Road funding

The Supreme Court – June 6, 2022 | Dorsey & Whitney LLP

Opinions:

Southwest Airlines vs. Saxon, No. 21-309: This case concerns the scope of the Federal Arbitration Act (FAA) exemption for certain interstate transportation workers, namely “sailors, railroad employees, or any other class workers engaged in foreign or interstate commerce”. The case arose out of a pay dispute between Southwest Airlines and Ramp Agent Supervisor Latrice Saxon. After Saxon filed a lawsuit in federal court, Southwest decided to reject in favor of arbitration. The district court found that Saxon was not a transportation worker and therefore did not fall within the scope of the FAA’s exemption for transportation workers. The United States Court of Appeals for the Seventh Circuit reversed, finding that Saxon fell within the scope of the exemption. Today, in a unanimous 8-0 decision, the Supreme Court ruled that Saxon, a ramp agent supervisor, qualifies as an interstate transportation worker within the meaning of the FAA exemption.

See the Court decision.

Siegel versus Fitzgerald, no. 21-441: This case involves the interpretation of the bankruptcy clause of the Constitution, which allows Congress to establish “uniform laws respecting the subject of bankruptcy throughout the United States”. const. Art I, §8, cl. 4. Because of the significant judicial and administrative responsibilities of bankruptcy judges, Congress created the United States Trustee Program to help separate these judicial and administrative functions. Congress attempted to expand the program nationwide in 1986, but met resistance from six judicial districts in North Carolina and Alabama. As a result, Congress exempted these six districts from the administrator program. Although the six judicial districts and the trustee program generally charge debtors similar fees, in 2017 the trustee program began charging significantly more to help fill any funding shortfall. The six judicial districts delayed adopting a similar fee structure, which meant that some debtors in similar circumstances were charged significantly different fees depending on where their case was located. A debtor challenged the increase in fees under the trustee program, arguing that the increase in fees was not uniform. The bankruptcy court agreed, but a split Fourth Circuit reversed, ruling that the fee increase was acceptable because it was not based solely on arbitrary geographic differences. In a unanimous decision, the Supreme Court ruled that Congress’ passage of a significant fee increase that exempted debtors in two states violated the uniformity requirement of the bankruptcy clause. The Court held that the differences in fees did not result from an external and geographically isolated need, but from the creation by Congress of a dual bankruptcy system.

See the Court decision.

Gallardo v. Marstiller, no. 20-1263: This case concerns reimbursement when a state Medicaid program covers the medical expenses incurred by a beneficiary, if the latter then recovers compensation from the third party who caused the damage. The victim in this case was a Florida girl who suffered serious injuries when a truck hit her as she got off a school bus. Florida’s Medicaid agency paid part of the girl’s medical bills, and the girl and her family later recovered an $800,000 settlement with the owner and driver of the truck. Today, in a 7-2 decision, the Supreme Court ruled that a provision of Medicaid law allows a state to seek reimbursement of settlement payments awarded for future medical care. Justices Sotomayor and Breyer dissented

See the Court decision.