Supreme Court Oral Arguments

Hughes v. Northwestern University Justia (with opinion) · Docket · oyez.org Argued on Dec 6, 2021.Decided on Jan 24, 2022. Petitioner: April Hughes, et al..Respondent: Northwestern University, et al.. Advocates: David C. Frederick (for the Petitioners) Michael R. Huston (for the United States, as amicus curiae, supporting the Petitioners) Gregory G. Garre (for the Respondents) Facts of the case (from oyez.org) Northwestern University offers two employee investment plans that are at issue in this case, a Retirement Plan in which Northwestern makes a matching contribution and a Voluntary Savings plan in which the University does not match. Laura Divane and other plaintiffs are beneficiaries of one or both of the employee investment plans. The plaintiffs sued Northwestern University for allegedly breaching its fiduciary duties under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. § 1001, et seq. The plaintiffs alleged that Northwestern breached its fiduciary duty by offering a stock account option with excessive fees and a history of underperformance. The district court found no breach, noting that participants could have avoided any problems with the undesirable funds by simply choosing other options. The U.S. Court of Appeals for the Seventh Circuit affirmed. Question Are allegations that a defined-contribution retirement plan paid or charged its participants fees that substantially exceeded fees for alternative available investment products or services sufficient to state a claim against plan fiduciaries for breach of the duty of prudence under the Employee Retirement Income Security Act of 1974 (ERISA)? Conclusion An allegation that fiduciaries breached their duty of prudence requires a context-specific inquiry involves assessing the fiduciaries’ duty to monitor all plan investments and remove any imprudent ones, which the Seventh Circuit below failed to do. Justice Sonia Sotomayor authored the opinion for the unanimous (8-0) Court. ERISA imposes a duty of prudence on fiduciaries that includes, among other things, a duty to monitor investments and remove imprudent ones. The mere fact that participants could have chosen lower-priced investments neither refutes nor supports whether fiduciaries fulfilled their duty of prudence. The court of appeals’ reliance on investor choice in reaching its conclusion for the University failed to make the proper inquiry. Justice Amy Cony Barrett took no part in the consideration or decision of the case.

Patel v. Garland Wikipedia · Justia (with opinion) · Docket · oyez.org Argued on Dec 6, 2021.Decided on May 16, 2022. Petitioner: Pankajkumar S. Patel, et al..Respondent: Merrick B. Garland, Attorney General. Advocates: Mark C. Fleming (for the Petitioners) Austin L. Raynor (for the Respondent supporting reversal) Taylor A.R. Meehan (for the judgment below) Facts of the case (from oyez.org) Pankajkumar Patel is a citizen of India who entered the United States without inspection. In 2012, the Department of Homeland Security charged Patel as removable for being present without inspection. At a hearing, Patel conceded that he was removable but sought discretionary relief from removal on the grounds that he had an approved I-140 employment authorization document. To be eligible for discretionary relief from removal, a noncitizen must show, among other things, “clearly and beyond doubt” that he is not inadmissible. However, Patel’s admissibility is in doubt because, when he applied for a Georgia driver’s license in 2008, he falsely represented himself when he checked a box indicating he is a U.S. citizen. At his removal hearing, Patel argued that it was simply a mistake and was immaterial since citizenship was not required to obtain the driver’s license. The immigration judge (IJ) rejected Patel’s arguments and denied his application for adjustment of status. The Board of Immigration Appeals affirmed, finding no clear error in the factual findings. A panel of the U.S. Court of Appeals for the Eleventh Circuit held that it lacked jurisdiction to review the factual findings of the IJ, based on 8 U.S.C. § 1252(a)(2)(B), which provides that “no court shall have jurisdiction to review” “any judgment regarding the granting of relief” for certain enumerated categories of discretionary relief, including the relief for which Patel applied. Question Does 8 U.S.C. § 1252(a)(2)(B)(i) preserve the jurisdiction of federal courts to review a nondiscretionary determination that a noncitizen is ineligible for certain types of discretionary relief? Conclusion Federal courts lack jurisdiction to review facts found as part of any judgment relating to the granting of discretionary-relief in immigration proceedings enumerated under 8 U.S.C. §1252(a)(2)(B)(i). Justice Amy Coney Barrett authored the 5-4 majority opinion of the Court. Section 1252(a)(2)(B)(i) strips courts of jurisdiction to review “any judgment regarding the granting of relief” under § 1255. Best understood, the word “judgment” in that phrase refers to any authoritative decision relating to the granting or denying of discretionary relief. Although this interpretation prohibits review of some factual determinations made in the discretionary-relief context that would be reviewable if made elsewhere in removal proceedings, that distinction reflects Congress’s choice to provide reduced procedural protection for discretionary relief. Justice Neil Gorsuch authored a dissenting opinion, in which Justices Stephen Breyer, Sonia Sotomayor, and Elena Kagan joined. Justice Gorsuch argued that the majority’s opinion permits a bureaucratic factual mistake to have life-changing consequences for an immigrant applying for legal residency and is an assertion of “raw administrative power” that neither the agency nor the Executive Branch endorses.

