federal courts

Michigan v. Bay Mills Indian Community

Issues: 
  1. Can a federal court exercise jurisdiction over a state suit alleging violations of the Indian Gaming Regulatory Act where the gaming activity is not located on Indian lands?
  2. Does tribal sovereign immunity bar a state from suing a tribe in federal court for violations of the Indian Gaming Regulatory Act?

In 2010, Bay Mills Indian Community used funds acquired through the Michigan Indian Land Claims Settlement Act to purchase property away from the tribe’s reservation and used the property to open a casino. Michigan sought an injunction to stop operation of the casino, which the state contends violates the Indian Gaming Regulatory Act ("IGRA") because it is not located on Indian lands. The district court granted an injunction to stop the gambling activities occurring  away from the reservation. The Sixth Circuit reversed, holding that it lacked jurisdiction over Michigan's suit because IGRA only establishes federal court jurisdiction when the gaming is conducted on Indian lands. The Sixth Circuit further concluded that Bay Mills was immune from suit because Congress did not expressly authorize such suits and Bay Mills did not waive its immunity. Michigan argues that the IGRA can grant federal court jurisdiction and abrogate tribal sovereign immunity. Bay Mills argues that the IGRA cannot abrogate tribal sovereign immunity, and even if it could it would only apply to suits on Indian lands. This case could substantially alter the relationship between states and tribes, and impact the creation and regulation of off-reservation gaming. Furthermore, the Supreme Court’s resolution of the sovereign immunity question could reshape the status of federally recognized tribes and impact the economic development of all federally recognized tribes.

Questions as Framed for the Court by the Parties: 

The Indian Gaming Regulatory Act, 25 U.S.C. § 2701 et seq. (IGRA), authorizes an Indian tribe to conduct class III gaming under limited circumstances and only on "Indian lands." 25 U.S.C. § 2710(d)(1). This dispute involves a federal court's authority to enjoin an Indian tribe from operating an illegal casino located off of "Indian lands." The petition presents two recurring questions of jurisprudential significance that have divided the circuits: 

  1. Whether a federal court has jurisdiction to enjoin activity that violates IGRA but takes place outside of Indian lands. 
  2. Whether tribal sovereign immunity bars a state from suing in federal court to enjoin a tribe from violating IGRA outside of Indian lands.

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Facts

Casino-style, or Class III, gaming is lawful on Indian lands under the Indian Gaming Regulatory Act (“IGRA”) if certain requirements are met. Michigan v. Bay Mills Indian Community, 695 F.3d 406, 410 (6th Cir.

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Sprint Communications Co. v. Jacobs

Issues: 

Should federal courts abstain from remedial actions—state administrative proceedings initiated by a private party—involving a federal question?

Sprint brought an action before the Iowa Utility Board to prevent Windstream, then called Iowa Telecom, from cutting off service to Sprint’s customers. After refusing Sprint’s request to cancel the hearing, the Board required Sprint to pay interstate access charges to Windstream. Sprint, thinking that the Iowa Utility Board did not have jurisdiction to make this determination, initiated suits in federal and state courts against Elizabeth S. Jacobs and other members of the Iowa Utility Board in their official capacity. In the federal suit, the district court granted the Board members’ abstention motion under Younger v. Harris—which requires a federal court to abstain from interfering with certain ongoing state judicial proceedings. The Eighth Circuit affirmed the abstention. The Supreme Court will clarify the difference between remedial and coercive actions, and determine whether Younger abstention applies to a federal suit when there is an ongoing remedial action in state court. The Court’s ruling implicates important issues of federalism including whether a party can seek federal judicial review of a state agency’s decision after the party voluntarily initiated the action.

Questions as Framed for the Court by the Parties: 

Whether the Eighth Circuit erred by concluding, in conflict with decisions of nine other circuits and this Court, that Younger abstention is warranted not only when there is a related state proceeding that is "coercive" but also when there is a related state proceeding that is, instead, "remedial."

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Facts

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Atlantic Marine Construction Co. v. United States District Court for the Western District of Texas

Issues: 
  1. Can forum-selection clauses render statutorily proper venue improper?
  2. How much weight should courts give forum-selection clauses under 28 U.S.C. § 1404(a)?

Petitioner, Atlantic, and Respondent, J-Crew, entered into a contract that included a forum-selection clause limiting venue to two courts in Virginia, including a federal court. Contrary to that provision, J-Crew filed suit in the Western District of Texas alleging breach of contract for nonpayment for contracted services. Atlantic asks the Supreme Court to reverse the lower courts and transfer the case to the venue specified by the contract. Atlantic argues that a valid forum-selection clause renders improper any venue not specified in the contract. In opposition, J-Crew contends that proper venue is defined by statute and that a forum-selection clause does not render improper a statutorily permissible forum. This case will resolve the circuit split regarding the enforceability of forum-selection clauses. Specifically, the Supreme Court will determine whether a § 1404(a) transfer is appropriate when a lawsuit is filed in violation of a valid forum-selection clause. This implicates the ability of private parties to contract around federal statutes, raising questions about the limits on the freedom of contract, the ability of plaintiffs to forum-shop, and the capacity for parties to secure a favorable choice-of-law by filing their case first.

Questions as Framed for the Court by the Parties: 

Following the Court's decision in M/S Bremen v. Zapata Off-Shore Co., 407 U.S. 1 (1972), the majority of federal circuit courts hold that a valid forum-selection clause renders venue “improper” in a forum other than the one designated by contract. In those circuits, forum-selection clauses are routinely enforced through motions to dismiss or transfer venue under Fed. R. Civ. P. 12(b)(3) and 28 U.S.C. § 1406. The Third, Fifth, and Sixth Circuits, however, follow a contrary rule. This Petition presents the following issues for review:

  1. Did the Court’s decision in Stewart Organization, Inc. v. Ricoh Corp., 487 U.S. 22 (1988), change the standard for enforcement of clauses that designate an alternative federal forum, limiting review of such clauses to a discretionary, balancing-of-conveniences analysis under 28 U.S.C. § 1404(a)?
  2. If so, how should district courts allocate the burdens of proof among parties seeking to enforce or to avoid a forum-selection clause?

