Justia Government & Administrative Law Opinion Summaries

The case involves a dispute between a taxpayers' association and a water district over the imposition of groundwater replenishment charges. The taxpayers' association alleged that the water district's charges violated constitutional provisions and unfairly benefited large agricultural businesses. The association sought a writ of mandate to stop the collection of these charges and to vacate the resolutions imposing them. They also claimed conversion, civil conspiracy, aiding and abetting, and violations of the Unfair Competition Law (UCL) against the water district's board members, general manager, and consulting firms.The Superior Court of Riverside County denied the defendants' anti-SLAPP motion, which sought to strike several causes of action on the grounds that they arose from protected activities. The court found that the public interest exemption to the anti-SLAPP statute applied. Additionally, the court sustained the defendants' demurrer to the first amended petition and complaint, finding the claims time-barred under the validation statutes. The court also awarded over $180,000 in attorney's fees to the plaintiffs, deeming the anti-SLAPP motion frivolous.The California Court of Appeal, Fourth Appellate District, Division Two, reviewed the case. The court held that the public interest exemption did not apply because the relief sought could only be provided by the water district, not the individual defendants. The court found that the anti-SLAPP motion should have been granted for most causes of action, except for conversion and the writ of mandate against the general manager. Consequently, the fee award was reversed. The court also affirmed the demurrer ruling, as the claims against the individual defendants were not legally sufficient. The case was remanded for further proceedings consistent with these findings. View "Howard Jarvis Taxpayers Assn. v. Powell" on Justia Law

In 2020, Utah law temporarily allowed municipalities to annex unincorporated areas without a petition or county consent. During this period, the Town of Hideout annexed land in Summit County. After receiving a certificate of annexation from the Lieutenant Governor, Summit County challenged the annexation and the related municipal ordinance in district court, claiming procedural violations and seeking to invalidate the annexation.The Fourth Judicial District Court in Wasatch County ruled in favor of Summit County, granting summary judgment on the grounds that Summit County had standing to challenge the annexation and that the annexation ordinance was invalid due to procedural issues. The court found that Summit County had standing under various statutes and the doctrine of public interest standing.The Utah Supreme Court reviewed the case and reversed the district court's decision. The Supreme Court held that Summit County lacked a legally protectible interest under the relevant statutory scheme, which did not provide counties with a right to challenge annexations. The court also determined that the public interest standing doctrine could not compensate for this lack of a legally protectible interest because the legislature had explicitly excluded counties from the annexation process. Consequently, the Supreme Court directed the district court to dismiss the case. View "Hideout v. Summit County" on Justia Law

The case involves a dispute between two federally recognized Indian tribes, the Muscogee (Creek) Nation and the Poarch Band of Creek Indians, over the excavation and development of a burial site known as Hickory Ground in Wetumpka, Alabama. The Muscogee Nation claims that the site is sacred and historically significant, containing graves and ceremonial grounds. The Poarch Band, which purchased the site in 1980 and later had it held in trust by the United States, excavated the site with Auburn University and announced plans to develop a hotel and casino on it. The Muscogee Nation sued to stop the development and restore the site.The United States District Court for the Middle District of Alabama dismissed the Muscogee Nation's complaint, ruling that the Poarch Band and its officials enjoyed sovereign immunity. The court also found that the Poarch officials were immune under an exception to Ex parte Young for claims that are the functional equivalent of a quiet title action and implicate special sovereignty interests. The district court did not analyze the claims individually but dismissed them collectively, leading to the current appeal.The United States Court of Appeals for the Eleventh Circuit reviewed the case and found that the district court erred by not analyzing the Poarch officials' sovereign immunity on a claim-by-claim basis. The appellate court emphasized that each claim must be considered separately to determine whether it is the functional equivalent of a quiet title action and whether it implicates special sovereignty interests. The Eleventh Circuit vacated the district court's order and remanded the case for further proceedings, instructing the lower court to allow the Muscogee Nation to amend its complaint and to analyze the claims individually. The appellate court also rejected the argument that the Supreme Court had abrogated the Coeur d’Alene exception to Ex parte Young, affirming that it remains a narrow but valid exception. View "Muscogee (Creek) Nation v. Rollin" on Justia Law