Scott G. Stewart advocates for the Petitioners, while Julie Rikelman and Elizabeth B. Prelogar represent the Respondents and the U.S., respectively. They dive deep into the constitutional foundations of Roe v. Wade, the implications of the Mississippi law banning abortions after 15 weeks, and the evolving nature of viability as a legal standard. The conversation also touches on women's autonomy, the historical context of abortion rights, and the potential consequences of restrictive legislation on marginalized communities. Prepare for an insightful legal showdown!

Cummings v. Premier Rehab Keller, P.L.L.C. Wikipedia · Justia (with opinion) · Docket · oyez.org Argued on Nov 30, 2021.Decided on Apr 28, 2022. Petitioner: Jane Cummings.Respondent: Premier Rehab Keller, P.L.L.C.. Advocates: Andrew Rozynski (for the Petitioner) Colleen E. Roh Sinzdak (for the United States, as amicus curiae, supporting the Petitioner) Kannon K. Shanmugam (for the Respondent) Facts of the case (from oyez.org) Jane Cummings has been deaf since birth and is legally blind. In 2016, she contacted Premier Rehab Keller to treat her chronic back pain and requested that Premier provide an ASL interpreter. Premier refused and told her she could communicate with her therapist using written notes, lipreading, gesturing, or provide her own ASL interpreter. Cummings ultimately went to another physical therapy provider but found the alternate provider “unsatisfactory.” Cummings sued Premier for disability discrimination under the Americans with Disabilities Act of 1990, the Rehabilitation Act of 1973, the Patient Protection and Affordable Care Act of 2010, and the Texas Human Resources Code § 121.003. In her complaint, she sought injunctive relief and damages. The district court granted Premier’s motion to dismiss, finding that “[t]he only compensable injuries that Cummings alleged Premier caused were ‘humiliation, frustration, and emotional distress,’" and emotional distress damages are unavailable under the statutes Cummings relied on. The U.S. Court of Appeals for the Fifth Circuit affirmed. Question Do the compensatory damages available under Title VI of the Civil Rights Act of 1964 and the statutes that incorporate its remedies for victims of discrimination, such as the Rehabilitation Act and the Affordable Care Act, include compensation for emotional distress? Conclusion Emotional distress damages are not recoverable in a private action to enforce either the Rehabilitation Act of 1973 or the Affordable Care Act. Chief Justice John Roberts authored the 6-3 majority opinion of the Court. Pursuant to its power under the Spending Clause of the Constitution, Congress enacted statutes—including the Rehabilitation Act of 1973 and the Affordable Care Act—prohibiting recipients of federal funds from discriminating on the basis of certain protected characteristics. The Supreme Court has recognized implied rights of action for private individuals seeking enforcement of those statutes, but because the rights of action are implied, the remedies available under the statutes are unclear. The Supreme Court uses the analogy of contract law to decide whether a remedy is available in these situations. Under this approach, a particular remedy is available “only if the funding recipient is on notice that, by accepting federal funding, it exposes itself to liability of that nature.” Because damages for emotional distress are not usually available under contract law and serious emotional disturbance is not a particularly likely result of violation of these statutes, federal funding recipients have not consented to be subject to such damages. Justice Brett Kavanaugh authored a concurring opinion, in which Justice Neil Gorsuch joined, suggesting that the separation of powers principle, rather than contract law, is better suited for determining remedies for this implied cause of action. Justice Stephen Breyer authored a dissenting opinion, in which Justices Sonia Sotomayor and Elena Kagan joined. Justice Breyer argued that the contracts most analogous to these anti-discrimination statutes did allow for recovery of emotional distress damages, as emotional disturbance is the likely result of invidious discrimination.  

