statutory interpretation

Issues

Section 507(a)(4) of the Bankruptcy Code states that “The following expenses and claims have priority in the following order: . . . Fourth, allowed unsecured claims for contributions to an employee benefit plan arising from services rendered within 180 days of the [filing of the petition].” Howard Delivery Service argues that it should not have to pay unpaid insurance premiums to Zurich American Insurance because workers compensation does not qualify as a “contribution to an employee benefit plan.” The Fourth and Ninth Circuits have held that workers compensation does fall within this language, while the Sixth,  Eighth  and Tenth Circuits have argued that it does not. The Supreme Court must now decide whether or not to interpret the language of § 507(a)(4) to include workers compensation policies as “contributions to an employee benefit plan,” which benefit from priority under the Bankruptcy Code.

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Section 507(a)(4) of the Bankruptcy Code states that “The following expenses and claims have priority in the following order: . . . Fourth, allowed unsecured claims for contributions to an employee benefit plan arising from services rendered within 180 days of the [filing of the petition].” Howard Delivery Service argues that it should not have to pay unpaid insurance premiums to Zurich American Insurance because workers compensation does not qualify as a “contribution to an employee benefit plan.” The Fourth and Ninth Circuits have held that workers compensation does fall within this language, while the Sixth,  Eighth  and Tenth Circuits have argued that it does not. The Supreme Court must now decide whether or not to interpret the language of § 507(a)(4) to include workers compensation policies as “contributions to an employee benefit plan,” which benefit from priority under the Bankruptcy Code.

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The Supreme Court will decide when Section 1113(2) of the Employee Retirement Income Security Act’s statute of limitations begins to run. Both parties agree that the text of Section 1113(2) establishes that the three-year statute of limitations runs from the date on which the plaintiff had actual knowledge of a violation, but dispute what actual knowledge means. Petitioner Intel Corp. Investment Policy Committee argues that actual knowledge means being in possession of proof of the violation, whether a plaintiff is aware of the violation or not. Respondent Christopher M. Sulyma argues that actual knowledge means when the plaintiff is fully aware and understands that a violation took place. The Court’s decision will affect both employers’ incentives to offer retirement plans and also employees who struggle to  comprehend the complex and lengthy plan documents provided to them by their employers.

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This case asks the Supreme Court to determine whether, under the Immigration and Nationality Act, the government must prove to an immigration judge by clear and convincing evidence, that an alien who has been detained for six months is a flight risk or dangerous to the community. In 2018, U.S. Immigration and Customs Enforcement agents detained Antonio Arteaga-Martinez, a native and citizen of Mexico, who had illegally entered the United States in September 2012. The parties differ on whether 8 U.S.C. § 1231 requires a bond hearing after six months of detention, or whether the Department of Homeland Security needs to prove that an alien is a flight risk or danger to the community. The government, represented by Tae Johnson, maintains that neither are required based on the plain meaning of the statute. Further, Johnson claims that current Immigration and Customs Enforcement policies satisfy due process requirements, citing mechanisms such as required hearings, review processes, and access to attorneys. In response, Arteaga-Martinez argues that a bond hearing is required after six months of detention, and that the Department of Homeland Security must then prove that the immigrant is a flight risk or a danger to the community. Mr. Arteaga-Martinez adds that due process is not met by the government’s scheme. This case has important implications for immigrant rights and the administration of immigration law.  

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This case asks the Supreme Court to decide whether Federal Rule of Civil Procedure 60(b)(1), which authorizes relief from a final judgment on the grounds of “mistake, inadvertence, surprise, or excusable neglect,” authorizes relief on the grounds that a district court committed an error of law. A federal district court determined that petitioner Dexter Earl Kemp’s motion for relief from legal error under Rule 60(b)(6) should instead be construed as a motion under Rule 60(b)(1) and dismissed Kemp’s petition because it was not presented within the one-year limitations period that applies to motions under Rule 60(b)(1) but not to motions under Rule 60(b)(6). On appeal to the Supreme Court, Kemp argues that, because Rule 60(b)(1) replicated identical state statutory provisions that did not allow relief for legal error, the Court cannot construe Rule 60(b)(1) to authorize relief for legal error. The United States responds that both the plain meaning of Rule 60(b)(1) and the fact that Rule 60(b)(1) replicated a California statute allowing relief for legal error establish that Rule 60(b)(1) allows relief for legal error. Because the Court’s decision on the meaning of Rule 60(b)(1) will determine for how long after entry of final judgment a litigant is entitled to seek relief for legal error, the resolution of this case will affect the expediency and finality of federal civil litigation. 

