Congressional intent

Mayo Foundation v. United States

Issues

Whether (1) Congress intended that the term “student” be given a broad construction under the Federal Insurance Contributions Act, and (2) the Treasury Department’s regulation construing “student” to exclude medical residents is arbitrary and unreasonable?

 

The Mayo Foundation is suing for a refund of FICA taxes paid on behalf of its medical residents. The IRS claims that medical residents are not students and thus are not eligible for the FICA exemption for student employment. The Treasury Department released regulations that deny the student exemption to any employee that works more than 40 hours per a week. The Mayo Foundation contends that the IRS’s interpretation of the term “student” is incorrect and contrary to congressional intent. If the court rules that medical residents are students, this could lead to significant tax savings for hospitals and residents while reducing the availability of worker protections for medical residents.

Questions as Framed for the Court by the Parties

Whether the Treasury Department can categorically exclude all medical residents and other  fulltime  employees from the definition of “student” in 26 U.S.C. § 3121(b)(10), which exempts from Social Security taxes “service performed in the employ of a school, college, or university” by a “student who is enrolled and regularly attending classes at such school, college, or university.”

FICA Tax

The tax dispute between the Respondent, United States of America (“IRS”), and the Petitioners, Mayo Foundation for Medical Education and Research, Mayo Clinic, and Regents of the University of Minnesota (“Mayo”), is over whether Mayo is responsible for paying 

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Additional Resources

Inside Higher Ed, Doug Lederman: High Court to Hear Tax Case (June 2, 2010)

chamberofcommerce.org, Tax Information Guide

 

 

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United States v. June

Issues

Can a two-year time limit for bringing a tort claim against the federal government be extended in situations where a claimant, despite exercising due diligence, could not have discovered the injury within that time window?

In 2010, Marlene June brought an administrative claim against the Federal Highway Administration (“FHWA”) under the Federal Tort Claims Act (“FTCA”), 28 U.S.C. § 2401(b), which the FHWA eventually denied. June then filed a wrongful-death suit against the government, which the district court dismissed as untimely because it was filed after the FTCA’s two-year statute of limitations period had already expired. This case turns on whether the two-year statute of limitations is subject to “equitable tolling,” wherein the statute of limitations does not begin to run for a plaintiff who, exercising due diligence, could not have discovered the injury in time to file. This case thus presents the Supreme Court with an opportunity address the ability of agencies to administer claims. 

Questions as Framed for the Court by the Parties

Whether the two-year time limit for filing an administrative claim with the appropriate federal agency under the Federal Tort Claims Act, 28 U.S.C. 2401(b), is subject to equitable tolling.

The Respondent in this case is Marlene June. See Brief for Petitioner, the United States of America, at II. She brought suit on behalf of her grandchild, the surviving child of her deceased son Andrew Edward Booth.

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Utility Air Regulatory Group v. EPA, American Chemistry Council v. EPA, Energy-Intensive Manufacturers v. EPA, Southeastern Legal Foundation v. EPA, Texas v. EPA, Chamber of Comm. v. EPA (Consolidated)

Issues

Does the Environmental Protection Agency have authority under the Clean Air Act to regulate stationary sources of greenhouse gas emissions?

 

Following the Supreme Court’s 2007 decision in Massachusetts v. EPA, the EPA began regulating greenhouse gas emissions from mobile sources, such as cars and trucks. The categorization of greenhouse gases an an “air pollutant” under the Clean Air Act automatically triggered the regulation of stationary sources, such as factories, through the EPA’s Prevention of Significant Deterioration and Title V permit programs. However, because the new regulatory framework easily triggered EPA oversight for low levels of emissions, the EPA decided to increase the threshold emissions level for greenhouse gases. Petitioners, including various states and industry groups, assert that the EPA’s regulation of greenhouse gas emissions from stationary sources expands the scope of the Act beyond Congress’s original intent. Accordingly, Petitioners argue that the EPA lacks authority for this regulation. The EPA responds that because greenhouse gases are plainly air pollutants, the agency has the statutory authority to regulate them. Moreover, the EPA contends that this reading of the Act conforms with Congress’s intent to give the EPA broad discretion in regulating air pollution to protect public health and welfare. The Supreme Court’s determination of whether the EPA may continue to regulate greenhouse gases under these programs will significantly impact the United States’ approach to climate change.

Questions as Framed for the Court by the Parties

After this Court decided Massachusetts v. EPA, 549 U.S. 497 (2007), the Environmental Protection Agency (EPA) found that its promulgation of motor vehicle greenhouse gas (GHG) emission standards under Title II of the Clean Air Act (CAA), 42 U.S.C. § 7521(a)(1), compelled regulation of carbon dioxide and other GHGs under the CAA's Title I prevention of significant deterioration (PSD) and Title V stationary-source permitting programs. Even though EPA determined that including GHGs in these programs would vastly expand the programs contrary to Congress's intent, EPA adopted rules adding GHGs to the pollutants covered. The panel below held the CAA and Massachusetts compelled inclusion of GHGs and, based on that holding, dismissed all petitions to review the GHG permitting program rules on standing grounds. The questions presented are: 

  1. Whether Massachusetts compelled EPA to in-clude GHGs in the PSD and Title V programs when inclusion of GHGs would (i) transform the size and scope of these programs into something that EPA found would be "unrecognizable to ... Congress," Petition Appendix 345a, 380a, and (ii) expand the PSD program to cover a substance that does not deteriorate the quality of the air that people breathe. 
  2. Whether dismissal of the petitions to review EPA's GHG permit-program rules was inconsistent with this Court's standing jurisprudence where the panel premised its holding that standing was absent on its merits holding that GHGs are regulated "pursuant to automatic operation of the CAA." Id. at 96a.

After the Supreme Court’s decision in Massachusetts v.

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