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Facts

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The authors would like to thank Professor Kevin Clermont of Cornell Law School for his insight into the issues in this case.

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Standard Fire Insurance Co. v. Knowles

After suffering property damage in a 2010 hailstorm, Greg Knowles filed a class action lawsuit in Miller County, Arkansas, against the Standard Fire Insurance Company ("Standard Fire") for failure to pay a contractor's retention fee. Standard Fire tried to remove the case to federal court under the Class Action Fairness Act of 2005 (“CAFA”), alleging that the amount in controversy exceeded $5,000,000. Pursuant to CAFA, a federal court has jurisdiction over a class action only if the amount in controversy exceeds $5,000,000. The district court remanded the case to state court because Knowles's complaint stipulated that he would not seek more than $5,000,000 in damages for the class. Standard Fire argues that Knowles cannot defeat removal under CAFA by using a stipulation because it would bind absent class members before class certification and before Knowles could be declared an adequate class representative. Knowles argues that as master of his complaint, he is free to limit his claims, and that class members are not adversely affected by the stipulation. The Supreme Court will determine whether a named plaintiff in a class action, before being declared an adequate class representative, can limit the entire class's claims to $5,000,000 in damages in order to defeat an attempt to remove the case to federal court.

Questions as Framed for the Court by the Parties: 

When a named plaintiff attempts to defeat a defendant's right of removal under the Class Action Fairness Act of 2005 by filing with a class action complaint a “stipulation” that attempts to limit the damages he “seeks” for the absent putative class members to less than the $5,000,000 threshold for federal jurisdiction, and the defendant establishes that the actual amount in controversy, absent the “stipulation,” exceeds $5,000,000, is the "stipulation" binding on absent class members so as to destroy federal jurisdiction?

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Already, LLC v. Nike, Inc.

Nike, Inc., sued Already, LLC d/b/a Yums, for selling shoes that allegedly infringed on Nike’s trademark covering the Air Force 1 shoe line. Yums counterclaimed to cancel Nike’s trademark. Shortly after Yums’s counterclaim, Nike dropped its claim and promised Yums that Nike would not assert its trademark against any of Yums’s current or previous products. The district court dismissed Yums’s counterclaim and the court of appeals affirmed the dismissal. Yums argues that a controversy remains after Nike’s promise not to sue because Nike’s trademark continues to hinder Yums’s ability to compete in the athletic footwear business. Nike argues that a court cannot hear a trademark claim without a controversy, and that Nike’s promise not to sue eliminated any controversy involving the Air Force 1 trademark. The Supreme Court’s decision here may determine whether intellectual property owners can drop infringement actions without having to defend counterclaims challenging their intellectual property rights. This decision may have a significant impact on intellectual property litigation and on the risks associated with commencing an infringement action.

Questions as Framed for the Court by the Parties: 

Whether a federal district court is divested of Article III jurisdiction over a party's challenge to the validity of a federally registered trademark if the registrant promises not to assert its mark against the party's then-existing commercial activities?

Issue

Does a federal district court lose jurisdiction over a trademark cancellation claim after the trademark holder terminates any infringement actions and promises not to assert its trademark against the party seeking the trademark’s cancellation?

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Tibbals v. Carter (11-218)

Sean Carter was convicted of aggravated murder, aggravated robbery, and rape, and was sentenced to death in Ohio. His counsel filed a federal habeas corpus petition challenging his conviction and requested a pre-petition competency hearing to determine whether Carter was competent to participate in the federal habeas proceeding. The district court granted both the petition and the request. Two years later, the district court determined that Carter was incompetent and dismissed his petition while also stopping the one-year statute of limitations. When the warden at the facility where Carter is imprisoned challenged the district court's decision, the United States Court of Appeals for the Sixth Circuit determined that even though the district court was justified in finding Carter incompetent, the proper course of action was to stay, rather than dismiss, the habeas proceedings until Carter was competent. Another warden now argues that a district court does not have the authority to stay federal habeas proceedings, nor does Carter have a right to competence in his own habeas proceedings. How the Supreme Court decides this case will determine the balance between recognizing the finality of state-court criminal judgments and allowing federal courts to use their discretion to implement stays in federal habeas proceedings where a capital prisoner’s competence to assist counsel is questionable.

Questions as Framed for the Court by the Parties: 

1. Do capital prisoners possess a "right to competence" in federal habeas proceedings under Rees v. Peyton, 384 U.S. 312 (1966)?
2. Can a federal district court order an indefinite stay of federal habeas proceeding under Rees?

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United States district courts

The trial courts of the federal court system. Congress and the Constitution limit these courts and within these limits, the district courts have jurisdiction to hear nearly all categories of federal cases.  This includes both civil and criminal matters. There are 94 federal judicial districts including at least one district in each state, the District of Columbia, and Puerto Rico. Three United States territories  -- the Virgin Islands, Guam, and the Northern Mariana Islands -- have district courts that hear federal cases, including bankruptcy cases.

 

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Administrative Office of the United States Courts

The Administrative Office of the United States Courts (AO) is an administrative agency that is the central support entity for the judicial branch providing a wide range of administrative, legal, financial, management, program, and information technology services to the federal courts. It is directly supervised by the Judicial Conference of the United States, which sets the national and legislative policy of the federal judiciary.

 

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