The Supreme Court of the United States announced decisions in two cases yesterday, and two cases today:

US Airways, Inc. v. McCutchen, No. 11-1285: Respondent McCutchen’s health benefits plan through his employer, petitioner US Airways, obligated US Airways to pay any medical expenses incurred due to a third party’s actions, and in turn entitled US Airways to reimbursement if McCutchen then recovered money from the third party. When McCutchen, recovered $110,000 from the negligent driver in a car accident, of which he received $66,000 after deducting attorney’s fees, US Airways demanded reimbursement for the full $66,866 it had paid in medical expenses. When McCutchen did not comply, US Airways filed suit under ERISA § 502(a)(3), which authorizes health-plan administrators “to obtain . . . appropriate equitable relief . . . to enforce . . . the terms of the plan.” The District Court granted summary judgment to US Airways, but the Third Circuit reversed, reasoning that equitable doctrines and defenses applied to ERISA suits under this section. Yesterday, the Court vacated the Third Circuit’s decision, holding that, in an action brought under ERISA § 502(a)(3) based on an equitable lien by agreement, the terms of the ERISA plan govern, and principles of unjust enrichment or doctrines such as the double-recovery or common-fund rules cannot override the clear terms of the plan. The Court, however, also held that where the plan is silent about allocating the costs of recovery, the common-fund doctrine plays a key role in interpreting US Airways’ plan.

The Court's decision is available here.

Genesis HealthCare Corp. v. Symczyk, No. 11-1059: In a suit involving the collective action device under the Fair Labor Standards Act of 1938 (FLSA), 29 U.S.C. § 216(b), the Court addressed whether such a case remains justiciable when the sole plaintiff’s individual claim becomes moot. Here, the District Court, after finding that no other individuals had joined respondent Symczyk’s collective action, and that petitioner’s Fed. R. Civ. P. 68 offer of judgment fully satisfied her claim, the court then found Symczyk’s suit moot and dismissed it for lack of subject-matter jurisdiction. The Third Circuit reversed, holding that although Symczyk’s individual claim was moot, the collective action was not, because allowing defendants to “pick off” named plaintiffs before certification would frustrate the goals of collective actions. Yesterday, the Court reversed, holding that Symczyk had no personal interest in representing putative, unnamed claimants, nor any other continuing interest that would preserve her suit from mootness, and it was thus appropriately dismissed for lack of subject-matter jurisdiction.

The Court's decision is available here.

Missouri v. McNeely, No. 11-1425: Respondent McNeely successfully suppressed blood test results for a DWI on the basis that the warrantless blood test violated his Fourth Amendment rights when there were no exigent circumstances other than the fact that his blood alcohol was dissipating. The Court today affirmed the judgment of the Missouri Supreme Court, holding that in drunk-driving investigations, the natural dissipation of alcohol in the bloodstream does not constitute an exigency in every case sufficient to justify conducting a blood test without a warrant.

The Court's decision is available here.

Kiobel v. Royal Dutch Petroleum Co., No. 10-1491: Petitioners are a group of Nigerian nationals residing in the United States that filed suit in federal court under the Alien Tort Statute (ATS), 28 U.S.C. § 1350, against Dutch, British, and Nigerian corporations they alleged had aided and abetted the Nigerian Government in committing violations of the law of nations in Nigeria. The District Court dismissed several of petitioners' claims, and on interlocutory appeal, the Second Circuit dismissed the entire complaint on the basis that the law of nations does not recognize corporate liability. The Court, in granting certiorari, ordered supplemental briefing on whether and under what circumstances courts may recognize a cause of action under the ATS for violations of the law of nations occurring within the territory of a sovereign other than the United States. Today, the Court affirmed the Second Circuit, holding that the presumption against extraterritoriality applies to ATS claims, and, on these facts, where all the relevant conduct took place outside the United States, the mere corporate presence of the defendants in the United States was insufficient to displace the presumption against extraterritorial application.

The Court's decision is available here.

On Monday, April 15, 2013, the Court granted review in two cases:

Heimeshoff v. Hartford Life Insurance, No. 12-729: When should a statute of limitations accrue for judicial review of an ERISA disability adverse benefit determination?

Sprint Communications Co. v. Jacobs, No. 12-815: Whether the Eighth Circuit erred by concluding, in conflict with decisions of nine other circuits and this Court, that Younger abstention is warranted not only when there is a related state proceeding that is "coercive" but also when there is a related state proceeding that is, instead, "remedial."