American Hospital Association v. Becerra Wikipedia · Justia (with opinion) · Docket · oyez.org Argued on Nov 30, 2021.Decided on Jun 15, 2022. Petitioner: American Hospital Association, et al..Respondent: Xavier Becerra, Secretary of Health and Human Services, et al.. Advocates: Donald B. Verrilli, Jr. (for the Petitioners) Christopher G. Michel (for the Respondents) Facts of the case (from oyez.org) The federal government reimburses hospitals for providing outpatient care to patients insured by Medicare Part B. Until recently, the government reimbursed all hospitals at a uniform rate for providing covered drugs. In 2018, the Department of Health and Human Services (HHS) reduced the reimbursement rates for certain types of hospitals (known as “340B hospitals”) because those hospitals can obtain the covered drugs far more cheaply than other hospitals can. HHS reasoned that it should not reimburse hospitals more than they paid to acquire the drugs. Several 340B hospitals and hospital associations affected by the decision filed a lawsuit challenging HHS’s decision to lower reimbursement rates. The district court ruled that HHS had exceeded its statutory authority by reducing drug reimbursement rates for 340B hospitals, but the U.S. Court of Appeals for the D.C. Circuit reversed, finding that HHS’s decision is based on a reasonable interpretation of the statute. Question 1. Is the Department of Health and Human Services’ decision to lower drug reimbursement rates for certain hospitals based on a reasonable interpretation of the Medicare statute? 2. Does 42 U.S.C. § 1395l(t)(12) preclude the petitioners’ challenge to HHS’s adjustments? Conclusion The Medicare Prescription Drug, Improvement, and Modernization Act of 2003 does not preclude judicial review of the reimbursement rates set by the Department of Health and Human Services (HHS) for certain outpatient prescription drugs that hospitals provide to Medicare patients. Here, because HHS did not conduct a survey of hospitals’ acquisition costs in 2018 and 2019, its decision to vary reimbursement rates only for 340B hospitals in those years was unlawful. Justice Brett Kavanaugh authored the unanimous opinion of the Court. There is a general presumption that judicial review is available, and the relevant provision of the Medicare act contains nothing precluding judicial review. HHS may not vary the reimbursement rates only for certain hospitals and not others without a survey. Permitting it to do so is contrary to the text and structure of the statute. Thus, its decision to change reimbursement rates only for 340B hospitals without conducting a survey was unlawful. 

Becerra v. Empire Health Foundation Wikipedia · Justia (with opinion) · Docket · oyez.org Argued on Nov 29, 2021.Decided on Jun 24, 2022. Petitioner: Xavier Becerra, Secretary of Health and Human Services.Respondent: Empire Health Foundation, for Valley Hospital Medical Center. Advocates: Jonathan C. Bond (for the Petitioner) Daniel J. Hettich (for the Respondent) Facts of the case (from oyez.org) In 2005, the U.S. Department of Health and Human Services promulgated a rule eliminating the word “covered” from 42 C.F.R. § 412.106(b)(2)(i), effectively amending HHS’s interpretation of the phrase “entitled to [Medicare]” in a subsection of the Medicare Act. This amendment affects the way HHS calculates its reimbursement to certain hospitals that serve low-income patients. Plaintiff Empire Health Foundation challenged the 2005 Rule as part of a larger challenge to HHS’s calculation of its 2008 reimbursement. The district court granted partial summary judgment for Empire based on a finding that HHS did not follow correct procedures under the Administrative Procedure Act (APA) because of numerous mistakes that occurred during the notice-and-comment process. The U.S. Court of Appeals affirmed on different grounds, concluding that HHS did follow the correct procedures under the APA, but the rule is substantively invalid  because it directly conflicts with Ninth Circuit precedent holding that the phrase “entitled to [Medicare] is unambiguous.” Question Did the Department of Health and Human Services follow the correct procedures when it promulgated a rule changing the way it calculates Medicare reimbursement rates for hospitals? Conclusion HHS followed the correct procedures; in calculating the Medicare fraction, individuals “entitled to [Medicare Part A] benefits” are all those qualifying for the program, regardless of whether they receive Medicare payments for part or all of a hospital stay. Justice Elena Kagan authored the 5-4 majority opinion of the Court. The phrase “entitled to benefits” means the same thing as “qualifying for benefits.” By counting everyone who qualifies for Medicare benefits in the Medicare fraction—and no one who qualifies for those benefits in the Medicaid fraction—HHS is following the statutory procedures that seek to capture two different segments of a hospital’s low-income patient population. Thus, HHS is correct in counting everyone regardless of whether they receive Medicare payments for part or all of a hospital stay. Justice Brett Kavanaugh authored a dissenting opinion, in which Chief Justice John Roberts and Justices Samuel Alito and Neil Gorsuch joined. Justice Kavanaugh focused on the text of the statute, arguing that a patient who, by statute, cannot have payment made by Medicare that day is not “entitled to” have payment made by Medicare for that day.

