Volume 574 — United States Reports

The Supreme Court of the United States handed down eight per curiam opinions during its 2014 term, which began October 6, 2014 and concluded October 4, 2015.

Held: Federal pleading rules do not countenance dismissal of a complaint for imperfect statement of the legal theory supporting the claim as- serted. See Fed. Rule Civ. Proc. 8(a)(2). Nor does any heightened pleading rule require plaintiffs seeking damages for violations of consti- tutional rights to invoke § 1983 expressly in order to state a claim.

Decided November 10, 2014 Jeremy Carroll, an offcer of the Pennsylvania State Police, was dispatched to the home of Andrew and Karen Carman to search for a car thief. Held: Offcer Carroll is entitled to qualifed immunity because he did not violate a statutory or constitutional right that was clearly established at the time of the challenged conduct.

Held: The Ninth Circuit's decision cannot stand. Most constitutional mis- takes call for reversal only if the government cannot demonstrate harm- lessness. Neder v. United States, 527 U. S. 1, 8.

Integrity Staffing Solutions, Inc. v. Busk, 574 U.S. 27 (2014), was a unanimous decision by the United States Supreme Court, ruling that time spent by workers waiting to undergo anti-employee theft security screenings is not "integral and indispensable" to their work, and thus not compensable under the Fair Labor Standards Act (FLSA). The Court delivered their ruling on December 9, 2014.

Warger v. Shauers, 574 U.S. 40 (2014), was a unanimous decision by the United States Supreme Court, ruling that jurors may not testify about what occurred during jury deliberations, even to expose dishonesty during jury selection or voir dire. The Court delivered its ruling on December 9, 2014.

Heien v. North Carolina, 574 U.S. 54 (2014), was a decision by the United States Supreme Court, ruling that a police officer's reasonable mistake of law can provide the individualized suspicion required by the Fourth Amendment to the United States Constitution to justify a traffic stop. The Court delivered its ruling on December 15, 2014.

Dart Cherokee Basin Operating Co. v. Owens, 574 U.S. 81 (2015), was a case in which the Supreme Court of the United States clarified procedures for removing a class action lawsuit from state court to federal court. The case involved a dispute about revenue from oil and gas leases in which the defendant filed a motion to remove the case from a state court in Kansas to the United States District Court for the District of Kansas. However, the plaintiff argued that the defendant's motion was defective because the defendant's notice of removal did not include evidence demonstrating that the amount in controversy satisfied the jurisdictional threshold.

Jesinoski v. Countrywide Home Loans, Inc., 574 U.S. 259 (2015), was a United States Supreme Court case in which the Court held that the Truth in Lending Act does not require borrowers to file a lawsuit to rescind loans and that sending written notice is sufficient to effectuate rescission. Some commentators described Justice Antonin Scalia's unanimous majority opinion as "terse" and the "shortest opinion of the year". Other analysts have described Jesinoski as a "landmark case" in Truth in Lending Act jurisprudence.

Whitfield v. United States, 574 U.S. 265 (2015), was a United States Supreme Court case that concerned whether the forced accompaniment statute under 18 U.S.C. § 2113(e) applies when a bank, credit union, or savings/loan association robber, or attempted robber, forces someone to accompany them for any distance. Defense attorney Joshua B. Carpenter argued on behalf of the Petitioner, and Assistant to the Solicitor General Brian H. Fletcher argued on behalf of the Department of Justice.

Jennings v. Stephens, 574 U.S. 271 (2015), was a United States Supreme Court case in which the court held that in a federal habeas proceeding, a criminal defendant may argue a defense of the district court's judgment on alternative grounds without first taking a cross-appeal or obtaining a certificate of appealability unless doing so would enlarge the defendant's rights under the district court's judgment.

T-Mobile South, LLC v. City of Roswell, 574 U.S. 293 (2015), was a United States Supreme Court case in which the court held that the Telecommunications Act of 1996 requires a locality that denies an application to build cell-phone tower to state its reasons for denial with sufficient clarity in a written record issued essentially contemporaneously with the denial.

Teva Pharmaceuticals USA, Inc. v. Sandoz, Inc., 574 U.S. 318 (2015), is a patent case of the Supreme Court of the United States regarding the Copaxone patent. The Court held that, when reviewing a district court's resolution of subsidiary factual matters made in the course of its construction of a patent claim, the Federal Circuit must apply a "clear error," not a de novo, standard of review.

Holt v. Hobbs, 574 U.S. 352 (2015), was a United States Supreme Court case in which the Court unanimously ruled that an Arkansas prison policy which prohibited a Muslim prisoner from growing a short beard in accordance with his religious beliefs violated the Religious Land Use and Institutionalized Persons Act (RLUIPA).

Held: In denying the motions for substitution of counsel, the courts below failed to properly consider the factors set out in Martel v. Clair, 565 U. S. 648, for evaluating whether substitution would serve the “ `inter- ests of justice,' ” id., at 663. Although the District Court recognized the governing standard, it did not properly account for all of the factors set forth in Clair.

Department of Homeland Security v. MacLean, 574 U.S. 383 (2015), was a United States Supreme Court case in which the court held that a whistleblower disclosure that is specifically prohibited by a rule or regulation is permitted because the disclosure is not "specifically prohibited by law" within the meaning of the statute protecting whistleblowers.

Gelboim v. Bank of America Corp., 574 U.S. 405 (2015), was a United States Supreme Court case in which the court held that when multiple claims are consolidated into one proceeding, the dismissal of one of the claims is a final decision that may be appealed without waiting for final decisions on all claims.

Hana Financial, Inc. v. Hana Bank, 574 U.S. 418 (2015), was a United States Supreme Court case in which the court held that whether two trademarks may be tacked for purposes of determining priority is a question for the jury.

M&G Polymers USA, LLC v. Tackett, 574 U.S. 427 (2015), was a United States Supreme Court case in which the court held that the interpretation of collective-bargaining agreements must follow ordinary contract principles when that interpretation does not conflict with federal labor policy.

Kansas v. Nebraska, 574 U.S. 445 (2015), was a United States Supreme Court case in which the court held that, when a state knowingly fails to comply with an interstate compact, the Supreme Court may order that state to disgorge its profits from the violation or pay damages. If there is no danger of the violation happening again, no injunctive relief is necessary.

North Carolina State Board of Dental Examiners v. Federal Trade Commission, 574 U.S. 494 (2015), was a United States Supreme Court case on the scope of immunity from US antitrust law. The Supreme Court held that a state occupational licensing board that was primarily composed of persons active in the market it regulates has immunity from antitrust law only when it is actively supervised by the state. The North Carolina Board of Dental Examiners had relied on the Parker immunity doctrine, established by the Supreme Court case Parker v. Brown, which held that actions by state governments acting in their sovereignty did not violate antitrust law.

Yates v. United States, 574 U.S. 528 (2015), was a United States Supreme Court case in which the Court construed 18 U.S.C. § 1519, a provision added to the federal criminal code by the Sarbanes-Oxley Act, to criminalize the destruction or concealment of "any record, document, or tangible object" to obstruct a federal investigation. By a 5-to-4 vote, the Court stated that the term "tangible object" as used in this section means an object used to record or preserve information, and that this did not include fish.