Supreme Court Decision Syllabus (SCOTUS Podcast‪)‬ Jake Leahy

In Glacier Northwest v. Teamsters, the Supreme Court reviewed whether the National Labor Relations Act preempts Glacier's state tort law claims that allege the Teamsters intentionally destroyed the company's concrete trucks when the truckers did not complete their deliveries in transit.  The Court held that these claims were not preempted by federal law, reasoning that it is well-established that the NLRA does not protect striking workers who fail to take reasonable precautions to protect against property damage. Read by Jake Leahy. 

In Slack Technologies v. Pirani the Court held that Section 11 of the Securities Act of 1933 requires the plaintiff to prove that they purchased securities that were registered under a materially misleading registration statement. The Court rejected the argument that the term "such security" could include securities that were not registered under an allegedly misleading registration statement. Read by Jeff Barnum. 

Supreme Court's decision is here. 

The False Claims Act allows for private citizens to bring a cause of action on behalf of the United Sates, against a person who "knowingly" submits a "false claim" to a federal program. The defendant can meet the knowledge requirement by, 1.) actual knowledge that the reported prices were not "usual and customary," 2.) being aware of a substantial risk that the retail prices were not usual and customary, or 3.) awareness of a substantial and unjustifiable risk but the defendant decided to submit the claim regardless. The Court adopted a subjective standard, even if an objective test would not meet the same requirement. 

In Dupree v. Younger, the Supreme Court addressed whether a post-trial motion of a purely legal issue that was resolved at summary judgment, requires a post-trial motion to be preserved on appeal. Kevin Younger sued Neil Dupree, who was a correctional officer under Section 1983. Dupree moved for summary judgment alleging that Younger had failed to exhaust administrative remedies. The district court denied the motion. After Younger prevailed at trial by obtaining $700,000 in damages, Dupree appealed alleging the district court improperly dismissed the suit. Under Fourth Circuit precedent, that court ruled against Younger reasoning that he was required to file a Rule 50 post-trial motion to preserve the issue on appeal. The Supreme Court reversed, finding that pure questions of law resolved in summary judgment do not require a post-trial motion to preserve the issue for appeal. The Court writes in the syllabus: "And it makes sense: Factual development at trial will not change the district court’s pretrial answer to a purely legal question, so a post-trial motion requirement would amount to an empty exercise." Read by Jake Leahy. 

In Sackett v. Environmental Protection Agency, the Supreme Court examines the scope the terms "waters" under the Clean Water Act. The EPA ordered the Sackets, who purchased property in Idaho, to restore the property after the family had backfilled it with dirt. The EPA claimed that putting dirt on their property violated the Clean Water Act, and threatened the family with $40,000 in penalties daily. 

The Sacketts claimed that the Clean Water Act did not apply as "waters of the United states" refers only to permanent bodies of water, such as streams, rivers, lakes, and adjacent wetlands that have a continuous surface connection to those bodies of water.  The EPA asked the Court for a broader interpretation of the statute. The Court ruled against the EPA, reasoning that there must be a clear connection between wetlands and traditionally navigable waters to obtain jurisdiction under the Clean Water Act. Read by guest host Jeff Barnum. 

In Tyler v. Hennepin County, Chief Justice Roberts writes for the majority, reversing the Eighth Circuit. The District Court and Circuit Court had rejected a taxpayer's claim that Hennepin County keeping the $25,000 surplus after a tax sale violated both the Takings Clause under the Fifth Amendment and the prohibition on excessive fines under the Eighth Amendment. The Court reversed, finding that the state is not entitled to recover the surplus after a property is sold after the owner's failure to pay real estate taxes.