Supreme Court Roundup, 6/5/2025
In a series of landmark U.S. Supreme Court decisions in 2025, the Court addressed critical issues of discrimination, liability, religious liberty, jurisdiction, and class-action certification. In Ames v. Ohio Department of Youth Services, the Court unanimously struck down the Sixth Circuit’s “background circumstances” rule, affirming that Title VII protects all individuals from workplace discrimination equally, regardless of majority or minority status. Smith & Wesson Brands, Inc. v. Estados Unidos Mexicanos saw the Court uphold the Protection of Lawful Commerce in Arms Act, dismissing Mexico’s lawsuit against U.S. gun manufacturers for failing to prove intentional aiding and abetting of illegal firearm sales. In Catholic Charities Bureau, Inc. v. Wisconsin Labor and Industry Review Commission, the Court ruled that Wisconsin’s denial of a tax exemption to Catholic Charities violated the First Amendment’s neutrality principle. CC/Devas (Mauritius) Ltd. v. Antrix Corp clarified that personal jurisdiction under the Foreign Sovereign Immunities Act relies solely on statutory requirements, not a separate minimum-contacts analysis. BLOM Bank SAL v. Honickman reinforced the stringent “extraordinary circumstances” standard for reopening cases under Rule 60(b)(6). Finally, Laboratory Corp. of America Holdings v. Davis was dismissed as improvidently granted, though Justice Kavanaugh’s dissent highlighted concerns over certifying damages classes with uninjured members under Rule 23. These rulings collectively underscore the Court’s commitment to statutory fidelity, individual fairness, and procedural clarity.
Here’s a detailed overview of the rulings:
Ames v. Ohio Department of Youth Services (Discrimination Case)
In a landmark decision the U.S. Supreme Court unanimously ruled in Ames v. Ohio Department of Youth Services (2025), reinforcing the principle that Title VII of the Civil Rights Act protects all individuals from workplace discrimination equally, regardless of whether they belong to a majority or minority group. The case centered on Marlean Ames, a heterosexual woman employed by the Ohio Department of Youth Services since 2004. Initially hired as an executive secretary, Ames rose to the role of program administrator. In 2019, she applied for a management position in the agency’s Office of Quality and Improvement but was passed over for a lesbian candidate. Days later, she was demoted to her original secretarial role with a significant pay cut, and a gay man was hired to replace her as program administrator. Ames filed a lawsuit under Title VII, alleging discrimination based on her sexual orientation.
The District Court and the Sixth Circuit Court of Appeals dismissed Ames’s claims, citing her failure to meet a heightened evidentiary standard known as the “background circumstances” rule. This Sixth Circuit precedent required majority-group plaintiffs, such as heterosexual or white individuals, to provide additional evidence-such as statistical proof or details about the decision-maker’s identity-to suggest that the employer was the rare entity that discriminates against the majority. Without this, Ames’s claims were deemed insufficient under the McDonnell Douglas framework, a three-step process used to evaluate circumstantial evidence of discrimination. The Sixth Circuit acknowledged that Ames met the standard prima facie requirements but faulted her for not satisfying this extra burden.
The Supreme Court, in an opinion authored by Justice Ketanji Brown Jackson, rejected the “background circumstances” rule as incompatible with Title VII’s text, which prohibits discrimination against “any individual” based on race, color, religion, sex, or national origin. The Court emphasized that the statute makes no distinction between majority and minority groups, citing precedents like Griggs v. Duke Power Co. (1971) and McDonald v. Santa Fe Trail Transportation Co. (1976). The decision vacated the Sixth Circuit’s ruling and remanded the case for reconsideration under the standard McDonnell Douglas framework, which requires plaintiffs to show they were qualified, rejected, and that circumstances suggest discrimination, without additional hurdles for majority groups.
Justice Thomas, joined by Justice Gorsuch, concurred, criticizing the “background circumstances” rule as atextual judicial overreach and questioning the McDonnell Douglas framework itself. Thomas argued that the framework, created in 1973, lacks statutory grounding and has caused confusion, particularly at the summary judgment stage, where its rigid structure misaligns with Federal Rule of Civil Procedure 56. He suggested the Court should reconsider its use in future cases.
The Ames decision marks a significant step toward ensuring Title VII’s equal application, eliminating discriminatory burdens on majority-group plaintiffs and reaffirming the law’s focus on individual fairness over group-based assumptions.
