Justia Government & Administrative Law Opinion Summaries

An agricultural company opposed a unionization effort initiated by the United Farm Workers of America, who sought certification as the exclusive bargaining representative for the company's employees under a new statutory procedure. The union filed a Majority Support Petition with the Agricultural Labor Relations Board, presenting evidence that a majority of employees supported union representation. The company responded by submitting objections and employee declarations alleging misconduct by the union during the signature collection process. The Board's regional director investigated and determined that the union had met the statutory criteria for certification, leading the Board to certify the union as the employees' representative.Following the certification, the company filed additional objections with the Agricultural Labor Relations Board, including constitutional challenges to the underlying statute. The Board dismissed most objections and set others for a hearing, but stated it could not rule on constitutional questions. While administrative proceedings were ongoing, the company filed a petition in the Superior Court of Kern County seeking to enjoin the Board from proceeding and to declare the statute unconstitutional. The Board and the union argued that the court lacked jurisdiction due to statutory limits on judicial review, but the superior court nonetheless issued a preliminary injunction halting the Board's proceedings. Appeals and writ petitions followed, consolidating the matter before the reviewing court.The Court of Appeal of the State of California, Fifth Appellate District, held that the superior court lacked jurisdiction to consider the challenge at this stage. The court reaffirmed that under California law, employers may not directly challenge union certification decisions in court except in extraordinary circumstances, which were not present here. The proper procedure is for employers to wait until an unfair labor practice proceeding or mandatory mediation is completed and a final order is issued before seeking judicial review. The court reversed the preliminary injunction and ordered dismissal of the company’s petition for lack of jurisdiction. View "Wonderful Nurseries v. Agricultural Labor Relations Board" on Justia Law

John Kenney, a resident of Florida, sought to obtain a retail cannabis license in Rhode Island as a social equity applicant. He argued that, as a recipient of a social equity cannabis license in the District of Columbia and someone with nonviolent marijuana convictions in Maryland and Nevada, he would otherwise qualify under Rhode Island’s Cannabis Act. Kenney challenged two provisions of the Act: the requirement that all license applicants must be Rhode Island residents or entities controlled by Rhode Island residents, and the definition of “social equity applicant,” which, according to Kenney, only recognizes nonviolent marijuana offenses eligible for expungement under Rhode Island law.After Kenney filed an amended complaint in the United States District Court for the District of Rhode Island, the defendants moved to dismiss for failure to state a claim and lack of subject matter jurisdiction. On February 6, 2025, the district court dismissed the case on ripeness grounds, reasoning that the Cannabis Control Commission had not yet promulgated final rules for retail cannabis licenses, and thus the court could not adjudicate the claims. The case was dismissed without prejudice, and Kenney appealed.The United States Court of Appeals for the First Circuit reviewed the appeal. Following the Commission’s issuance of final rules for retail cannabis licenses, effective May 1, 2025, the appellate court determined that the district court erred in dismissing the case for lack of ripeness. The First Circuit held that Kenney’s claims were not moot and that he had standing to pursue them. The court reversed the district court’s dismissal order and remanded the case for prompt consideration of the merits of Kenney’s constitutional challenges, instructing the district court to rule at least forty-five days before the Commission issues retail licenses. View "Kenney v. Rhode Island Cannabis Control Commission" on Justia Law

