Okay, we've made some headway on the recent Supreme Court decisions, but this being close to the end of the 2024 term, they're cranking them out now. As they did on June 5, the justices handed down six more decisions on June 12, four of them unanimous, and two with an 8-1 split (Gorsuch being the lone dissenter in both).
The bulk of these decisions were, again, procedural, and several of them were quite granular, making distilling them into a pithy "skinny" summation a wee bit challenging. Nevertheless, here they are:
June 12, 2025 Decisions
A. J. T. v. Osseo Area Schools, Independent School Dist. No. 279
Date: June 12, 2025
Author: Roberts
Split: 9-0
Dissent: N/A
Appeal From: 8th Circuit
Multiple federal laws afford protections for children with disabilities in public schools. Three statutory schemes are particularly relevant to this case. Section 504 of the Rehabilitation Act of 1973 provides that no qualified individual with a disability shall be excluded from participation in, denied the benefits of, or subjected to discrimination under any federally funded program solely by reason of her or his disability. Similarly, Title II of the Americans with Disabilities Act (ADA) prohibits qualified individuals with disabilities from being excluded from or denied the benefits of a public entity’s services, programs, or activities by reason of disability. While the antidiscrimination guarantees of Section 504 and Title II apply in a variety of contexts, the Individuals with Disabilities Education Act (IDEA) offers federal funds to States in exchange for the commitment to furnish the core guarantee of a “free appropriate public education” to children in public schools with certain physical or intellectual disabilities. The centerpiece of the IDEA is the provision of an “individualized educational program,”(IEP) which “spells out” a plan to meet all of the educational needs of a child with a qualifying disability. Fry v. Napoleon Community Schools, 580 U. S. 154, 158.
Petitioner A. J. T. is a teenage girl with a rare form of epilepsy that severely limits her physical and cognitive functioning. She suffers from seizures that are so frequent in the mornings that she cannot attend school before noon, though she is alert and able to learn from noon until 6 p.m. For the first few years of her schooling, school officials accommodated A. J. T.’s condition by permitting her to avoid morning activities and instead receive evening instruction. But when A. J. T.’s family moved to Minnesota in 2015, her new school district—Osseo Area Public Schools, Independent District No. 279—denied her parents’ repeated requests to include evening instruction in A. J. T.’s IEP. Between 2015 and 2018, A. J. T. received only 4.25 hours of instruction daily compared to the typical 6.5-hour school day for nondisabled students in the district. After even further cuts to A. J. T.’s school day were proposed, her parents filed an IDEA complaint with the Minnesota Department of Education, alleging that the school’s refusal to provide afterhours instruction denied A. J. T. a free appropriate public education. An Administrative Law Judge determined that the school district had violated the IDEA and ordered the school to provide compensatory education and evening instruction. Federal courts subsequently affirmed A. J. T.’s IDEA victory.
A. J. T. and her parents then sued under the ADA and the Rehabilitation Act, requesting a permanent injunction, reimbursement for certain costs, and compensatory damages. The District Court granted summary judgment for the school, and the Eighth Circuit affirmed. In so holding, the Eighth Circuit stated that a school district’s failure to provide a reasonable accommodation was not enough to state a prima facie case of discrimination under Monahan v. Nebraska, 687 F. 2d1164, which requires a plaintiff to prove conduct by school officials rising to the level of bad faith or gross misjudgment.
Whether the ADA and Rehabilitation Act require children with disabilities to satisfy a uniquely stringent "bad faith or gross misjudgment" standard when seeking relief for discrimination relating to their education.
Holding: Vacated and remanded.
Schoolchildren bringing ADA and Rehabilitation Act claims related to their education are not required to make a heightened showing of “bad faith or gross misjudgment” but instead are subject to the same standards that apply in other disability discrimination contexts.
Skinny: As with the Ames case from the week before, you can't use discriminatory standards to assess whether someone's been discriminated against.
Date: June 12, 2025
Author: Thomas
Split: 9-0
Dissent: N/A
Appeal From: Federal Circuit
The Barring Act, 31 U. S. C. §3702, establishes default settlement procedures for claims against the Government and subjects most claims to a 6-year limitations period. However, the Act includes an exception: If “another law” confers authority to settle a claim against the Government, that law displaces the Barring Act’s settlement mechanism, including its limitations period. §3702(a). In 2002, Congress enacted a statute providing “combat-related special compensation” (CRSC) to qualifying veterans who have suffered combat-related disabilities. 10 U. S. C. §1413a. Under federal law, retired veterans generally must waive a portion of their military retirement pay to receive Veterans Affairs (VA) disability benefits, but the CRSC statute allows combat-disabled retirees to receive special compensation up to the amount of waived retired pay.
Petitioner Simon Soto served in the Marine Corps from 2000 to 2006, including two tours in Operation Iraqi Freedom. He was medically retired in 2006 and later received a 100-percent disability rating for post-traumatic stress disorder from the VA. In 2016, Soto applied for CRSC payments. The Secretary of the Navy approved his application limited retroactive compensation to six years, citing the Barring Act’s limitations period. Soto filed a class-action lawsuit arguing that the Barring Act’s 6-year limitations period does not apply to CRSC claims because the CRSC statute constitutes “another law” that provides its own settlement mechanism. The District Court granted summary judgment for the class, but the Federal Circuit reversed, holding that the CRSC statute does not explicitly grant settlement authority and therefore cannot displace the Barring Act.
When a person makes a demand for money from the federal government pursuant to federal statute, what test should courts and agencies use to determine whether that statute includes a settlement procedure that displaces the default procedures and limitations set forth in the Barring Act (31 U.S.C. § 3702)?
Holding: Reversed and remanded.
The CRSC statute confers authority to settle CRSC claims and thus displaces the Barring Act’s settlement procedures and limitations period.
Skinny: The vet gets the benefits.
Date: June 12, 2025
Author: Sotomayor
Split: 8-1
Dissent: Gorsuch
Appeal From: 4th Circuit
Federal inmate Donte Parrish alleges that he was placed in restricted segregated confinement for 23 months based on his suspected involvement in another inmate’s death. After a hearing officer cleared him of wrongdoing, Parrish filed suit in Federal District Court seeking damages for his time in segregated confinement. The District Court dismissed his case on March 23, 2020, holding that some claims were untimely and others unexhausted. When the court’s order reached the federal prison two weeks later, Parrish was no longer there, having been transferred to a different facility. Parrish received the dismissal order three months after it was issued and promptly filed a notice of appeal, explaining his delayed receipt. The Fourth Circuit recognized that Parrish’s notice of appeal came well after the 60-day appeal period for suits against the United States, so it construed Parrish’s filing as a motion to reopen the time to appeal under 28 U. S. C. §2107(c). On remand, the District Court granted reopening for 14 days. Parrish did not file a second notice of appeal. Although both Parrish and the United States argued that the original notice of appeal was sufficient, the Fourth Circuit held that Parrish’s failure to file a new notice of appeal within the reopened appeal period deprived the court of jurisdiction.
Whether a litigant who files a notice of appeal after the ordinary appeal period expires must file a second, duplicative notice after the appeal period is reopened.
Holding: Reversed and remanded.
A litigant who files a notice of appeal after the original appeal deadline but before the court grants reopening need not file a second notice after reopening. The original notice relates forward to the date reopening is granted.
Skinny: Even inmates sometimes qualify for grace, and when they do, they don't have to start all over again and refile the very pleading that prompted that grace, to begin with.
Date: June 12, 2025
Author: Gorsuch
Split: 9-0
Dissent: N/A
Appeal From: 11th Circuit
On October 18, 2017, the FBI raided the wrong house in suburban Atlanta. Officers meant to execute search and arrest warrants at a suspected gang hideout at 3741 Landau Lane but instead stormed 3756 Denville Trace, a quiet family home occupied by petitioners Hilliard Toi Cliatt, his partner Curtrina Martin, and her 7-year-old son. A six-member SWAT team breached the front door, detonated a flash-bang grenade, and assaulted the innocent occupants before realizing their mistake. The cause of the error was Special Agent Guerra’s reliance on a personal GPS device, combined with the team’s failure to notice the street sign for “Denville Trace” and the house number visible on the mailbox. Left with personal injuries and property damage, petitioners sued the United States under the Federal Tort Claims Act (FTCA), 28 U. S. C. §2671 et seq., seeking damages resulting from the officers’ alleged negligent and intentional actions during the raid. The district court granted summary judgment to the government. The Eleventh Circuit affirmed, applying a unique approach to FTCA claims.
The FTCA waives the federal government’s sovereign immunity from suit as to certain torts committed by federal employees acting within the scope of their employment. But that waiver is subject to statutory exceptions, including two relevant to a law enforcement misconduct case like this one. The first is the intentional-tort exception in §2680(h), which bars claims against the government for 11 enumerated intentional torts. The second is the discretionary-function exception in §2680(a), which bars claims against the government that are based on an official’s exercise of discretionary functions. Section 2680(h) also contains a “law enforcement proviso” which countermands the intentional-tort exception, allowing suits for six specified torts (including assault, battery, false imprisonment, and false arrest) to proceed against the United States when the torts are committed by “investigative or law enforcement officers.” While most courts hold that the law enforcement proviso applies only to the intentional-tort exception, the Eleventh Circuit’s approach is different in two key respects. First, the Eleventh Circuit alone holds that the proviso overrides all exceptions in §2680, including the discretionary-function exception, meaning that intentional-tort claims covered by the proviso automatically proceed to the merits without further analysis of other applicable §2680 exceptions. Second, to compensate for this plaintiff friendly approach, the Eleventh Circuit permits the government to assert a restrictive Supremacy Clause defense at the liability stage, allowing the government to escape liability when an officer’s actions have “some nexus with furthering federal policy” and reasonably “comply[ ] with the full range of federal law.” Denson v. United States, 574 F. 3d 1318, 1348.
Applying its distinctive approach, the Eleventh Circuit held that the law enforcement proviso protected petitioners’ intentional-tort claims from both the intentional-tort and discretionary-function exceptions. The court dismissed petitioners’ negligence claims under the discretionary-function exception, reasoning that Special Agent Guerra enjoyed discretion in preparing for the warrant execution. On the merits of the remaining intentional-tort claims, the court found the government had a valid Supremacy Clause defense and granted summary judgment for the United States.
- Whether the Constitution's Supremacy Clause bars claims under the FTCA - a federal statute enacted by Congress - when the negligent or wrongful acts of federal employees "have some nexus with furthering federal policy and can reasonably be characterized as complying with the full range of federal law." Pet. App. 17a (quotation omitted)
- Whether the FTCA's discretionary-function exception bars claims for torts arising from wrong-house raids and similar negligent or wrongful acts by federal employees.
Holding: Vacated and remanded.
The Supremacy Clause does not afford the United States a defense in a suit against it under the Federal Tort Claims Act and the law enforcement proviso in Section 2680(h) of the act overrides only the intentional-tort exception in that subsection, not the discretionary-function exception or other exceptions throughout Section 2680.
Skinny: The 11th Circuit needs to take another look at the case without coming up with its own "distinctive approach."
Added Note: It's possible (though not guaranteed) that the petitioners' claims will survive and their case will be allowed to proceed, but if I'm being completely honest, I cannot keep straight the proviso/exception to the exceptions to the waiver or sovereign immunity and they make my head hurt trying.
Date: June 12, 2025
Author: Barrett
Split: 8-1
Dissent: Gorsuch
Appeal From: 3rd Circuit
This case involves the jurisdiction of the United States Tax Court over appeals from collection due process hearings when there is no longer an ongoing levy. The dispute here began in 2012, when Jennifer Zuch and her then-husband Patrick Gennardo each filed an untimely 2010 federal tax return. Gennardo subsequently submitted an offer in compromise to resolve outstanding tax liabilities. This offer implicated $50,000 in estimated tax payments that the couple had previously sent to the IRS; following the offer, the IRS applied these payments to Gennardo’s account. For her part, Zuch later amended her 2010 tax return to report additional income, which resulted in an additional $28,000 in taxes due. But Zuch maintained that the IRS should have credited the couple’s $50,000 payment to her account, entitling her to a $ 22,000 refund. The IRS disagreed and sought to collect her unpaid taxes by placing a levy on her property pursuant to its authority under 26 U. S. C. §6331(a). Zuch requested a collection due process hearing to contest the levy. The appeals officer rejected Zuch’s argument about the misapplied $50,000 tax payment and issued a Notice of Determination sustaining the levy action under §6330(c)(3). Zuch then appealed to the Tax Court under §6330(d)(1). During the multi-year proceedings before the agency and the Tax Court that followed, Zuch filed several annual tax returns showing overpayments. Each time, the IRS applied these overpayments to her outstanding 2010 tax liability rather than issuing refunds. Once Zuch’s liability reached zero, the IRS moved to dismiss the Tax Court proceeding as moot, arguing that the Tax Court lacked jurisdiction because the IRS no longer had a basis to levy on Zuch’s property. The Tax Court agreed. But on appeal, the Third Circuit vacated the dismissal, holding that the IRS’s abandonment of the levy did not moot the Tax Court proceedings.
Whether a proceeding under 26 U.S.C. 6330 for a pre-deprivation determination about a levy proposed by the Internal Revenue Service to collect unpaid taxes becomes moot when there is no longer a live dispute over the proposed levy that gave rise to the proceeding
Holding: Reversed and remanded.
The Tax Court lacks jurisdiction under §6330 to resolve disputes between a taxpayer and the IRS when the IRS is no longer pursuing a levy.
Skinny: The IRS has the upper hand here.
Added Note: Gorsuch's dissent points out that this decision allows the IRS to effectively sidestep a taxpayer's appeal.
Date: June 12, 2025
Author: Jackson
Split: 9-0
Dissent: N/A
Appeal From: 5th Circuit
Petitioner Danny Rivers was convicted in Texas state court of continuous sexual abuse of a child and related charges. After unsuccessfully seeking direct appeal and state habeas relief, Rivers filed his first federal habeas petition under 28 U. S. C. §2254 in August 2017, asserting claims of prosecutorial misconduct, ineffective assistance of counsel, and other constitutional violations. The District Court denied the petition in September 2018, and Rivers appealed to the Fifth Circuit, which granted a certificate of appealability on his ineffective-assistance claim in July 2020.
While his appeal was pending, Rivers obtained his trial counsel’s client file, which contained a state investigator’s report that he believed was exculpatory. After the Fifth Circuit denied his request to supplement the record on appeal, Rivers filed a second §2254 petitionin the District Court based on this newly discovered evidence. The District Court classified this second-in-time filing as a “second or successive” habeas application under §2244(b) and transferred it to the Fifth Circuit for authorization to file. Rivers appealed the transfer order, and the Fifth Circuit affirmed, holding that the fact that Rivers’s first petition was still on appeal did not permit him to circumvent the requirements for successive petitions under §2244 as to his second filing.
Whether § 2244(b)(2) applies (i) only to habeas filings made after a prisoner has exhausted appellate review of his first petition, (ii) to all second-in-time habeas filings after final judgment, or (iii) to some second-in-time filings, depending on a prisoner's success on appeal or ability to satisfy a seven-factor test.
Holding: Affirmed.
Once a district court enters its judgment with respect to a first-filed habeas petition, a second-in-time filing qualifies as a “second or successive application” properly subject to the requirements of §2244(b).
Skinny: Rules is rules, and if you want a second bite at the apple, you have to jump through the applicable hoops.
You can check out prior installments of The Skinny on SCOTUS series here.
