Supreme Court Decision Syllabus (SCOTUS Podcast)

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The Supreme Court held that the government's prosecution of Ali Hemani under 18 U.S.C. §922(g)(3)'s prohibition on firearm possession by unlawful users of controlled substances violated the Second Amendment as applied to him. Justice Gorsuch, writing for seven Justices, concluded that the government failed to identify a historical tradition of firearm regulation analogous to its interpretation of §922(g)(3), which automatically disarms anyone who regularly uses a controlled substance regardless of whether the person is dangerous, intoxicated, or incapable of managing his affairs. The Court rejected the government's reliance on historical laws regulating "habitual drunkards," finding that those laws targeted individuals whose intoxication rendered them incapacitated, served different purposes, and generally required individualized proceedings before liberty could be restricted. Because Hemani was prosecuted solely for possessing a firearm while being an admitted marijuana user, and because the government failed to show that such a broad prohibition is consistent with the Nation's historical tradition of firearm regulation, the Court held the prosecution unconstitutional. The Court emphasized the narrowness of its ruling, leaving open the validity of laws targeting addicts, intoxicated persons, or individuals shown through individualized evidence to be dangerous because of their drug use. 
Justice Alito, joined by Justice Kagan, concurred in the judgment.
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In a 6–3 decision, the Supreme Court held that Section 47(b) of the Investment Company Act does not create an implied private right of action allowing investors or other private parties to sue for rescission of contracts that allegedly violate the Act. The case arose when activist investor Saba Capital challenged voting-right restrictions adopted by several closed-end mutual funds and sought rescission under Section 47(b). Writing for the Court, Justice Barrett explained that Congress, not the courts, determines who may enforce federal statutes, and Section 47(b)’s language is directed at courts’ remedial authority once parties are already before them rather than at creating enforceable rights for a particular class of individuals. The Court emphasized that the ICA establishes a comprehensive enforcement scheme centered on the Securities and Exchange Commission and expressly authorizes private suits in only limited circumstances, making it unlikely that Congress intended an additional implied cause of action. The Court also rejected reliance on Transamerica Mortgage Advisors v. Lewis, noting that Congress amended Section 47(b) in 1980 to remove the “shall be void” language that supported an implied remedy in that case. Accordingly, the Court reversed the Second Circuit and held that Saba could not use Section 47(b) as a standalone basis to seek rescission of contracts allegedly violating the ICA.
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In a unanimous opinion by Justice Jackson, the Supreme Court vacated a Fifth Circuit decision that had barred Thomas Keathley’s personal-injury lawsuit under the doctrine of judicial estoppel after he failed to disclose the claim during his ongoing Chapter 13 bankruptcy. The Court held that when determining whether a debtor’s omission of a legal claim was inadvertent or mistaken, courts must consider the totality of the circumstances rather than applying the Fifth Circuit’s rigid rule that focused almost exclusively on whether the debtor knew of the claim and had a potential motive to conceal it. Emphasizing that judicial estoppel is an equitable doctrine requiring flexibility and case-specific analysis, the Court explained that the Fifth Circuit’s approach was both too narrow and too broad because knowledge of a claim and a theoretical incentive to conceal it are present in nearly every nondisclosure case. Without deciding whether judicial estoppel should apply in the bankruptcy context at all, or whether inadvertence is always an exception, the Court concluded that lower courts must evaluate all relevant evidence bearing on whether the omission was truly an honest mistake, and remanded for further proceedings.
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In a unanimous opinion by Justice Kagan, the Supreme Court held that a prosecution for falsifying a document in violation of 18 U.S.C. §1519 must be brought in the district where the falsification occurred, not where the federal investigation that the defendant intended to obstruct was located. Ahmad Abouammo, while in Seattle, created and emailed a fake invoice to FBI agents conducting an investigation based in San Francisco, and was subsequently tried and convicted in the Northern District of California. The Court reversed, explaining that constitutional venue rules focus on the location of the offense’s “essential conduct elements,” and §1519 criminalizes only the act of falsifying a document with obstructive intent. Because the statute does not require any actual obstruction or effect on an investigation, the location of the investigation and any contemplated consequences are irrelevant to venue. Rejecting both the Ninth Circuit’s reliance on the statute’s intent element and the Government’s argument that §1519 is an inchoate obstruction offense, the Court concluded that the only conduct constituting the crime occurred in Seattle, making the Western District of Washington the proper venue for trial.
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In a unanimous opinion by Justice Jackson, the Supreme Court held that Amarin failed to plausibly allege that Hikma actively induced infringement of Amarin’s patented cardiovascular-use methods for Vascepa. Although Hikma marketed a generic version of the drug using an FDA-approved “skinny label” that omitted the patented cardiovascular indication, Amarin argued that various statements in Hikma’s labeling, website, patient materials, and press releases nevertheless encouraged doctors to prescribe the drug for the patented use. The Court rejected that theory, emphasizing that inducement under 35 U.S.C. §271(b) requires affirmative, purposeful steps designed to encourage infringement, not merely statements that could conceivably lead someone to infringe. Many of Hikma’s challenged statements reflected legal requirements or standard industry practices, while others were omissions or vague references that did not plausibly show an intent to promote infringing use. Because Amarin’s allegations relied on speculation and attenuated chains of inference rather than concrete acts encouraging infringement, the complaint failed to state a claim, and the Court reversed the Federal Circuit’s decision allowing the suit to proceed.
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