City of Austin, Texas v. Reagan National Advertising of Texas Inc. Justia (with opinion) · Docket · oyez.org Argued on Nov 10, 2021.Decided on Apr 21, 2022. Petitioner: City of Austin, Texas.Respondent: Reagan National Advertising of Texas Inc., et al.. Advocates: Michael R. Dreeben (for the Petitioner) Benjamin W. Snyder (for the United States, as amicus curiae, supporting the Petitioner) Kannon K. Shanmugam (for the Respondents) Facts of the case (from oyez.org) Reagan National Advertising of Austin and Lamar Advantage Outdoor Company own and operate signs and billboards that display commercial and non-commercial messages. They filed applications with the City of Austin to digitize existing billboards, but the City denied the applications because its sign code does not allow the digitization of off-premises signs. Reagan and Lamar sued, arguing that the code’s distinction between on-premise signs and off-premise signs violates the First Amendment. The district court held that the sign code was content-neutral and thus that it need only satisfy intermediate scrutiny—it must further an important government interest through means that are substantially related to that interest. The court found the code satisfied this test and entered judgment for the City. The U.S. Court of Appeals for the Fifth Circuit reversed, finding the code’s distinction is content-based, therefore subject to scrutiny, and that it cannot withstand strict scrutiny. Question Does the Austin city code’s distinction between on-premise signs, which may be digitized, and off-premise signs, which may not, constitute facially unconstitutional content-based regulation? Conclusion The City of Austin’s on-/off-premises distinction is facially content-neutral under the First Amendment. Justice Sonia Sotomayor authored the majority opinion of the Court. When the government regulates speech based on its content, the regulation is subject to strict scrutiny, which requires that the government show the regulation is narrowly tailored to achieve a compelling governmental interest. A regulation of speech is content based if it “applies to particular speech because of the topic discussed or the idea or message expressed.” The City’s off-premises distinction is agnostic as to content. It does not single out any topic or subject matter for differential treatment, and its focus on location is akin to ordinary time, place, or manner restrictions, which are also not subject to strict scrutiny. Thus, it is facially content neutral. Justice Stephen Breyer authored a concurrring opinion arguing that while Reed v. Town of Gilbert, 576 U.S. 155 (2015) is binding precedent that determines the outcome in this case (as the majority acknowledges), he disagrees with the Court’s reasoning in that decision. Justice Samuel Alito authored an opinion concurring in the judgment in part and dissenting in part. He would reverse the lower court’s holding that the signs are facially unconstitutional but disagrees with the majority that the provisions defining on- and off- premises signs do not discriminate on the basis of content, at least as applied in some situations. Justice Clarence Thomas authored a dissenting opinion, in which Justices Neil Gorsuch and Amy Coney Barrett joined, arguing that the majority misinterprets Reed’s rule for content-based restrictions and replaces it with “an incoherent and malleable standard.”

