Justia Government & Administrative Law Opinion Summaries

The appellants, including trustees of several trusts and Hall Atlas, LLC, held coal mining rights to the Hall Ranch in Wyoming, containing significant coal reserves. In 1985, the Wyoming Department of Environmental Quality (WDEQ) determined that a portion of the Hall Ranch was located on an alluvial valley floor (AVF), which limited mining under the Surface Mining Control and Reclamation Act (SMCRA). For decades, neither the appellants nor Exxon Coal Resources, the lessee at the time, pursued a coal exchange. In 2010, Hall Atlas applied to the Bureau of Land Management (BLM) for a coal exchange. BLM initially rejected WDEQ’s 1985 determination but changed position in 2014, and Hall Atlas submitted a mine plan. In 2016, BLM determined the Hall Ranch AVF coal had a value of $0. In 2017, BLM reiterated its $0 valuation and rejected the appellants’ proposed exchange tract, instead proposing alternatives based on the same valuation.The United States Court of Federal Claims dismissed the appellants’ takings claim for lack of subject matter jurisdiction, holding that the claim was time-barred because it was filed more than six years after the claim accrued. The appellants argued that their claim did not accrue until BLM’s 2017 letter, but the court found that the relevant accrual date was in 2016, when BLM finalized its $0 valuation.On appeal, the United States Court of Appeals for the Federal Circuit affirmed the decision. The Federal Circuit held that any takings claim accrued no later than 2016, making the 2023 filing untimely under the Tucker Act’s six-year statute of limitations. The court rejected arguments for equitable tolling and the application of the continuing claim or stabilization doctrines, and concluded the dismissal for lack of subject matter jurisdiction was correct. The judgment was affirmed and costs were awarded to the appellee. View "WYOMING TRUST CO. v. US " on Justia Law

A public school district alleged that, beginning in 2008, another district enrolled students who resided within its boundaries without its approval, in violation of Michigan’s State School Aid Act. Because state funding is allocated based on student enrollment, the plaintiff claimed it was deprived of millions in funding. After an initial lawsuit was dismissed for failure to exhaust administrative remedies, the plaintiff sought relief from the Michigan Department of Education (MDE), which twice declined to issue a declaratory ruling on the matter. The plaintiff then repeatedly returned to court, seeking declaratory relief and asserting unjust enrichment. Each time, the MDE’s refusal to issue a ruling and the plaintiff’s failure to appeal that denial through a petition for review under the Administrative Procedures Act (APA) became the basis for dismissal.The Macomb Circuit Court twice granted summary disposition to the defendant, concluding that the plaintiff was required to exhaust administrative remedies by appealing the MDE’s denial through the APA process. On appeal, the Michigan Court of Appeals ultimately affirmed the trial court, relying on the earlier decision in Human Rights Party v Michigan Corrections Commission, and held that the plaintiff was required to challenge the agency’s refusal through the APA’s petition-for-review procedure, not via an independent action.The Supreme Court of Michigan reversed the judgment of the Court of Appeals. The Supreme Court held that neither MCL 24.263 nor MCL 24.264 required a party to appeal an agency’s decision not to issue a declaratory ruling through the APA petition-for-review process. Instead, after an agency declines to issue a declaratory ruling, the requesting party is free to seek a declaratory judgment in circuit court or pursue any other available remedy. The Court overruled Human Rights Party and related decisions, remanding the case for further proceedings. View "Warren Consolidated School District v. Hazel Park School District" on Justia Law

