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In Waetzig v. Halliburton Energy Services, Inc., the Supreme Court held that a case voluntarily dismissed without prejudice under Federal Rule of Civil Procedure 41(a) qualifies as a "final proceeding" under Rule 60(b), allowing a district court to reopen the case. Gary Waetzig sued Halliburton for age discrimination but later dismissed his case without prejudice and pursued arbitration. After losing in arbitration, he sought to reopen his federal case and vacate the arbitration award under Rule 60(b). The district court granted his motion, but the Tenth Circuit reversed. Writing for a unanimous Court, Justice Alito explained that the text, context, and history of Rule 60(b) support treating a voluntary dismissal as final for purposes of post-judgment relief. The ruling clarifies that Rule 60(b) relief is discretionary and distinct from appellate finality, ensuring courts retain flexibility to revisit cases when necessary. The Court reverses and remands for further proceedings.

Justice Alito delivered the opinion for a unanimous Court.

Read by RJ Dieken.

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In Glossip v. Oklahoma, the Supreme Court held that a criminal defendant is entitled to a new trial when the prosecution knowingly fails to correct false testimony and that error could have contributed to the verdict. Richard Glossip was convicted and sentenced to death based primarily on the testimony of Justin Sneed, who claimed Glossip orchestrated the 1997 murder of Barry Van Treese. Years later, newly discovered evidence revealed that the prosecution withheld key documents, allowed Sneed to give false testimony about his mental health history, and engaged in other misconduct. Oklahoma’s attorney general ultimately conceded that Glossip’s conviction was tainted and supported granting him a new trial, but the Oklahoma Court of Criminal Appeals rejected the argument and upheld the conviction. The Supreme Court ruled that the prosecution’s failure to correct Sneed’s false testimony violated Napue v. Illinois, which prohibits the government from allowing false evidence to go unchallenged. Given that Sneed’s credibility was central to Glossip’s conviction, the Court found a reasonable likelihood that the error influenced the jury and reversed the lower court’s decision, granting Glossip a new trial.

Justice Sotomayor delivered the opinion of the Court, joined by Chief Justice Roberts and Justices Kagan, Kavanaugh, and Jackson, with Justice Barrett joining in part. Justice Barrett also filed a separate opinion concurring in part and dissenting in part. Justice Thomas filed a dissenting opinion, joined by Justice Alito, with Justice Barrett joining certain sections. Justice Gorsuch took no part in the decision.

Read by Jeff Barnum.

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In Lackey v. Stinnie, the Supreme Court held that plaintiffs who secure only preliminary injunctive relief before their case becomes moot do not qualify as "prevailing parties" entitled to attorney’s fees under 42 U.S.C. §1988(b). Virginia drivers challenged the constitutionality of a law suspending licenses for unpaid court fines. After a district court granted a preliminary injunction, the Virginia General Assembly repealed the law, and restored licenses -- making the case moot. Writing for the Court, Chief Justice Roberts explains that preliminary injunctions do not constitute enduring, merits-based relief because they are temporary and do not resolve the case. The ruling reinforces prior precedents, including Buckhannon Board & Care Home v. West Virginia DHHR and Sole v. Wyner, requiring a judicially sanctioned, enduring change in the legal relationship between parties to qualify for attorney’s fees. The Court also notes that this decision does not apply to consent decrees, since that does provide lasting relief that's sanctioned by a court. The Court reverses the Fourth Circuit's en banc decision, emphasizing a bright-line rule to ensure clarity in fee disputes.

Chief Justice Roberts writing for the majority, joined by Justices Thomas, Alito, Kagan, Gorsuch, Kavanaugh, and Barrett. Justice Jackson filed a dissenting opinion, which was joined by Justice Sotomayor.

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In Williams v. Reed, the Supreme Court rejects Alabama’s administrative-exhaustion rule, holding that states cannot require claimants to complete an allegedly delayed administrative process before filing a 42 U.S.C. §1983 lawsuit challenging that very delay. Writing for the Court, Justice Kavanaugh explains that the Alabama Supreme Court’s decision effectively immunized state officials from §1983 claims, contradicting prior precedents such as Felder v. Casey and Haywood v. Drown. The ruling clarifies that a state law cannot shield officials from federal civil rights litigation by erecting procedural roadblocks. The Court reverses and remands, rejecting arguments that alternative remedies like mandamus petitions justify Alabama’s exhaustion requirement. Justice Thomas dissents, joined in part by Justices Alito, Gorsuch, and Barrett, arguing that the Court improperly disregards Alabama’s jurisdictional framework.