Smith & Wesson Brands, Inc. v. Estados Unidos Mexicanos (Mexico’s Lawsuit Against Gun Makers)
In 2021, the Mexican government launched a bold legal challenge against major U.S. gun manufacturers, including Smith & Wesson, Barrett, Beretta, and others, in a U.S. District Court. Mexico alleged that these companies fueled its severe gun violence problem by knowingly enabling the trafficking of firearms to Mexican drug cartels. The lawsuit claimed that manufacturers were negligent, asserting they supplied firearms to “rogue” dealers who illegally sold guns, often through straw purchases or without background checks, which cartels then used for crimes like murder and kidnapping. Mexico argued that the manufacturers’ failure to regulate their distribution networks and their production of military-style weapons, like AR-15s and .50 caliber sniper rifles, deliberately catered to criminal markets, exacerbating violence south of the border. Citing statistics that up to 90% of guns recovered at Mexican crime scenes originated in the U.S., Mexico sought to hold the manufacturers liable for the resulting harms.
The lawsuit faced a significant hurdle: the Protection of Lawful Commerce in Arms Act (PLCAA), a 2005 U.S. law shielding gun manufacturers from liability for third-party criminal misuse of their products. Mexico attempted to invoke PLCAA’s “predicate exception,” which allows suits if a manufacturer knowingly violates a firearms-related statute, arguing that the companies aided and abetted illegal sales. The District Court dismissed the case, citing PLCAA’s protections, but the First Circuit reversed, finding Mexico’s allegations of aiding and abetting plausible enough to proceed.
The case reached the U.S. Supreme Court, which on June 5, 2025, unanimously (9-0) reversed the First Circuit in Smith & Wesson Brands, Inc. v. Estados Unidos Mexicanos (2025). Justice Elena Kagan’s opinion held that Mexico’s complaint failed to plausibly allege aiding and abetting under federal law. Unlike Direct Sales Co. v. United States (1943), where a pharmacy actively encouraged illegal narcotic sales, Mexico’s claims lacked specific evidence that manufacturers intentionally assisted rogue dealers. The Court noted that manufacturers sell through independent distributors, not directly to dealers, and Mexico provided no concrete proof they knowingly targeted lawbreakers. Allegations of failing to regulate distribution or producing appealing firearms, like those with cartel-friendly names, amounted to “passive nonfeasance” or indifference, not culpable participation, akin to the insufficient claims in Twitter v. Taamneh (2023). The Court emphasized that PLCAA’s purpose was to block such lawsuits, which seek to hold manufacturers liable for downstream criminal acts, and allowing Mexico’s suit would undermine this intent.
Justices Thomas and Jackson concurred separately. Thomas highlighted unresolved questions about whether PLCAA requires a prior adjudication of a violation, warning of constitutional issues in litigating criminal guilt civilly. Jackson stressed that Mexico’s failure to tie claims to specific statutory violations revealed the lawsuit as an attempt to impose judicial regulation, which PLCAA was designed to prevent. The case was remanded for dismissal, affirming PLCAA’s shield for gun manufacturers and reinforcing that gun control policies should stem from legislatures, not courts.
Catholic Charities Bureau, Inc. v. Wisconsin Labor and Industry Review Commission (Faith-Based Tax Exemption)
In a landmark decision the U.S. Supreme Court unanimously ruled in Catholic Charities Bureau, Inc. v. Wisconsin Labor & Industry Review Commission (2025) that Wisconsin violated the First Amendment by denying a tax exemption to Catholic Charities of the Diocese of Superior. The case centered on Wisconsin’s unemployment compensation program, which exempts religious organizations “operated primarily for religious purposes” and controlled by a church from paying unemployment taxes. Catholic Charities, the social ministry arm of the Diocese, sought this exemption, but Wisconsin denied it, arguing that the organization’s services-job training, mental health support, and aid for those with developmental disabilities-were not primarily religious because they were offered to all, regardless of faith, and lacked overt proselytizing.
The Supreme Court, in an opinion by Justice Sonia Sotomayor, found that Wisconsin’s application of Wis. Stat. §108.02(15)(h)(2) discriminated against Catholic Charities by favoring religious organizations that limit services to co-religionists or engage in evangelistic activities. This distinction, the Court held, violated the First Amendment’s neutrality principle, which prohibits the government from preferring one religion over another or making theological judgments. Applying strict scrutiny, the Court concluded that Wisconsin failed to provide a compelling state interest for its discriminatory treatment, reversing the Wisconsin Supreme Court’s ruling (2024 WI 13, 411 Wis. 2d 1, 3 N.W.3d 666) and remanding the case.
Justice Thomas, in his concurrence, emphasized the church autonomy doctrine, arguing that Wisconsin’s reliance on Catholic Charities’ separate corporate status to deny the exemption infringed on the Diocese’s right to define its internal structure. He noted that, under Catholic canon law, Catholic Charities is an extension of the Diocese, led by the Bishop of Superior, and serves its religious mission of charity, which is inseparable from the Church’s sacramental and teaching roles. By treating Catholic Charities as distinct from the Diocese, Wisconsin improperly imposed secular criteria on a religious institution’s governance, violating the First Amendment’s protection of church autonomy.
Justice Jackson’s concurrence took a different angle, focusing on the Federal Unemployment Tax Act (FUTA), which Wisconsin’s law mirrors. She argued that the exemption’s phrase “operated primarily for religious purposes” refers to an organization’s function, not its motivation or proselytizing efforts. Congressional intent, as shown in legislative history, limits the exemption to entities like seminaries or novitiates that prepare individuals for religious life, not general charitable organizations like Catholic Charities. Jackson criticized Wisconsin’s motives-and-activities test for entangling the state in religious matters, advocating a function-based approach to avoid such constitutional issues.
This ruling marks a significant victory for religious liberty, affirming that states cannot penalize religious organizations for their inclusive service models or redefine their internal structures. It also clarifies the scope of FUTA’s religious exemption, potentially guiding future state policies to align with Congress’s focus on organizational function over motivation.
CC/Devas (Mauritius) Ltd. v. Antrix Corp. (Satellite Subleasing Case)
The U.S. Supreme Court case CC/Devas (Mauritius) Ltd. v. Antrix Corp (2025) addressed a critical question about personal jurisdiction under the Foreign Sovereign Immunities Act (FSIA). The dispute originated from a 2005 satellite-leasing agreement between Antrix Corporation Ltd., an Indian government-owned entity under the Department of Space, and Devas Multimedia Private Ltd., an Indian company developing satellite-based telecommunications technology. Antrix agreed to build and launch satellites into geostationary orbit and lease capacity to Devas for multimedia broadcasting in India. The agreement proceeded smoothly until 2011, when the Indian government, citing a new policy prioritizing its own satellite needs, directed Antrix to terminate the contract under a force majeure clause. Devas disputed this termination, arguing it was self-induced, and initiated arbitration. In 2015, an arbitral panel ruled in Devas’s favor, awarding $562.5 million in damages plus interest for wrongful termination.
Devas sought to confirm this arbitration award in the U.S. District Court for the Western District of Washington under the FSIA’s arbitration exception (28 U.S.C. §1605(a)(6)), which waives sovereign immunity for enforcing certain arbitral awards, such as those governed by the New York Convention. The district court confirmed the award, entering a $1.29 billion judgment against Antrix. However, complications arose when an Indian tribunal found Devas had secured the contract through fraud, leading to its dissolution, and the High Court of New Delhi later set aside the arbitration award. Meanwhile, Devas shareholders and an American subsidiary intervened in the U.S. proceedings to enforce the judgment, securing post-judgment discovery and registering the judgment in Virginia, where Antrix held assets.
Antrix appealed, and the Ninth Circuit reversed the district court’s decision, holding that personal jurisdiction under the FSIA required a “minimum contacts” analysis per International Shoe Co. v. Washington (1945), which Antrix lacked with the U.S. The Supreme Court granted certiorari to determine whether the FSIA mandates such a requirement beyond its statutory provisions.
The Supreme Court, in a unanimous opinion, reversed the Ninth Circuit, holding that the FSIA’s personal jurisdiction provision (28 U.S.C. §1330(b)) does not require a separate minimum-contacts analysis. The Court emphasized that §1330(b) clearly states personal jurisdiction exists when an FSIA immunity exception applies and proper service is made under §1608. The FSIA’s exceptions, such as those for commercial activities or arbitration, already incorporate necessary U.S. connections, satisfying due process without additional requirements. The Court rejected the Ninth Circuit’s reliance on precedent and legislative history, noting that the FSIA’s text and structure comprehensively govern jurisdiction over foreign states, linking immunity exceptions directly to jurisdiction. Antrix’s alternative arguments, including Fifth Amendment due process and the applicability of the arbitration exception, were left for the Ninth Circuit to address on remand.
The Court’s ruling clarified that personal jurisdiction under the FSIA hinges solely on statutory requirements, streamlining jurisdictional analysis in cases involving foreign sovereigns.
BLOM Bank SAL v. Honickman (Anti-Terrorism Act Case)
In the case of BLOM Bank SAL v. Honickman (2025), the U.S. Supreme Court addressed a legal dispute involving the application of Federal Rule of Civil Procedure 60(b)(6), which allows courts to reopen a case for “any other reason that justifies relief,” but only under “extraordinary circumstances.” The case arose from a lawsuit filed by plaintiffs, led by Michal Honickman, against BLOM Bank SAL, a Lebanese bank, under the Justice Against Sponsors of Terrorism Act (JASTA). The plaintiffs alleged that BLOM aided and abetted Hamas’s terrorist activities by providing financial services to customers purportedly linked to Hamas. However, the District Court dismissed the complaint for failing to plausibly allege that BLOM had the requisite “general awareness” of its role in Hamas’s violent activities, as required under JASTA. The dismissal was with prejudice, as the plaintiffs repeatedly declined opportunities to amend their complaint, choosing instead to stand by their original allegations.
The plaintiffs appealed to the Second Circuit, which affirmed the dismissal but clarified that the District Court had applied an overly stringent foreseeability standard for aiding-and-abetting liability. Despite this clarification, the Second Circuit found the plaintiffs’ allegations insufficient. Subsequently, the plaintiffs returned to the District Court, seeking to vacate the final judgment under Rule 60(b)(6) to amend their complaint based on the Second Circuit’s clarified standard. The District Court denied this motion, reasoning that a change in decisional law did not constitute “extraordinary circumstances” under Rule 60(b)(6), and the plaintiffs’ deliberate choice not to amend earlier weighed against them. The court also noted that any amendment was likely futile, as the plaintiffs were unlikely to meet even the clarified standard.
On appeal, the Second Circuit reversed, holding that when a party seeks to reopen a case to amend a complaint, courts must balance Rule 60(b)(6)’s strict finality standard with Rule 15(a)’s liberal amendment policy, which encourages granting leave to amend “when justice so requires.” The Supreme Court, however, disagreed. In a majority opinion, it ruled that Rule 60(b)(6)’s “extraordinary circumstances” requirement must be satisfied before Rule 15(a)’s amendment standard applies. The Court emphasized that Rule 60(b)(6) is a narrow catchall provision, distinct from the more lenient Rule 15(a), and that conflating the two undermines the finality of judgments. The Court found the District Court’s denial of the motion to vacate was within its discretion, as the plaintiffs failed to show extraordinary circumstances, and their prior refusal to amend did not justify relief.
Justice Jackson concurred in part, agreeing that Rule 60(b)(6)’s standard applies but dissenting from the majority’s endorsement of the District Court’s reasoning that faulted the plaintiffs for choosing to appeal rather than amend. She argued that pursuing an appeal is a legitimate statutory right and should not automatically preclude Rule 60(b)(6) relief, provided extraordinary circumstances exist. The Supreme Court reversed the Second Circuit’s decision, reinforcing the stringent requirements for reopening a case under Rule 60(b)(6).
Laboratory Corp. of America Holdings v. Davis (Dismissed as Improvidently Granted)
In Laboratory Corporation of America Holdings v. Luke Davis, et al. (2025), the U.S. Supreme Court grappled with a pivotal class-action issue but ultimately dismissed the case as improvidently granted, prompting a dissent from Justice Brett Kavanaugh. The dispute began in 2017 when Labcorp, a diagnostic laboratory services provider, introduced self-service check-in kiosks at its patient service centers in California. While convenient for most, the kiosks were inaccessible to blind and visually impaired patients, leading Labcorp to maintain enhanced front-desk services to accommodate them.
Despite these measures, legally blind plaintiffs filed a lawsuit in the U.S. District Court for the Central District of California, alleging that Labcorp’s kiosks violated the Americans with Disabilities Act (ADA) and California’s Unruh Civil Rights Act, which mandates at least $4,000 in statutory damages per violation. The plaintiffs sought to certify a damages class under Federal Rule of Civil Procedure 23, potentially encompassing all legally blind individuals in California who visited Labcorp’s centers and were denied equal access due to the kiosks’ inaccessibility, with estimated damages up to $500 million annually.
In May 2022, the District Court certified the class, defining it as legally blind individuals denied equal access to Labcorp’s services due to the kiosks. Labcorp challenged this, arguing the class was overbroad, including “uninjured” members-blind individuals who preferred front-desk assistance or disliked kiosks and thus suffered no harm. Labcorp sought an interlocutory appeal under Rule 23(f). In August 2022, while the appeal was pending, the District Court clarified the class definition to include only those unable to use the kiosks due to their disability, stating this did not materially alter the May order. The Ninth Circuit granted Labcorp’s appeal, reviewed the May order, and upheld the certification, citing precedent allowing classes with more than a minimal number of uninjured members.
Labcorp appealed to the Supreme Court, which granted certiorari to determine whether Rule 23 permits certifying a damages class with both injured and uninjured members. The plaintiffs argued the case was moot, claiming Labcorp appealed the wrong order (May instead of August). In his dissent, Kavanaugh rejected this, noting the District Court’s clarification that the August order didn’t change the May certification, and Ninth Circuit precedent only allowed appeals of materially altered orders. Since the August order didn’t grant or deny certification, Labcorp’s appeal was proper.
Kavanaugh argued that Rule 23 requires common questions to predominate in damages class actions, which is impossible when uninjured members are included. He criticized the Ninth Circuit’s ruling as contrary to Rule 23 and Supreme Court precedents, warning that overbroad classes could coerce businesses into costly settlements, raising consumer prices and harming retirees and workers. The Supreme Court, however, dismissed the case without addressing mootness or the merits, leading Kavanaugh to dissent, urging a ruling that such class certifications are impermissible under Rule 23.
