Opinion Summary: Soto v. United States | Date Decided: 6/12/25 | Case No. 24-320

Link to Docket: Here.

Question Presented:

Holding:

Result:

Voting Breakdown:

Link to Opinion: Here.

Oral Advocates:

• For Petitioner:
• For Respondent:

Website Link to Oral Argument: Here.

Apple Podcast Link to Oral Argument: Here.

Opinion Summary: Martin v. United States | Date Decided: 6/12/25 | Case No. 24–362

Link to Docket: Here.

Background:

Petitioners are the innocent victims of a wrong-house raid conducted by an FBI SWAT team in Atlanta, Georgia. Seeking a remedy for torts committed against them, Petitioners brought a cause of action against the United States under the Federal Tort Claims Act. In its opinion below, the Eleventh Circuit held that all of Petitioners' FTCA claims are barred by sovereign immunity supplied either through the Constitution's Supremacy Clause or the FTCA's discretionary-function exception. In one or more ways, the opinion below conflicts with decisions from every other circuit.

Questions Presented:

1. Whether the Constitution's Supremacy Clause bars claims under the FTCA-a federal statute enacted by Congress-when the negligent or wrongful acts of federal employees have some nexus with furthering federal policy and can reasonably be characterized as complying with the full range of federal law.
2. Whether the FTCA's discretionary-function exception bars claims for torts arising from wrong-house raids and similar negligent or wrongful acts by federal employees.

Holdings:

1. The law enforcement proviso in Section 2680(h) overrides only the intentional-tort exception in that subsection, not the discretionary-function exception or other exceptions throughout Section 2680.
2. The Supremacy Clause does not afford the United States a defense in FTCA suits.
3. On remand, the Eleventh Circuit should consider whether subsection (a)'s discretionary-function exception bars either the plaintiffs' negligent- or intentional-tort claims—undertaking that assessment without reference to the mistaken view that the law enforcement proviso applies to subsection (a).

Result: Vacated and remanded.

Voting Breakdown: 9-0. Justice Gorsuch delivered the opinion for a unanimous Court. Justice Sotomayor filed a concurring opinion, in which Justice Jackson joined.

Link to Opinion: Here.

Oral Advocates:

• For Petitioners: Patrick M. Jaicomo
• For Respondents: Frederick Liu, Assistant to the Solicitor General
• For Court-Appointed Amicus Curiae in Support of Judgment Below on Question 1: Christopher E. Mills

Website Link to Oral Argument: Here.

Apple Podcast Link to Oral Argument: Here.

Timestamps:

Opinion Summary: Parrish v. United States | Date Decided: 6/12/25 | Case No. 24–275

Link to Docket: Here.

Background:

Ordinarily, litigants must file a notice of appeal within 30 or 60 days of an adverse judgment. 28 U.S.C. § 2107(a)-(b). Under 28 U.S.C. § 2107(c) and Fed. R. App. P. 4(a)(6), however, district courts can reopen an expired appeal period when a party did not receive timely notice of the judgment. The Courts of Appeals have divided about whether a notice of appeal filed after the expiration of the ordinary appeal period but before the appeal period is reopened becomes effective once reopening is granted.

Holding: A litigant who files a notice of appeal after the original appeal deadline but before the court grants reopening need not file a second notice after reopening. The original notice relates forward to the date reopening is granted.

Result: Reversed and remanded.

Voting Breakdown: 8-1. Justice Sotomayor delivered the opinion of the Court, in which Chief Justice Roberts and Justices Alito, Kagan, Kavanaugh and Barrett joined. Justice Jackson filed an opinion concurring in the judgment, in which Justice Thomas joined. Justice Gorsuch filed a dissenting opinion.

Link to Opinion: Here.

Oral Advocates:

• For petitioner: Amanda Rice, Detroit, Mich.
• For respondent in support of petitioner: Aimee Brown, Assistant to the Solicitor General, Department of Justice, Washington, D.C.
• For Court-appointed amicus curiae in support of judgment below: Michael R. Huston, Phoenix, Ariz.

Website Link to Oral Argument: Here.

Apple Podcast Link to Oral Argument: Here.

Opinion Summary: Commissioner of Internal Revenue v. Zuch | Date Decided: 6/12/25 | Case No. 24–416

Link to Docket: Here.

Question Presented: Whether a proceeding under 26 U.S.C. 6330 for a pre-deprivation determination about a levy proposed by the Internal Revenue Service to collect unpaid taxes becomes moot when there is no longer a live dispute over the proposed levy that gave rise to the proceeding.

Holding: The Tax Court lacks jurisdiction under Section 6330 to resolve disputes between a taxpayer and the IRS when the IRS is no longer pursuing a levy.

Result: Reversed and remanded.

