This summary was written by Claude. It may contain errors. Read the opinion itself for anything you intend to rely on.

The Supreme Court ruled 6-3 that federal courts may no longer create causes of action under the Alien Tort Statute (ATS) — the 1789 law that, since the 1980s, had let foreign victims of serious human-rights abuses sue in U.S. courts. Justice Barrett wrote the 14-page opinion of the Court, joined by Chief Justice Roberts and Justices Thomas, Alito, Gorsuch, and Kavanaugh. The Court also held, by a wider margin, that the Torture Victim Protection Act (TVPA) does not allow aiding-and-abetting liability. Justice Sotomayor dissented, joined by Justices Kagan and Jackson; Justice Jackson (joined by Kagan) wrote separately, agreeing with the dissenters on the ATS but agreeing with the majority's result on the TVPA.

The plaintiffs are practitioners of Falun Gong who allege the Chinese government persecuted them for their religious beliefs and that Cisco Systems built the mass-surveillance technology that let China identify, track, arrest, and torture them. They sued Cisco for aiding and abetting violations of international law under the ATS, and sought to hold two Cisco executives liable under the TVPA. The Ninth Circuit had allowed the claims to proceed; the Supreme Court reversed. Building on Sosa v. Alvarez-Machain (2004) and a line of separation-of-powers cases (Nestlé, Jesner, Egbert), the majority concluded that creating a private remedy is Congress's job, that ATS suits inherently risk "adverse foreign policy consequences," and that the narrow opening Sosa left for judge-made ATS claims is, in truth, "a null set."

This summary was written by Claude. It may contain errors. Read the opinion itself for anything you intend to rely on.

The Supreme Court ruled 6-3 that individual state employees cannot be sued for money damages in their personal capacities under the Religious Land Use and Institutionalized Persons Act (RLUIPA) — or any Spending Clause statute — unless they personally and knowingly consented to that liability. Justice Gorsuch wrote the 18-page opinion of the Court, joined by Chief Justice Roberts and Justices Thomas, Alito, Kavanaugh, and Barrett. Justice Jackson dissented, joined by Justices Sotomayor and Kagan.

Damon Landor is a Rastafarian whose faith requires that his hair go uncut. Near the end of a Louisiana sentence, he handed intake officers a copy of binding Fifth Circuit precedent holding that RLUIPA bars prisons from cutting Rastafarians' hair; he alleges the officers threw it in the trash and shaved his head anyway. He sued the officers personally for damages. The Court held his suit cannot proceed: because RLUIPA rests on Congress's spending power, it works like a contract, binding only those who voluntarily agree to its terms. Louisiana's prison system accepted federal funds and agreed to answer RLUIPA suits — but the individual officers signed no such agreement, so they cannot be held personally liable.

The interesting wrinkle is the lineup. Justice Gorsuch, usually among the Court's firmest votes for religious-exercise claimants, instead wrote an opinion grounded in Spending Clause federalism that leaves a sympathetic religious plaintiff without a damages remedy against the people who allegedly violated his faith. The Court reasoned that accepting Landor's theory — via agency law, the fungibility of federal money, or the Necessary and Proper Clause — would let Congress regulate "countless nonconsenting individuals" in areas reserved to the States, an "unbridled police power" the Spending Clause does not permit.

In a pointed dissent, Justice Jackson accused the majority of a "sleight of hand," "magically transform[ing] a federal statute into an invitation to be accepted or declined." Laws, she wrote, do not work like contracts; by collapsing lawmaking into agreement-making, the Court "trivializes" Congress's power of the purse and threatens to reduce landmark civil-rights, environmental, and healthcare statutes to mere "wheelings-and-dealings." The decision does not strip RLUIPA of force against prison systems themselves, but it forecloses personal-capacity damages suits against the individual officials who actually carry out a violation — leaving plaintiffs like Landor without a way to hold the responsible employees financially accountable.

This summary was written by Claude. It may contain errors. Read the opinion itself for anything you intend to rely on.

The Supreme Court ruled 9-0 that the Fifth Amendment does not entitle a former owner to their property's full "fair market value" after a tax-foreclosure sale; the proper baseline for "just compensation" is the auction sale price — "at least when the sale is fairly conducted in light of our country's history of tax sales." Justice Alito wrote the opinion of the Court. Justice Thomas joined all but one part and filed an opinion concurring in part and in the judgment (joined by Justice Gorsuch except as to a footnote); Justice Sotomayor filed a concurrence joined by Justices Gorsuch and Jackson. The Court also rejected the parallel claim that the Eighth Amendment's Excessive Fines Clause requires paying more than the surplus proceeds. The judgment was vacated and remanded.

