Justia Government & Administrative Law Opinion Summaries

A group of individuals traveling through Kansas were stopped by Kansas Highway Patrol (KHP) troopers while driving on interstate highways, primarily I-70. In each instance, the drivers and passengers were from out of state, often driving to or from Colorado, and were stopped for alleged traffic violations. After the initial traffic stop was concluded, troopers used a tactic known as the “Kansas Two-Step”—they would briefly disengage, then reinitiate conversation in an attempt to gain consent for further questioning or searches. These stops often led to extended detentions and searches, but no contraband was discovered. The troopers testified that they considered the drivers’ out-of-state status, travel to or from Colorado, and other factors in developing reasonable suspicion.The individuals sued under 42 U.S.C. § 1983 in the United States District Court for the District of Kansas, alleging violations of their Fourth Amendment rights against unreasonable searches and seizures and their constitutional right to travel. Some plaintiffs also brought damages claims, resulting in jury verdicts in their favor. For their claims for injunctive relief, the district court conducted a bench trial and found that KHP had a pattern and practice of targeting out-of-state drivers and using the Two-Step in a manner violating the Fourth Amendment. The court granted a permanent injunction, requiring changes in KHP’s training, documentation, consent procedures, and supervision.On appeal, the United States Court of Appeals for the Tenth Circuit reviewed whether the plaintiffs had standing for injunctive relief and whether the district court abused its discretion in issuing the injunction. The Tenth Circuit held that the plaintiffs had standing because there was a substantial risk they would be stopped again and that KHP had a pattern of unconstitutional conduct. However, the Tenth Circuit found that the injunction was overly broad regarding the use of a driver’s state of origin and the Two-Step tactic. The court affirmed the injunction in part, reversed it in part, and remanded for further proceedings. View "Shaw v. Smith" on Justia Law

A political action committee comprised of residents and registered voters in Richland, Washington, submitted a valid petition in October 2024 to amend the city charter. The proposed amendment would change the composition of the city council to be partly elected by district and partly at large. The Benton County Auditor, upon receiving the petition, scheduled the proposed amendment for the November 2025 general election ballot. The committee, however, sought to have the measure placed on a special election ballot in either February or April 2025.The committee filed a petition for a writ of mandamus in Benton County Superior Court, seeking an order to compel the auditor to place the amendment on the special election ballot. The superior court judge denied the writ, ruling that the amendment would appear on the November 2025 general election ballot instead. The committee obtained direct review of this decision by the Supreme Court of the State of Washington.The Supreme Court of the State of Washington unanimously concluded that the case was moot because the relevant special election dates had passed. Nonetheless, the court exercised its discretion to address the issue as one of continuing and substantial public interest. The majority of justices held that the phrase “next regular municipal election” in RCW 35.22.120 includes both special and general elections. However, a majority also agreed that mandamus was not appropriate in this case because the petitioner did not establish a nondiscretionary duty requiring the auditor to call a special election. The court affirmed the superior court’s dismissal of the writ of mandamus. View "A Better Richland v. Chilton" on Justia Law

A female custodian employed by a public university filed a Title IX complaint alleging physical assault and a pattern of sexual harassment by a male co-worker, both of whom were members of the same union. The university, which receives federal funding, initiated a Title IX grievance process compliant with 2020 federal Title IX Regulations. After an investigation and hearing in which both parties participated, university decision-makers found the accused violated university policy and determined there was just cause for his termination. The accused’s appeal within the Title IX process was unsuccessful, and he was terminated.The union representing the accused employee filed a grievance under its 2019 collective negotiation agreement (CNA) with the university, seeking arbitration to determine whether the termination was for just cause. The university denied the grievance, arguing that the federal Title IX Regulations preempted the CNA’s grievance procedure. The union sought arbitration through the New Jersey Public Employment Relations Commission (PERC), which denied the university’s request to restrain arbitration and held, applying state preemption law, that the Title IX Regulations did not preempt arbitration. The Superior Court, Appellate Division, affirmed, finding no conflict precluding the union’s grievance procedure.The Supreme Court of New Jersey reviewed the case and reversed the lower courts. The Court held that the CNA’s grievance procedure is preempted by the 2020 federal Title IX Regulations because those regulations require that any grievance or appeal process must apply equally to both complainant and respondent. The CNA’s arbitration process excluded the alleged victim from participation, granting rights only to the accused. The Court concluded that this inequality creates a direct conflict with federal law, which therefore preempts the CNA’s arbitration provision in this context. The decision is limited to this particular CNA and does not preempt all union grievance procedures. View "In the Matter of Rutgers, the State University of New Jersey v. AFSCME Local 888" on Justia Law