A nonprofit organization dedicated to promoting electoral transparency operates a website that republishes voter registration data collected from state agencies. The group obtained New Mexico’s voter data through a third party and published it online, including information such as names, addresses, party affiliation, and voting history. After the website highlighted discrepancies in the state’s voter rolls, New Mexico’s Secretary of State publicly questioned the group’s motives and the lawfulness of its actions. The Secretary referred the group to the Attorney General for criminal investigation under state statutes that restrict the use and sharing of voter data. The group’s subsequent requests for updated voter data were denied.After the state’s refusal, the organization filed suit in the United States District Court for the District of New Mexico, seeking declaratory and injunctive relief on the grounds that New Mexico’s restrictions were preempted by the National Voter Registration Act (NVRA) and violated the First and Fourteenth Amendments. The district court issued a preliminary injunction preventing prosecution, which was later stayed by the Tenth Circuit. After cross-motions for summary judgment, the district court found that the NVRA preempted New Mexico’s restrictions and enjoined criminal prosecution. The court rejected most of the group’s remaining constitutional claims but, following a bench trial, held that the state engaged in unconstitutional viewpoint discrimination by refusing further data requests.On appeal, the United States Court of Appeals for the Tenth Circuit affirmed the district court’s finding that the NVRA preempts New Mexico’s restrictions on the use and sharing of voter data, holding that state laws that prevent broad public disclosure of voter data conflict with the NVRA’s requirements. The Tenth Circuit did not reach the First Amendment claims, remanding the case for further proceedings. View "Voter Reference Foundation v. Torrez" on Justia Law

The case involves a request made by an individual to the Oklahoma State Department of Health for correspondence related to the COVID-19 pandemic, specifically seeking email records sent to the Governor’s office. The requester asked for digital copies, expressing a preference for receiving the records by email. The Department produced over 11,000 pages of email correspondence in PDF format, but the requester argued that this was insufficient because the PDFs did not contain the embedded metadata present in the emails’ native file format (such as PST files from Microsoft Outlook), which he believed was necessary for fully understanding the records.After initially filing for declaratory and injunctive relief in the District Court of Oklahoma County, the Department responded by providing records in PDF format and, later, some in native format. The Department moved for summary judgment, contending that the Oklahoma Open Records Act (ORA) did not require production in native file format. The District Court agreed, granting summary judgment for the Department and finding substantial compliance with the ORA. On appeal, the Oklahoma Court of Civil Appeals reversed, holding that the Department was required to provide records in their native format if it had the capability to do so. The Department then sought review from the Oklahoma Supreme Court.The Supreme Court of the State of Oklahoma held that the ORA does not require a public body to provide copies of email records in their native file format containing embedded metadata. The Court found the statute’s language clear, interpreting “data files” not to include metadata, and concluded that the Act does not obligate agencies to provide records in any specific format, so long as reasonable access is provided. The Supreme Court vacated the Court of Civil Appeals’ opinion and affirmed the District Court’s order. View "BROOKE v. REED" on Justia Law

A bail bondsman requested records from a county jail operated by a public trust after an incident involving his ex-wife at the facility. Specifically, he sought audio and video footage, communications, jail policies and procedures, and a list of employees working during a certain time frame, citing the Oklahoma Open Records Act (ORA). The jail trust denied most of the requests, asserting that as a "law enforcement agency" under the ORA, it had discretion to withhold the records except for certain mandatory disclosures.The District Court of LeFlore County granted summary judgment to the jail trust, agreeing with its argument that it qualified as a "law enforcement agency" under the ORA. The court thus found the trust had discretion to withhold the requested records and was not required to provide them to the requester.On appeal, the Supreme Court of the State of Oklahoma reviewed the matter de novo and focused on whether the jail trust fit the statutory definition of a "law enforcement agency" under 51 O.S.2022, § 24A.3(5). The court concluded that, although the trust was a "public body," it was not "charged with enforcing state or local criminal laws and initiating criminal prosecutions" as required by the statute. The court emphasized that the trust merely operated the jail and was not responsible for enforcing laws or initiating prosecutions. As a result, the court held that the jail trust does not qualify as a "law enforcement agency" under the ORA. The Supreme Court of Oklahoma reversed the district court's summary judgment and remanded the case for further proceedings. View "LAWSON v. LeFLORE CO. DETENTION CENTER PUBLIC TRUST SECURITY COMM." on Justia Law

