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In Donald J. Trump, President of the United States, et al. v. J.G.G., et al., the Supreme Court granted the government’s application to vacate temporary restraining orders issued by the District Court for the District of Columbia, which had blocked the removal of several Venezuelan detainees allegedly affiliated with the foreign terrorist organization Tren de Aragua (TdA). The detainees challenged President Trump’s Proclamation No. 10903, issued under the Alien Enemies Act (AEA), which authorized their detention and removal.

The Court construed the TROs as appealable injunctions and held that the detainees’ claims must be brought in habeas corpus. Because the claims necessarily challenged the legality of confinement and removal under the AEA, they fell within the “core” of habeas jurisdiction. As such, jurisdiction and venue lay solely in the district of confinement—Texas—not in the District of Columbia. The Court emphasized that equitable relief cannot be sought outside habeas in this context, relying on precedents such as Ludecke v. Watkins and Heikkila v. Barber.

Although the detainees are entitled to judicial review regarding their classification and removal under the AEA—including notice and an opportunity to seek habeas relief—the proper venue to litigate those claims is the district of confinement. The Court clarified that such notice must be given promptly to allow detainees to exercise those rights before removal occurs.

Read by RJ Dieken.

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In Department of Education, et al. v. California, the Supreme Court in a per curiam decision granted the federal government’s application to stay a district court order that had mandated continued payment of certain education-related grants. The District Court for the District of Massachusetts had issued a temporary restraining order (TRO) on March 10, 2025, barring the termination of grant payments and requiring the government to pay both past-due and ongoing obligations. The lower court found that the states challenging the terminations were likely to succeed on their claims under the Administrative Procedure Act (APA).

The Supreme Court, however, treated the TRO as a de facto preliminary injunction and concluded that the district court likely lacked jurisdiction to order monetary payments under the APA. Citing precedents such as Sampson v. Murray and Great-West Life & Annuity Ins. Co. v. Knudson, the Court emphasized that the APA does not waive sovereign immunity for claims that essentially seek money damages or enforce a contractual obligation to pay money—relief instead governed by the Tucker Act and reserved to the Court of Federal Claims.

The Court also held that the government demonstrated a likelihood of success on appeal and that the balance of equities favored a stay. Respondents had not shown they would suffer irreparable harm, particularly because they had the resources to continue their programs and could seek recovery in another forum if successful. The Court concluded that any harm resulting from program shutdowns would be self-imposed.

Read by RJ Dieken.

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In Medical Marijuana, Inc. v. Horn, the Supreme Court affirmed the Second Circuit and held that a plaintiff may seek treble damages under the civil RICO statute for injuries to business or property, even if those injuries stem from a personal injury. Douglas Horn was fired after testing positive for THC, allegedly caused by using a CBD product marketed as THC-free. He sued the manufacturer under RICO, claiming his job loss constituted a business injury. The district court dismissed the case, applying the so-called “antecedent personal injury bar,” which precludes recovery under RICO for business losses resulting from personal injury. The Second Circuit reversed.

Writing for the Court, Justice Barrett rejected the categorical bar. The Court held that while civil RICO does not authorize damages for personal injuries themselves, it does not exclude claims for business or property losses merely because they originate from a personal injury. Drawing on the statute’s text, the Court emphasized the ordinary meaning of “injured in his business or property” and declined to import tort-based limitations or narrow definitions unsupported by the statutory language. The Court also declined to adopt a rigid rule for distinguishing personal from business injuries, finding such distinctions difficult to apply and inconsistent with prior precedent.

Justice Barrett delivered the opinion of the Court, joined by Justices Sotomayor, Kagan, Gorsuch, and Jackson. Justice Jackson filed a concurring opinion. Justice Thomas dissented. Justice Kavanaugh filed a dissenting opinion, joined by Chief Justice Roberts and Justice Alito.

Read by RJ Dieken.

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In FDA v. Wages and White Lion Investments, the Supreme Court unanimously vacated a Fifth Circuit decision that found the Food and Drug Administration acted arbitrarily and capriciously when it denied authorization for flavored e-cigarette products. Under the Tobacco Control Act of 2009, manufacturers must receive FDA approval before marketing “new tobacco products,” including most modern e-cigarettes. The Act permits approval only if the product is “appropriate for the protection of the public health,” requiring the FDA to weigh population-wide risks and benefits, including youth usage.

Respondents, manufacturers of flavored e-liquids, submitted premarket applications but failed to provide robust scientific evidence—such as randomized controlled trials or longitudinal studies—showing their products posed fewer risks than tobacco-flavored alternatives. The FDA denied their applications. The Fifth Circuit, sitting en banc, held the FDA improperly departed from its own guidance and failed to consider the applicants’ marketing plans, which had been labeled “critical.”

Justice Alito, writing for a unanimous Court, rejected the Fifth Circuit’s findings. The Court held that the FDA’s denials were consistent with its guidance and did not violate the change-in-position doctrine. The FDA had made clear that strong scientific evidence would be necessary and that fruit- and dessert-flavored products were likely to appeal to youth. The Court also found that the Fifth Circuit misread Calcutt v. FDIC in concluding that the FDA’s failure to review the marketing plans required automatic remand. Instead, the harmless-error rule applies in administrative cases, and remand is not always necessary. The case was remanded for further consideration under the correct standard.

Justice Sotomayor filed a concurring opinion.

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In United States v. Miller, the Supreme Court reversed the Tenth Circuit and held that a bankruptcy trustee cannot use §544(b) of the Bankruptcy Code to claw back funds from the federal government under a state fraudulent-transfer law, due to sovereign immunity. The case arose after shareholders of a failed Utah business used $145,000 of company money to pay personal federal tax debts. The bankruptcy trustee sought to “avoid” that transfer under Utah law, invoking §544(b), which permits a trustee to assert the rights of an “actual creditor” to void certain transfers. The government argued the claim was barred because sovereign immunity prevents such a state-law suit against the United States.