The President issued an executive order in January 2025 suspending the entry of all refugees into the United States under the United States Refugee Admissions Program (USRAP), citing concerns about national capacity and security. The Department of State, in response, suspended and later terminated funding for both overseas and domestic refugee resettlement services, including cooperative agreements with resettlement organizations. Plaintiffs, consisting of affected refugees and resettlement agencies, challenged these actions, arguing that the suspension exceeded the President’s statutory authority and that the funding terminations violated the Administrative Procedure Act (APA) and the Refugee Act.Upon review, the United States District Court for the Western District of Washington granted two preliminary injunctions. The first prohibited enforcement of the executive order suspending refugee admissions and related funding, and the second required the reinstatement of terminated cooperative agreements with resettlement agencies. The Government immediately appealed and sought stays of these injunctions. The district court also certified three plaintiff classes and further clarified the scope of its injunctions.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that the President acted within his statutory authority under 8 U.S.C. § 1182(f) in suspending refugee admissions and in pausing decisions on refugee applications, and it reversed the district court’s injunctions to the extent they blocked these actions. The court also concluded that suspending overseas refugee processing and related funding did not violate the Refugee Act or the APA. However, the court affirmed the injunction as to the termination of domestic resettlement services, holding that the Government was likely acting contrary to law and arbitrarily and capriciously by failing to provide statutorily mandated resettlement services to admitted refugees. The scope of the injunction was upheld as compliant with recent Supreme Court precedent. View "PACITO V. TRUMP" on Justia Law

A transgender woman petitioned the Sixth Judicial Circuit Court in Hughes County, South Dakota, to amend her birth certificate. She requested that the certificate reflect her legal name change, already recognized by Minnesota, and to change the sex designation from male to female, matching her gender identity. The Department of Health did not initially participate in the proceedings. The petitioner’s main argument on appeal concerned only the sex designation, asserting a right to have her birth certificate reflect her gender identity, referencing her legal documents as proof and citing constitutional guarantees of equal protection.The circuit court denied the petition. It interpreted the governing administrative regulation (ARSD 44:09:05:02) as permitting amendments only if the data was incorrect at the time of or immediately after birth. The court found that the certificate correctly reflected the facts at birth and was not meant to record changes occurring later in life. Regarding the equal protection claim, the court determined that neither a fundamental right nor a suspect classification was involved. It applied rational basis review, finding the rule rationally related to legitimate state interests, such as the accurate recording of newborn sex and the integrity of vital records.On appeal, the Supreme Court of the State of South Dakota reviewed both the regulatory interpretation and the equal protection claim de novo. The court affirmed the lower court’s decision, holding that the administrative rule unambiguously limits amendments to correcting errors existing at the time of birth and does not permit changes based solely on a subsequent change in gender identity. Furthermore, the court held that the regulation neither classifies on the basis of sex or transgender status nor targets a suspect class, and rational basis review is appropriate. The court concluded that the rule is rationally related to legitimate state objectives and does not violate equal protection. The judgment was affirmed. View "Amended Birth Certificate Of Nielsen" on Justia Law

Two sisters died in a car accident on U.S. Highway 281 in Beadle County, South Dakota, when their vehicle drifted off the paved roadway onto a gravel shoulder that was five to six inches lower than the pavement. While attempting to steer back onto the road, the driver overcorrected, resulting in a collision with an oncoming vehicle. The mother, acting as the personal representative of her daughters’ estates, filed a wrongful death and survivor action against six South Dakota Department of Transportation (DOT) employees. She alleged these employees failed to maintain the gravel shoulder in accordance with DOT policies and federal standards, and that this negligence caused the accident.The case was first heard in the Circuit Court of the Third Judicial Circuit, Beadle County. The DOT employees sought summary judgment, arguing that sovereign immunity and the public duty doctrine barred the claims. The circuit court dismissed the official capacity claims based on sovereign immunity but denied summary judgment on the individual capacity claims under the same theory. However, it granted summary judgment on the individual capacity claims on the grounds that the public duty doctrine applied, finding that the alleged duties were owed to the public at large, not to any individual.On appeal, the Supreme Court of the State of South Dakota reviewed both the application of the public duty doctrine and the denial of sovereign immunity for the individual capacity claims. The court held that none of the statutes, policies, or standards cited by the plaintiffs imposed a ministerial duty on the defendants. The court concluded that the actions in question were discretionary and thus shielded by sovereign immunity. The Supreme Court affirmed the grant of summary judgment for the individual capacity claims, but on the basis of sovereign immunity, making it unnecessary to address the public duty doctrine. View "Estate Of Sanborn v. Peterson" on Justia Law

