Supreme Court

Introduction

On October 6, 2025, the United States Supreme Court denied certiorari in Syngenta Crop, LLC v. Nemeth, passing on an opportunity to clarify its prior decision in Mallory v. Norfolk Southern and address whether Pennsylvania’s “consent to jurisdiction” statute violates the dormant Commerce Clause. The result: for now, out-of-state corporations registered to do business in Pennsylvania remain subject to general personal jurisdiction in the Commonwealth, regardless of the extent of their in-state operations.

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The Texas Supreme Court’s recent decision in Werner Enterprises, Inc. v. Blake (No. 23-0493) clarifies proximate causation in personal injury cases ensuring an appropriate bar for proving the causation element of a negligence claim. The Court reversed a nearly $90 million jury verdict in favor of the plaintiffs, hinged on a holding that the substantial factor element of proximate causation was not met in a deadly collision where a vehicle carrying the plaintiffs lost control on an icy road, crossed a wide median into oncoming traffic, and collided with an 18-wheeler operated negligently by the commercial truck driver. “Proximate cause is not established merely by proof that the injury would not have happened if not for the defendant’s negligence,” but rather also requires “proof that the defendant’s negligence was a substantial factor in causing the injury.”  Werner Enterprises, Inc. v. Blake No. 23-0493, 2025 WL 2239275, at *1 (Tex. June 27, 2025).

It is extremely rare for a civil case filed in New York State to be reviewed by its highest court—the New York Court of Appeals. In 2023, 1,030,781 civil cases were filed in New York State trial courts; however, only 93 appeals were decided by the Court of Appeals.1 This represents just 0.009% of civil cases filed that year. Due to a recent decision from the Supreme Court, Appellate Division, Fourth Department (“Fourth Department”), the Court of Appeals may soon address a question of law regarding the state’s causation standard in asbestos cases.2

On July 23, 2025, the U.S. Supreme Court, in a 6-3 vote, granted the Trump Administration’s request to stay a permanent injunction that had ordered the reinstatement of three Democratic CPSC Commissioners: Mary Boyle, Alexander Hoehn-Saric, and Richard Trumka Jr. (the “Commissioners”), after the Administration fired them from the independent agency without cause.

Background

On June 23, 2025, Judge Matthew J. Maddox of the U.S. District Court for the District of Maryland denied a motion by President Donald J. Trump and other officials (“Defendants”) to stay his order reinstating three Democratic CPSC Commissioners: Mary Boyle, Alexander Hoehn-Saric, and Richard Trumka Jr. (the “Commissioners”). The motion, filed on June 16, 2025, sought to pause the court’s injunction, prohibiting any action to effectuate the Commissioners’ removal, while the case is appealed to the U.S. Court of Appeals for the Fourth Circuit. Prior to the district court’s decision, Defendants filed an emergency motion for a stay with the Fourth Circuit on June 17, 2025, which was denied on July 1, 2025. The next day, the Trump Administration submitted an application to the U.S. Supreme Court for an administrative stay and a stay pending appeal.

Released yearly in December, the American Tort Reform (ATR) Foundation publishes its annual “Judicial Hellhole” rankings for the upcoming year. The Hellholes represent the worst of the worst jurisdictions to defend tort lawsuits in the United States. The 2024-2025 Judicial Hellhole rankings crown a new #1 Judicial Hellhole (thanks in large part to a 10-figure nuclear verdict that sealed the crown) and also welcome a new member (King County, Washington) to the ranks.

The United States Supreme Court building

On May 16, 2024, the Supreme Court of the United States (“SCOTUS”) unanimously held that when a district court finds that when a lawsuit involves an arbitrable dispute and a party has requested a stay of the court proceeding pending arbitration, the Federal Arbitration Act (“FAA”) compels the court to issue a stay and the court does not have discretion to dismiss the action.  Smith v. Spizzirri, 601 U.S. 472 (May 16, 2024) (citing 9 U. S. C. §3).