Volume 562 — United States Reports

The Supreme Court of the United States handed down ten per curiam opinions during its 2010 term, which began October 4, 2010 and concluded October 1, 2011.

Abbott v. United States, 562 U.S. 8 (2010), is a decision by the Supreme Court of the United States that addressed the mandatory sentencing increase under federal law for the possession or use of a deadly weapon in drug trafficking and violent crimes. In an 8–0 decision, the Court ruled that 18 U.S.C. § 924(c), which required a minimum five-year prison sentence, was to be imposed in addition to any other mandatory sentence given for another crime, including the underlying drug-related or violent offense. The only exception to the five-year addition applied only when another provision required a longer mandatory term for conduct violating §924(c) specifically, rather than a mandatory sentence for another crime as the defendants had unsuccessfully argued.

Los Angeles County v. Humphries, 562 U.S. 29 (2010), is a decision by the Supreme Court of the United States that clarified one of the requirements for imposing liability on a municipality for violations of a federal right, in lawsuits brought under Section 1983 of the Civil Rights Act of 1871 (codified at 42 U.S.C. § 1983).

541 F. 3d 982, affirmed by an equally divided Court. Roy T. Englert, Jr., argued the cause for petitioner. With him on the briefs were Ariel N. Lavinbuk, Norman H. Le vine, and Aaron J. Moss. Aaron M. Panner argued the cause for respondent. With him on the brief were Michael K. Kellogg and Matthew C. Wagner. Deputy Solicitor General Stewart argued the cause for the United States as amicus curiae urging affirmance.

Held: The case is remanded for the Second Circuit to address, in the first instance, whether to revisit its sovereign immunity ruling in light of this development, and—if necessary—proceed to address other relevant questions consistent with its sovereign immunity ruling. 605 F. 3d 149, vacated and remanded.

Mayo Foundation v. United States, 562 U.S. 44 (2011), is a United States Supreme Court case in which the Court upheld a Treasury Department regulation on the grounds that the courts should defer to government agencies in tax cases in absence of an unreasonable decision on the part of the agency.

Ransom v. FIA Card Services, N. A., 562 U.S. 61 (2011), is a decision by the Supreme Court of the United States involving the means test in Chapter 13 of the United States Bankruptcy Code. The means test had been adopted by the Bankruptcy Abuse Prevention and Consumer Protection Act of 2005, and Ransom is one of several cases in which the Supreme Court addressed provisions of that act.

Harrington v. Richter, 562 U.S. 86 (2011), was a United States Supreme Court case in which the court held that the Antiterrorism and Effective Death Penalty Act of 1996's standard for federal habeas relief applies even when a state court does not issue an opinion explaining the basis of its decision. The case also dealt with assistance of counsel issues under Strickland v. Washington.

Premo v. Moore, 562 U.S. 115 (2011), is a United States Supreme Court case involving the right of individuals to federal habeas corpus relief on state-law claims. In a unanimous ruling, the court held that habeas relief may not be granted with respect to any claim that a state-court has found on the merits unless the state-court decision denying relief involves an "unreasonable application" of "clearly established federal law, as determined by" the Court.

NASA v. Nelson, 562 U.S. 134 (2011), is a decision by the Supreme Court of the United States holding that NASA's background checks of contract employees did not violate any constitutional privacy right.

Thompson v. N. Am. Stainless, 562 U.S. 170 (2011), was a United States Supreme Court case in which the court held that Title VII of the Civil Rights Act protects a worker from retaliation if that worker's fiancé files a workplace grievance.

Ortiz v. Jordan, 562 U.S. 180 (2011), was a United States Supreme Court case in which the Court held that a party may not appeal a denial of summary judgment after a district court has conducted a full trial on the merits.

Chase Bank USA, N.A. v. McCoy, 562 U.S. 195 (2011), was a United States Supreme Court case in which the court held that, before August 2009, Regulation Z did not require banks to provide credit-card holders with a change-in-terms notice before raising their interest rate after a delinquency or default.

Held: The Ninth Circuit erred in granting habeas relief in these cases. Federal courts may not grant federal habeas relief to state prisoners “ ‘for errors of state law.’ ” Estelle v. McGuire, 502 U. S. 62, 67. The Ninth Circuit’s holding that California law creates a liberty interest in parole is a reasonable application of this Court’s cases, see, e. g., Greenholtz v. Inmates of Neb.

