Horne v Department of Agriculture

Horne challenged the fines asses for failure to turn over raisins to the federal government without compensation. The 9th Circuit ultimately upheld the fines. The Court 8 (five justice majority plus three concurring in part)-1 reversed. It held that the 5th Amendment takings clause applies in full force to claims involving personal property, the required delivery of raisins under the Department’s marketing plan is a taking, Horne’s right to net proceeds from the seized raisins did not change the physical taking into a regulatory one and requiring the delivery of the raisins as a condition to enter the raisin market is also a taking as selling goods in the market is not a special privilege government may require delivery of some of those goods to participate in the market. Five justices held that because the Department has already calculated the market value of the raisins not delivered by Horne under the marketing plan, department is stuck with that value and remand is not necessary to calculate damages here. Thomas added a concurrence noting that takings must be for public use and it is not clear here that eh set aside raisins were seized for any public use. Breyer, joined by Ginsberg and Kegan dissented in part arguing that benefits to Horne for participating in the marketing plan may itself be just compensation under the circumstances. Sotomayor dissented arguing that there was no taking as Horne’s retained some rights to the raisins and government can require the delivery here as a condition to enter a regulated market.

Kingsley v Hendrickson

Kingsley appealed the judgment in favor of Hendrickson in his pretrial detainee excessive force case arguing the district court erred in adding a subjective mental element in the jury instructions. The 7th circuit rejected his appeal. Resolving a circuit split on whether the standard for pretrial detainee excessive force claims includes the subjective mental element, the Court, 5-4, reversed. The majority held the objective standard to evaluate excessive force claims is appropriate in detainee cases as this is the standard for other detainee cases, is a workable rule and still protects officers who act in good faith. It held the addition of the subjective mental element was error and remanded for further proceedings. Scalia, joined by Roberts and Thomas, dissented arguing that only conditions of confinement that raise to the level of punishment are prohibited by the 14th Amendment and mere use of excessive force does not meet that definition. Alito dissented arguing the case should be dismissed as the appropriate source of law is the 4th Amendment and Kingsley did not raise that issue.

City of Los Angeles, California v Patel

Patel and other hotel owners sued city arguing the requirement that the hotels show their guest registry to police officers on demand violated the 4th amendment. The 9th Circuit ultimately agreed and found the requirement unconstitutional. The Court, 5-4, affirmed. The majority first held that facial challenges under the 4th Amendment are allowed and are not disfavored as demonstrated by successful changes in the Court’s precedents. It held that eth on demand requirement is unconstitutional because it does not allow any mechanism to challenge the demand before compliance and noted administrative subpoenas are one way this reviewer could be allowed though motions to quash. The majority held that hotels are not inherently dangerous and the minimal regulations in the City’s code do not make a comprehensive regulatory scheme and further noted that if the minimal regulation were sufficient to authorize warrantless searches, all businesses would be subject to those searches. Scalia, joined by Roberts and Thomas dissented arguing that hotels are closely regulated entities with reduced expectations of privacy in their records, the visual inspection of the registry is not burdensome while the need to obtain a warrant or stay in the hotel to protect the registry from alteration are burdensome and the ordinance here do not authorize the police to go anywhere not already opened to the public. Thus, he would hold the administrative searches here reasonable. Alito, joined by Thomas, dissented arguing that there are circumstances when the requirement can be applied constitutionally and thus the facial challenge must be rejected.

Kimble v Marvel Entertainment, LLC

Marvel sued for declaratory judgment that its obligation to pay Kimble royalties under a settlement agreement ended when the underlying patent expired. Citing Supreme Court precedent, the district court issued the declaratory judgment and the 9th Circuit reluctantly affirmed. The Court, 6-3, affirmed. The majority held that stare decisis applied and there was no special justification for overturning the precedent here as it is a statutory case involving property and contracts and Congress has had numerous opportunities to change the statute and has declined to do so. The majority held that even if the current rule is economically unsound, Congress, not the Court, is the proper entity to make the change. Alito, joined by Roberts and Thomas, dissented arguing that the precedent here was bald policymaking masquerading as statutory interpretation, its reasoning has been refuted and it has bad economic consequences and upsets party expectations. Thus, he would have overturned the precedent.