Case Highlights
2004-2005 Term
Following are case highlights for the topic areas of False Claims, Federal Courts, and Federalism. To access other case highlights for the 2004-2005 Term or other terms, or to return to the main Case Highlights page, use the Topic Area menu to the right.
FALSE CLAIMS
Graham County Soil & Water Conservation District e al. v. United States ex rel. Wilson
Docket No. 04-169
Reversed: The Fourth Circuit
Argued: April 20, 2005
Decided: June 20, 2005
For Case Analysis: See ABA Preview 401
Does the 6-year statute of limitations in the False Claims Act (FCA) govern FCA civil actions for retaliation?
No. The most closely analogous state limitations period applies instead.
From the opinion by Justice Thomas (joined by Chief Justice Rehnquist and Justices O'Connor, Scalia, and Kennedy, and joined by Justice Souter as to all but n.2):
To determine the applicable statute of limitations for a cause of action created by a federal statute, we first ask whether the statute expressly supplies a limitations period. If it does not, we generally "borrow" the most closely analogous state limitations period. … In the rare case, we have even borrowed analogous federal limitations periods in the absence of an expressly applicable one … but no party points to a reason why we should do so here, and we can think of none.
Concurring in the judgment: Justice Stevens
Dissenting: Justice Breyer (joined by Justice Ginsburg)
FEDERAL COURTS
Exxon Mobil Corp. v. Allapattah Services Inc. et al.
and
Ortega et al. v. Star-Kist Foods, Inc. Docket Nos. 04-70 and 04-79
Affirmed: The Eleventh Circuit in No. 04-70
Reversed: The First Circuit in No. 04-79
Argued: March 1, 2005
Decided: June 23, 2005
For Case Analysis: See ABA Preview 263
May a federal court in a diversity action exercise supplemental jurisdiction over additional plaintiffs whose claims do not satisfy the minimum amount-in-controversy requirement, provided the claims are part of the same case or controversy as the claims of plaintiffs who do allege a sufficient amount in controversy?
Yes. If the other elements of jurisdiction are present and at least one named plaintiff in the action satisfies 28 U.S.C. §1332(a)'s amount-in-controversy requirement, §1367 authorizes supplemental jurisdiction over the claims of other plaintiffs in the same Article III case or controversy, even if those claims are for less than the requisite amount.
From the opinion by Justice Kennedy (joined by Chief Justice Rehnquist and Justices Scalia, Souter, and Thomas):
When the well-pleaded complaint contains at least one claim that satisfies the amount-in-controversy requirement, and there are no other relevant jurisdictional defects, the district court, beyond all question, has original jurisdiction over that claim. The presence of other claims in the complaint, over which the district court may lack original jurisdiction, is of no moment. If the court has original jurisdiction over a single claim in the complaint, it has original jurisdiction over a "civil action" within the meaning of §1367(a), even if the civil action over which it has jurisdiction comprises fewer claims than were included in the complaint. Once the court determines it has original jurisdiction over the civil action, it can turn to the question whether it has a constitutional and statutory basis for exercising supplemental jurisdiction over the other claims in the action.
Dissenting: Justice Stevens (Joined by Justice Breyer)
Dissenting: Justice Ginsburg (joined by Justices Stevens, O'Connor, and Breyer)
Exxon Mobil Corp. et al. v. Saudi Basic Industries Corp.
Docket No. 03-1696
Reversed: The Third Circuit
Argued: February 23, 2005
Decided: March 30,2005
For Case Analysis: See ABA Preview 290
Is the Rooker-Feldman doctrine, which limits the jurisdiction of federal district courts, confined to cases in which the loser in a state court case seeks district court review and rejection of the state court judgment?
Yes. The court decided that the Rooker-Feldman doctrine precludes a federal district court from proceeding in the narrow circumstances in which the loser in a state court seeks district court review and rejection of a state court judgment. The case at hand, in which federal court litigation was commenced before state court litigation had concluded, and the plaintiff in the federal court was the victor in the state court case, is not one in which Rooker-Feldman prevents a federal district court from proceeding.
From the opinion by Justice Ginsburg (for a unanimous Court):
The Rooker-Feldman doctrine, we hold today, is confined to cases of the kind from which the doctrine acquired its name: cases brought by state-court losers complaining of injuries caused by state-court judgments rendered before the district court proceedings commenced and inviting district court review and rejection of those judgments. Rooker-Feldman does not otherwise override or supplant preclusion doctrine or augment the circumscribed doctrines that allow federal courts to stay or dismiss proceedings in deference to state-court actions. In the case before us, the Court of Appeals for the Third Circuit misperceived the narrow ground occupied by Rooker-Feldman, and consequently erred in ordering the federal action dismissed for lack of subject-matter jurisdiction.
FEDERAL COURTS
Grable & Sons Metal Products Inc. v. Darue Engineering & Manufacturing
Docket No. 04-603
Affirmed: The Sixth Circuit
Argued: April 18, 2005
Decided: June 13, 2005
For Case Analysis: See ABA Preview 430
Does the absence of a federal cause of action to try claims of title to land obtained at a federal tax sale preclude removal to federal court of a state action raising a disputed issue of federal title law?
No. The national interest in providing a federal forum for federal tax litigation is sufficiently substantial to support the exercise of federal question jurisdiction over the disputed issue on removal.
