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

McCutcheon v. Federal Election Commission, No. 12-536: The Federal Election Campaign Act of 1971 (FECA), as amended, imposes two types of limits on campaign contributions. The first imposes base limits, which restrict how much money a donor may contribute to a particular candidate or committee. 2 U.S.C. §441a(a)(1). This base limit restriction has been upheld as serving the permissible objective of combatting corruption. The second restriction imposes aggregate limits, which restrict how much money a donor may contribute in total to all candidates or committees. 2 U.S.C. §441a(a)(3). Appellants McCutcheon and the Republican National Committee filed a complaint seeking injunctive relief before a three-judge District Court, claiming that the aggregate limits were unconstitutional under the First Amendment. The District Court denied Appellants’ motion for preliminary injunction and granted the Government’s motion to dismiss. The District Court assumed that the base limits appropriately served the Government’s anticorruption interest, and then concluded that the aggregate limits survived First Amendment scrutiny because they prevented evasion of the base limits. Appellants directly appealed to the Supreme Court. Today, a fractured Court reversed the District Court’s judgment and remanded, with five justices agreeing that the aggregate limits are invalid under the First Amendment.

The Court's decision is available here.

Northwest, Inc. v. Ginsberg, No. 12-462: Respondent Ginsberg’s frequent flyer membership was terminated by Petitioner Northwest, based on a provision in the frequent flyer agreement giving Northwest sole discretion to determine whether a participant had abused the program. Ginsberg filed suit, alleging in part that Northwest had violated the duty of good faith and fair dealing by terminating his membership in a way contravening his reasonable expectations. The District Court granted Northwest’s motion to dismiss this claim, finding that the Airline Deregulation Act of 1978 (ADA) pre-empted the claim. The Ninth Circuit reversed. The Court today reversed, holding that, in accord with American Airlines, Inc. v. Wolens, 513 U.S. 219 (1995), the ADA pre-empts a state-law claim for breach of the implied covenant of good faith and fair dealing if it, as was the case here, seeks to enlarge the contractual obligations that the parties voluntarily adopt.

The Court's decision is available here.

On Monday, March 31, the Court granted certiorari in the following case:

Teva Pharmaceuticals USA, Inc. v. Sandoz, Inc., et al., No. 13-854: Federal Rule of Civil Procedure 52(a) provides that in matters tried to a district court, the court’s “[f]indings of fact . . . must not be set aside unless clearly erroneous.” The question presented is whether a district court’s factual finding in support of its construction of a patent claim term may be reviewed de novo, as the Federal Circuit requires (and as the panel explicitly did in this case), or only for clear error, as Rule 52(a) requires.