A group of plaintiffs, including individual Temporary Protected Status (TPS) beneficiaries and an organization, challenged actions taken by the Secretary of Homeland Security. These actions included vacating and terminating Venezuela’s TPS designation and partially vacating Haiti’s TPS designation. TPS provides eligible nationals of designated countries temporary protection from deportation and work authorization due to conditions such as armed conflict or environmental disaster in their home countries. The Secretary’s actions resulted in many TPS holders losing their protection and work authorization, leading to job loss, detention, deportation, and family separation.The plaintiffs filed suit in the United States District Court for the Northern District of California. The district court initially postponed the effectiveness of the Venezuela TPS vacatur and later granted partial summary judgment for the plaintiffs. The district court held that the Secretary exceeded her statutory authority under 8 U.S.C. § 1254a by vacating and terminating the Venezuela TPS designation and partially vacating Haiti’s TPS designation. The court also found these actions arbitrary and capricious under the Administrative Procedure Act (APA) and set them aside. The government appealed these rulings to the United States Court of Appeals for the Ninth Circuit.The United States Court of Appeals for the Ninth Circuit affirmed the district court’s judgment. The Ninth Circuit held that the TPS statute does not grant the Secretary authority to vacate an existing TPS designation or to partially vacate a TPS extension. The court further held that the Secretary’s attempted vacatur and terminations were in excess of statutory authority and invalid. The Ninth Circuit also concluded that setting aside these actions under the APA was appropriate and not barred by statutory limitations on judicial review or injunctive relief. The court affirmed full vacatur of the Secretary’s actions, restoring the prior TPS designations and extensions. View "National TPS Alliance v. Noem" on Justia Law

Kevin Lewis, who is legally blind, was arrested in Georgia on an outstanding warrant and detained for less than 48 hours in the Chatham County jail and for about 16 days in the Fulton County jail. During both periods of incarceration, Lewis alleges he was denied assistance with reading documents, navigating the facilities, accessing the grievance process, and obtaining requested medications. He also reports that, despite his requests, he was not provided accommodations for using jail telephones and kiosks.After his release and the dismissal of criminal charges against him, Lewis filed suit in the United States District Court for the Northern District of Georgia against Sheriffs John Wilcher and Patrick Labat in their official capacities, seeking damages and injunctive relief under Title II of the Americans with Disabilities Act and § 504 of the Rehabilitation Act. The district court granted summary judgment in favor of the sheriffs. The court found that Lewis had not produced sufficient evidence to show he was denied benefits or discriminated against “by reason of” his disability, and had not shown that the sheriffs engaged in intentional discrimination. Regarding his claims for injunctive relief, the court determined they were moot because Lewis was no longer incarcerated.On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s decision. The appellate court held that Lewis failed to present evidence of intentional discrimination by the sheriffs, as required for damages under both statutes. It also held that his claims for injunctive relief were moot, as there was no reasonable expectation he would be subject to the challenged conditions again. The district court’s grant of summary judgment was thus affirmed. View "Lewis v. Sheriff, Fulton County Georgia" on Justia Law

