion traced the historical context of judicial interpretation, asserting that the judiciary has the ultimate responsibility to interpret laws, a role that should not be abdicated to executive agencies. The Court concluded that Chevron's requirement for deference was inconsistent with the APA's directive that courts decide all relevant questions of law.

Separate Opinions

Justice Thomas and Justice Gorsuch filed concurring opinions. Justice Thomas emphasized that Chevron deference violates the Constitution's separation of powers by allowing agencies to exercise judicial power. Justice Gorsuch focused on the historical context of judicial interpretation and the need for courts to maintain their role in statutory interpretation without deferring to agencies.

Dissenting Opinions

Justice Kagan, joined by Justices Sotomayor and Jackson, dissented. The dissent argued that Chevron has been a cornerstone of administrative law for decades, providing a framework for courts and agencies to operate effectively. Kagan contended that the majority's decision undermines the expertise of agencies in regulatory matters and shifts power from agencies to courts, which may not have the same level of expertise. The dissent also emphasized the importance of stare decisis, arguing that the majority failed to provide a compelling justification for overruling a long-standing precedent.

Administrative Law and the Chevron Doctrine

The ruling in Loper Bright Enterprises reflects a significant shift in administrative law, particularly regarding the relationship between courts and agencies. The Chevron doctrine, established in 1984, allowed agencies to interpret ambiguous statutes within their jurisdiction, with courts deferring to those interpretations if deemed reasonable. The Supreme Court's decision to overrule Chevron underscores a belief that the APA requires courts to engage in independent statutory interpretation, thereby reinforcing the judiciary's role in the separation of powers. This change raises questions about the future of agency authority and the balance of power between the legislative, executive, and judicial branches, as well as the implications for regulatory practices across various sectors. The Court's emphasis on the historical role of courts in interpreting laws suggests a return to a more traditional understanding of judicial authority, potentially complicating the regulatory landscape and the relationship between agencies and the courts.


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United States v. Rahimi, Docket No. 22-915

A Supreme Court ruling that's igniting debates across the nation is at the heart of United States v Rahimi. The case asks a powder keg question: Can the government step in to restrict gun ownership when someone is deemed a threat? This case isn't just about legal technicalities - it's about the tug-of-war between personal freedoms and public safety. As we unpack this decision, you'll see how the highest court in the land is reshaping the landscape of gun rights.

The justices decided that it is indeed permissible to disarm such individuals, aligning this decision with the Second Amendment. Specifically, they upheld a law that stops people under certain domestic violence restraining orders from having guns. This ruling emphasizes that the right to bear arms can be balanced with the need to protect individuals from potential harm.

Chief Justice John Roberts led the majority opinion, which was supported by several other justices. However, Justice Clarence Thomas disagreed with the ruling, highlighting the ongoing debate about gun rights in America.

This case illustrates the delicate balance between individual rights and public safety, a topic that continues to spark discussions across the nation.

Summary of the Case

The case of United States v. Rahimi arose from the indictment of Zackey Rahimi under 18 U.S.C. §922(g)(8), which prohibits individuals subject to domestic violence restraining orders from possessing firearms. Rahimi acknowledged that the restraining order against him met the statutory criteria but contended that the statute itself violated the Second Amendment. The District Court denied his motion to dismiss the indictment, but the Fifth Circuit reversed this decision, asserting that the government failed to demonstrate that §922(g)(8) aligned with the historical tradition of firearm regulation in the United States. The Supreme Court granted certiorari to resolve the constitutional question.

Opinion of the Court

The Supreme Court, in a decision delivered by Chief Justice Roberts, held that individuals found by a court to pose a credible threat to the physical safety of others may be temporarily disarmed under the Second Amendment. The Court emphasized that the right to keep and bear arms is fundamental but not unlimited. It noted that historical firearm laws have included regulations preventing individuals who threaten physical harm from misusing firearms. The Court found that §922(g)(8) fits within this historical tradition, as it applies only to individuals who have been judicially determined to pose a credible threat. The Court rejected the Fifth Circuit's interpretation that required a "historical twin" for modern regulations, asserting that a "historical analogue" suffices. The Court concluded that §922(g)(8) is constitutional as applied to Rahimi's case.

Separate Opinions

Justice Sotomayor filed a concurring opinion, expressing her belief that while she disagreed with the Bruen decision, she supported the application of its precedent in this case. She emphasized that the regulation must align with the principles underlying the Second Amendment but need not have a precise historical match. Justices Gorsuch, Kavanaugh, Barrett, and Jackson also filed concurring opinions, each reinforcing the majority's reasoning and the importance of historical context in Second Amendment cases.

Dissenting Opinions

Justice Thomas dissented, arguing that §922(g)(8) is unconstitutional because it does not have a historical analogue that justifies its broad prohibition on firearm possession. He contended that the statute imposes a more severe burden than historical laws, such as surety laws, which did not strip individuals of their right to keep and bear arms. Thomas maintained that the government failed to demonstrate that §922(g)(8) is consistent with the historical tradition of firearm regulation, emphasizing that the Second Amendment protects all members of the political community, not just those deemed "responsible."

Domestic Violence, Invidividual Rights and the Second Amendment

The law in question, §922(g)(8), reflects a balance between individual rights and public safety, particularly in the context of domestic violence. The Supreme Court's interpretation underscores that while the Second Amendment protects the right to bear arms, this right is not absolute and can be regulated in specific circumstances, particularly when an individual poses a credible threat to others. The Court's reliance on historical analogues rather than requiring exact matches allows for a more flexible application of the Second Amendment in contemporary contexts. This case illustrates the ongoing tension between the right to bear arms and the need for regulations aimed at preventing violence, particularly in domestic situations. The dissent highlights concerns about due process and the potential for overreach in disarming individuals without a criminal conviction, emphasizing the need for careful scrutiny of laws that infringe upon constitutional rights.