United States v. Vaello-Madero Wikipedia · Justia (with opinion) · Docket · oyez.org Argued on Nov 9, 2021.Decided on Apr 21, 2022. Petitioner: United States.Respondent: Jose Luis Vaello-Madero. Advocates: Curtis E. Gannon (for the Petitioner) Hermann Ferré (for the Respondent) Facts of the case (from oyez.org) Congress established the Supplemental Security Income program in 1972 to provide cash benefits to low-income people who are 65 or older and have disabilities. The program extends to residents of the 50 states, the District of Columbia, and the unincorporated territory of the Northern Mariana Islands, but not to those living in Puerto Rico. Jose Luis Vaello-Madero was born in Puerto Rico in 1954 and moved to New York in 1985. In 2012, he started receiving SSI payments after he experienced severe health problems, and in 2013, he moved back to Puerto Rico to help care for his wife. In 2016, the Social Security Administration (SSA) informed Vaello-Madero that because he had moved back to Puerto Rico, it was terminating his SSI benefits. Moreover, the federal government filed a lawsuit in federal court in Puerto Rico to recover over $28,000 in benefits it had paid Vaello-Madero between 2013 and 2016 when he was living in Puerto Rico. The district court ruled for Vaello-Madero, finding, among other things, that the exclusion of Puerto Rico violated the equal-protection component of the Due Process Clause of the Fifth Amendment. The U.S. Court of Appeals for the First Circuit affirmed. Question Did Congress violate the Fifth Amendment by establishing the Supplemental Security Income program in the 50 states, the District of Columbia, and the Northern Mariana Islands, but not in Puerto Rico? Conclusion The Constitution does not require Congress to make Supplemental Security Income benefits available to the residents of Puerto Rico. Justice Brett Kavanaugh authored the 8-1 majority opinion of the Court reversing the lower court. Two precedents dictate the answer to the question presented in this case. In Califano v. Torres, 435 U.S. 1 (1978), the Court held that Congress’s decision not to extend Supplemental Security Income (SSI) to Puerto Rico did not violate the constitutional right to interstate travel because Congress had a rational basis for that decision (that residents of Puerto Rico were exempt from paying federal taxes). And in Harris v. Rosario, 446 U.S. 651 (1980), the Court held that Congress’s differential treatment of Puerto Rico did not violate the equal protection component of the Fifth Amendment’s Due Process Clause because it had the same rational basis for doing so. Applying these two precedents to the present case, the Court concluded that because Congress had a rational basis for the differential treatment, it was not required to extend SSI benefits to the residents of Puerto Rico. Justice Clarence Thomas authored a concurring opinion to suggest that the Fourteenth Amendment’s Citizenship Clause is a better basis for prohibiting the federal government from discriminating on the basis of race than the so-called equal protection component of the Fifth Amendment’s Due Process Clause. Justice Neil Gorsuch authored a concurring opinion noting that although no party asked the Court to overrule the Insular Cases, in which the Court held that the federal government could rule Puerto Rico and other territories without regard to the Constitution, those cases are based on racial stereotypes and “deserve no place in our law.” Justice Sonia Sotomayor authored a dissenting opinion, arguing that there is no rational basis for treating needy citizens living within a territory of the United States so differently from others.

Ramirez v. Collier Wikipedia · Justia (with opinion) · Docket · oyez.org Argued on Nov 9, 2021.Decided on Mar 24, 2022. Petitioner: John H. Ramirez.Respondent: Bryan Collier, Executive Director, Texas Department of Criminal Justice, et al.. Advocates: Seth Kretzer (for the Petitioner) Eric J. Feigin (for the United States, as amicus curiae, supporting neither party) Judd E. Stone, II (for the Respondents) Facts of the case (from oyez.org) State laws differ and have vacillated as to whether and to what extent spiritual advisers may be present in the execution chamber. In 2019, the Court upheld Alabama’s refusal to allow an imam present at the execution of a Muslim man, even though the state at the time permitted a Christian chaplain to be present. A month later, the Court prohibited Texas from executing a Buddhist inmate unless he was allowed to have a Buddhist priest present. As a result, Texas passed a law prohibiting all spiritual advisers from the execution chamber but then after another legal challenge reversed course to allow their presence. The Court subsequently prohibited another Alabama death-row inmate’s execution without his pastor present, so the state executed him eight months later with his pastor at his side, praying with him and touching his leg. John Ramirez, a Texas death-row inmate, brought a lawsuit asking that he be permitted to have his pastor present at his execution and that his pastor be allowed to pray audibly and touch him while he is being executed. Question Does Texas’s decision to allow Ramirez’s pastor to enter the execution chamber but not to lay hands on the parishioner as he dies, sing, pray, or read scripture violate the Free Exercise Clause of the First Amendment or the Religious Land Use and Institutionalized Persons Act? Conclusion Texas’s restrictions on religious touch and audible prayer in the execution chamber violate the Religious Land Use and Institutionalized Persons Act (RLUIPA) because they burden religious exercise and are not the least restrictive means of furthering the State’s compelling interests. Chief Justice John Roberts authored