Comptroller of the Treasury of Maryland v Wynne

Wynne challenged his income tax deficiency arguing Maryland’s refusal to give a credit for taxes paid on out of state income violated the dormant commerce clause. The Maryland Court of Appeals agreed and held the income tax provision unconstitutional. The Court, 5-4, affirmed. The majority held that the dormant commerce clause applies to state taxation schemes of individuals, that precedent bars tax schemes which tax interstate income higher than intrastate income, there is no reason not to apply those precedents here even though they arose in the corporate context and under the applicable internal consistency rule, Maryland’s scheme here fails as Wynn’s burden is higher because he earned income out of state and this result would be the same if all states adopted the scheme demonstrating the discrimination against ine4trstate commerce and tarifflike nature of the scheme. The majority reiterated that the dormant commerce clause precedent remained good law and is not a judicial fraud. Justice Scalia, joined in part by Thomas, dissented arguing the Court’s negative commerce clause jurisprudence is flat wrong as the commerce clause only authorizes regulation of interstate commerce and precedent provides no governing principle, is unstable and requires judges to go beyond their proper role. For himself, he argued the tax scheme is constitutional as it does not discriminate against interstate commerce on its face. Justice Thomas, joined in part by Scalia, argued the Maryland scheme is constitutional as the income tax schemes adopted by the states around the time of the ratification did not provide credits for out of state taxation. For himself, he argued the negative commerce clause is void of textual support and cannot be used to strike down a state law. Justice Ginsberg, joined by Scalia and Kagan, dissented arguing that states have the power to tax the income of its residence from whatever source as residents receive great benefits from the state and can elect new legislators if they don’t like the tax policy adopted by the current government. She also argued that Maryland’s scheme is consistent with most of the early modern income tax schemes adopted by states and that those schemes have been upheld by the court. She also argued that the majority’s rule will not result in the elimination of double taxation as states can comply by reducing other taxes on different taxpayers instead.

Henderson v United States

Henderson was convicted of drug violations. He sought a court order to transfer his firearms to a friend who agreed to buy them. The district court refused ruling 18 USC 922(g) bars transfers. The 11th Circuit affirmed. Resolving a circuit split, the Court reversed and remanded. It held that 922(g) strips a gun owner’s right to possess firearms but does not take away the right to alienate. The Court held that transfers could be barred if the defendant would exercise control over the firearms after the transfer, but, transfers cannot be barred absent those circumstances. The case was remanded to evaluate Henderson’s motion under the correct standard.

Tibble v Edison International

Tibble sued Edison under ERISA alleging breach of fiduciary duty for failing to replace certain mutual funds with cheaper identical funds. The district court ruled the claims time barred and the 9th Circuit affirmed. The Court reversed holding that under the common law of trusts, trustees have a continuing duty to monitor investments and replace imprudent ones. The case was remanded to determine if this continuing duty was breached here and if so whether it was breached within the 6 year limitations period.

Coleman v Toffelson

Coleman filed a variety of cases and sought in forma paueris status in each. Three cases had been dismissed as frivolous and under the three strikes provision, 28 USC 1915(g), Coleman was required to pay fees up front. He appealed arguing a case on appeal from the frivolous ruling should not count as a strike. The district court disagreed and denied his motion. The 6th Circuit affirmed. Resoling a circuit split, the Court affirmed. It held that under 1915(g), the key event is when a case “was dismissed” for frivolousness or other listed reasons and this language does not include appellate review and reading the statute to include appealed third strike rulings serves the normal treatment of district court judgments and effectuates congressional intent to limit frivolous suits.

Harris v Viegelahn

Harris converted his Chapter 13 bankruptcy case to a Chapter 7. Viegelahn, the trustee, distributed accumulated postpetition wages to creditors. The bankruptcy court ordered the monies refunded to Harris. The 5th Circuit reversed. The Court, resolving a circuit split, reversed. It held that under Chapter 7 the postpetition wages belonged to Harris and the moment he converted the case, any claim by anyone else to the accumulated wages ended and the monies should have been sent to him not distributed to creditors.

City and County of San Francisco v Sheehan

The Court, with Breyer recused, granted certiorari to resolve a circuit split on whether the American’s with Disabilities Act applies to arrests. It dismissed as improvidently granted that issue as city argued the Act did apply and thus there was no adversarial proceeding on the issue. Six justices then decided the issue of qualified immunity for the officers involved in the arrest and held that there was no controlling authority in either the Court’s precedent or in the circuit authority cited below to put the officers on notice that their second entry into Sheehan’s room was unreasonable. Justices Scalia and Ginsberg would have dismissed the immunity issue in order to avoid rewarding City for its bait and switch on the issue of arrest and the ADA.