The Supreme Court issued four opinions in argued cases this morning:
(1) Sturgeon v. Frost: By a vote of 8-0 the judgment of the Ninth Circuit is vacated and the case remanded. Per the Chief Justice's opinion for a unanimous Court: "For almost 40 years, John Sturgeon has hunted moose along the Nation River in Alaska. Because parts of the river are shallow and difficult to navigate, Sturgeon travels by hovercraft, an amphibious vehicle capable of gliding over land and water. To reach his preferred hunting grounds, Sturgeon must pilot his hovercraft over a stretch of the Nation River that flows through the Yukon-Charley Rivers National Preserve, a 1.7 million acre federal preservation area managed by the National Park Service....Alaska law permits the use of hovercraft. National Park Service regulations do not.... After Park Service rangers informed Sturgeon that he was prohibited from using his hovercraft within the boundaries of the preserve, Sturgeon filed suit, seeking declaratory and injunctive relief. He argues that the Nation River is owned by the State, and that the Alaska National Interest.Lands Conservation Act (ANILCA) prohibits the Park Service from enforcing its regulations on state-owned land in Alaska. The Park Service disagrees, contending that it has authority to regulate waters flowing through federally managed preservation areas. The District Court and the Court of Appeals ruled in favor of the Park Service....Looking at ANILCA both as a whole and with respect to Section 103(c), the Act contemplates the possibility that all the land within the boundaries of conservation system units in Alaska may be treated differently from federally managed preservation areas across the country, and that “non-public” lands within the boundaries of those units may be treated differently from “public” lands within the unit. Under the Ninth Circuit’s reading of Section 103(c), however, the former is not an option, and the latter would require contorted and counterintuitive measures. We therefore reject the interpretation of Section 103(c) adopted by the court below. That reading of the statute was the sole basis for the disposition of this case by the Court of Appeals. We accordingly vacate the judgment of that court and remand for further proceedings."
(2) Tyson Foods, Inc. v. Bouaphakeo: By a vote of 6-2 the judgment of the Eighth Circuit is affirmed and the case is remanded. Per Justice Kennedy's majority opinion: "Following a jury trial, a class of employees recovered $2.9 million in compensatory damages from their employer for a violation of the Fair Labor Standards Act of 1938 (FLSA).... The employees’ primary grievance was that they did not receive statutorily mandated overtime pay for time spent donning and doffing protective equipment. The employer seeks to reverse the judgment....First, the employer argues the class should not have been certified because the primary method of proving injury assumed each employee spent the same time donning and doffing protective gear, even though differences in the composition of that gear may have meant that, in fact, employees took different amounts of time to don and doff. Second, the employer argues certification was improper because the damages awarded to the class may be distributed to some persons who did not work any uncompensated overtime. The Court of Appeals for the Eighth Circuit concluded there was no error in the District Court’s decision to certify and maintain the class.... Reasonable minds may differ as to whether the average time [expert witness] Mericle calculated is probative as to the time actually worked by each employee. Resolving that question, however, is the near-exclusive province of the jury. The District Court could have denied class certification on this ground only if it concluded that no reasonable juror could have believed that the employees spent roughly equal time donning and doffing....The District Court made no such finding, and the record here provides no basis for this Court to second-guess that conclusion.....As petitioner and its amici stress, the question whether uninjured class members may recover is one of great importance.... It is not, however, a question yet fairly presented by this case, because the damages award has not yet been disbursed, nor does the record indicate how it will be disbursed. Respondents allege there remain ways of distributing the award to only those individuals who worked more than 40 hours. For example, by working backwards from the damages award, and assuming each employee donned and doffed for an identical amount of time (an assumption that follows from the jury’s finding that the employees suffered equivalent harm under the policy), it may be possible to calculate the average donning and doffing time the jury necessarily must have found, and then apply this figure to each employee’s known gang-time hours to determine which employees worked more than 40 hours. Whether that or some other methodology will be successful in identifying uninjured class members is a question that, on this record, is premature. Petitioner may raise a challenge to the proposed method of allocation when the case returns to the District Court for disbursal of the award...."
The Chief Justice and Justices Ginsburg, Breyer, Sotomayor, and Kagan joined Justice Kennedy's majority opinion. The Chief Justice filed a concurring opinion, which Justice Alito joined as to Part II. Justice Thomas filed a dissenting opinion, which Justice Alito joined.
(3) Nebraska v. Parker: By a vote of 8-0 the judgment of the Eighth Circuit is affirmed. Per Justice Thomas' opinion for a unanimous Court: "The village of Pender, Nebraska sits a few miles west of an abandoned right-of-way once used by the Sioux City and Nebraska Railroad Company. We must decide whether Pender and surrounding Thurston County, Nebraska, are within the boundaries of the Omaha Indian Reservation or whether the passage of an 1882 Act empowering the United States Secretary of the Interior to sell the Tribe’s land west of the right-of-way 'diminished' the reservation’s boundaries, thereby 'free[ing]' the disputed land of 'its reservation status.' Solem v. Bartlett, 465 U. S. 463, 467 (1984). We hold that Congress did not diminish the reservation in 1882 and that the disputed land is within the reservation’s boundaries."
(4) Hawkins v. Community Bank: Per curiam: The judgment of the Eighth Circuit (which affirmed a grant of summary judgment by the district court in favor of Community Bank on the Hawkins' claim under the Equal Credit Opportunity Act and its striking of their demand for a jury trial) is "affirmed by an equally divided Court." The questions presented were: (1) Whether “primarily and unconditionally liable” spousal guarantors are unambiguously excluded from being Equal Credit Opportunity Act (ECOA) “applicants” because they are not integrally part of “any aspect of a credit transaction”; and (2) whether the Federal Reserve Board has authority under the ECOA to include by regulation spousal guarantors as “applicants” to further the purposes of eliminating discrimination against married women.