A participant in the federal Section 8 housing assistance program received notice from the local housing authority that her benefits would be terminated based on several alleged violations, including a recent eviction for serious lease violations, untimely submission of eligibility documentation, failure to allow an inspection, and failure to maintain her unit. The participant contested the termination, explaining that her appeal of the eviction was still pending and that she ultimately complied with inspection and paperwork requirements.At the administrative hearing, the hearing officer concluded that because a court-ordered eviction had occurred and, according to the officer, had been upheld on appeal, termination of assistance was mandatory under federal regulations. The participant then petitioned the Superior Court of Riverside County for a writ of administrative mandamus, arguing that the finding regarding her eviction was factually incorrect, as the appeal was still pending. Soon after, the appellate division of the Riverside County Superior Court reversed the eviction judgment for insufficient evidence. The trial court acknowledged that the hearing officer’s findings regarding the eviction were not supported by the record. However, it proceeded to independently review the evidence and found other violations of program obligations, upholding the housing authority’s discretionary decision to terminate benefits.The California Court of Appeal, Fourth Appellate District, Division Two, found that the trial court misunderstood the scope of judicial review under Code of Civil Procedure section 1094.5. The appellate court held that the trial court was required to review whether the administrative agency’s factual findings—not any alternative grounds—were supported by the record. Since the hearing officer’s findings were unsupported and the court could not uphold termination based on new grounds not adjudicated at the administrative hearing, the judgment was reversed with instructions to grant the petition and vacate the termination of assistance. View "Harrington v. Housing Authority of Riverside County" on Justia Law

For many years, the federal government and private entities engaged in activities at the Santa Susana Field Laboratory in Ventura County, resulting in significant environmental contamination. The Boeing Company, which owns much of the site, planned to demolish several buildings within a specific area known as Area IV. California’s Department of Toxic Substances Control (DTSC) is authorized to regulate chemical contamination cleanup at the site, and its actions are subject to environmental review under the California Environmental Quality Act (CEQA). In 2013, after Boeing notified DTSC of its demolition intent, the plaintiffs raised concerns about environmental impacts and filed a writ petition alleging DTSC failed to comply with CEQA.The Superior Court of Sacramento County denied the plaintiffs’ petition, finding that demolition activities were private actions not subject to CEQA’s discretionary approval requirements, and thus not subject to CEQA review. The California Court of Appeal, Third Appellate District, affirmed this decision, and the California Supreme Court declined review. During subsequent events, DTSC voluntarily included an environmental analysis of the building demolition in its final Environmental Impact Report (EIR), released after the litigation had concluded.The plaintiffs then sought attorney fees under California’s private attorney general statute (Code of Civil Procedure section 1021.5), arguing that their litigation was the catalyst for DTSC’s changed conduct. The superior court denied the fee request, finding the plaintiffs were not a “successful party” under the catalyst theory because their lawsuit had been resolved on the merits against them, and thus there was no “threat of victory” that motivated DTSC’s actions.On appeal, the California Court of Appeal, Third Appellate District, affirmed the denial. The court held that attorney fees under the catalyst theory are not warranted where the moving party lost on the merits, and there was no causal connection between the litigation and the agency’s subsequent voluntary actions. DTSC was awarded its costs on appeal. View "Physicians for Social Responsibility - Los Angeles v. Dept. of Toxic Substances Control" on Justia Law

