Volume 592 — United States Reports

The Supreme Court of the United States handed down fourteen per curiam opinions during its 2020 term, which began October 5, 2020, and concluded October 3, 2021.

Taylor v. Riojas, 592 U.S. 7 (2020), was a United States Supreme Court case dealing with qualified immunity. It was the first case in which the Supreme Court relied on the obviousness of a constitutional violation to overturn a lower court's decision to grant qualified immunity.

The Religious Freedom Restoration Act of 1993 (RFRA) was enacted in the wake of Employment Div., Dept. of Human Resources of Ore. v. Smith, 494 U. S. 872, to provide a remedy to redress Federal… Held: RFRA's express remedies provision permits litigants, when appro- priate, to obtain money damages against federal offcia ls in their individ- ual capacities. Pp. 46–52.

Tanzin v. Tanvir, 592 U.S. 43 (2020), was a United States Supreme Court case involving legal remedies that could be sought by litigants against federal officials for violations of the Religious Freedom Restoration Act of 1993. In a unanimous decision issued December 10, 2020, the court ruled that the Act allowed for litigants to seek not only injunctive relief but also monetary damages.

Delaware’s Constitution contains a political balance requirement for ap- pointments to the State’s major courts. Held: Because Adams has not shown that he was “able and ready” to ap- ply for a judicial vacancy in the imminent future, he has failed to show a “personal,” “concrete,” and “imminent” injury necessary for Article III standing. Pp. 4–13. (a) Two aspects of standing doctrine are relevant here.

The Uniform Code of Military Justice (UCMJ) has long provided that a military offense, “punishable by death, may be tried and punished at any time without limitation.” 10 U. S. C. §843 (a). Held: Respondents’ prosecutions for rape under the UCMJ were timely. Pp. 2–9. (a) Respondents contend that the UCMJ phrase “punishable by death” means capable of punishment by death when all applicable law is taken into account.

Pharmacy benefit managers (PBMs) act as intermediaries between phar- macies and prescription-drug plans. Held: Arkansas’ Act 900 is not pre-empted by ERISA. Pp. 4–10. (a) ERISA pre-empts state laws that “relate to” a covered employee benefit plan. 29 U. S. C. §1144 (a). “[A] state law relates to an ERISA plan if it has a connection with or reference to such a plan.” Egelhoff 2 RUTLEDGE v. PHARMACEUTICAL CARE MANAGEMENT ASSN.

The 1949 interstate Pecos River Compact provides for equitable appor- tionment of the use of the Pecos River’s water by New Mexico and Texas. Held: New Mexico’s motion for credit for the evaporated water was not untimely. Both parties agreed to postpone the River Master’s resolu- tion of the evaporated-water issue. Neither party may now object to the negotiation procedure outlined by the River Master for resolving the dispute. Pp. 6–7. 2.

The Constitution requires an “Enumeration” of the Nation's population every ten years “in such Manner” as Congress “shall by Law direct.” Art. I, § 2, cl. 3. Held: The Court lacks jurisdiction because standing has not been shown and the case is not ripe for the Court's review. The administration has made plain its desire to exclude aliens without lawful status from the apportionment base.

Trump v. New York, 592 U.S. 125 (2020), was a United States Supreme Court case dealing with the 2020 United States census. It centered on the validity of a July 2020 executive memorandum from President Donald Trump to the Department of Commerce, which conducts and reports the census. The memo ordered the department to report the estimated counts of illegal immigrants in each state, allowing the president to exclude them for purposes of congressional apportionment. The memo was challenged by a coalition of U.S. states led by New York along with several cities and other organizations suing to block action on the memo.

The filing of a petition under the Bankruptcy Code automatically “cre- ates an estate” that, with some exceptions, comprises “all legal or eq- uitable interests of the debtor in property as… Held: The mere retention of estate property after the filing of a bank- ruptcy petition does not violate §362(a)(3) of the Bankruptcy Code. Under that provision, the filing of a bankruptcy petition operates as a “stay” of “any act” to “exercise control” over the property of the estate.

Federal Republic of Germany v. Philipp, 592 U.S. 169 (2021), was a United States Supreme Court case that dealt with the applicability of the Foreign Sovereign Immunities Act (FSIA) for heirs of victims of the Holocaust to sue Germany in the United States court systems for compensation for items that were taken by the Nazi Party during World War II. At issue in the case was whether claims fell within the FSIA's exception to sovereign immunity for "property taken in violation of international law", 28 U.S.C. §1605(a)(3), given that the sovereign here was alleged to have engaged in a taking of its own nationals' property; and whether courts can invoke the doctrine of international comity under the FSIA to abstain from exercising jurisdiction based on prudential considerations.