Voting Breakdown: 8-1. Justice Barrett delivered the opinion of the Court, in which Chief Justice Roberts and Justices Thomas, Alito, Sotomayor, Kagan, Kavanaugh and Jackson joined. Justice Gorsuch filed a dissenting opinion.

Link to Opinion: Here.

Oral Advocates:

• For petitioner: Erica L. Ross, Assistant to the Solicitor General, Department of Justice, Washington, D.C.
• For respondent: Shay Dvoretzky, Washington, D.C.

Website Link to Oral Argument: Here.

Apple Podcast Link to Oral Argument: Here.

Opinion Summary: Rivers v. Guerrero | Date Decided: 6/12/25 | Case No. 23-1345

Link to Docket: Here.

Background:

Under the federal habeas statute, a prisoner "always gets one chance to bring a federal habeas challenge to his conviction," Banister v. Davis, 590 U.S. 504, 509 (2020). After that, the stringent gatekeeping requirements of 28 U.S.C. § 2244(b)(2) bar nearly all attempts to file a "second or successive habeas corpus application." Here, petitioner sought to amend his initial habeas application while it was pending on appeal. The Fifth Circuit applied § 2244(b)(2) and rejected the amended filing.

The circuits are intractably split on whether § 2244(b)(2) applies to such filings. The Fifth, Sixth, Seventh, Eighth, Ninth, and Eleventh Circuits hold that § 2244(b)(2) categorically applies to all second-in-time habeas filings made after the district court enters final judgment. The Second Circuit disagrees, applying § 2244(b)(2) only after a petitioner exhausts appellate review of his initial petition. And the Third and Tenth Circuits exempt some second-in-time filings from § 2244(b)(2), depending on whether a prisoner prevails on his initial appeal (Third Circuit) or satisfies a seven-factor test (Tenth Circuit).

Question Presented: Whether § 2244(b)(2) applies (i) only to habeas filings made after a prisoner has exhausted appellate review of his first petition, (ii) to all second-in-time habeas filings after final judgment, or (iii) to some second-in-time filings, depending on a prisoner's success on appeal or ability to satisfy a seven-factor test.

Holding: Once a district court enters its judgment with respect to a first-filed habeas petition, a second-in-time filing qualifies as a "second or successive application" properly subject to the requirements of Section 2244(b).

Result: Affirmed.

Voting Breakdown: 9-0. Justice Jackson delivered the opinion for a unanimous court. There were no concurring opinions.

Link to Opinion: Here.

Oral Advocates:

• For Petitioner: Peter A. Bruland, Washington, D.C.
• For Respondent: Aaron L. Nielson, Solicitor General, Austin, Tex.; and Matthew Guarnieri, Assistant to the Solicitor General, Department of Justice, Washington, D. C. (for United States, as amicus curiae.)

Website Link to Oral Argument: Here.

Apple Podcast Link to Oral Argument: Here.

Supreme Court Roundup: Decisions, Emergency Actions, and New Grants

In this episode, we analyze the Supreme Court's recent activities across three key areas:

• Six unanimous decisions released on June 5th, 2025
• Two significant emergency docket interventions involving DOGE
• Three major cases granted certiorari via June 6th, 2025 Order

June 5, 2025 Unanimous Decisions

• Remarkable consensus: 5 unanimous decisions, 1 8-1 dismissal
• Strategic clearing of non-controversial cases with 30 contentious cases pending
• Justice Thomas's concurrences in 5 of 6 cases challenging judge-made doctrines
• Heavy focus on procedural rules as proxies for deeper policy debates

Emergency Docket Actions

1. U.S. DOGE Service v. CREW: Court limits discovery of internal executive communications

• Court orders narrowing of discovery rather than outright prohibition
• Decision based on separation of powers principles
• Justices Sotomayor, Kagan, and Jackson dissented

2. Social Security Administration v. AFSCME: Court allows DOGE access to sensitive SSA records

• Justice Jackson's forceful dissent highlighting privacy concerns
• Lower courts' compromise solution rejected by majority
• Concerns about disclosure of personal data without legal determination

Certiorari Grants

1. Coney Island Auto Parts v. Burton | Case No. 24-808

• Docket Link: Here
• Question Presented: Whether a motion to vacate a void judgment under Rule 60(b)(4) must be filed within a "reasonable time"
• Key Facts: Coney Island claims improper service six years after default judgment
• Petitioner's Argument: Void judgments are legal nullities from the start; no time limit should apply
• Respondent's Argument: Rule 60(c)(1) explicitly requires "reasonable time" with no exceptions
• Stakes: Balance between jurisdictional principles and need for legal finality