While incarcerated in a Colorado state prison, the plaintiff, a practicing member of the Sac & Fox faith, brought suit seeking monetary and injunctive relief. He alleged that certain prison regulations and practices violated his rights under the First Amendment and the Religious Land Use and Institutionalized Persons Act. His claims focused on being denied possession of sacred items, spiritual cleansing of his cell, use of donated firewood for religious ceremonies, and access to faith grounds during and after the COVID-19 pandemic. The plaintiff named numerous officials and employees, including the Governor of Colorado, in both their official and individual capacities.The United States District Court for the District of Colorado denied the Governor’s motion to dismiss the official-capacity claims for injunctive relief, rejecting his assertion of Eleventh Amendment immunity. The Governor argued he lacked the required connection to the challenged regulations to qualify for the Ex Parte Young exception. During the appeal, the plaintiff was transferred to another facility within the Colorado Department of Corrections. The Governor raised the issue of mootness due to this transfer.The United States Court of Appeals for the Tenth Circuit considered whether the claims for injunctive relief against the Governor were moot because of the transfer and whether Eleventh Amendment immunity applied. The court held that the claims were neither constitutionally nor prudentially moot, as the plaintiff’s affidavit showed ongoing exposure to substantially similar conditions at the new facility. The court further held that, under Colorado law and the facts alleged, the Governor had sufficient authority and demonstrated involvement in the challenged practices to satisfy the Ex Parte Young exception. The court therefore affirmed the district court’s denial of Eleventh Amendment immunity and remanded for further proceedings. View "Eaves v. Polis" on Justia Law

Two companies that operate app-based delivery platforms challenged a Seattle ordinance enacted in 2023, which aims to protect gig economy workers from unwarranted account deactivations. The law requires “network companies” to provide workers with written deactivation policies and mandates that these policies be “reasonably related” to the companies’ safe and efficient operations. The ordinance also delineates examples of impermissible deactivation grounds, such as those based solely on customer ratings or certain background checks. The companies did not contest the general bar on unwarranted deactivations but argued that the notice and deactivation policy requirements violate the First Amendment and that the ordinance is unconstitutionally vague.In the United States District Court for the Western District of Washington, the companies sought a preliminary injunction to prevent the ordinance from taking effect. The district court denied their motion. It found that the ordinance regulates conduct (the act of deactivating accounts) rather than speech, and that any impact on expression is incidental. The court also concluded that the use of “reasonable” in the ordinance was not unconstitutionally vague, pointing to statutory context and specific examples for guidance.On appeal, the United States Court of Appeals for the Ninth Circuit affirmed the district court’s denial of injunctive relief. The court held that the ordinance regulates nonexpressive conduct, not speech, and thus does not trigger First Amendment scrutiny. Alternatively, if the ordinance were seen as regulating speech, that speech would be commercial in nature, and the law would satisfy the lower level of scrutiny applicable to compelled factual commercial disclosures. The court further held that the ordinance is not unconstitutionally vague, as it provides adequate notice of what is prohibited. The disposition by the Ninth Circuit was to affirm the district court’s denial of injunctive relief. View "MAPLEBEAR INC. V. CITY OF SEATTLE" on Justia Law

The case concerns injuries suffered by two individuals, one in New York and one in Pennsylvania, each struck by buses operated by New Jersey Transit Corporation (NJ Transit), a public transportation entity created by the New Jersey Legislature. NJ Transit operates as a “body corporate and politic” with significant powers such as suing and being sued, entering contracts, and raising funds. Its founding statute specifies that debts or liabilities of NJ Transit are not debts of the State of New Jersey, and all expenses must be paid from NJ Transit’s own funds. The State retains substantial control over NJ Transit through board appointments and removal powers, veto authority, and some legislative oversight, but the statute also stresses NJ Transit’s operational independence.After the incidents, the injured parties filed negligence lawsuits against NJ Transit in their home state courts. NJ Transit moved to dismiss both suits, arguing it was an arm of New Jersey and thus entitled to sovereign immunity. The Court of Appeals of New York concluded that NJ Transit is not an arm of New Jersey, allowing the New York suit to proceed. Conversely, the Supreme Court of Pennsylvania found that NJ Transit is an arm of New Jersey and dismissed the Pennsylvania suit.The Supreme Court of the United States reviewed both cases to resolve the conflict. It held that NJ Transit is not an arm of the State of New Jersey and therefore does not share in New Jersey’s interstate sovereign immunity. The Court emphasized that NJ Transit’s status as a legally separate corporation, responsible for its own debts and judgments, and the absence of formal state liability for its obligations, are decisive. The Court affirmed the New York decision, reversed the Pennsylvania decision, and remanded both cases for further proceedings. View "Galette v. New Jersey Transit Corp." on Justia Law