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Biden v. Nebraska

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"Department of Education v. Brown" redirects here. Not to be confused with Brown v. Board of Education.

Biden v. Nebraska
Supreme Court of the United States
Argued February 28, 2023
Decided June 30, 2023
Full case nameJoseph R. Biden, President of the United States, et al. v. Nebraska, et al.
Docket no.22-506
Citations600 U.S. 477 (more)
143 S. Ct. 2355
ArgumentOral argument
Opinion announcementOpinion announcement
DecisionOpinion
Questions presented
(1) Whether respondents have Article III standing; and
(2) Whether the student loan forgiveness plan exceeds the Secretary of Education's statutory authority or is arbitrary and capricious.
Holding
1. At least Missouri has standing to challenge the Secretary’s program.
2. The HEROES Act allows the Secretary to "waive or modify" existing statutory or regulatory provisions applicable to financial assistance programs under the Education Act, but does not allow the Secretary to rewrite that statute to the extent of canceling $430 billion of student loan principal.
Court membership
Chief Justice
John Roberts
Associate Justices
Clarence Thomas · Samuel Alito
Sonia Sotomayor · Elena Kagan
Neil Gorsuch · Brett Kavanaugh
Amy Coney Barrett · Ketanji Brown Jackson
Case opinions
MajorityRoberts, joined by Thomas, Alito, Gorsuch, Kavanaugh, Barrett
ConcurrenceBarrett
DissentKagan, joined by Sotomayor, Jackson
Laws applied
U.S. Const. art. III
HEROES Act
Administrative Procedure Act

Biden v. Nebraska, 600 U.S. 477 (2023), was a United States Supreme Court case related to the forgiveness of federal student loans by the Biden administration in 2022, challenged by multiple states. The Supreme Court's ruling was issued on June 30, 2023, ruling 6–3 that the Secretary of Education did not have the power to waive student loans under the HEROES Act.

Biden was heard and decided alongside Department of Education v. Brown, 600 U.S. 551 (2023), in which members within the student loan program had brought suit against the debt forgiveness program. This case was vacated on the basis of lack of standing by the student loan members.

Background

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See also: Student loans in the United States and Issues in higher education in the United States § Cost and financing issues and financial value of degrees

While campaigning for president in 2020, Joe Biden promised to cancel up to $10,000 of federal student loan debt per borrower.[1] After being elected president, Biden called for the 117th U.S. Congress to pass a bill to facilitate $10,000 in student loan forgiveness.[2][3] In August 2022, Biden announced that he would use executive action to forgive $10,000 in student loans for borrowers earning less than $125,000 individually and $250,000 as married couples, including an additional $10,000 for Pell Grant recipients.[4] The Biden administration invoked the HEROES Act as the basis for his executive authority to forgive loans. In particular, the administration utilized language that states that the U.S. Secretary of Education has the authority to "waive or modify any statutory or regulatory provision applicable to the student financial assistance programs under Title IV" of the Higher Education Act of 1965 to ensure that "affected individuals" are not placed in a worse position financially in relation to that financial assistance. Affected individuals include, among others, those who "reside or are employed in an area declared a disaster area in connection with a national emergency" and those who "suffered direct economic hardship as a result of a war, military operation, or national emergency."[5]

On September 29, 2022, Nebraska, Missouri, Arkansas, Iowa, Kansas and South Carolina filed a lawsuit in the Eastern Missouri U.S. District Court challenging the forgiveness program, asserting that it violated the separation of powers and the Administrative Procedure Act.[6] The states asserted they had standing because the American Rescue Plan Act of 2021 bars them from taxing loans that are discharged for 3 years. Missouri in particular also asserted that it had standing because the Higher Education Loan Authority of the State of Missouri (MOHELA) is a public entity that would lose revenue from student loan forgiveness and become less able to fund Missouri's student financial aid program. On October 20, 2022, district judge Henry Autrey dismissed the suit, holding that the states lacked standing to sue. The states appealed, and on November 14, 2022, the U.S. 8th Circuit Court of Appeals granted an injunction pending appeal.[7]

