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Some Opinions We Missed, and a Fond Farewell

By Mark Wilson, Esq. on May 29, 2015 | Last updated on March 21, 2019

Last week, amid lofty opinions about excessive force and the dormant commerce clause, we did not have a chance to report on some of the more work-a-day cases the Supreme Court decided.

These decisions -- all of which were unanimous -- don't implicate constitutional principles necessarily, and aren't as contentious as some of the Court's other cases, but hey, they're important, too.

Henderson v. United States

The case so nice, they argued it twice! The question in Henderson, which was, in fact, re-argued, was what happens to a federal felon's guns. Henderson wanted to transfer them to a friend rather than give them up altogether, but the Eleventh Circuit said such a transfer would still give Henderson "constructive possession" of the weapons.

The Court unanimously concluded that federal courts do have the authority to allow felons to transfer their guns to someone else. However, as to Henderson, it affirmed that allowing him to transfer his guns to his friend would still give him constructive possession in violation of federal law.

Coleman v. Tollefson

Prisoners can file federal lawsuits without paying the filing fee if they claim in forma pauperis (IFP) status (basically, "I'm too poor to pay the fee"). However, a prisoner who files three lawsuits that are ruled vexatious can no longer claim IFP status.

Coleman was on the verge of hitting the limit: His third vexatious claim was on appeal from dismissal and he wanted to file four more lawsuits after that. A unanimous Court said that a dismissal counted as a strike notwithstanding its being appealed. Most trial court judgments take effect immediately, even if they are appealed, and the Prison Litigation Reform Act doesn't change that.

Tibble v. Edison International

Employees of Edison International claimed that a retirement plan administrator filed his fiduciary duty to plan members by selecting mutual funds that carried administrative fees that would be charged to plan members, then shared between Edison and the mutual fund administrator. Without deciding whether this was actually a breach of a fiduciary duty, the question for the Court was whether the retirement plan administrator's actions fell within the six-year statute of limitations.

The Supreme Court held -- again, unanimously -- that they did. In reversing the Ninth Circuit, the court said that a retirement plan administrator is under a continuing duty to the beneficiaries under the common law of trusts. Consequently, the cause of action arises not when the administrator initially selects the funds, but rather when the administrator fails to properly monitor investments. The case goes back to the Ninth Circuit for more argument on the merits.

So Long, and Thanks for All the Fish

And now for something completely different.

Monday, June 1 will be my final day as a blog writer for FindLaw. Over the course of 10 months or so, I've thoroughly enjoyed bringing you the latest legal developments, whether they've been Supreme Court opinions, federal circuit opinions, news on how the NSA is listening in on our phone calls, or complaints about the state of the legal job market.

I regret that I won't be here to write posts on some of the more interesting Supreme Court cases argued this term, including Facebook threats, the Affordable Care Act, and of course, the fate of same-sex marriage. I leave those posts in the more-than-capable hands of my fellow FindLaw writers.

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