In 1992, petitioner Manfredo M. Salinas began seeking disability bene- fits under the Railroad Retirement Act of 1974 (RRA) based on serious injuries he suffered during his 15-year career with the… Held: The Board’s refusal to reopen a prior benefits determination is sub- ject to judicial review. Pp. 4–13. (a) The RRA makes judicial review available to the same extent that review is available under the Railroad Unemployment Insurance Act (RUIA).

Held: at a time when New York was lifting restrictions to refec t declining case rates, that the policy at issue was “far more severe than has been shown to be required to prevent the spread of the virus.” Id., at 18. No court—or, at any rate, no court with any sense of modesty— can make that claim here.

Brownback v. King, 592 U.S. 209 (2021), was a United States Supreme Court case in which the Court held that a dismissal for failure to state a claim under the Federal Tort Claims Act (FTCA) is a judgment on the merits that triggers the FTCA's judgment bar on future actions.

Immigration officials initiated removal proceedings against Clemente Avelino Pereida for entering and remaining in the country unlawfully, a charge Mr. Pereida did not contest. Held: Under the INA, certain nonpermanent residents seeking to cancel 2 PEREIDA v. WILKINSON Syllabus a lawful removal order bear the burden of showing they have not been convicted of a disqualifying offense.

United States Fish and Wildlife Service v. Sierra Club, Inc., 592 U.S. 261 (2021), was a United States Supreme Court case involving whether the use of a Freedom of Information Act (FOIA) request can be used to access documents from a U.S. agency that are protected under the deliberative process privilege exemption, in this specific case, draft biological opinions made and reviewed by the United States Fish and Wildlife Service (FWS) and the National Marine Fisheries Service (NMFS) prior to a final rulemaking decision by the Environmental Protection Agency (EPA) related to impacts on endangered aquatic species, requested by the Sierra Club.

Uzuegbunam v. Preczewski, 592 U.S. 279 (2021), is a decision by the Supreme Court of the United States, dealing with nominal damages to be awarded to individuals whose right to freedom of speech has been suppressed by an entity but subsequently rendered moot due to intervening circumstances. In an 8–1 decision, the Court held that such nominal damages satisfy the Article Three requirement of redressability, when awarded for a past violation of a legal rights.

Torres v. Madrid, 592 U.S. 306 (2021), was a United States Supreme Court case based on what constitutes a "seizure" in the context of the Fourth Amendment to the United States Constitution, in the immediate case, in the situation where law enforcement had attempted to use physical force to stop a suspect but failed to do so. The Court ruled in a 5–3 decision that the use of physical force with the intent to restrain a person, even if that fails to restrain the person, is considered a seizure.

Ford Motor Co. v. Montana Eighth Judicial District, 592 U.S. 351 (2021), was a U.S. Supreme Court case involving personal jurisdiction of a state court in product liability lawsuits against an out-of-state manufacturer. The case, consolidated with Ford Motor Co. v. Bandemer, involved two product liability lawsuits brought against the Ford Motor Company at the state level related to two drivers' injuries in separate accidents involving Ford's vehicles in Montana and Minnesota. Ford challenged the lawsuits as the vehicles in question were designed, manufactured, and sold in other states, and therefore Ford contended that the states in which the accidents actually occurred did not have specific personal jurisdiction over its allegedly tortious conduct.

Facebook, Inc. v. Duguid, 592 U.S. 395 (2021), was a United States Supreme Court case related to the definition and function of auto dialers under the Telephone Consumer Protection Act of 1991 (TCPA) to send unsolicited text messages. In a unanimous decision based on statutory interpretation of the TCPA, the Supreme Court ruled that auto dialers are defined by their function to either store or produce telephone numbers from a random or sequential number generator.

Prometheus Radio Project v. FCC, 592 US 414 (2021), is the general title of a series of cases heard by the U.S. Court of Appeals for the Third Circuit from 2003 to 2019 and finalized by the U.S. Supreme Court in 2021. A media activist group, Prometheus Radio Project, challenged new media ownership rules put forth by the Federal Communications Commission (FCC) in 2002. In the first court challenge in 2004, the Third Circuit overruled an attempt by the FCC to raise the limits of media ownership within markets and relax cross-ownership (radio, television, and newspaper) prohibitions, and determined that a diversity index used by the FCC had been formulated inconsistently.