A senior account manager at a telecommunications company was terminated after several major accounts she managed decided to discontinue the company’s services. In the months leading up to her termination, she took eight and a half days of paid leave to care for her ill daughter and mother. Her supervisor had expressed concerns about her performance, particularly with her newer accounts, but consistently granted all her leave requests without referencing the Family and Medical Leave Act (FMLA). Despite meeting some of her performance objectives, the loss of major accounts and her supervisor’s ongoing performance criticisms culminated in her dismissal.The United States District Court for the Southern District of New York granted summary judgment to the employer on the employee’s FMLA interference and retaliation claims. The district court found that the employee had not shown she was denied any FMLA benefits or that her termination was in retaliation for taking leave. The court also declined to exercise supplemental jurisdiction over her related claim under the New York City Human Rights Law (NYCHRL), dismissing it without prejudice.The United States Court of Appeals for the Second Circuit affirmed the district court’s judgment. The appellate court held that the employee did not establish an FMLA interference claim because her supervisor’s criticisms were unrelated to her leave requests, which were fully granted, and she was not prejudiced by the employer’s failure to provide FMLA notice. The court also held that the employee failed to show retaliation, as her termination was based on documented performance issues rather than the exercise of FMLA rights. Finally, the court upheld the district court’s decision to dismiss the NYCHRL claim without prejudice. View "Haran v. Orange Business Services, Inc." on Justia Law

A candidate for city clerk with over ten years of experience working for the city requested her hiring interview with the Cedar Rapids City Council be conducted in a closed session, citing concerns about potential harm to her reputation if the interview were public and livestreamed. The council unanimously voted to honor her request and held the interview in closed session pursuant to Iowa Code § 21.5(1)(i), which allows closed sessions to protect an individual’s reputation when the individual requests it. The interview proceeded positively, and the candidate was later hired at a subsequent open meeting.A resident challenged the closed session, arguing that the council had violated the Iowa Open Meetings Act by not making an evidence-based determination of reputational harm before closing the interview. After a bench trial, the Iowa District Court for Linn County held that the council had not violated the statute, finding that a specific reputational threat need not be identified prior to closure if the interviewee requests it and the nature of the interview is unpredictable. The district court dismissed the case with prejudice.The Iowa Court of Appeals reversed, ruling that the city council should have conducted further inquiry into the necessity of closing the session and that a candidate’s request alone was insufficient without evidence of reputational harm. Upon further review, the Supreme Court of Iowa vacated the decision of the court of appeals and affirmed the district court’s judgment. The Supreme Court held that under Iowa Code § 21.5(1)(i), a governmental body may close a hiring interview at the candidate’s request as a precaution to protect reputation, without needing evidence of specific harm. The court also upheld the confidentiality of closed session records and found no error regarding courtroom access during trial. View "Teig v. Loeffler" on Justia Law

In this case, two police officers responded to a robbery at a car dealership and pursued the suspects on the highway. During the chase, one officer was shot multiple times by a hidden suspect, and both officers exchanged gunfire with the perpetrator, who was ultimately killed. One officer suffered serious injuries and required extensive medical care. Following the incident, a newspaper reporter requested public records from the Columbus Police Department, including body camera and dash camera footage of the shootout. The police department denied the request for unredacted video footage, citing statutory provisions that protect the privacy of crime victims, specifically Marsy's Law and related Ohio statutes.The Columbus Police Department eventually released redacted versions of the body camera footage, concealing the identities of the two officers and ending the video before the shooting. The newspaper maintained that, as public officials acting in the line of duty, the officers could not be considered "victims" under Marsy's Law and filed an original action in the Supreme Court of Ohio seeking a writ of mandamus to compel production of the unredacted footage.The Supreme Court of Ohio reviewed whether the officers were "victims" under Article I, Section 10a of the Ohio Constitution (Marsy's Law), and thus entitled to privacy protections under the Victim Privacy Law and the Public Records Act. The court held that police officers are "persons against whom crimes can be committed" and therefore qualify as victims under Marsy's Law. As a result, the statutory provisions apply, and the redaction of identifying information from the footage was proper. The court denied the newspaper's request for a writ of mandamus, holding that the newspaper was not entitled to unredacted body camera and dash camera footage identifying the officers. View "State ex rel. GateHouse Media Ohio Holdings II, Inc. v. Columbus Police Dept." on Justia Law