Separately, on October 10, 2022, two student loan borrowers who did not qualify for the proposed debt forgiveness filed a lawsuit in the Northern Texas U.S. District Court, seeking to vacate the student loan forgiveness program.[8] The borrowers asserted they had standing due to their inability to voice their disagreement with the program through a formal notice-and-comment rule making process required by the Administrative Procedure Act. The two borrowers were backed by the conservative advocacy organization Job Creators Network.[9]

On November 10, 2022, district judge Mark Pittman issued an order to strike down the student loan forgiveness program.[10] On November 30, 2022, the U.S. 5th Circuit Court of Appeals declined to issue a hold on the order in response to an appeal from the U.S. Department of Education.[11]

Supreme Court

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United States Senator Elizabeth Warren speaks at a demonstration in support of student debt cancellation outside of the United States Supreme Court Building on February 28, 2023

After the 8th Circuit granted an injunction pending appeal, the federal government sought to vacate the stay at the Supreme Court on November 18, 2022. On December 1, 2022, the court deferred resolution of the application, granted certiorari before judgment and set the case for argument in the February 2023 sitting.[12] On December 2, 2022, the Biden administration requested that the court either hear the government's appeal from Pittman's order alongside the Nebraska case or issue a hold on his order.[7] On December 12, the Supreme Court agreed to hear arguments in the second case initiated by the student loan borrowers, Department of Education v. Brown, jointly with Biden v. Nebraska.[13][14] On January 4, 2023, the Justice and Education Departments filed a brief with the Court that argued that the plaintiffs failed to demonstrate legal injury from the proposal and thereby lacked standing under Article III, and that denied the claims made by the plaintiffs that the administration was overstepping its statutory authority in promulgating the proposal under the HEROES Act.[15]

Oral arguments for both Department of Education v. Brown and Biden v. Nebraska were held on February 28, 2023.[16][17] Many journalists and legal commentators stated that, based on oral arguments, the Court seemed likely to overturn the Biden debt relief program.[18][19][20][21][22]

On June 30, 2023, the Court issued a 6–3 decision for Biden v. Nebraska, striking down the debt forgiveness program. The majority opinion was authored by Chief Justice John Roberts and joined by Justices Samuel Alito, Clarence Thomas, Neil Gorsuch, Brett Kavanaugh, and Amy Coney Barrett. After first establishing that at least Missouri had Article III standing to challenge the debt forgiveness program, Roberts held that the statutory grant of authority to the Secretary of Education to 'waive or modify' loan terms could not be extended to the student loan forgiveness program, and that a debt cancellation of this scale required clear congressional authorization and fell under the major questions doctrine.[23][24] The Court also issued a unanimous decision authored by Justice Alito for Department of Education v. Brown, holding that the plaintiffs did not have standing.[25][26]

The dissenting opinion was authored by Justice Elena Kagan and joined by Sonia Sotomayor and Ketanji Brown Jackson.[27]

Impact

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President Biden responded to the Supreme Court's decision by pledging a new effort to cancel student loans by utilizing the Higher Education Act of 1965.[23] He also contrasted the debt forgiveness program with the Paycheck Protection Program.[28] The Supreme Court's ruling in Biden v. Nebraska was used as guidance in implementing preliminary injunctions against further proposals to forgive student loans via the SAVE repayment plan.[29][30]