Bruesewitz v. Wyeth LLC, 562 U.S. 223 (2011), is a United States Supreme Court case that decided whether a section of the Vaccine Act of 1986 preempts all vaccine design defect claims against vaccine manufacturers.

CSX Transp., Inc. v. Ala. Dept. of Revenue, 562 U.S. 277 (2011), was a Supreme Court of the United States case in which the Court held that a railroad may challenge a state's sales and use taxes as "discriminatory" under the Railroad Revitalization and Regulatory Reform Act of 1976 (4-R Act) if the state exempts the railroad's competitors from the tax.

Walker v. Martin, 562 U.S. 307 (2011), was a United States Supreme Court case in which the court held that a state's rule requiring state habeas petitions to be filed "as promptly as the circumstances allow" constitutes an independent state ground that is adequate to bar habeas relief in federal court.

Williamson v. Mazda Motor of America, Inc., 562 U.S. 323 (2011), was a decision by the Supreme Court of the United States, in which the Court unanimously held that Federal Motor Vehicle Safety Standard 208, promulgated by the National Highway Traffic Safety Administration, does not federally preempt state tort lawsuits against auto manufacturers from injuries caused by a defective lack of certain types of seat belts.

Michigan v. Bryant, 562 U.S. 344 (2011), was a United States Supreme Court case in which the Court further developed the "primary purpose" test to determine whether statements are "testimonial" for Confrontation Clause purposes. In Bryant, the Court expanded upon the test first articulated in Davis v. Washington, "addressing for the first time circumstances in which the 'ongoing emergency' discussed in Davis extended to a potential threat to the responding police and the public at large." The Court stated that determination of whether an interrogation's primary purpose was to assist in an "ongoing emergency" was an objective evaluation of the circumstances "in which the encounter occur[ed] and the statements and actions of the parties."

Federal Communications Commission v. AT&T Inc., 562 U.S. 397 (2011), was a United States Supreme Court case on aspects of corporate personhood. It held that the exemption from Freedom of Information Act disclosure requirements for law enforcement records which "could reasonably be expected to constitute an unwarranted invasion of personal privacy" does not protect information related to corporate privacy.

Staub v. Proctor Hospital, 562 U.S. 411 (2011), is a United States Supreme Court case in which the Court held that an employer may be held liable for employment discrimination under the Uniformed Services Employment and Reemployment Rights Act (USERRA) if a biased supervisor's actions are a proximate cause of an adverse employment action, even if the ultimate decision-maker was not personally biased. This case affirmed the 'Cat's Paw' theory of liability.

Henderson v. Shinseki, 562 U.S. 428 (2011), was a United States Supreme Court case in which the Court held that the deadline for filing a notice of appeal with the United States Court of Appeals for Veterans Claims does not have jurisdictional consequences.

Snyder v. Phelps, 562 U.S. 443 (2011), is a landmark decision by the Supreme Court of the United States in which the Court held that speech made in a public place on a matter of public concern cannot be the basis of liability for a tort of emotional distress, even if the speech is viewed as offensive or outrageous.

Pepper v. United States, 562 U.S. 476 (2011), is a 2011 decision by the Supreme Court of the United States concerning whether a United States District Court properly handled the sentencing of a former methamphetamine dealer. He was originally sentenced to 24 months in prison, far shorter than what federal guidelines generally specify for crimes of that nature. Prosecutors appealed the case to the United States Court of Appeals for the Eighth Circuit, which remanded the case back to the United States District Court for the Northern District of Iowa, which affirmed the original sentence after testimony relating the defendant's rehabilitation. The case was appealed to the Eighth Circuit again, and was again remanded. A different District Court judge gave him a 65-month sentence.

Skinner v. Switzer, 562 U.S. 521 (2011), is a decision by the U.S. Supreme Court regarding the route through which a prisoner may obtain biological DNA material for testing to challenge his conviction; whether through a civil rights suit or a habeas corpus petition. A majority of the Court held that the civil rights path was the appropriate path.

Wall v. Kholi, 562 U.S. 545 (2011), was a United States Supreme Court case in which the court held that it is proper to toll the time available for a habeas petition upon a properly filed application for state post-conviction or other collateral review with respect to the pertinent judgment or claim.

Milner v. Department of the Navy, 562 U.S. 562 (2011), was a United States Supreme Court case in which the court held that the Freedom of Information Act's Exemption 2 only allows the government to withhold records relating to employee relations and human resources issues. In the 30 years before Milner, the courts of appeal had developed a different test for applying Exemption 2: Milner invalidated that test.