2. Rutherford v. United States | Case No. 24-820 (Consolidated with Carter v. United States | Case No. 24-860)

• Docket Link: Here
• Question Presented: Whether the Sentencing Commission exceeded its authority in allowing courts to consider non-retroactive changes in law as "extraordinary and compelling reasons" for sentence reduction
• Key Fact: Carter received 70-year sentence under pre-First Step Act "stacking" provisions that would result in much shorter sentence today
• Petitioner's Argument: Commission has broad authority to define "extraordinary and compelling reasons"; gross disparities qualify
• Government's Argument: Commission can't circumvent Congress's decision not to make First Step Act retroactive
• Stakes: Potential relief for hundreds of federal prisoners serving lengthy "stacked" sentences

3. Hamm v. Smith | Case No. 24-872

• Docket Link: Here
• Question Presented: How courts should apply the clinical definition of intellectual disability when all IQ scores are above 70
• Key Fact: Smith has five IQ scores (75, 74, 72, 78, 74) all above 70 but significant adaptive deficits
• Petitioner's Argument: Multiple IQ scores above 70 should preclude intellectual disability finding; states should be able to require proof of IQ ≤70
• Respondent's Argument: Supreme Court precedent requires considering standard error of measurement and adaptive functioning when scores are in 70-75 range
• Stakes: Implementation of Atkins prohibition on executing intellectually disabled individuals; states' authority to define intellectual disability criteria

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Opinion Summary: Laboratory Corp. of America Holdings v. Davis | Date Decided: 6/5/25 | Case No. 24–304

In this episode, I breakdown the dismissal, Justice Kavanaugh's dissent and theories for the dismissal.

Link to Docket: Here.

Question Presented: Whether a federal court may certify a class action when some of its members lack any Article III injury.

Result: Dismissed as improvidently granted.

Voting Breakdown: 8-1. Per Curiam decision.  Justice Kavanaugh filed a dissenting opinion.

Link to Opinion: Here.

Oral Advocates:

• For Petitioner: Noel J. Francisco
• For United States, as Amicus Curiae: Sopan Joshi, Assistant to the Solicitor General
• For Respondents: Deepak Gupta

Website Link to Oral Argument: Here.

Apple Podcast Link to Oral Argument: Here.

Opinion Summary: Smith & Wesson Brands, Inc. v. Estados Unidos Mexicanos | Date Decided: 6/5/25 | Case No. 23–1141

Link to Docket: Here.

Background:

The Mexican Government sued leading members of the American firearms industry, seeking to hold them liable for harms inflicted by Mexican drug cartels. According to Mexico, America's firearms companies have engaged in a series of business practices for decades-from selling semi-automatic rifles, to making magazines that hold over ten rounds, to failing to impose various sales restrictions-that have created a supply of firearms later smuggled across the border and ultimately used by the cartels to commit crimes. Mexico asks for billions of dollars in damages, plus extensive injunctive relief imposing new gun-control measures in the United States. The district court dismissed the case under the Protection of Lawful Commerce in Arms Act (PLCAA), which generally bars suits against firearms companies based on criminals misusing their products. But the First Circuit reversed. It held that PLCAA does not bar this suit because Mexico stated a claim that defendants' business practices have aided and abetted firearms trafficking to the cartels, proximately harming the Mexican government.

Questions Presented:

1. Whether the production and sale of firearms in the United States is the "proximate cause" of alleged injuries to the Mexican government stemming from violence committed by drug cartels in Mexico.
2. Whether the production and sale of firearms in the United States amounts to "aiding and abetting" illegal firearms trafficking because firearms companies allegedly know that some of their products are unlawfully trafficked.

Holding: Because Mexico’s complaint does not plausibly allege that the defendant gun manufacturers aided and abetted gun dealers’ unlawful sales of firearms to Mexican traffickers, PLCAA bars the lawsuit.

Result: Reversed and remanded.

Voting Breakdown: 9-0. Justice Kagan delivered the opinion for a unanimous Court. Justice Thomas and Justice Jackson each filed concurring opinions.

Link to Opinion: Here.

Oral Advocates:

• For petitioners: Noel J. Francisco, Washington, D.C.
• For respondent: Catherine E. Stetson, Washington, D.C.

Website Link to Oral Argument: Here.

Apple Podcast Link to Oral Argument: Here.

Timestamps:

Opinion Summary: Catholic Charities Bureau, Inc. v. Wisconsin Labor and Industry Review Comm’n. | Date Decided: 6/5/25 | Case No. 24–154

Link to Docket: Here.

Question Presented:

Holding: The Wisconsin Supreme Court’s application of § 108.02(15)(h)(2) to petitioners violates the First Amendment.

Result: Reversed and remanded.

Voting Breakdown: 9-0. Justice Sotomayor delivered the opinion for a unanimous Court.  Justices Thomas and Jackson each filed concurring opinions.

Link to Opinion: Here.

Oral Advocates:

• For Petitioner:
• For Respondent:

Website Link to Oral Argument: Here.

Apple Podcast Link to Oral Argument: Here.

Timestamps: