Moving right along into the June decisions from the Supreme Court, there were six in mid-June. Three of those were unanimous; the others were split 8-1, 6-3, and 5-4.
Issues addressed include venue in falsified documents cases, the Investment Company Act, bankruptcy disclosure requirements, the Rooker-Feldman doctrine, waiver of criminal appeals, and firearm possession for "unlawful users."
And this installment features both orangutans and weed (though not together).
Here we go:
Date: June 11, 2026
Author: Elena Kagan
Split: 9–0
Dissent: N/A
Appeal From: 9th Circuit
Basic Facts:
While employed by Twitter at its San Francisco office, petitioner Ahmad Abouammo provided confidential information to a high-level Saudi official about Saudi dissidents posting on the company's platform. In exchange, the official wired Abouammo $300,000. Around the same time, Abouammo left Twitter and relocated to Seattle, where he started a social-media consulting business. Two San Francisco-based FBI agents, who were investigating unauthorized disclosures of Twitter account information, later flew to Seattle to interview Abouammo at his home. During the interview, Abouammo denied giving the Saudi official confidential information, claiming that the payments were for consulting work. When the agents asked for supporting documentation, Abouammo went upstairs, created a fake invoice, and emailed it to one of the agents. Back in San Francisco, the agents discovered from the emailed document's date-and-time metadata what Abouammo had just done.
Abouammo was indicted in the Northern District of California for falsifying a record under § 1519. He moved to dismiss the charge for improper venue, arguing that he could be tried only where the alleged falsification occurred. The District Court denied the motion, finding venue also proper in the place where the FBI investigation was located, and a jury convicted Abouammo. The Ninth Circuit affirmed, reasoning that § 1519's intent requirement—“with the intent” to “obstruct” an investigation—made the “contemplated effects” of the falsification part of the “essential conduct” of the offense, thereby permitting trial “where the investigation” the defendant “intended to stymie [was] ongoing or contemplated.” 122 F. 4th 1072, 1092–1093.
Issue:
When someone is charged under 18 U.S.C. § 1519 with falsifying a document intending to obstruct a federal investigation, where is proper venue: where the document was falsified, or also where the investigation he intended to obstruct was located?
Holding: Reversed and remanded.
A defendant charged with violating § 1519 must be tried in the district where the falsification occurred; he cannot be tried in a different district where the investigation was located because no “conduct constituting the offense” happened there.
Skinny: You did the crime in Seattle, you do the trial in Seattle.
FS Credit Opportunities Corp. v. Saba Capital Master Fund, Ltd.
Date: June 11, 2026
Author: Amy Coney Barrett
Split: 6–3
Dissent: Kagan; Jackson, joined by Sotomayor and by Kagan as to Parts I and II
Appeal From: 2nd Circuit
Basic Facts:
The Investment Company Act (ICA) comprehensively regulates investment companies. The ICA designates the Securities and Exchange Commission as its primary enforcer and expressly permits shareholders and issuers of securities to enforce two of its provisions. The question presented in this case is whether Section 47(b) of the ICA impliedly empowers private parties to sue for rescission of any contract that allegedly violates the Act.
Petitioners (“Funds”) are investment companies that manage closed-end mutual funds. These funds are “closed” because each contains a fixed number of shares issued at one time, and the price of each share is determined by trading on the open market. Respondents Saba Capital Master Fund, Ltd., and Saba Capital Management, L. P., (collectively, Saba) engage in activist investing—a practice that involves identifying low-performing closed-end funds and purchasing a large enough stake to alter the funds' investment strategies. The Funds are incorporated in Maryland, which has enacted the Maryland Control Share Acquisition Act (MCSAA), and have adopted resolutions opting into MCSAA provisions that limit voting rights for shareholders holding a disproportionate number of shares (like activist investors) unless other shareholders approve. In June 2023, Saba sued the Funds, alleging that the Funds' resolutions violate the ICA's requirement that every share of stock shall be a voting stock with equal voting rights. Saba's suit invoked Section 47(b) of the ICA, which provides that “a court may not deny rescission” of contracts that violate the ICA “at the instance of any party” unless the court finds that doing so would be consistent with equity and the ICA's goals. 15 U. S. C. § 80a–46(b)(2). The District Court held that Section 47(b) creates an implied private right of action to sue for contract rescission and granted Saba summary judgment. The Second Circuit summarily affirmed.
Issue:
Does Section 47(b) of the Investment Company Act itself give private parties a right to sue to rescind contracts that allegedly violate the Act?
Holding: Reversed and remanded.
Section 47(b) of the ICA does not impliedly empower private parties to sue for rescission of contracts that allegedly violate the Act.
Skinny: §47(b) is the remedy, not the route. (It tells the judge what you can get, not whether you can sue.)
Keathley v. Buddy Ayers Construction, Inc.
Date: June 11, 2026
Author: Ketanji Brown Jackson
Split: 9–0
Dissent: N/A
Appeal From: 5th Circuit
Basic Facts:
Thomas Keathley and his wife filed a Chapter 13 bankruptcy petition in U. S. Bankruptcy Court in December 2019. The Bankruptcy Code requires debtors to file bankruptcy schedules listing their property, including “[c]laims against third parties, whether or not [the debtor] ha[s] filed a lawsuit or made a demand for payment.” Official Form 106A/B, Schedule A/B: Property, Pt. 4, Question 33. Debtors must swear “[u]nder penalty of perjury” that the information provided is “true and correct.” Official Form 106Dec, Declaration About an Individual Debtor's Schedules. In April 2020, based on the Keathley's disclosures, the Bankruptcy Court confirmed an amended repayment plan providing for interest-free repayment of 100% of creditors' claims over five years. In August 2021, while the bankruptcy case remained open, Keathley was involved in a car accident in Mississippi with a driver employed by Buddy Ayers Construction, Inc. Keathley retained a personal-injury attorney and informed his bankruptcy counsel that he intended to sue Buddy Ayers Construction. Neither Keathley nor his bankruptcy counsel disclosed the potential personal-injury claim to the Bankruptcy Court. Keathley then filed a personal-injury action in U. S. District Court in December 2021, asserting negligence claims against the company, again without notifying the Bankruptcy Court.
In March 2023, Buddy Ayers Construction moved for summary judgment on grounds of judicial estoppel based on Keathley's failure to disclose his personal-injury claims in the pending bankruptcy proceeding. Keathley immediately filed an amended schedule notifying the Bankruptcy Court of his pending claims. He then submitted affidavits in response to the motion for summary judgment, explaining that his omission had been inadvertent. The District Court, relying on Fifth Circuit precedent, found that Keathley knew of the facts underlying his claims and hypothetically had a motive to conceal, and therefore held the omission was not inadvertent or a mistake, entering summary judgment for Buddy Ayers Construction. The Fifth Circuit affirmed, with one judge concurring but expressing doubt that judicial estoppel's goals were advanced by its application given evidence the omission was an “honest mistake.”
Issue:
When determining whether a bankruptcy debtor's failure to disclose a legal claim was inadvertent or mistaken for purposes of judicial estoppel, may a court limit its inquiry to whether the debtor knew about the claim and had a potential motive to conceal it, or must it consider the totality of the circumstances?
Holding: Vacated and remanded.
To determine whether an omission of a claim in the bankruptcy context was inadvertent or mistaken for purposes of judicial estoppel, courts should look to the totality of the circumstances surrounding the omission; the Fifth Circuit erred by artificially narrowing its inquiry to whether the debtor had knowledge of the underlying facts or a potential motive to conceal the claim.
Skinny: Equity isn't one-size-fits-all — you've got to look at the whole picture.
T. M. v. University of Maryland Medical System Corp.
Date: June 18, 2026
Author: Sonia Sotomayor
Split: 5-4
Dissent: Barrett, Roberts, Kagan, Gorsuch
Appeal From: 4th Circuit
Basic Facts:
The Rooker-Feldman doctrine bars federal district courts from exercising jurisdiction over cases brought by state-court losers seeking review and rejection of state-court judgments rendered before district court proceedings commenced. See Exxon Mobil Corp. v. Saudi Basic Industries Corp., 544 U. S. 280, 284. This case asks whether the doctrine applies only to final judgments rendered by the highest court of a State in which a decision could be had, or whether it also bars suit when the state-court judgment at issue remains subject to further review in state appellate proceedings.
Petitioner T. M. alleges that she has a medical condition that causes changes in her mental status, including psychosis, when she ingests gluten. In March 2023, T. M. accidentally ingested gluten and was taken to the emergency room at Baltimore Washington Medical Center, where, after an administrative hearing and over her and her father's objections, she was involuntarily committed for about three months. During her stay, T. M.'s treating psychiatrist and the medical center obtained an order authorizing the facility to forcibly inject T. M. with antipsychotic medication. These events prompted a flurry of litigation, with T. M. and her parents filing several state and federal lawsuits seeking T. M.'s release and to avoid the forced injections. T. M. and respondents negotiated a settlement agreement to facilitate T. M.'s discharge, and the state judge presiding over T. M.'s state habeas petition entered the agreement as a consent order on June 12, 2023. The consent order provided for T. M.'s immediate release subject to several conditions, including that T. M. obtain a new treating psychiatrist, continue taking her prescribed medications, and dismiss with prejudice all pending actions against respondents. Ten days after the state court entered the consent order, T. M. and her parents obtained new counsel and sued respondents in Federal District Court for the District of Maryland, seeking a declaration that the consent order violated T. M.'s federal and state due-process rights, a declaration that the order was obtained under duress, and an injunction preventing its enforcement. Meanwhile, T. M. appealed the consent order to the Appellate Court of Maryland and raised similar arguments. T. M. later successfully moved to stay the state-court appeal to prevent inconsistent rulings. The District Court dismissed the complaint sua sponte for lack of subject matter jurisdiction under the Rooker-Feldman doctrine. The Fourth Circuit affirmed, rejecting T. M.'s argument that Rooker-Feldman applies only to judgments that are final judgments from the highest court of a State in which the decision could be had.
