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The Hain Celestial Group, Inc. v. Palmquist

Issues

Must an appellate court vacate a district court’s final judgment as to completely diverse parties if it determines the district court was wrong to dismiss a non-diverse party at the time the case was removed?

 

This case asks the Court to determine whether an appellate court must vacate a district court’s final judgment if it determines the district court erred in dismissing a non-diverse party when the case was removed. The Hain Celestial Group (“Hain”), as Petitioner, argues that the district court had jurisdiction to enter final judgment because the parties before it were completely diverse after Whole Foods, Inc. (“Whole Foods”) was dismissed. Alternatively, Hain argues Whole Foods could be dismissed under Federal Rule of Civil Procedure 21 as a dispensable party. Sarah Palmquist, Grant Palmquist, and E.P. (the “Palmquists”), as Respondents, argue that Whole Foods remained a part of the litigation until the final judgment, destroying the district court’s subject matter jurisdiction. Alternatively, the Palmquists argue that Hain’s Rule 21 argument is improper and would result in prejudice to them. The outcome of this case could impact forum shopping strategies and increase the resources parties must expend if they must relitigate claims after a final judgment is vacated.

Questions as Framed for the Court by the Parties

Whether a district court’s final judgment as to completely diverse parties must be vacated when an appellate court later determines that it erred by dismissing a non-diverse party at the time of removal.

Grant and Sarah Palmquist (the “Palmquists”) had a son (“E.P.”) in 2014. See Palmquist v. Hain Celestial Group, Inc.at 2. The Palmquists allege that E.P.’s diet consisted of “almost exclusively” products manufactured by Hain Celestial Group, Inc. (“Hain”) during his first two years of life.

Acknowledgments

The authors would like to thank Professor Maggie Gardner for her insights into this case. 

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Rico v. United States

Issues

When an individual on supervised release absconds, does the clock on their supervision time pause, such that the time while missing does not count toward serving the supervised release term?

 

This case asks the Supreme Court to decide whether a term of supervised release automatically extends if a releasee absconds from supervision. Petitioner Isabel Rico absconded while serving a term of supervised release related to a drug trafficking offense. If Rico’s timer for supervised release was paused while in abscondment, her total punishment would be longer than if it were running. The district court applied the fugitive tolling doctrine, which means that the timer stopped when the releasee is missing, and the Ninth Circuit affirmed her extended sentence. Rico argues that the timer on a term of supervised release does not stop while a releasee is missing. Rico claims that the statute authorizing supervised release clearly does not authorize the use of the fugitive tolling doctrine. In response, the United States argues that the fugitive tolling doctrine must extend to absconders like Rico, that supervision only counts when the defendant is actively under oversight, and that the court should not allow for absconders to manipulate their sentence. This case’s outcome has significant implications on the fairness and rehabilitation for supervised releasees.

Questions as Framed for the Court by the Parties

Whether the fugitive-tolling doctrine applies in the context of supervised release?

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Learning Resources, Inc. v. Trump

Issues

Does the International Emergency Economic Powers Act authorize the President to impose tariffs?

 

This case asks whether the International Emergency Economic Powers Act (“IEEPA”) authorizes the president to impose tariffs in an emergency. Learning Resources contends that the IEEPA does not give the president tariff authority, and—even if it does—does not grant the broad authority the President claims. President Trump argues that a plain-meaning interpretation of the IEEPA grants tariff authority, and the IEEPA does not limit the scope of the tariff power because the limitation is not expressly listed as other limitations are. This case raises significant issues about the separation of powers and future of foreign relations.

Questions as Framed for the Court by the Parties

Whether the International Emergency Economic Powers Act authorizes the president to impose tariffs. 

The 1917 Trading with the Enemy Act (“TWEA”) granted the United States President the power to restrict trade with certain foreign countries during wartimes. Brief for Respondent, Donald J.

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Hencely v. Fluor Corporation

Issues

Can state-law tort claims be brought against an otherwise-immune federal military contractor where that contractor’s conduct breached its contract with the military and violated military orders?

 

This case asks the Supreme Court to decide whether a federal military contractor can be sued on state-law tort claims provided that the contractor breached its contract and violated military orders. Winston Hencely, a veteran who was injured in a suicide bombing at Bagram Airfield in Afghanistan, argues that Boyle v. United Technologies Corporation, which created federal military contractor immunity, does not apply in such circumstances, and that Boyle’s reasoning should not be extended to apply in such circumstances. Fluor Corporation counters that the federal interests at stake in bold military operations require broad immunity for military contractors. The outcome of this case will determine the scope of military contractors’ liability and the Supreme Court’s willingness to rely upon and expand doctrines made by courts rather than Congress. This case will also impact future military safety and defense contracting.

Questions as Framed for the Court by the Parties

Whether Boyle v. United Technologies Corporation should be extended to allow federal interests emanating from the Federal Tort Claims Act’s combatant-activities exception to preempt state tort claims against a government contractor for conduct that breached its contract and violated military orders.

Winston T. Hencely, the Petitioner, was an active-duty soldier stationed at Bagram Airfield in Afghanistan. Hencely v. Fluor Corp.

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Coney Island Auto Parts, Inc. v. Burton

Issues

Does Federal Rule of Civil Procedure 60(c)(1) create any time limit to dismiss a void default judgment for lack of personal jurisdiction?

 

This case asks the Supreme Court to decide whether Federal Rule of Civil Procedure 60(c)(1) may impose a time limit on motions to set aside a default judgment that is void for lack of personal jurisdiction. Petitioner Coney Island Auto Parts Unlimited, Inc. (“Coney Island”) contends that Rule 60(c)(1) was intended to govern only voidable judgments, not those that were void from the beginning of the judgment, or ab initio. Coney Island argues that enforcing a judgment void from the outset from lack of personal jurisdiction necessarily violates the fundamental principles of due process, as no court lacking jurisdiction ever has lawful authority to adjudicate a defendant’s rights. Respondent, Trustee for Vista-Pro Automotive, Jeanne Ann Burton (“Burton”), maintains that the drafters of Rule 60(c)(1) intended the rule to apply to all void judgments regardless of whether they were void for lack of personal jurisdiction. Burton argues that even if the rule is enforced, defendants still have avenues to raise the fact that their original judgment was void for lack of personal jurisdiction through other procedural means if the judgment is referenced later on. Additionally, Burton argues that the reasonable-time restriction in Rule 60(b)(4) correctly balances the public policy goals. Burton states that the Rule encourages finality in judgments to prevent excess litigation while also allowing for defendants to bring motions, within reasonable limits, when they believe their rights are being violated by the enforcement of a judgment lacking personal jurisdiction. The outcome of this case has implications for the behavior of parties in a suit and the fairness of notice requirements.

Questions as Framed for the Court by the Parties

Whether Federal Rule of Civil Procedure 60(c)(1) imposes any time limit to set aside a void default judgment for lack of personal jurisdiction.

Federal Rule of Civil Procedure Rule 60(b)(4) permits substantive relief from a judgment that is void, including when a court rules it lacked personal jurisdiction over a defendant. Fed. R. Civ. P.

Acknowledgments

The authors would like to thank Professor Kevin Clermont for his guidance and insights into this case. 

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cannabis

Cannabis is statutorily synonymous to marijuana. Cannabis is broadly categorized into two principal subspecies: cannabis sativa and cannabis indica. Cannabis plants have trichomes, which are hair-like structures on the surface of flowers and leaves; these trichomes contain cannabinoids such as cannabidiol (CBD) and tetrahydrocannabinol (THC).

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