Is the US Supreme Court the only court that can overrule a Supreme Court ruling?

Answer 1

Yes. The US Supreme Court is the highest appellate court in the nation. Decisions of the Court are said to be Res Judicata, meaning the matter has been adjudicated and the verdict is final and binding on all parties involved. The case is no longer eligible for appeal.

This doesn't mean a lower court won't occasionally try to overstep its authority. For example, in Shearson/American Express Inc. v. McMahon, 482 U.S. 220 (1987), the Supreme Court used a precedent set by an earlier Supreme Court decision, Wilko v. Swan, 346 U.S. 427, (1953) to validate an arbitration agreement between a brokerage house and its investors.

The agreement, signed by all parties, stipulated that disagreement about how investment accounts are handled would be settled out-of-court by arbitration, a process whereby both parties agree to allow a non-judicial third-party to review the case and issue a decision about liability and damages. Arbitration is not only legally binding, but provides no avenue for appeal if either party disagrees with the decision.

The Respondents in McMahon were customers of Shearson/American Express, Inc., a brokerage house registered with the SEC. They claimed a sale of certain stock had been undertaken fraudulently, and with an intent to conceal relevant information, that resulted in substantial financial loss, so they filed suit in federal court seeking relief under the 1934 Securities Exchange Act, Rule 10b of the SEC, and the Racketeer Influenced and Corrupt Organizations Act (RICO).

Shearson/American Express filed a motion to force the investors to submit to binding arbitration, per the signed agreement. The court supported Shearson's request and told the investors they had to honor their legal agreement with the brokerage to resolve the matter.

The investors appealed the lower court decision, and the appellate court reversed the ruling, under the theory that the petitioners couldn't sign away statutory rights granted by the government.

The case was eventually granted certiorari by the US Supreme Court, which reversed the appellate court ruling, stating, in part:

"The Arbitration Act establishes a federal policy favoring arbitration, requiring that the courts rigorously enforce arbitration agreements. This duty is not diminished when a party bound by an agreement raises a claim founded on statutory rights. The Act's mandate may be overridden by a contrary congressional command, but the burden is on the party opposing arbitration to show that Congress intended to preclude a waiver of judicial remedies for the statutory rights at issue. Such intent may be discernible from the statute's text, history, or purposes."

This decision was in line with precedent set by the ruling in Wilko v. Swan, (1953). The High Court also believed the investors' rights were adequately protected by the Arbitration Act, and that the third-party arbitrator was empowered to decide matters involving RICO and other federal statutes. The lower-court ruling was reversed and the case remanded.

In a bold move, the U.S. Court of Appeals, 845 F.2d 1296, 1299 (5th circuit 1988) declared the decision in Wilko obsolete and refused to follow the Court's ruling.

Following the U.S. Court of Appeals rebellion, numerous District Courts also deviated from the rule established in Wilko v. Swan.

In response, the Supreme Court reviewed the original Wilko case, concluded the 1953 decision was incorrect, and overruled the earlier Court's judgment.

In a later case against the same company, Rodriguez De Quijas v. Shearson/American Express, 490 U.S. 477 (1989) the Supreme Court took the appellate court to task for its refusal to abide by the Court's decision:

"We do not suggest that the Court of Appeals on its own authority should have taken the step of renouncing Wilko. If a precedent of this Court has direct application in a case, yet appears to rest on reasons rejected in some other line of decisions, the Court of Appeals should follow the case which directly controls, leaving to this Court the prerogative of overruling its own decisions. We now conclude that Wilko was incorrectly decided and is inconsistent with the prevailing uniform construction of other federal statutes governing arbitration agreements in the setting of business transactions. Although we are normally and properly reluctant to overturn our decisions construing statutes, we have done so to achieve a uniform interpretation of similar statutory language..."

Justice Stevens, who wrote the dissenting opinion of the 5-4 ruling, also reprimanded the lower court:

"The Court of Appeals refused to follow Wilko v. Swan, 346 U.S. 427 (1953), a controlling precedent of this Court. As the majority correctly acknowledges, ante, at 484, the Court of Appeals therefore engaged in an indefensible brand of judicial activism. 1 We, of course, are not subject to the same restraint when asked to upset one of our own precedents. But when our earlier opinion gives a statutory provision concrete meaning, which Congress elects not to amend during the ensuing 3 1/2 decades, our duty to respect Congress' work product is strikingly similar to the duty of other federal courts to respect our work product."

Subsequent legislation by Congress can change future rulings, so that there may be a conflict between older and newer decisions, but the U.S. Constitution expressly prohibits ex post facto laws (laws applied retroactively), so new legislation wouldn't change the verdict in cases decided before the law was enacted.

Answer 2

Yes. And they have frequently done so.

In fact, the Ninth Circuit court is regarded as the most overturned court of the federal appellate system.