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In Wisconsin Bell, Inc. v. United States ex rel. Heath, the Supreme Court unanimously affirms that E-Rate reimbursement requests qualify as “claims” under the False Claims Act (FCA). The case centers on whether federal subsidies distributed through the E-Rate program—funded by contributions from telecommunications carriers and administered by a private corporation—constitute government-provided money for FCA purposes.

Writing for the Court, Justice Kagan holds that because the government transferred over $100 million from the U.S. Treasury into the E-Rate fund, it “provided” a portion of the money requested, satisfying the statutory definition under 31 U.S.C. §3729(b)(2)(A)(ii)(I). The ruling rejects Wisconsin Bell’s argument that the government was merely an intermediary, emphasizing that the government actively collected, managed, and disbursed funds, akin to its broader fiscal operations.

The decision affirms the Seventh Circuit and allows the FCA suit to proceed. Justices Thomas and Kavanaugh each filed concurring opinions (both of whom signed onto one another's), and Justice Alito signed onto a portion of the Thomas concurrence.

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In Republic of Hungary v. Simon, the Supreme Court held the mere allegation of commingling funds doesn't satisfy the commercial nexus requirement under the Foreign Sovereign Immunities Act (FSIA)’s expropriation exception. Holocaust survivors sued Hungary and its national railway, seeking damages for property seized during World War II, arguing that Hungary liquidated the property, commingled the proceeds with government funds, and later used some of those funds in U.S. commercial activities.

The Court ruled that the FSIA requires plaintiffs to plausibly trace specific expropriated property or its direct proceeds to commercial activity in the United States. A broad commingling theory, doesn't meet this standard. The Court vacated the D.C. Circuit’s ruling and remanded the case for further proceedings. Justice Sotomayor writing for a unanimous Court.

Read by Jeff Barnum.

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Andrew v. White

In Andrew v. White, the Supreme Court reviewed the Tenth Circuit's decision to reject Brenda Andrew's due process challenge to her conviction for murder. Andrew was charged with murdering her husband -- at trial, the prosecution introduced prejudicial evidence with little probative value to the issue of her guilt. This included her sexual history, personal attire, and alleged failings as a wife and mother. The prosecution further elicited evidence meant to contrast this with her husband's character. On appeal, Andrew alleged that these irrelevant characteristics were meant to improperly impute the murder to her.

The Tenth Circuit rejected her due process claim, but the Supreme Court disagreed. Though the decision below reasoned that there was no general rule that the wrongful admission of prejudicial evidence violates due process -- the Supreme Court disagreed. Relying on Payne v. Tennessee, the Court clarified that introducing inadmissible prejudicial evidence, may violate the Due Process Clause when it renders the trial fundamentally unfair. So, the case was remanded to the Tenth Circuit to determine whether the prosecution's inflammatory evidence materially affected the outcome of the trial.

Per curiam decision. Justice Alito concurring. Justice Thomas dissenting.

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***Special edition -- with no syllabus in this case -- the recording includes the entire per curiam decision, as well as the two concurring opinions.***

In TikTok Inc. v. Garland, the Supreme Court reviewed the constitutionality of the Protecting Americans from Foreign Adversary Controlled Applications Act. The Act prohibits U.S. companies from providing services to TikTok unless its U.S. operations are separated from Chinese control.

TikTok and a group of U.S. users argued that the Act constitutes a content-based restriction on speech because it singles out TikTok's platform, targeting the content it hosts and its unique mode of communication. They contended that such a restriction is subject to strict scrutiny, the highest level of judicial review, and that the government could not meet the burden of proving the law was narrowly tailored to achieve a compelling interest. TikTok asserted that less restrictive alternatives, such as data localization or transparency measures, could address any national security concerns without burdening free expression.

The government countered that PAFACA is content-neutral, as its primary aim is to mitigate national security risks stemming from TikTok’s data collection practices and its connections to ByteDance Ltd., a Chinese-owned company potentially subject to Chinese government influence. The government maintained that the Act is a permissible regulation addressing the platform’s structural risks rather than the speech it hosts and argued that national security constitutes a significant governmental interest.

The Court, in a per curiam opinion, ruled that PAFACA does not violate the First Amendment. It determined that the Act is content-neutral, targeting the ownership and control of TikTok rather than the content on its platform. Applying intermediate scrutiny, the Court held that the Act was narrowly tailored to address well-substantiated national security concerns. The ruling emphasized Congress’s findings regarding the risks posed by TikTok’s data collection practices and its potential for misuse by a foreign adversary.

The Court’s decision affirmed the legality of requiring ByteDance to divest its U.S. operations by January 19, 2025, or face a nationwide ban.

Read the full decision here.