The case involves an individual, B.K., who has schizophrenia and has been under a conservatorship pursuant to the Lanterman-Petris-Short (LPS) Act since 2019. The conservatorship was initially established after B.K. was found to be gravely disabled as a result of a mental disorder, and it has been renewed annually following court hearings. In several renewal proceedings, B.K. expressed her desire to contest the conservatorship, at times requesting either a court or jury trial. At the most recent renewal proceeding, B.K. initially requested a jury trial but later, after consulting with her attorney, chose to proceed with a court trial instead. B.K. confirmed this choice in open court.The Superior Court of Los Angeles County conducted the court trial, during which expert testimony and B.K.’s own statements supported a finding that she remained gravely disabled and unable to care for herself due to her mental illness. The court renewed the conservatorship for another year. B.K. appealed, arguing that the trial court failed to adequately advise her of her right to a jury trial or to ensure that her waiver of that right was knowing and intelligent.The California Court of Appeal, Second Appellate District, Division Four, reviewed the case. Applying de novo review to statutory claims and substantial evidence review to the trial court’s implied finding, the Court of Appeal concluded that B.K. was aware of her right to a jury trial and that, under the totality of the circumstances, her waiver—made through counsel and confirmed in court—was knowing and intelligent. The appellate court held that direct advisement or a personal waiver was not required under the LPS Act when counsel confers with the conservatee and there is no indication of lack of authority or client understanding. The court affirmed the ruling, finding no reversible error. View "Conservatorship of B.K." on Justia Law

In 2005, an individual was convicted of endangering the welfare of a child and placed on Parole Supervision for Life (PSL) in New Jersey. The State Parole Board imposed two special conditions: a ban on accessing social media and a ban on viewing or possessing pornography. In 2018, the individual was arrested on a parole warrant for allegedly violating both conditions. After a hearing, the Parole Board found violations, revoked PSL, and ordered twelve months of incarceration. The individual challenged the constitutionality of the conditions, arguing they violated First Amendment rights. While an appeal was pending, the Parole Board vacated the revocation in February 2020 and later discharged the conditions. On June 1, 2020, the Board issued a decision stating there was no clear and convincing evidence of violations.The complainant and spouse then filed suit under the New Jersey Civil Rights Act (CRA) and the Tort Claims Act (TCA) against the State and others, alleging substantive due process violations, gross negligence, deliberate indifference, and false arrest/imprisonment. The trial court dismissed all claims as time-barred, holding that the statute of limitations began to run at various points before June 2020. The Appellate Division affirmed, finding that the claims accrued earlier and that even under the favorable-termination rule from Heck v. Humphrey, the relevant accrual event was the Board's February 2020 vacatur of the revocation.The Supreme Court of New Jersey held that the favorable-termination rule from Heck v. Humphrey applies to claims under the CRA and the TCA, meaning that civil rights claims that necessarily challenge the validity of a criminal or quasi-criminal proceeding do not accrue until that proceeding is terminated in the plaintiff’s favor. The Court determined that substantive due process and related claims accrued on June 1, 2020, making them timely, but that any false arrest/imprisonment claim accrued earlier and was time-barred. The Court reversed the dismissal of the first three counts and affirmed the dismissal of the false arrest/imprisonment claim. View "C.A.L. v. State of New Jersey" on Justia Law

After the Missouri General Assembly enacted Senate Bill No. 22 (SB 22) in 2025, which made several changes to statutes governing ballot summaries and judicial proceedings, a Missouri resident and taxpayer challenged its constitutionality. SB 22 as introduced focused solely on amending the process for judicial review of ballot summary statements. During the legislative process, SB 22 was amended to include provisions expanding the attorney general’s authority to appeal certain preliminary injunctions, a subject unrelated to ballot summaries, and the bill’s title was changed from “relating to ballot summaries” to “relating to judicial proceedings.” After passage by both legislative chambers and the Governor’s signature, the bill became law.The Circuit Court of Cole County reviewed the case after the plaintiff alleged SB 22 violated the Missouri Constitution’s original purpose, single subject, and clear title requirements, as well as equal protection guarantees. The circuit court found the bill did not violate the procedural constitutional provisions, but it did find that the amendment to section 526.010 (concerning the attorney general’s appellate rights) violated equal protection and was severable from the rest of the bill. The court allowed the remaining portions, primarily those addressing ballot summaries, to stand. The plaintiff appealed, challenging the findings on the procedural requirements, while the State cross-appealed on standing and equal protection.The Supreme Court of Missouri heard the case and held that the plaintiff had taxpayer standing because SB 22’s provisions resulted in a direct expenditure of public funds. Upon de novo review, the Supreme Court found that SB 22 violated the original purpose requirement of article III, section 21 of the Missouri Constitution because the added provision regarding the attorney general’s appellate rights was not germane to the bill’s original purpose. The Court further held that the offending provision could not be severed, and therefore invalidated SB 22 in its entirety, reversing the judgment of the circuit court. View "Nicholson v. State" on Justia Law