K.M., an adult with multiple disabilities, including autism and a seizure disorder, has been receiving Medicaid-funded developmental disabilities services for over twenty years. These services, provided by Washington County Mental Health Services (WCMHS), were supposed to include more than thirty hours of community support each week. However, since March 2020, K.M. has only received two to five hours of support weekly, leading to negative health effects.K.M. petitioned the Human Services Board to order the Department of Disabilities, Aging, and Independent Living (DAIL) to provide the full services he is entitled to. The Board dismissed his petition, stating it failed to specify the action required for compliance and that an order to provide services without available staff was too vague. The Board also interpreted K.M.'s request as seeking a broader policy change, which it deemed outside its authority, citing Husrefovich v. Department of Aging & Independent Living.The Vermont Supreme Court reviewed the case and reversed the Board's dismissal. The Court held that the Board has the statutory authority to order DAIL to provide the services K.M. is entitled to under federal and state law. The Court clarified that while the Board cannot issue broad policy injunctions, it can provide specific relief to individuals. The Court found K.M.'s request for services clear and specific enough to inform DAIL of the required action. The case was remanded to the Board for further proceedings consistent with this opinion. View "In re Appeal of K.M." on Justia Law

A county auditor filed an administrative complaint against the Secretary of State, alleging that the statewide voter registration file, known as I-Voters, lacked adequate security measures and safeguards to prevent unauthorized access and erroneous removal of eligible voters, thus violating the Help America Vote Act (HAVA). The Secretary of State moved to dismiss the complaint, arguing that it was speculative and that the file complied with federal standards. The administrative body agreed and dismissed the complaint.The county auditor then sought judicial review in the Iowa District Court for Polk County, arguing that the administrative body had erred in dismissing his complaint without an evidentiary hearing. The Secretary of State contended that the county auditor lacked standing and that the complaint was insufficient. The district court dismissed the petition, concluding that the county auditor had not demonstrated an injury in fact.The Iowa Supreme Court reviewed the case and concluded that the county auditor had standing due to his role as the county commissioner of elections, which gave him a specific, personal, and legal interest in the integrity of the voter registration file. The court also found that the administrative body had improperly resolved factual questions without allowing an opportunity for the presentation of evidence. The court held that the county auditor's allegations were sufficient to survive a motion to dismiss and that the administrative body should not have decided factual issues at the motion to dismiss stage.The Iowa Supreme Court reversed the district court's order and remanded the case for further proceedings consistent with its opinion. View "Linn County Auditor v. Iowa Voter Registration Commission" on Justia Law

Adam Richardson, a citizen and taxpayer, petitioned the Supreme Court of Florida for writs of quo warranto and mandamus, alleging that the Governor, Attorney General, and Secretary of the Florida Agency for Health Care Administration (AHCA) violated section 104.31, Florida Statutes, by advocating against a proposed constitutional amendment (Amendment 4) related to abortion rights. Richardson claimed that their actions, including statements on an AHCA webpage and social media, as well as participation in a public call and opinion piece, unlawfully interfered with the vote on Amendment 4.The lower courts did not review this case as it was directly brought to the Supreme Court of Florida. Richardson argued that the respondents' actions violated a statute limiting political activities of state officers and employees, which he believed should be enforced through extraordinary writs.The Supreme Court of Florida denied the petition. The court held that the writ of quo warranto is traditionally used to test the right of a person to hold an office or exercise a state-derived power, not to compel criminal prosecution or enable private enforcement of a criminal statute. The court found that Richardson's grievances were more about the merits of the respondents' actions rather than their authority to act. Additionally, the court denied the writ of mandamus, stating that Richardson did not establish a clear legal right or an indisputable legal duty on the part of the respondents, nor did he show that there was no other adequate remedy available. The court concluded that no further relief was required to complete the exercise of its jurisdiction and denied the petition without permitting a rehearing. View "Richardson v. Secretary, Florida Agency for Health Care Administration" on Justia Law

The case involves a challenge to Montana House Bill 702 (HB 702), which prohibits discrimination based on vaccination status. Plaintiffs, including health care providers and individuals with compromised immune systems, argued that HB 702 is preempted by the Americans with Disabilities Act (ADA) and the Occupational Health and Safety Act (OSH Act) and violates the Equal Protection Clause of the Fourteenth Amendment. They sought to invalidate HB 702 in all health care settings, claiming it prevents employers from knowing employees' vaccination status, thus hindering ADA-required accommodations and OSH Act compliance.The United States District Court for the District of Montana ruled in favor of the plaintiffs, holding that HB 702 is preempted by the ADA and the OSH Act and violates the Equal Protection Clause. The court issued a permanent injunction against the enforcement of HB 702 in health care settings, reasoning that the law conflicts with federal requirements for reasonable accommodations and workplace safety.The United States Court of Appeals for the Ninth Circuit reversed the district court's decision and vacated the injunction. The Ninth Circuit held that neither the ADA nor the OSH Act facially preempts HB 702 in health care settings. The court found that the plaintiffs did not demonstrate a genuine conflict between HB 702 and the ADA or OSH Act in any specific case, much less in all health care settings. The court also held that HB 702 does not violate the Equal Protection Clause, as the classification and differential treatment of facilities could rationally reflect Montana's interest in balancing personal privacy and public health.The Ninth Circuit reserved judgment on whether the ADA and the OSH Act could preempt HB 702 on a narrower, as-applied basis in future cases. The court deemed moot the portion of the district court's order related to interim CMS regulations, as those regulations have been rescinded. The court concluded that HB 702 is not facially invalid under the ADA, OSH Act, or Equal Protection Clause and vacated the district court's injunction in full. View "MONTANA MEDICAL ASSOCIATION V. KNUDSEN" on Justia Law

