Justia Government & Administrative Law Opinion Summaries

Several individuals who reside in DeKalb County, Georgia, outside the city limits of Atlanta, opposed the construction of a new public safety training facility on city-owned land and wished to collect signatures for a referendum petition to repeal the city ordinance authorizing the lease for the facility. Atlanta’s municipal code required that signature gatherers for such petitions be residents of the City of Atlanta. Because they did not meet this residency requirement, the plaintiffs filed suit against the City, arguing that the restriction violated their First Amendment rights. They sought a preliminary injunction to prevent enforcement of the residency requirement, as well as other relief connected to the signature collection process.The United States District Court for the Northern District of Georgia granted the preliminary injunction, enjoining Atlanta from enforcing the residency requirement for signature gatherers. The court also ordered the City to issue new petitions without the residency restriction and restarted the 60-day signature collection period, while counting previously collected signatures. The City appealed the injunction and obtained a stay from the United States Court of Appeals for the Eleventh Circuit.On appeal, the United States Court of Appeals for the Eleventh Circuit held that the plaintiffs failed to demonstrate irreparable harm sufficient for injunctive relief. The court specified that, under Kemp v. City of Claxton, 496 S.E.2d 712 (Ga. 1998), Georgia law does not allow the use of a referendum petition to challenge or repeal a city ordinance unless it amends the city charter. Because the plaintiffs could not lawfully utilize the referendum process for their intended purpose, they lacked a right to the process and consequently could not show irreparable injury. The Eleventh Circuit vacated the preliminary injunction and remanded the case to the district court for further proceedings. View "Baker v. City of Atlanta" on Justia Law

Charles Cui was charged with bribery and related offenses after he attempted to secure the assistance of Edward Burke, a powerful Chicago alderman, in reversing a permit denial by the Chicago Department of Buildings (CDOB) regarding a pole sign at his commercial property. Cui’s financial interests were jeopardized by the permit denial, which threatened both a lucrative lease with Binny’s Beverage Depot and tax increment financing from the City. To influence Burke, Cui offered to retain Burke’s law firm for property tax appeal work, explicitly seeking Burke’s intervention in the CDOB matter.The United States District Court for the Northern District of Illinois, Eastern Division, presided over a six-week trial in which a jury convicted Cui on all counts: bribery under 18 U.S.C. § 666(a)(2), violations of the Travel Act, and making false statements to the government. The district court admitted evidence over Cui’s objections, including a photoshopped photograph sent to the CDOB, and denied Cui’s post-trial motions for acquittal and a new trial. The court sentenced Cui to 32 months’ imprisonment and applied an obstruction-of-justice enhancement for failing to produce key emails in response to a grand jury subpoena.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed Cui’s challenges to the sufficiency of evidence, jury instructions, evidentiary rulings under Federal Rule of Evidence 404(b), and sentencing. The court held that sufficient evidence supported the convictions, that the jury instructions correctly conveyed the law’s requirements—including the quid pro quo element and the definition of “corruptly”—and that the admission of the photoshopped photograph was not an abuse of discretion. The court also found that the sentencing enhancement and the disparity between Cui’s and Burke’s sentences were justified. The Seventh Circuit affirmed the judgment of the district court. View "USA v Cui" on Justia Law

A corrections officer at the Anamosa State Penitentiary was killed during a prison escape attempt in March 2021, along with a nurse, when two inmates armed themselves with tools from the prison’s machine shop and attacked staff in the infirmary. The inmates were apprehended and convicted of first-degree murder. The officer’s surviving spouse filed compensation claims with the state appeal board against co-employees of the Iowa Department of Corrections, alleging gross negligence contributed to the security lapses that enabled the attack. The claims identified several co-employees by name as potential parties at fault.After the claims were withdrawn due to lack of resolution, the surviving spouse filed suit in the Iowa District Court for Jones County against twenty-six co-employees, including some not previously named in the administrative process. The defendants moved to dismiss, arguing that Iowa’s workers’ compensation law precluded gross negligence claims against state or local government co-employees, that the spouse failed to comply with administrative requirements under the Iowa Tort Claims Act (ITCA), and that the pleading was insufficient under qualified immunity standards. The district court denied the motion on all grounds.The Iowa Supreme Court reviewed the case after treating the appeal as an interlocutory application. The court held that Iowa Code section 85.2 does not bar gross negligence claims against state co-employees; such claims are permissible under section 85.20(2). The court also found that, while the administrative claims process under the ITCA was satisfied as to those co-employees named in the initial claims, it was not satisfied for those not identified. Therefore, the motion to dismiss was properly denied for co-employees named in the administrative claims and should have been granted for those who were not. The denial was affirmed in part, reversed in part, and the case remanded. View "Montague v. Skinner" on Justia Law

