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J. T. v. Osseo Area Schools, Independent School Dist. No. 279
Multiple federal laws afford protections for children with disabilities in public schools. Three statutory schemes are particularly relevant to this case. Section 504 of the Rehabilitation Act of 1973 provides that no qualified individual with a disability shall be excluded from participation in, denied the benefits of or subjected to discrimination under any federally funded program solely by reason of her or his disability.
Similarly, Title II of the Americans with Disabilities Act prohibits qualified individuals with disabilities from being excluded from or denied the benefits of a public entity’s services, programs or activities by reason of disability. While the antidiscrimination guarantees of Section 504 and Title II apply in a variety of contexts, the Individuals with Disabilities Education Act offers federal funds to States in exchange for the commitment to furnish the core guarantee of a “free appropriate public education” to children in public schools with certain physical or intellectual disabilities. The centerpiece of the IDEA is the provision of an individualized educational program, which spells out a plan to meet all of the educational needs of a child with a qualifying disability.
A.J.T. is a teenage girl with a rare form of epilepsy that severely limits her physical and cognitive functioning. She suffers from seizures that are so frequent in the mornings that she cannot attend school before noon, though she is alert and able to learn from noon until 6 p.m. For the first few years of her schooling, school officials accommodated A.J.T.’s condition by permitting her to avoid morning activities and instead receive evening instruction. But when A.J.T.’s family moved to Minnesota in 2015, her new school district Osseo Area Public Schools, Independent District No. 279 denied her parents’ repeated requests to include evening instruction in A.J.T.’s IEP. Between 2015 and 2018, A.J.T. received only 4.25 hours of instruction daily compared to the typical 6.5-hour school day for nondisabled students in the district. After even further cuts to A.J.T.’s school day were proposed, her parents filed an IDEA complaint with the Minnesota Department of Education, alleging that the school’s refusal to provide afterhours instruction denied A.J.T. a free appropriate public education.
An administrative law judge determined that the school district had violated the IDEA and ordered the school to provide compensatory education and evening instruction. Federal courts subsequently affirmed A.J.T.’s IDEA victory.
A.J.T. and her parents then sued under the ADA and the Rehabilitation Act, requesting a permanent injunction, reimbursement for certain costs and compensatory damages. The district court granted summary judgment for the school, and the 8th Circuit Court of Appeals affirmed. In so holding, the 8th Circuit stated that a school district’s failure to provide a reasonable accommodation wasn’t enough to state a prima facie case of discrimination under Monahan v. Nebraska, which requires a plaintiff to prove conduct by school officials rising to the level of bad faith or gross misjudgment.
The U.S. Supreme Court held that schoolchildren bringing ADA and Rehabilitation Act claims related to their education aren’t required to make a heightened showing of bad faith or gross misjudgment but instead are subject to the same standards that apply in other disability discrimination contexts.
The court vacated the judgment and remanded the case.
Chief Justice John Roberts Jr. delivered the opinion for a unanimous court. Justice Clarence Thomas filed a concurring opinion, in which Justice Brett Kavanaugh joined. Justice Sonia Sotomayor filed a concurring opinion, in which Justice Ketanji Brown Jackson joined
The Barring Act establishes default settlement procedures for claims against the government and subjects most claims to a six-year limitations period. However, the act includes an exception. If another law confers authority to settle a claim against the government, that law displaces the Barring Act’s settlement mechanism, including its limitations period.
In 2002, Congress enacted a statute providing combat-related special compensation to qualifying veterans who have suffered combat-related disabilities. Under federal law, retired veterans generally must waive a portion of their military retirement pay to receive Veterans Affairs disability benefits, but the CRSC statute allows combat disabled retirees to receive special compensation up to the amount of waived retired pay.
Simon Soto served in the Marine Corps from 2000 to 2006, including two tours in Operation Iraqi Freedom. He was medically retired in 2006 and later received a 100% disability rating for post-traumatic stress disorder from the VA. In 2016, Soto applied for CRSC payments. The Secretary of the Navy approved his application but limited retroactive compensation to six years, citing the Barring Act’s limitations period. Soto filed a class-action lawsuit arguing that the Barring Act’s six-year limitations period doesn’t apply to CRSC claims because the CRSC statute constitutes another law that provides its own settlement mechanism.
The district court granted summary judgment for the class, but the Federal Circuit reversed, holding that the CRSC statute doesn’t explicitly grant settlement authority and therefore cannot displace the Barring Act.
