United States Reports Volume 604: Supreme Court Case Summaries
The United States Reports serve as the official record of the rulings and opinions issued by the Supreme Court of the United States. Volume 604 contains a diverse array of decisions spanning late 2024 and early 2025, touching upon everything from national security and corporate liability to constitutional rights and administrative law.
It is important to note that as of December 2025, final bound volumes have only been published through Volume 585 (June 2018). Consequently, cases in Volume 604 do not yet have official page numbers. In legal citations, these are typically represented by three underscores (e.g., 604 U.S. ___) until the bound volume is released. However, the Court has recently begun committing to citation page numbers on its official website prior to final publication.
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Key Facts
- Volume Status: Volume 604 contains cases decided between November 2024 and March 2025.
- Citation Gap: Official bound volumes are currently published only up to Volume 585.
- Major Rulings: Includes significant decisions on the First Amendment (TikTok), the False Claims Act, and the Gun Control Act of 1968.
- Procedural Actions: Several cases were dismissed as improvidently granted (DIG), meaning the Court decided the case did not warrant review after the writ of certiorari was already issued.
Detailed Analysis of Case Rulings
Constitutional and Civil Rights
The Court addressed several critical constitutional issues. In TikTok v. Garland, the Court ruled that the Protecting Americans from Foreign Adversary Controlled Applications Act did not infringe upon the First Amendment rights of ByteDance or TikTok users. Regarding criminal procedure, Andrew v. White established that the Due Process Clause prohibits the use of evidence so prejudicial that it renders a trial fundamentally unfair.
In Glossip v. Oklahoma, the Court asserted its jurisdiction to review the OCCA's judgment, finding that the prosecution failed its constitutional duty to correct false testimony.
Administrative and Regulatory Law
Administrative authority was a recurring theme. In Bouarfa v. Mayorkas, the Court affirmed that the Secretary of Homeland Security has broad discretion under §1155 to revoke visa petitions, a decision that bars judicial review under §1252(a)(2)(B)(ii). Similarly, in City and County of San Francisco v. EPA, the Court limited the EPA's authority, ruling that Section 1311(b)(1)(C) does not allow the inclusion of "end-result" provisions in NPDES (National Pollutant Discharge Elimination System) permits.
Regarding firearms regulation, Bondi v. VanDerStok held that the ATF's interpretation of "firearm" to include ghost gun kits is consistent with the Gun Control Act of 1968.
Corporate and Commercial Litigation
The Court clarified several standards for corporate liability and employment. In E.M.D. Sales, Inc. v. Carrera, it was determined that a preponderance-of-the-evidence standard applies when employers claim an employee is exempt from Fair Labor Standards Act (FLSA) minimum-wage and overtime provisions.
In Dewberry Group, Inc. v. Dewberry Engineers Inc., the Court ruled that profits awarded under the Lanham Act for trademark infringement do not extend to the profits of a defendant's corporate affiliates.
Federal Statutes and Jurisdiction
The Court provided clarity on the False Claims Act and the Foreign Sovereign Immunities Act (FSIA). In Wisconsin Bell, Inc. v. United States ex rel. Heath, the Court found that fraudulent representations to private administrators of government programs violate the False Claims Act if the funds are at least partially government-sourced. Meanwhile, Republic of Hungary v. Simon clarified that alleging the commingling of funds is insufficient to satisfy the commercial nexus requirement of the FSIA's expropriation exception.
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Summary of Volume 604 Cases
| Case Name | Docket No. | Date Decided | Primary Outcome/Ruling |
|---|---|---|---|
| TikTok v. Garland | 24–656 | Jan 17, 2025 | Act does not infringe First Amendment rights. |
| Bouarfa v. Mayorkas | 23–583 | Dec 10, 2024 | Visa revocation is discretionary; bars judicial review. |
| Wisconsin Bell, Inc. v. US | 23–1127 | Feb 21, 2025 | Fraudulent claims to private admins can violate False Claims Act. |
| Bondi v. VanDerStok | 23–852 | Mar 26, 2025 | Ghost gun kits can be interpreted as "firearms." |
| E.M.D. Sales, Inc. v. Carrera | 23–217 | Jan 15, 2025 | Preponderance-of-evidence standard for FLSA exemptions. |
Frequently Asked Questions
Why do some cases in Volume 604 lack page numbers?
Official bound volumes of the United States Reports are published with a significant delay; currently, they are only available through Volume 585. Cases in newer volumes use placeholders (three underscores) until the final bound version is printed.
What does "dismissed the writ of certiorari as improvidently granted" mean?
This occurs when the Supreme Court decides that a case it previously agreed to hear (granted certiorari) is not suitable for review or does not present a clear legal question that requires the Court's intervention.
How did the Court rule on the TikTok ban legislation?
In TikTok v. Garland, the Court ruled that the Protecting Americans from Foreign Adversary Controlled Applications Act did not violate the First Amendment rights of TikTok users or ByteDance.
What is the ruling regarding ghost gun kits?
In Bondi v. VanDerStok, the Court held that the ATF's rule interpreting the term "firearm" to include ghost gun kits is not facially inconsistent with the Gun Control Act of 1968.
What is the standard for proving FLSA exemptions?
According to E.M.D. Sales, Inc. v. Carrera, employers must use a preponderance-of-the-evidence standard to show that an employee is exempt from minimum-wage and overtime pay provisions.