SCOTUS Opinions 1/20/15: Holt v. Hobbs & Teva Pharmaceuticals v. Sandoz

The Court today issued two merits opinions separately from the order list:

(1)  Holt v. Hobbs, with Justice Alito issuing the opinion for a unanimous Court.  The Court held that an Arkansas correctional policy requiring a Muslim inmate to shave his 1/2 inch beard violated the federal RLUIPA statute.  The Eighth Circuit was reversed and the case remanded for further proceedings:

​”​Petitioner Gregory Holt, also known as Abdul Maalik​ ​Muhammad, is an Arkansas inmate and a devout Muslim​ ​who wishes to grow a​ 1/2​-inch beard in accordance with his​ ​religious beliefs. Petitioner’s objection to shaving his​ ​beard clashes with the Arkansas Department of Correction’s grooming policy, which prohibits inmates from​ ​growing beards unless they have a particular dermatological condition. We hold that the Department’s policy, as​ ​applied in this case, violates the Religious Land Use and​ ​Institutionalized Persons Act of 2000 (RLUIPA)​…which prohibits a state​ ​or local government from taking any action that substantially burdens the religious exercise of an institutionalized​ ​person unless the government demonstrates that the​ ​action constitutes the least restrictive means of furthering​ ​a compelling governmental interest. We conclude in this case that the Department’s policy substantially burdens petitioner’s religious exercise.​ Although we do not question the importance of the Department’s interests in stopping the flow of​ ​contraband​ ​and facilitating prisoner identification, we do doubt​ ​whether the prohibition against petitioner’s beard furthers​ ​its compelling interest about contraband. And we conclude that the Department has failed to show that its​ ​policy is the least restrictive​ ​means of furthering its compelling interests. We thus reverse the decision of the​ ​United States Court of Appeals for the​ ​Eighth Circuit.​”​

​Justice Ginsburg filed a concurring opinion in which Justice Sotomayor joined, and Justice Sotomayor also filed a concurring opinion.​

​(2) Teva Pharmaceuticals USA v. Sandoz with Justice Breyer issuing the opinion of the Court and holding that a clear error rather than de novo standard applies to appellate review of a trial court’s resolution of subsidiary factual matters in the course of construing a patent claim.  By a vote of ​7-2 the decision of the Federal Circuit is vacated and remanded:

​”​I​n ​Markman​ ​v.​ ​Westview Instruments, Inc., 517 U. S.​ ​370 (1996), we explained that a patent claim is that “por­tion of the patent document that defines the scope of the​ ​patentee’s rights.”​ ​Id.,​ ​at 372. We held that “the con­​​struction of a patent, including terms of art within its​ ​claim,” is not for a jury but “exclusively” for “the court” to​ ​determine.​ ​Ibid. That is so even where the construction​ ​of a term of art has “evidentiary underpinnings.”​ ​Id.,​ ​at​ ​390.​ ​Today’s case involves claim​ ​construction with “eviden­tiary underpinnings.​”…​And, it requires​ ​us to determine what standard the Court of Appeals​ ​should use when it reviews a trial judge’s resolution of an​ ​underlying factual dispute. Should the Court of Appeals​ ​review the district court’s factfinding​ ​de novo​ ​as it would​ ​review a question of law? Or, should it review that factfinding as it would review a trial judge’s factfinding in​ ​other cases, namely by taking​ ​them as correct “unless​ ​clearly erroneous?” See Fed. Rule Civ. Proc. 52(a)(6). We​ ​hold that the appellate court must apply a “clear error,”​ not a de novo, standard of review.”

​Justice Breyer’s opinion for the Court was joined by all justices except Thomas and Alito.  Justice Thomas filed a dissenting opinion in which Justice Alito joined.