US Supreme Court Slip Opinions
Galette v. New Jersey Transit Corp. - Sovereign Immunity
The Supreme Court ruled that NJ Transit is not an arm of the State of New Jersey and therefore is not entitled to sovereign immunity. This decision resolves a conflict between state courts and clarifies the application of sovereign immunity to state-created entities.
Supreme Court: Substantial-Evidence Standard for Asylum Persecution Determinations
The Supreme Court ruled that courts of appeals must apply the substantial-evidence standard when reviewing the Board of Immigration Appeals' determination of whether undisputed facts constitute 'persecution' under the Immigration and Nationality Act. This decision clarifies the standard of review for asylum cases.
Villarreal v. Texas - Qualified Testimony Discussion Ban Affirmed
The Supreme Court affirmed a conviction in Villarreal v. Texas, holding that a qualified order prohibiting a testifying defendant from discussing their testimony during an overnight recess does not violate the Sixth Amendment. This ruling clarifies the balance between a defendant's right to counsel and the integrity of trial testimony.
GEO Group, Inc. v. Menocal - Denial of Yearsley Protection Not Immediately Appealable
The Supreme Court ruled in GEO Group, Inc. v. Menocal that a pretrial order denying a federal contractor 'Yearsley protection' is not immediately appealable. The Court held that the denial of this defense is not an immunity from suit, and thus does not qualify for interlocutory review under the collateral-order doctrine.
Supreme Court Vacates Judgment Due to Jurisdictional Defect
The Supreme Court vacated a judgment in Hain Celestial Group, Inc. v. Palmquist, ruling that the District Court lacked diversity jurisdiction when the case was removed from state court. The Fifth Circuit correctly reversed the lower court's decision, requiring the case to be remanded to state court.
US v. Konan - Sovereign Immunity for Mail Nondelivery
The Supreme Court ruled that the United States retains sovereign immunity for claims arising from the intentional nondelivery of mail. The decision clarifies the scope of the Federal Tort Claims Act's postal exception, impacting how individuals can sue the Postal Service for mail delivery issues.
Barrett v. United States - Firearms Offenses and Cumulative Punishments
The Supreme Court ruled in Barrett v. United States that a single act violating both 18 U.S.C. §924(c)(1)(A)(i) and §924(j) can only yield one conviction, not two. This decision resolves a circuit split regarding cumulative punishments for firearms offenses that cause death.
Supreme Court: Delaware affidavit law not applicable in federal court
The Supreme Court ruled that Delaware's affidavit of merit law does not apply in federal court for medical malpractice cases. The Court held that Federal Rule of Civil Procedure 8, which requires a 'short and plain statement of the claim,' displaces contrary state pleading rules.
Supreme Court: Reasonable Time Limit Applies to Void Judgment Motions
The Supreme Court ruled that the "reasonable time" limit under Federal Rule of Civil Procedure 60(c)(1) applies to motions seeking to vacate void judgments under Rule 60(b)(4). This decision clarifies the procedural requirements for challenging judgments based on alleged defects in service.
Supreme Court Rules on Mandatory Victims Restitution Act
The Supreme Court ruled that restitution under the Mandatory Victims Restitution Act (MVRA) constitutes criminal punishment for Ex Post Facto Clause purposes. The Court reversed the Eighth Circuit's decision, holding that the MVRA's restitution provisions are criminal sanctions, not civil remedies.
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