The Supreme Court of the United States issued decisions in three cases today:

CRST Van Expedited, Inc. v. EEOC, No. 14-1375:  The Equal Employment Opportunity Commission (“EEOC”) brought a suit in its own name under Title VII of the Civil Rights Act of 1964 against Petitioner CRST Van Expedited, Inc., alleging sexual harassment against numerous women.   The District Court dismissed the claims, and under Title VII’s provision permitting a district court to award attorney’s fees to “the prevailing party,” CRST was awarded more than $4 million in fees.  On appeal, the Eighth Circuit reversed the dismissal of claims against only two employees, but it also vacated the fee award.  On remand, the EEOC settled one of these claims and withdrew the other.  The District Court again awarded more than $4 million in fees, and the Eighth Circuit reversed again, holding CRST was not a “prevailing party” because it did not obtain a “ruling on the merits.”  Today, the Court vacated and remanded, holding that a favorable ruling on the merits is not a necessary predicate to find that a defendant has prevailed, but declining to decide whether a defendant must obtain a preclusive judgment in order to prevail. 

The Court's decision is available here

Luna Torres v. Lynch, No. 14-1096:  Petitioner Jorge Luna Torres, a lawful permanent resident, pleaded guilty in New York state court to attempted third-degree arson.  This caused immigration officials to initiate removal proceedings.  During those proceedings, Luna applied for cancellation of removal, but the Immigration Judge found him ineligible on the basis that his arson conviction was an “aggravated felony” under the Immigration and Nationality Act (“INA”).  Under the INA, an “aggravated felony” is defined by identifying offenses described in the federal criminal code, and then stating that those offenses are aggravated felonies irrespective of whether they are in violation of Federal, State, or foreign law.  Luna acknowledged that the New York arson law differed from the federal statute only in that it lacked an interstate commerce element.  The Board of Immigration Appeals affirmed and the Second Circuit denied review.  Today, the Court affirmed, holding that the absence of such a jurisdictional element is immaterial.  A state crime counts as an aggravated felony when it corresponds to a specified federal offense in all ways but the lack of an interstate commerce element.

The Court's decision is available here

Betterman v. Montana, No. 14-1457:  Petitioner Brandon Betterman was charged with bail jumping in Montana state court after failing to appear in court on domestic assault charges.  He pleaded guilty to the bail-jumping charge, and was held in jail for 14 months while awaiting sentencing.  The Montana Supreme Court rejected Betterman’s argument that the 14-month gap violated his Sixth Amendment right to a speedy trial.  The Court today affirmed, holding that the Sixth Amendment’s speedy trial guarantee protects the accused from arrest or indictment through trial, but does not apply once a defendant has been found guilty at trial or has pleaded guilty to criminal charges. 

The Court's decision is available here.