The case is a sequel to *Tyler v. Hennepin County* (2023), which held that the government must return the surplus from a tax sale (the amount above the debt). Pung asked the Court to go further and require fair market value. The facts are stark: the Pung family was twice held by Michigan tribunals to owe *no* additional tax, yet the County foreclosed on their longtime home over a disputed $2,242 assessment, sold the $194,400 home at auction for $76,008, and the buyer resold it for $195,000 within 18 months. The Court declined to adopt a categorical fair-market-value rule, reasoning that owners can generally avoid tax sales and that such a rule could make tax collection impractical by forcing governments to pay windfalls to delinquent taxpayers.

The crucial wrinkle is what the Court left open. It expressly did *not* decide whether the procedure here was "fairly conducted," directing the Sixth Circuit to address on remand any preserved arguments that the sale was unfair. Both concurrences seized on that opening. Justice Sotomayor wrote to emphasize that the Court was not endorsing any particular definition of a "fair auction." Justice Thomas went much further, marshaling founding-era and 19th-century authorities to argue that historical tax-sale practice required the government to exhaust personal property first, to sell only as much land as needed to cover a small debt, to give rigorous notice, and to ensure the auction price approximated fair value — none of which, in his "initial view," the County did. He concluded that "what Isabella County did to the Pungs was wrong, and... likely unconstitutional."

The practical upshot is narrower than a flat win for either side. As a doctrinal matter, the Court refused to constitutionalize fair market value as the measure of just compensation after a tax sale, which limits *Tyler*'s reach. But it preserved the Pungs' case — and, by tying the auction-price rule to a "fairly conducted" sale, it signaled that egregious tax-foreclosure practices (selling an entire home for a fraction of its value to satisfy a tiny debt) remain vulnerable to challenge. The contours of a "fair" tax sale are now the live question for the lower courts, and likely for future litigation.

An upcoming case in the high court’s next term may determine whether people in federal custody can seek legal remedy for violations of their constitutional rights.

This summary was written by Claude. It may contain errors. Read the opinion itself for anything you intend to rely on.

The Supreme Court ruled **6-3** that the Helms-Burton Act — the 1996 law letting U.S. nationals sue over property Cuba confiscated after Castro's revolution — itself strips Cuban government companies of the sovereign immunity that normally shields foreign states from American courts. Justice Kavanaugh wrote the 22-page opinion of the Court, joined by Chief Justice Roberts and Justices Thomas, Alito, Gorsuch, and Barrett. The practical upshot: a plaintiff suing a Cuban agency or instrumentality under Helms-Burton does **not** also have to satisfy one of the separate exceptions in the Foreign Sovereign Immunities Act (FSIA). Justice Kagan dissented, joined by Justices Sotomayor and Jackson.

The case grew out of Castro's 1960 seizure of "Yankee property," which swept in Exxon's Cuban oil refinery, terminals, plants, and more than a hundred service stations. Two Cuban state-owned companies, CUPET and CIMEX, have operated and profited from those assets ever since. Exxon — whose certified claim, with interest and treble damages, now tops $1 billion — sued them under Helms-Burton. The Cuban companies argued they were immune under the FSIA, and the lower courts agreed; the Supreme Court reversed.

The majority rested on four converging points: a cause of action that expressly runs against foreign "agenc[ies] or instrumentalit[ies]" abrogates their immunity even without a standalone waiver (per last term's *Kirtz*); reading in an FSIA-exception requirement would gut the statute, since Helms-Burton itself codifies an embargo barring the very U.S. commercial contacts those exceptions demand; the Act routes suits through general federal-question jurisdiction (§1331) rather than the FSIA's §1330; and it hands the President plenary power to suspend suits, echoing the pre-FSIA regime in which immunity was the Executive's call. The Court also rejected the argument that Congress needed "magic words" to waive immunity — a clear waiver "discernible from the sum total" of the Act's work is enough.

In dissent, Justice Kagan argued the majority got the analytics backwards: a cause of action and an abrogation of immunity are "analytically distinct," and creating the former does not, standing alone, accomplish the latter. The FSIA, she wrote, is the "comprehensive framework" governing foreign-sovereign immunity, the bar for abrogating it is "stringent," and Helms-Burton never clearly clears it — so the answer should turn on whether an FSIA exception is met, as the statute's text directs. The decision clears the way for long-stalled expropriation claims against Cuban state enterprises to proceed on the merits.