Armstrong v Exceptional Child Center, Inc.

Center sued to raise reimbursement under Medicaid Act 30(A). The district court granted summary judgment to Center and the 9th circuit affirmed. The Court, 5 (4 justice plurality joined in part by Breyer)-4, reversed. A majority held that Center had no claim under the Supremacy clause as it grants no rights and allowing private enforcement of federal law would improperly limit congressional power to ensure proper administration of federal law. The majority also held that suit under 30(A) or equity was not available as there was no judicially administrable standard in the text and Congress chose to enforce 30(A) through administrative withholding of funds. The plurality also argued that the agreements between the federal government and Idaho were not enforceable by private providers like Center. Justice Breyer added his concurrence in judgment arguing that 30(A) is not privately enforceable because of the need for administrative judgment in setting rates and the possible availability of an Administrative Procedures Act suit in egregious cases. Justice Sotomayor, joined by Kennedy, Ginsberg and Kagan dissented arguing that 30(A) is privately enforceable because injunctive suits to stop state laws from interfering with federal law have long been recognized and Congress should be presumed to allow them unless specially rejected in the statute in question. 30(A) contains no alternate remedial program and while broad the standard in 30(A) is similar to other provisions held to allow private enforcement. Thus, the dissent argued that the lower courts should have been affirmed.

Young v United Postal Service, Inc.

Young sued for pregnancy discrimination when UPS would not offer her a light duty job during her pregnancy. The district court granted summary judgment to UPS and the 4th Circuit affirmed. The Court, 6(5 justice majority plus a concurrence in judgment)-3 vacated and remanded. The majority held that under the statute, 42 USC 2000e(k), both discrimination because of pregnancy and treating pregnant workers differently than other workers with similar ability or inability to work. The majority held this did not mean pregnant workers must receive the same benefits as any other worker nor did it mean that the second protection merely clarified the first. Instead, it adopted a new rule limited to 2000e(k) claims that claim is stated when an employer substantially burdens pregnant employees and does not provide a strong enough reason for doing so. The case was remanded to evaluate Young’s claim under the new standard in the first instance. Justice Alito concurred in judgment agreeing that differing treatment claims are authorized, that the comparison group is those in the same or similar jobs and that Young stated such a claim as she identified drivers, like herself, who got accommodation when their DOT certificate was revoked and UPS failed to explain why accommodation was not also extended to pregnant workers. Justice Scalia, joined by Kennedy and Thomas, dissented arguing 2000e(k) either means pregnant employees must receive all benefits given to any employee or that such workers are protected for discrimination based on their status as pregnant workers. The dissent argued the later interpretation should be adopted as the most plausible in light of congressional intent. It criticized the majority’s new rule as unconnected the actual language of the statute and unworkable. Justice Kennedy added a dissent acknowledging the challenges faced by pregnant workers and identifying some of the other legal remedies available to them.

Alabama Legislative Black Caucus v Alabama

Caucus challenged the state legislature redistricting plan arguing it diluted minority voting power. A split three judge district court panel rejected the challenge.  The Court, 5-4, vacated and remanded. The majority held that the panel failed to evaluate the challenge on a district by district basis, failed to allow Caucus to prove standing, failed to treat compliance with equal protection principles as a given instead of a competing interest and failed to apply the correct test to determine if strict scrutiny is satisfied if race discrimination occurred. Justice Scalia, joined by Roberts, Thomas and Alito, dissented arguing Caucus raised only a statewide challenge and thus waived its potentially viable district by district challenges. Justice Thomas added a dissent arguing the court’s precedent recognizing vote dilution is wrong and should be abandoned.

Grady v North Carolina

Grady challenged his lifetime satellite GPS tracking as a sex offender under the 4th Amendment. North Carolina courts rejected the challenge based on state precedent holding civil programs like the tracking one here are not searches. The court summarily reversed holding that just like attaching a tracer to a car is a search, the ankle bracelet system here is also a search. The case was remanded to evaluate whether the tracking program is reasonable.

Woods v Donald

Donald filed a federal habeas petition arguing his trial counsel was ineffective by being absent during testimony about codefendants which was irrelevant to Donald’s defense. The district court granted his petition and the 6th Circuit affirmed. The Court summarily reversed. It held no Court case has ever held that absence during testimony about other defendants irrelevant to the claimant’s defense is per se ineffective and thus the Michigan state court’s rejection of Donald’s claim was due deference and the petition should have been denied.