Ten nonprofit organizations that received federal grants through the U.S. Citizenship and Immigration Services’ “Citizenship and Integration Grant Program” filed suit after the Department of Homeland Security (DHS) froze and subsequently terminated their grant funding. The freeze and termination followed an executive order issued by the incoming President in January 2025 directing DHS to pause and review grants that funded services to undocumented immigrants, with the aim of ensuring compliance with law and preventing waste, fraud, or abuse. DHS notified grantees of the freeze in February 2025 and terminated the grants in March 2025, prompting the plaintiffs to seek a preliminary injunction to restore the program and funding.The United States District Court for the District of Maryland denied the plaintiffs’ motion for a preliminary injunction. The court determined that the plaintiffs’ claims were essentially contractual—seeking disbursement of funds based on grant agreements—and thus fell under the exclusive jurisdiction of the United States Court of Federal Claims pursuant to the Tucker Act. The court also found that the plaintiffs had not identified a reviewable “final agency action” under the Administrative Procedure Act (APA). Additionally, it concluded that the plaintiffs had failed to provide adequate legal authority for their ultra vires and separation-of-powers claims.Reviewing the appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s decision. The Fourth Circuit held that the relief sought by the plaintiffs was materially indistinguishable from relief denied in recent Supreme Court cases, Department of Education v. California and National Institutes of Health v. Public Health Association. It concluded that claims seeking to enforce contractual obligations to pay money must be brought in the Court of Federal Claims and that the plaintiffs had not shown a likelihood of success on their alternative constitutional or statutory claims. The district court’s denial of the preliminary injunction was therefore affirmed. View "Solutions in Hometown Connections v. Noem" on Justia Law

The case centers on the Trans Alaska Pipeline System (TAPS), which transports crude oil from Alaska’s North Slope, with oil from different shippers being commingled in the pipeline. To address variations in oil quality, a “Quality Bank” compensates shippers who inject higher-quality oil and charges those with lower-quality oil. The valuation of one particular oil component, Resid—the heaviest and least valuable cut—has been disputed for decades. Petro Star, a shipper whose refineries lack specialized units to further process Resid, argued that Resid was undervalued, while ConocoPhillips contended it was overvalued. The TAPS owners, who administer the Quality Bank, also challenged a Federal Energy Regulatory Commission (FERC) finding that the Bank’s administrator violated tariff provisions.Following a 2013 FERC investigation into the Resid valuation formula, both Petro Star and ConocoPhillips intervened, seeking changes. After initial FERC findings were remanded for further explanation by the United States Court of Appeals for the District of Columbia Circuit, FERC held additional hearings. An administrative law judge (ALJ) concluded the formula was just and reasonable, and FERC largely affirmed this result, also finding a tariff violation by the Quality Bank administrator for failing to update formula yields based on monthly Resid testing.On review, the United States Court of Appeals for the District of Columbia Circuit held that FERC’s formula for valuing Resid remains just and reasonable, as neither Petro Star nor ConocoPhillips demonstrated the formula to be unjust or unreasonable. The court also upheld FERC’s finding that the Quality Bank administrator violated the tariff by not updating formula yields with each test, but found FERC’s prospective remedy—requiring monthly testing and annual yield updates—was appropriate. The court denied all three petitions. View "Petro Star Inc. v. FERC" on Justia Law