The State of Wyoming owns a 3.37-acre parcel in Uinta County, leased to Pilot Corporation for operating a truck stop. The property, held for the benefit of the Wyoming State Hospital, generates revenue for the hospital through the lease. In 2022, the Uinta County Assessor assessed the property for taxation, which the State contested, claiming the property was used primarily for a governmental purpose and thus exempt from taxation.The County Board of Equalization initially ruled in favor of the State, stating the property was used for a governmental purpose because the Board of Land Commissioners had a fiduciary duty to generate revenue for the hospital. However, the State Board of Equalization reversed this decision, holding that the Department of Revenue’s rules, which state that governmental property used by a lessee for non-governmental purposes is not tax-exempt, were binding. The district court affirmed the State Board’s decision, agreeing that the lessee’s use of the property for a truck stop did not constitute a governmental purpose.The Wyoming Supreme Court reviewed the case and affirmed the district court’s ruling. The Court held that the property was not exempt from taxation because it was used by the lessee, Pilot Corporation, for a non-governmental purpose. The Court emphasized that the end use of the property by the lessee determines its tax status, not the purpose of the lease. Additionally, the Court found that the legislature had not provided an exemption for such properties, as required by the Wyoming Constitution. Therefore, the property was subject to taxation. View "State of Wyoming v. Uinta County Assessor" on Justia Law

A group called Moms for Liberty, along with several individual members, filed a lawsuit against Brevard Public Schools and members of the Brevard County School Board. The plaintiffs claimed that their speech was unconstitutionally restricted at school board meetings. They argued that the Board's policies prohibiting "abusive," "personally directed," and "obscene" speech were unconstitutional. The plaintiffs sought declaratory and injunctive relief, as well as nominal damages.The United States District Court for the Middle District of Florida granted summary judgment in favor of the Board. The district court concluded that the plaintiffs lacked standing because they could not show an actual or imminent injury. It also held that the Board's policies did not objectively chill the plaintiffs' protected speech. Despite finding no standing, the district court went on to rule that the Board's policies were constitutional.The United States Court of Appeals for the Eleventh Circuit reviewed the case and reversed the district court's decision. The Eleventh Circuit found that the plaintiffs had standing to seek both retrospective and prospective relief. The court held that the Board's policy on "abusive" speech was unconstitutional because it was viewpoint-based and prohibited offensive speech. The policy on "personally directed" speech was also found to be unreasonable and inconsistently enforced, making it unconstitutional. Lastly, the court ruled that the prohibition on "obscene" speech was unreasonably applied to restrict protected speech, particularly when it involved reading from books available in school libraries. The case was remanded for further proceedings consistent with the Eleventh Circuit's opinion. View "Moms for Liberty v. Brevard Public Schools" on Justia Law

In 2018, Campaign Legal Center (CLC) filed an administrative complaint with the Federal Election Commission (FEC) alleging that 45Committee, Inc. violated the Federal Election Campaign Act by not registering as a political committee. After nearly two years of inaction by the FEC, CLC sued the FEC, seeking a declaration that the FEC's failure to act was "contrary to law." The court agreed and ordered the FEC to act within thirty days. When the FEC did not appear to act within that period, the court allowed CLC to bring a citizen suit against 45Committee.The United States District Court for the District of Columbia initially found that the FEC had failed to act on CLC's complaint and issued a default judgment against the FEC. The court ordered the FEC to act within thirty days, but the FEC did not notify the court or CLC of any action taken. Consequently, the court allowed CLC to bring a citizen suit against 45Committee. However, it later emerged that the FEC had held a reason-to-believe vote within the thirty-day period, which failed to garner the necessary votes to proceed with an investigation or dismiss the complaint.The United States Court of Appeals for the District of Columbia Circuit reviewed the case and concluded that the district court was correct in dismissing CLC's citizen suit. The appellate court held that the FEC's holding of a reason-to-believe vote within the thirty-day period constituted conformance with the contrary-to-law determination. Therefore, the preconditions for bringing a citizen suit were not met, as the FEC had taken the required action by holding the vote, even though the vote did not result in a decision to investigate or dismiss the complaint. The court affirmed the district court's dismissal of the citizen suit. View "Campaign Legal Center v. 45Committee, Inc." on Justia Law