References

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  1. ^ Minsky, Adam (October 7, 2020). "Biden Affirms: "I Will Eliminate Your Student Debt"". forbes.com. Retrieved December 7, 2022.
  2. ^ Seddiq, Oma; Sheffey, Ayelet (December 14, 2021). "White House punts Biden's promise to cancel $10,000 in student debt to Congress: 'They haven't sent him a bill on that yet'". businessinsider.com. Retrieved December 7, 2022.
  3. ^ Nova, Annie (January 8, 2021). "Biden will call on Congress to forgive $10,000 in student debt for all borrowers". cnbc.com. Retrieved December 7, 2022.
  4. ^ Nova, Annie (August 24, 2022). "Biden cancels $10,000 in federal student loan debt for most borrowers". CNBC. Retrieved January 10, 2023.
  5. ^ "Statutory Basis for Biden Administration Student Loan Forgiveness". congress.gov. September 13, 2022. Retrieved December 7, 2022.
  6. ^ "STATE OF NEBRASKA, et al v. JOSEPH R. BIDEN, JR., et al" (PDF). moed.uscourts.gov. Retrieved December 7, 2022.
  7. ^ a b Howe, Amy (December 1, 2022). "Court will review legality of Biden's student-debt relief, but plan remains on hold for now". SCOTUSblog. Retrieved December 1, 2022.
  8. ^ "Brown v. U.S. Department of Education". courtlistener.com. Retrieved December 7, 2022.
  9. ^ Cochran, Lexi Lonas (January 3, 2023). "Where student loan forgiveness stands: Legal fight shifts to Supreme Court". The Hill. Retrieved November 5, 2024.
  10. ^ Lobosco, Katie (November 10, 2022). "What student loan borrowers need to know as Biden's forgiveness program is stuck in legal limbo". cnn.com. Retrieved December 7, 2022.
  11. ^ Douglas-Gabriel, Danielle (November 30, 2022). "Another appeals court rejects bid to revive Biden student loan relief". washingtonpost.com. Retrieved December 7, 2022.
  12. ^ Mangan, Dan (December 1, 2022). "Supreme Court takes Biden student debt relief case, holds program for now". CNBC. Retrieved December 12, 2022.
  13. ^ Mangan, Dan (December 12, 2022). "Supreme Court takes second case challenging Biden student loan relief". CNBC. Retrieved December 12, 2022.
  14. ^ "Department of Education, et al., Applicants v. Myra Brown, et al". supremecourt.gov. Retrieved February 27, 2023.
  15. ^ Nova, Annie (January 5, 2023). "Biden administration files its brief with the Supreme Court, defending student loan forgiveness". CNBC. Retrieved January 5, 2023.
  16. ^ "Biden v. Nebraska". SCOTUSblog. Retrieved February 27, 2023.
  17. ^ "Department of Education v. Brown". SCOTUSblog. Retrieved February 27, 2023.
  18. ^ Liptak, Adam (February 28, 2023). "Supreme Court Appears Skeptical of Biden's Student Loan Forgiveness Plan". The New York Times. ISSN 0362-4331. Retrieved March 1, 2023.
  19. ^ "Biden's student-loan forgiveness plan gets cold reception from conservative justices". SCOTUSblog. February 28, 2023. Retrieved March 1, 2023.
  20. ^ "Supreme Court justices question student loan forgiveness plan". Washington Post. February 28, 2023. Retrieved March 1, 2023.
  21. ^ Cole, Tierney Sneed, Devan (February 28, 2023). "Takeaways from the Supreme Court oral arguments in cases challenging Biden's student debt relief plan | CNN Politics". CNN. Retrieved March 1, 2023.{{cite web}}: CS1 maint: multiple names: authors list (link)
  22. ^ Lonas, Lexi (February 28, 2023). "Student loan forgiveness Supreme Court hearing: Top takeaways". The Hill. Retrieved March 1, 2023.
  23. ^ a b "Student Loan Forgiveness: Supreme Court Rejects Biden's Debt Forgiveness Plan". The New York Times. June 30, 2023.
  24. ^ Savage, Charlie (June 30, 2023). "Highlights of the Student Loan Forgiveness Opinions and Dissent". The New York Times. Retrieved June 30, 2023.
  25. ^ "The Supreme Court strikes down Biden's student-loan forgiveness plan, blocking debt relief for millions of borrowers". businessinsider.com. June 30, 2023.
  26. ^ "Department of Education et al v. Brown et al" (PDF). supremecourt.gov. June 30, 2023.
  27. ^ Salam, Erum (June 30, 2023). "US supreme court rules against Biden's student loan relief program". The Guardian. ISSN 0261-3077. Retrieved June 30, 2023.
  28. ^ Ivanova, Irina; Picchi, Aimee (June 30, 2023). "PPP loans cost nearly double what Biden's student debt forgiveness would have. Here's how the programs compare". MSNBC. Retrieved July 1, 2023.
  29. ^ "Courts grant injunctions against Biden's student loan repayment plan". Washington Post. June 24, 2024.
  30. ^ "State of Missouri, et. al. v. Joseph R. Biden, et. al" (PDF). US District Court for the Eastern District of Missouri. June 24, 2024.
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