From the opinion by Justice Souter (for a unanimous Court):
This case warrants federal jurisdiction. Grable's state complaint must specify "the facts establishing the superiority of [its] claim" … and Grable has premised its superior title claim on a failure by the IRS to give it adequate notice, as defined by federal law. Whether Grable was given notice within the meaning of the federal statute is thus an essential element of its quiet title claim, and the meaning of the federal statute is actually in dispute; it appears to be the only legal or factual issue contested in the case. The meaning of the federal tax provision is an important issue of federal law that sensibly belongs in a federal court. The Government has a strong interest in the "prompt and certain collection of delinquent taxes" … and the ability of the IRS to satisfy its claims from the property of delinquents requires clear terms of notice to allow buyers like Darue to satisfy themselves that the Service has touched the bases necessary for good title. The Government thus has a direct interest in the availability of a federal forum to vindicate its own administrative action, and buyers (as well as tax delinquents) may find it valuable to come before judges used to federal tax matters. Finally, because it will be the rare state title case that raises a contested matter of federal law, federal jurisdiction to resolve genuine disagreement over federal tax title provisions will portend only a microscopic effect on the federal-state division of labor.
Concurring: Justice Thomas
FEDERAL COURTS
Tenet et al. v. Doe et ux.
Docket No. 03-1395
Reversed: The Ninth Circuit
Argued: January 11, 2005
Decided: March 2, 2005
For Case Analysis: See ABA Preview 231
Is a federal court barred from considering due process and tort claims that the CIA has wrongfully refused to keep its alleged promise to provide lifetime financial assistance in exchange for the claimants' alleged espionage services for the CIA?
Yes. The rule established in Totten v. United States, 92 U.S. 105 (1876), prohibits suits against the Government based on covert espionage agreements.
From the opinion by Chief Justice Rehnquist (for a unanimous Court):
In Totten v. United States … we held that public policy forbade a self-styled Civil War spy from suing the United States to enforce its obligations under their secret espionage agreement… We adhere to Totten. The state secrets privilege and the more frequent use of in camera judicial proceedings simply cannot provide the absolute protection we found necessary in enunciating the Totten rule. The possibility that a suit may proceed and an espionage relationship may be revealed, if the state secrets privilege is found not to apply, is unacceptable… Forcing the Government to litigate these claims would also make it vulnerable to "graymail," i.e., individual lawsuits brought to induce the CIA to settle a case (or prevent its filing) out of fear that any effort to litigate the action would reveal classified information that may undermine ongoing covert operations. And requiring the Government to invoke the privilege on a case-by-case basis risks the perception that it is either confirming or denying relationships with individual plaintiffs.
Concurring: Justice Stevens (joined by Justice Ginsburg)
Concurring: Justice Scalia
FEDERALISM
Gonzalez v. Raich, et al.
Docket No. 03-1454
Reversed: The Ninth Circuit
Argued: November 29, 2004
Decided: June 6, 2005
For Case Analysis: See ABA Preview 124
Does application of the federal Controlled Substances Act (CSA) to state-approved personal medicinal use of marijuana exceed Congress's Commerce Clause power?
No. Congress' Commerce Clause authority includes the power to prohibit the local cultivation and use of marijuana in compliance with California law.
From the opinion by Justice Stevens (joined by Justices Kennedy, Souter, Ginsburg, and Breyer):
The case is made difficult by respondents' strong arguments that they will suffer irreparable harm because, despite a congressional finding to the contrary, marijuana does have valid therapeutic purposes. The question before us, however, is not whether it is wise to enforce the statute in these circumstances; rather, it is whether Congress' power to regulate interstate markets for medicinal substances encompasses the portions of those markets that are supplied with drugs produced and consumed locally. Well-settled law controls our answer. The CSA is a valid exercise of federal power, even as applied to the troubling facts of this case.
.... Our case law firmly establishes Congress' power to regulate purely local activities that are part of an economic "class of activities" that have a substantial effect on interstate commerce. …In this vein, we have reiterated that when "a general regulatory statute bears a substantial relation to commerce, the de minimis character of individual instances arising under that statute is of no consequence." … [T]he regulation is squarely within Congress' commerce power because production of the commodity meant for home consumption… has a substantial effect on supply and demand in the national market for that commodity.
Concurring in the judgment: Justice Scalia
Dissenting: Justice O'Connor (joined by Chief Justice Rehnquist and joined by Justice Thomas as to all but Part III)
Dissenting: Justice Thomas
FEDERALISM
Rancho Palos Verdes et al. v. Abrams
Docket No. 03-1601
Reversed: The Ninth Circuit
Argued: January 19, 2005
Decided: March 22, 2005
For Case Analysis: See ABA Preview 237
Are local governments liable for damages and attorney's fees under 42 U. S. C. §1983 for wrongfully denying a permit for a wireless service facility?
No. An individual may not enforce the limitations on local zoning authority set forth in §332(c)(7) of the Telecommunications Communications Act (TCA) through an action under §1983 because the TCA provides a different judicial remedy, which precludes resort to §1983.
From the opinion by Justice Scalia (joined by Chief Justice Rehnquist, and Justices O'Connor, Kennedy, Souter, Thomas, Ginsburg and Breyer):
Enforcement of §332(c)(7) through §1983 would distort the scheme of expedited judicial review and limited remedies created by §332(c)(7)(B)(v). We therefore hold that the TCA—by providing a judicial remedy different from §1983 in §332(c)(7) itself—precluded resort to §1983.
Concurring: Justice Breyer (joined by Justices O'Connor, Souter, and Ginsburg
Concurring in the judgment: Justice Stevens
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