The U.S. Supreme Court held that the CRSC statute confers authority to settle CRSC claims and thus displaces the Barring Act’s settlement procedures and limitations period.
It reversed and remanded.
Justice Clarence Thomas delivered the opinion for a unanimous court.
Federal inmate Donte Parrish alleged that he was placed in restrictive segregated confinement for 23 months based on his suspected involvement in another inmate’s death. After a hearing officer cleared him of wrongdoing, Parrish filed suit in federal district court seeking damages for his time in segregated confinement.
The district court dismissed his case on March 23, 2020, holding that some claims were untimely and others unexhausted. When the court’s order reached the federal prison two weeks later, Parrish was no longer there, having been transferred to a different facility. Parrish received the dismissal order three months after it was issued and promptly filed a notice of appeal, explaining his delayed receipt. The 4th Circuit Court of Appeals recognized that Parrish’s notice of appeal came after the 60-day appeal period for suits against the U.S., so it construed Parrish’s filing as a motion to reopen the time to appeal under Section 2107(c). On remand, the district court granted reopening for 14 days.
Parrish didn’t file a second notice of appeal. Although both Parrish and the U.S. argued that the original notice of appeal was sufficient, the 4th Circuit held that Parrish’s failure to file a new notice of appeal within the reopened appeal period deprived the court of jurisdiction.
The U.S. Supreme Court held that 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.
It reversed and remanded.
Justice Sonia Sotomayor delivered the opinion of the court, in which Chief Justice John Roberts Jr. and Justices Sameul Alito Jr., Elena Kagan, Brett Kavanuagh and Amy Coney Barrett joined. Justice Ketanji Brown Jackson filed an opinion concurring in the judgment, in which Justice Clarence Thomas joined. Justice Neil Gorsuch filed a dissenting opinion.
Gorsuch noted that he would have dismissed this case as improvidently granted.
On Oct. 18, 2017, the FBI raided the wrong house in suburban Atlanta. Officers meant to execute search and arrest warrants at a suspected gang hideout at 3741 Landau Lane but instead stormed 3756 Denville Trace, a quiet family home occupied by petitioners Hilliard Toi Cliatt, his partner Curtrina Martin, and her 7-year-old son. A six-member SWAT team breached the front door, detonated a flash-bang grenade, and assaulted the innocent occupants before realizing their mistake. The cause of the error was Special Agent Lawrence Guerra’s reliance on a personal GPS device, combined with the team’s failure to notice the street sign for “Denville Trace” and the house number visible on the mailbox.
Left with personal injuries and property damage, petitioners sued the U.S. under the Federal Tort Claims Act seeking damages resulting from the officers’ alleged negligent and intentional actions during the raid. The district court granted summary judgment to the government. The 11th Circuit Court of Appeals affirmed, applying a unique approach to FTCA claims.
The FTCA waives the federal government’s sovereign immunity from suit as to certain torts committed by federal employees acting within the scope of their employment. But that waiver is subject to statutory exceptions, including two relevant to a law enforcement misconduct case like this one. The first is the intentional-tort exception in Section 2680(h), which bars claims against the government for 11 enumerated intentional torts. The second is the discretionary-function exception in Section 2680(a), which bars claims against the government that are based on an official’s exercise of discretionary functions. Section 2680(h) also contains a “law enforcement proviso” which countermands the intentional-tort exception, allowing suits for six specified torts (including assault, battery, false imprisonment, and false arrest) to proceed against the U.S. when the torts are committed by “investigative or law enforcement officers.”
While most courts hold that the law enforcement proviso applies only to the intentional-tort exception, the 11th Circuit’s approach is different in two key respects. First, the 11th Circuit alone holds that the proviso overrides all exceptions in Section 2680, including the discretionary-function exception, meaning that intentional-tort claims covered by the proviso automatically proceed to the merits without further analysis of other applicable Section 2680 exceptions. Second, to compensate for this plaintiff-friendly approach, the 11th Circuit permits the government to assert a restrictive supremacy clause defense at the liability stage, allowing the government to escape liability when an officer’s actions have some nexus with furthering federal policy and reasonably comply with the full range of federal law.
Applying its distinctive approach, the 11th Circuit held that the law enforcement proviso protected petitioners’ intentional-tort claims from both the intentional-tort and discretionary-function exceptions.
The court dismissed petitioners’ negligence claims under the discretionary-function exception, reasoning that Guerra enjoyed discretion in preparing for the warrant execution. On the merits of the remaining intentional-tort claims, the court found the government had a valid supremacy clause defense and granted summary judgment for the U.S.
