The Supreme Court of the United States announced decisions in four cases this morning:

Fox v. Vice, No. 10-114: In a federal lawsuit in which both state claims and federal civil rights claims were asserted, attorneys fees were sought under 42 U.S.C. sec. 1988 after the federal claims were dismissed. The district court awarded fees and did not require the defendant to separate out the work done on the state claims. The court of appeals affirmed. The Supreme Court today held that when a plaintiff’s suit involves both frivolous and non-frivolous claims, a court may grant reasonable fees to the defendant, but only for costs that the defendant would not have incurred but for the frivolous claims, and remanded for application of the correct standard.

The Court's decision is available here.

McNeill v. United States, No. 10-5258: Under the Armed Career Criminal Act, a sentence can be more severe if a defendant has certain prior convictions, including for "serious drug offenses" under state law, defined as offenses which carry a maximum imprisonment term of ten years or more. At the time petitioner committed his prior crimes, each bore a ten-year sentence, which he in fact received. When the state later reduced the maximum sentence for those crimes to fewer than ten years, petitioner argued they were no longer "serious drug offenses," as defined. The Court today held that a federal sentencing court must determine whether “an offense under State law” is a “serious drug offense” by consulting the “maximum term of imprisonment” applicable to a defendant’s prior state drug offense at the time of the defendant’s conviction for that offense. Accordingly, it affirmed the lower courts, which had so held.

The Court's decision is available here.

Board of Trustees of Leland Stanford Junior Univ. v. Roche Molecular Systems, Inc., No. 09-1159: Petitioner claimed respondent's HIV test kits infringed petitioner's patents. Respondent claimed it had been assigned rights by an individual inventor, but petitioner asserted the individual had no rights to assign because the University and Small Business Patent Procedures Act of 1980—commonly referred to as the Bayh-Dole Act—gave it superior rights in a federally-funded invention, such as that at issue. The district court agreed with petitioner, but the court of appeals reversed. Today the Supreme Court affirmed the court of appeals, holding that the Bayh-Dole Act does not automatically vest title to federally-funded inventions in federal contractors or authorize contractors to unilaterally take title to such inventions.

The Court's decision is available here.

Erica P. John Fund v. Halliburton Co., No. 09-1403: Petitioner alleged that respondent made various misrepresentations designed to inflate the company’s stock price in violation of federal securities laws, and sought certification for the suit to proceed as a class action. The district court found that the suit could proceed as a class action except that, under Fifth Circuit precedent, securities fraud plaintiffs had to prove “loss causation”—i.e., that the defendant’s deceptive conduct caused the investors’ claimed economic loss—in order to obtain class certification, which petitioner had failed to do. The court of appeals agreed and affirmed the denial of class certification. The Court today held that although they must eventually do so in order to prevail on the merits in a private securities fraud action, investors need not prove loss causation in order to obtain class certification.

The Court's decision is available here.

The Court also granted review in two cases today:

Martinez v. Ryan, No. 10-1001: Whether a defendant in a state criminal case who is prohibited by state law from raising on direct appeal any claim of ineffective assistance of trial counsel, but who has a state-law right to raise such a claim in a first postconviction proceeding, has a federal constitutional right to effective assistance of first post-conviction counsel specifically with respect to his ineffective-assistance-of-trial-counsel claim.

Kurns v. Railroad Friction Products Corp., No. 10-879: Whether the field preempted by the Locomotive Inspection Act, 49 U.S.C. 20701 et seq., includes state-law tort claims based on exposure to asbestos-containing materials during the repair of locomotives at railroad maintenance facilities.