Issue:
Does Rooker-Feldman bar a federal district court from reviewing a state-court judgment while that judgment is still subject to appeal in the state courts, or does the doctrine kick in only after the state appellate process is finished?
Holding: Affirmed.
The Rooker-Feldman doctrine bars federal district court jurisdiction over cases brought by state-court losers complaining of injuries caused by state-court judgments rendered before the district court proceedings commenced and seeking district court review and rejection of those judgments, regardless of whether the state-court judgments remain subject to further review in state appellate proceedings.
Skinny: An unfavorable state court outcome doesn't get you a federal district court do-over.
Date: June 18, 2026
Author: Elena Kagan
Split: 8–1
Dissent: Thomas
Appeal From: 5th Circuit
Basic Facts:
Petitioner Munson Hunter III was charged with 10 counts of bank and wire fraud for a years-long scheme costing various financial institutions about half a million dollars. He entered into a written plea agreement with the Government under which he pleaded guilty to one count of aiding and abetting wire fraud in exchange for dismissal of the remaining nine charges and a promise not to prosecute him for the described conduct in the future. The agreement included an appeal waiver under which Hunter waived the right to appeal his conviction and sentence, except that he did not waive the right to raise a claim of ineffective assistance of counsel. The agreement further provided that “any modification” of its terms “must be in writing and signed by all parties.” The District Court accepted the plea after deeming it knowing and voluntary.
At sentencing, the Probation Office recommended that as a condition of supervised release Hunter be required to participate in a mental-health treatment program and take all mental-health medications prescribed by his treating physician. Hunter objected to the mandatory-medication part of that condition. The District Court told Hunter that if “the treatment provider prescribes drugs, you should take them,” while also telling Hunter that he could “address” any future dispute about medication “to the probation officer” or, if needed, “to me.” The District Court then imposed a sentence of 51 months in prison followed by three years of supervised release, including the contested medication condition. At the close of the hearing, the court told Hunter: “All right. You have a right to appeal. If you wish to appeal, [your trial counsel] will continue to represent you.” When asked if either party wished to say anything else, Hunter's lawyer said “Nothing from the defense,” and the prosecutor replied: “Your Honor, I believe—well, no. I—no.”
Hunter appealed, challenging the mandatory-medication condition as infringing on his “fundamental due process liberty interest in being free of unwanted mental health medication.” The Government sought dismissal based on the appeal waiver. Hunter acknowledged he had knowingly and voluntarily signed the waiver but argued that an appeal waiver is unenforceable when the disputed aspect of a sentence violates a fundamental constitutional right, and alternatively that the District Court's statement at sentencing about appeal rights, along with the prosecutor's failure to object, voided the waiver. The Court of Appeals for the Fifth Circuit dismissed the appeal, holding that the District Court's misstatement “did not impact the validity of the appeal waiver” and that under Circuit precedent the “general rule” that appeal waivers are enforceable has only two exceptions: when the waiver was tainted by ineffective assistance of counsel and when the sentence exceeded the statutory maximum. Because neither exception applied, the Fifth Circuit held that Hunter's appeal could not go forward.
Issue:
Can a court refuse to enforce an otherwise valid criminal appeal waiver when enforcing it would result in a miscarriage of justice?
Holding: Vacated and remanded.
An agreement not to appeal a sentence is unenforceable when it would result in a miscarriage of justice—meaning, when it would leave in place the kind of egregious error that would bring the judicial system into disrepute.
Skinny: You can waive your appeal — but you've still got an escape hatch if the sentence winds up in "orangutan picked it out of a hat" territory.
Date: June 18, 2026
Author: Neil Gorsuch
Split: 9-0
Dissent: N/A
Appeal From: 5th Circuit
Basic Facts:
Ali Hemani is a dual citizen of the United States and Pakistan who was born in Texas. He has spent most of his life living in the Dallas area with his parents and working a stable job. Suspecting Mr. Hemani and his family members of terrorism-related activities, the government conducted a search of the family home in 2022. Throughout the process, Mr. Hemani proved cooperative: he surrendered a gun he kept in the house, pointed agents to some marijuana on the property, and consented to an interview during which he told law enforcement agents that he used marijuana about every other day. More than six months after the search, and relying solely on Mr. Hemani's admitted use of marijuana, the government prosecuted Mr. Hemani under 18 U. S. C. § 922(g)(3) for knowingly possessing a gun in his home while being an unlawful user of a controlled substance. Mr. Hemani moved to dismiss the indictment, arguing that the government's effort to enforce § 922(g)(3) against him violated the Second Amendment. The district court granted the motion, and after an unsuccessful appeal to the Fifth Circuit, the government asked this Court to review the case.
Issue:
Does the federal prohibition on firearm possession by an “unlawful user” of a controlled substance violate the Second Amendment as applied to someone whom the government seeks to disarm based solely on his regular marijuana use?
Holding: Affirmed.
The government's prosecution of Mr. Hemani under § 922(g)(3)'s unlawful user provision is inconsistent with the Second Amendment.
Skinny: Regular weed use does not a habitual drunkard make.