The U.S. Supreme Court held that 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.
It also held that the supremacy clause doesn’t afford the U.S. a defense in FTCA suits. The FTCA is the supreme federal law governing the U.S.’s tort liability and serves as the exclusive remedy for damages claims arising from federal employees’ official conduct. The statute generally makes the government liable under state law on the same terms as a private individual would be liable under the law of the place where the tortious conduct occurred.
On remand, the Supreme Court explained that the 11th 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).
The court vacated the judgment and remanded the case.
Justice Neil Gorsuch , delivered the opinion for a unanimous court. Justice Sonia Sotomayor filed a concurring opinion, in which Justice Ketanji Brown Jackson joined.
This case involves the jurisdiction of the U.S. Tax Court over appeals from collection due process hearings when there is no longer an ongoing levy. The dispute here began in 2012, when Jennifer Zuch and her then-husband Patrick Gennardo each filed an untimely 2010 federal tax return. Gennardo subsequently submitted an offer in compromise to resolve outstanding tax liabilities. This offer implicated $50,000 in estimated tax payments that the couple had previously sent to the IRS; following the offer, the IRS applied these payments to Gennardo’s account. For her part, Zuch later amended her 2010 tax return to report additional income, which resulted in an additional $28,000 in taxes due. But Zuch maintained that the IRS should have credited the couple’s $50,000 payment to her account, entitling her to a $22,000 refund.
The IRS disagreed and sought to collect her unpaid taxes by placing a levy on her property pursuant to its authority under Section 6331(a). Zuch requested a collection due process hearing to contest the levy. The appeals officer rejected Zuch’s argument about the misapplied $50,000 tax payment and issued a notice of determination sustaining the levy action under Section 6330(c)(3). Zuch then appealed to the tax court under Section 6330(d)(1). During the multi-year proceedings before the agency and the tax court that followed, Zuch filed several annual tax returns showing overpayments. Each time, the IRS applied these overpayments to her outstanding 2010 tax liability rather than issuing refunds. Once Zuch’s liability reached zero, the IRS moved to dismiss the tax court proceeding as moot, arguing that the tax court lacked jurisdiction because the IRS no longer had a basis to levy on Zuch’s property. The tax court agreed. But on appeal, the 3rd Circuit Court of Appeals vacated the dismissal, holding that the IRS’s abandonment of the levy didn’t moot the tax court proceedings.
The U.S. Supreme Court held that 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.
It reversed and remanded.
Justice Amy Coney Barrett delivered the opinion of the court, in which Chief Justice John Roberts Jr. and Justices Clarence Thomas, Samuel Alito Jr., Sonia Sotomayor, Elena Kagan, Brett Kavanaugh and Ketanji Brown Jackson joined. Justice Neil Gorsuch filed a dissenting opinion.
Gorsuch asserted that if Zuch had prevailed on her claim, the IRS wouldn’t have a basis for keeping her overpayments in later years.
“Nothing prevented the Tax Court from saying as much,” Gorsuch wrote. “Today’s decision holding otherwise leaves [Zuch] with no meaningful way to pursue her argument that the IRS erred or to recoup the overpayments she believes the IRS has wrongly retained. Along the way, the [court’s] decision hands the IRS a powerful new tool to avoid accountability for its mistakes in future cases like this one.”
Danny Rivers was convicted in Texas state court of continuous sexual abuse of a child and related charges. After unsuccessfully seeking direct appeal and state habeas relief, Rivers filed his first federal habeas petition under Section 2254 in August 2017, asserting claims of prosecutorial misconduct, ineffective assistance of counsel and other constitutional violations. The district court denied the petition in September 2018, and Rivers appealed to the 5th Circuit Court of Appeals, which granted a certificate of appealability on his ineffective-assistance claim in July 2020.
While his appeal was pending, Rivers obtained his trial counsel’s client file, which contained a state investigator’s report that he believed was exculpatory. After the 5th Circuit denied his request to supplement the record on appeal, Rivers filed a second Section 2254 petition in the district court based on this newly discovered evidence.
The district court classified this second-in-time filing as a second or successive habeas application under Section 2244(b) and transferred it to the 5th Circuit for authorization to file. Rivers appealed the transfer order, and the 5th Circuit affirmed, holding that the fact that Rivers’s first petition was still on appeal did not permit him to circumvent the requirements for successive petitions under Section 2244 as to his second filing.
The U.S. Supreme Court held that 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).
The court affirmed the judgment.
Justice Ketanji Brown Jackson delivered the opinion for a unanimous court.