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Michael Knight, trustee of the Rudkin Testamentary Trust, petitioned the United States Tax Court to dispute the Internal Revenue Service ("IRS") assessment that the Trust owed taxes for investment-advisory expenses Knight had deducted in full. The Internal Revenue Code contains a 2% floor on all itemized deductions. The IRS assessed that Knight failed to recognize this floor, significantly lowering the deduction amount. Knight argued these expenses should be exempt because they were necessary for Knight to fulfill his fiduciary duties as a trustee. The Tax Court stated that, to be exempt, Knight needed to show these expenses would not have been incurred if the assets were not held in trust. The Tax Court found Knight failed to satisfy his burden of showing that the expenses were unique to trusts and decided in favor of the IRS. The United States Court of Appeals for the Second Circuit affirmed the Tax Court's holding. The Supreme Court of the United States granted certiorari to resolve a conflict between a holding by the Sixth Circuit and those of the Second, Fourth, and Federal Circuits. As trustees spend billions of dollars yearly on management advice, this case will have wide-reaching consequences. A decision for the IRS will result in the same level of taxation on investment-management expenses for individuals and trusts and more taxes to the IRS tempered by decreased use of management services by trustees. A decision for Knight would lower the taxes of trustees and encourage trustees to use investment-management services.

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Agron Kucana, an Albanian immigrant, missed his immigration hearing and, in absentia, was ordered to be removed. The Board of Immigration Appeals (the “Board”) denied Kucana's motion to reopen his case. Kucana appealed the decision to the Seventh Circuit Court of Appeals, which ruled that the Board’s decision was not subject to judicial review. In relevant part, 8 U.S.C. § 1252(a)(2)(B)(ii) specifies that certain matters subject to the Attorney General’s discretion are not subject to judicial review. The dispute in this case centers on the scope and proper interpretation of the statute — in particular, on whether it allows judicial review of decisions not to reopen cases, or whether these decisions are outside the realm of judicial review, because they are the subject to the Attorney General’s discretion. The outcome of this case will determine the ability of immigrants to challenge denials of their motions to reopen through the regular judicial process.

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This case asks the Supreme Court if a party must win a case to get attorney’s fees or if it is enough to win a preliminary injunction that solves the underlying controversy of the case. Lackey argues that the Supreme Court should reject the Circuit consensus and decide that a preliminary injunction winner is not a “prevailing party” under 42 U.S. Code § 1988 to be consistent with the Supreme Court’s previous cases. Additionally, Lackey maintains that when the case has been resolved due to a voluntary change in the law rather than a judicial order, there is no “prevailing party” as defined by § 1988. Stinnie counters that the winner of a preliminary injunction does indeed “win” a case in the way Congress intended when it used the term “prevailing party.” Further, Stinnie contends that the voluntary change in the law was not necessary for them to achieve meaningful relief, so they have already “prevailed” over the other party. The Supreme Court’s decision, in this case, will impact federal, state, local, and municipal governments’ ability to protect the public interest, private attorneys’ ability to vindicate civil rights, and the workload facing lower courts. 

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This case asks the Supreme Court to determine whether a train that has stopped temporarily in a rail yard as part of its journey is considered “in use” on a railroad’s line and subject to the Locomotive Inspection Act (LIA) and other safety regulations. LeDure asserts that precedent cases under related legislation apply to the LIA and argues the term “use” encompasses locomotives, like UP5683, stopped en route to a destination, furthering the goal of the statutes to protect employees. Union Pacific counters that the precedent under similar statutes does not interpret “use” to encompass sidelined locomotives, and that the LIA contains unique aspects that limit the “use” of locomotives to their main purpose of actively hauling railcars. The outcome of this case has important implications for the safety and compensation of employees and the expectations of railroad operations.

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Under 35 U.S.C. § 271(f)(1), when a party, without the authority to do so, ships from the United States either “all or a substantial portion of the components of a patented invention” or “any component . . . that is especially made or especially adapted for use in the invention” in a way that would induce another party abroad to combine the component(s) to form the patented invention, that party commits patent infringement. Section 271(f)(1) prevents parties from evading domestic patent law when engaging in international transactions. The parties differ on how broad § 271(f)(1) should be construed. Life Technologies Corporation argues that courts should construe § 271(f)(1) narrowly to refer to the percentage of components for the invention that a party ships abroad. Promega Corporation, on the other hand, argues that the statute takes into account a combination of quantity and relative importance of the component(s) shipped abroad. The outcome of this case will determine the limits of 35 U.S.C. § 271(f)(1) and, consequently, the limits of private action in shipping materials abroad. 

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