the 8-1 majority opinion holding that Ramirez satisfied the test for a preliminary injunction and reversing the court below. As a threshold matter, Ramirez properly exhausted his administrative remedies before seeking a judicial remedy. As to the merits, Ramirez satisfied all of the requirements of a preliminary injunction—likelihood of success on the merits, risk of irreparable harm, and balance of equities and public interest. First, Ramirez demonstrated a likelihood of success on the merits. RLUIPA prohibits the state from imposing a substantial burden on an inmate unless imposition of that burden is the least restrictive means of achieving a compelling government interest. Texas’s ban on audible prayer and touch imposed a substantial burden on Ramirez because the laying on of hands and prayer are significant parts of his religious exercise. Although the state has compelling interests in monitoring an inmate’s condition during the lethal injection process and in preventing disruptions in the execution chamber, the State failed to show that its refusal to grant Ramirez’s request is the least restrictive means of achieving those interests. Further, even though the State has compelling interests in security in the execution chamber, preventing unnecessary suffering of the prisoner, and avoiding further emotional trauma to the victim’s family members, it failed to show that a categorical ban on touch is the least restrictive means of accomplishing any of these goals. Second, Ramirez is likely to suffer irreparable harm because without injunctive relief, he would be prohibited from engaging in protected religious exercise in the final moments of his life. Finally, the balance of equities and public interest tilt in Ramirez’s favor because it is possible to accommodate Ramirez’s sincere religious beliefs without delaying or impeding his execution. Justice Sonia Sotomayor joined the majority opinion in full but wrote a separate concurring opinion to underscore the importance of the legal obligation of prison officials to set clear grievance processes. Justice Brett Kavanaugh also joined the majority opinion in full but wrote a separate concurring opinion to point out the need for states to treat all religions equally; to highlight how difficult it is under RLUIPA to determine whether a state interest is “compelling” and whether a particular rule is the “least restrictive means”; and to call upon states to clarify their processes to ensure efficient executions in the future. Justice Clarence Thomas dissented, arguing that Ramirez was simply seeking to further delay his execution and that his claims either do not warrant equitable relief or are procedurally barred.

Unicolors, Inc. v. H&M Hennes & Mauritz, L.P. Wikipedia · Justia (with opinion) · Docket · oyez.org Argued on Nov 8, 2021.Decided on Feb 24, 2022. Petitioner: Unicolors, Inc..Respondent: H&M Hennes & Mauritz, L.P.. Advocates: E. Joshua Rosenkranz (for the Petitioner) Melissa N. Patterson (for the United States, as amicus curiae, supporting the Petitioner) Peter K. Stris (for the Respondent) Facts of the case (from oyez.org) Unicolors, Inc., a company that creates art designs for use on fabrics, created and copyrighted as part of a collection of designs a two-dimensional artwork called EH101 in 2011. In 2015, retail clothing store H&M began selling a jacket and skirt with an art design called “Xue Xu.” Unicolors sued H&M for copyright infringement, alleging that the Xue Xu design is identical to its EH101 design. The district court rejected H&M’s argument that Unicolors’ copyright was invalid because it had improperly used a single copyright registration to register 31 separate works. The court noted that invalidation of a copyright requires an intent to defraud, and no such evidence was presented in this case. Further, it concluded that the application contained no inaccuracies because the separate designs in the single registration were published on the same day. A jury returned a verdict for Unicolors, finding that it owned a valid copyright in EH101, that H&M had infringed on that copyright, and that the infringement was willful. On appeal, the U.S. Court of Appeals for the Ninth Circuit reversed, finding that there is no intent-to-defraud requirement for registration invalidation, and the district court failed to refer the matter to the Copyright Office, as required under 17 U.S.C. § 411(b)(2), when it was informed of inaccuracies in the copyright registration. Question Does 17 U.S.C. § 411 require a district court to request advice from the Copyright Office when there are questions about the validity of a copyright registration but no evidence of fraud or material error? Conclusion Lack of either factual or legal knowledge can excuse an inaccuracy in a copyright registration under 17 U.S.C. § 411(b)(1)(A)’s safe harbor. Justice Stephen Breyer authored the 6-3 majority opinion. The Copyright Act safe harbor, 17 U.S.C. § 411(b)(1)(A) says that a certificate of registration is valid regardless of whether it contains inaccurate information unless the inaccurate information was included “with knowledge that it was inaccurate.” The statutory language makes no distinction between lack of legal knowledge or lack of factual knowledge. The U.S. Court of Appeals thus erred in holding that a copyright holder cannot benefit from the safe harbor if its lack of knowledge stems from a failure to understand the law. Justice Clarence Thomas filed a dissenting opinion, in which Justice Samuel Alito joined, and Justice Neil Gorsuch joined in part. Justice Thomas would dismiss the case as improvidently granted because the Court granted certiorari on a question of fraud but Unicolors put forth a different argument that the court below did not meaningfully consider.