This case concerns the State Water Resources Control Board's intervention in the Tulare Lake groundwater subbasin pursuant to California’s Sustainable Groundwater Management Act (the Act). After local agencies in the subbasin submitted a groundwater sustainability plan that the Department of Water Resources twice determined to be inadequate, the State Board designated the basin as probationary in April 2024. This designation triggered state-imposed monitoring, reporting, and fee obligations on certain groundwater extractors. In response, the Kings County Farm Bureau and others filed a petition for writ of mandate and complaint, asserting that the State Board exceeded its authority and challenging the validity of the designation and associated fees on several grounds.The Superior Court of Kings County addressed both a demurrer filed by the State Board and a request from the Farm Bureau for a preliminary injunction. The trial court dismissed the equal protection claim with leave to amend, but overruled the demurrer as to claims that (1) the State Board used improper “underground regulations” not adopted under the Administrative Procedure Act (APA), (2) the imposed extraction fee constituted an unlawful tax, and (3) general declaratory relief was appropriate. The trial court also granted a preliminary injunction, temporarily halting the State Board’s enforcement activities.The California Court of Appeal, Fifth Appellate District, reviewed the trial court’s order overruling the demurrer. The appellate court held that all actions by the State Board taken under sections 10735.2 and 10735.8 of the Act—including the designation of a probationary basin—are exempt from the APA unless the State Board voluntarily opts to adopt regulations using APA procedures. Therefore, the claim for improper “underground regulations” could not proceed. The court also held that a challenge to the extraction fee as an unlawful tax was barred by the constitutional “pay first” rule, as no exception applied. Lastly, the court determined that declaratory relief was unavailable because the Legislature provided for review of State Board actions exclusively by writ of mandate. The appellate court ordered the trial court to grant the demurrer without leave to amend as to these three claims. View "State Water Resources Control Bd. v. Superior Court" on Justia Law

The dispute centers on the State Water Resources Control Board’s designation of the Tulare Lake groundwater subbasin as a probationary basin under California’s Sustainable Groundwater Management Act (the Act). The Tulare subbasin is categorized as high-priority and critically overdrafted, requiring coordinated local management and submission of a sustainability plan. Local agencies formed a single groundwater sustainability plan, which the Department of Water Resources twice found inadequate, leading the State Board to designate the subbasin as probationary. Following this, the Board imposed monitoring and reporting requirements with associated fees, prompting farmers and landowners, including Kings County Farm Bureau, to challenge the Board’s actions as exceeding its authority and lacking proper notice.Before reaching the California Court of Appeal, the Superior Court of Kings County reviewed the matter. The trial court had issued a preliminary injunction against the State Board, barring it from enforcing requirements and fees related to the probationary designation. The trial court found the plaintiffs likely to succeed on several claims, including improper denial of “good actor” exclusions and failures in notice, and determined the balance of harms weighed in favor of plaintiffs. A nominal bond was set, and the trial court later denied objections to the bond amount.The California Court of Appeal, Fifth Appellate District, reviewed the preliminary injunction. The appellate court held that the trial court abused its discretion by issuing an overly broad injunction affecting the entire Tulare subbasin, where only certain areas had plausible claims. The court clarified that the State Board must exclude any basin portion where a local agency demonstrates compliance with sustainability goals, but this exclusion does not require an independently approved plan for every area. The appellate court reversed the preliminary injunction and remanded the case for further proceedings, instructing the trial court to consider whether a narrower injunction may be appropriate. The petition for writ of supersedeas was denied as moot. View "Kings County Farm Bureau v. State Water Resources Control Bd." on Justia Law