The lower courts sided with the trustee, reasoning that §106(a) of the Bankruptcy Code waived sovereign immunity for actions brought under §544. But the Supreme Court disagreed. Writing for the Court, Justice Jackson held that §106(a)’s waiver applies only to the federal claim under §544—not to the state-law cause of action it incorporates. The Court emphasized that waivers of sovereign immunity must be unambiguous and strictly construed. Since Utah law could not otherwise be used to sue the federal government outside bankruptcy, the trustee’s claim failed.

Justice Jackson delivered the opinion of the Court, joined by Chief Justice Roberts and Justices Thomas, Alito, Sotomayor, Kagan, Kavanaugh, and Barrett. Justice Gorsuch filed a dissenting opinion.

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In Bondi v. Vanderstok, the Supreme Court reversed the Fifth Circuit and upheld the ATF’s 2022 rule interpreting the Gun Control Act of 1968 (GCA) to cover certain “ghost gun” kits and unfinished firearm parts. The GCA requires licenses and background checks for firearm sales and defines “firearm” to include both weapons and their frames or receivers. In recent years, companies have sold weapon parts kits enabling individuals to easily assemble functional guns at home, leading to a surge in untraceable “ghost guns.”

Challengers brought a facial Administrative Procedure Act challenge, arguing the GCA does not authorize the ATF to regulate incomplete kits or parts. The Fifth Circuit agreed, holding the statute covers only fully functional weapons and finished frames or receivers.

The Supreme Court disagreed. Writing for the Court, Justice Gorsuch held that the statute’s text, structure, and context support the ATF’s rule. Kits like Polymer80’s, which can be assembled into operable weapons in 20 minutes with household tools, qualify as “weapons” under §921(a)(3)(A). Likewise, partially complete frames and receivers fall within the meaning of §921(a)(3)(B), as Congress contemplated regulation of unfinished items in other provisions. The facial challenge fails because at least some kits and components clearly fall within the statute’s reach. The Court also rejected arguments based on the rule of lenity and constitutional avoidance.

Justice Gorsuch delivered the opinion of the Court, joined by Chief Justice Roberts and Justices Sotomayor, Kagan, Kavanaugh, Barrett, and Jackson. Justices Sotomayor, Kavanaugh, and Jackson each filed concurring opinions. Justices Thomas and Alito dissented.

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In Delligatti v. United States, the Supreme Court held that New York attempted second-degree murder qualifies as a crime of violence under 18 U.S.C. §924(c) because the knowing or intentional causation of death, whether by act or omission, necessarily involves the use of physical force under §924(c)(3)(A).

Salvatore Delligatti was convicted under §924(c) after recruiting gang members to kill a suspected police informant and providing a loaded revolver for the crime. Before trial, he moved to dismiss the §924(c) charge, arguing that the predicate offense—attempted murder under the violent-crimes-in-aid-of-racketeering (VICAR) statute (§1959(a)(5))—was not a crime of violence. His argument relied on New York law, which allows second-degree murder to be committed by omission, such as failing to perform a legal duty, meaning it does not categorically require the use of physical force. The Second Circuit rejected his argument, concluding that attempted second-degree murder under New York law necessarily involves force.

In a 7-2 opinion by Justice Thomas, the Court affirmed. Applying the reasoning from United States v. Castleman, the Court held that the knowing or intentional causation of bodily injury inherently involves the use of physical force, even when the offense is committed by omission. The Court reasoned that force does not require direct physical contact and can include indirect means such as poisoning or starvation. The majority further concluded that the term "crime of violence" must be understood in a manner consistent with how intentional homicide has historically been treated under criminal law, including liability for omissions.

Justice Gorsuch, joined by Justice Jackson, dissented, arguing that §924(c) requires an affirmative use of force, not mere inaction, and that Congress did not clearly intend to include crimes of omission within its definition of a violent crime.

The Court’s ruling upholds Delligatti’s conviction and clarifies the scope of federal firearm enhancements for violent crimes.

Read by Jeff Barnum.

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In Thompson v. United States the Supreme Court held that 18 U.S.C. §1014, which prohibits “knowingly mak[ing] any false statement” to influence the FDIC’s actions on a loan, does not extend to statements that are merely misleading but not technically false.

Patrick Thompson, a former Chicago Alderman, was charged under §1014 after disputing his loan balance in conversations with FDIC contractors, stating he had only borrowed $110,000 when in fact he had borrowed $219,000 in total. A jury convicted him, and the lower courts upheld the conviction on the basis that his statements, though potentially technically true, were misleading. They concluded §1014 criminalizes misleading statements.

The Supreme Court reversed, emphasizing that the statute's text criminalizes only “false” statements—not misleading ones. The Court distinguished between the two, noting that misleading statements can be true, and true statements are not false. Because Congress included only the word “false,” and not “misleading,” the Court concluded the statute’s reach does not extend beyond literal falsehoods.

Contextual analysis reinforced this conclusion. Other statutes in Title 18 use both terms explicitly. The historical and legislative context showed that Congress knew how to include “misleading” when it intended to do so, and declined to do so in §1014. Precedents like United States v. Wells and Williams v. United States also supported a narrow interpretation of §1014, requiring statements that are actually and factually false.

The Court remanded the case for the Seventh Circuit to decide whether a reasonable jury could find that Thompson’s statements were, in fact, false—not merely misleading.

Chief Justice Roberts delivered the opinion for a unanimous Court. Justices Alito and Jackson filed concurring opinions.