Indiana amended its laws in 2022 to prohibit and criminalize the use of telehealth and telemedicine for abortions, requiring that abortion-inducing drugs be dispensed and consumed in person by a physician in a hospital or qualified surgical center. The Satanic Temple, a Massachusetts-based religious nonprofit, operates a telehealth abortion clinic serving only patients in New Mexico but seeks to extend these services to its Indiana members. It does not run, nor intends to operate, an in-person abortion clinic in Indiana or maintain ties to Indiana hospitals or surgical centers. The Temple filed suit against the Indiana Attorney General and Marion County Prosecutor, seeking to enjoin enforcement of the criminal statute (§ 16-34-2-7(a)) and to obtain declaratory relief under Indiana’s Religious Freedom Restoration Act.The United States District Court for the Southern District of Indiana reviewed the case and granted the defendants’ motion to dismiss for lack of standing. The court found that the Satanic Temple failed to identify any specific member who suffered an injury from the challenged law, thus lacking associational standing. It also held that the Temple itself lacked standing, as it could not show an injury in fact and could not demonstrate that favorable relief would redress its alleged harms due to other Indiana laws independently barring its intended conduct.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s dismissal. The Seventh Circuit held that the Satanic Temple lacked both associational and individual standing. The Temple failed to identify a specific injured member and relied only on statistical probabilities and generalized claims of stigmatic injury, which were insufficient. Additionally, the Temple did not present concrete plans to violate the law, and even if § 16-34-2-7(a) were enjoined, other statutes would independently prevent its telehealth abortion services in Indiana. Thus, the Seventh Circuit affirmed the dismissal for lack of subject matter jurisdiction. View "Satanic Temple, Inc. v Rokita" on Justia Law

For many years, one company exclusively provided emergency medical services (EMS) in a California county. Seeking improvements, the county initiated a competitive bidding process, issuing a request for proposals (RFP) and identifying policy goals such as improved service, efficiency, and reinvestment. Two entities submitted proposals. After evaluation by a review committee, one received the highest cumulative score, while the other received higher scores from most individual evaluators. The county determined the scores were substantially equivalent and proceeded to negotiate with both parties, ultimately awarding the contract to the bidder that did not have the highest cumulative score.The company that lost the contract protested the decision, arguing the county was required to negotiate only with the highest-scoring proposer, as set forth in the RFP. After an unsuccessful protest, the losing bidder first sued in federal court, where its federal antitrust claims were dismissed under the Parker immunity doctrine, and the district court declined to address state law claims. The company then filed a new action in San Bernardino County Superior Court, seeking a writ of mandate and a preliminary injunction. The superior court found the county’s selection process was ministerial and that the RFP required negotiations only with the highest-scoring proposer. The court granted a preliminary injunction, halting the contract’s implementation.The California Court of Appeal, Fourth Appellate District, Division One, reviewed the case. It held that neither the governing statute (the EMS Act) nor the RFP imposed a ministerial duty on the county to negotiate exclusively with the highest-scoring proposer. The court further concluded the county acted within its discretionary authority and did not abuse its discretion by considering both proposals. The appellate court reversed the preliminary injunction and remanded the case to the superior court, directing it to deny the motion for a preliminary injunction and reconsider the bond amount. View "American Medical Response of Inland Empire v. County of San Bernardino" on Justia Law

In early 2025, the National Institutes of Health (NIH), an agency within the Department of Health and Human Services (HHS), issued a Supplemental Guidance that implemented a uniform 15% cap on indirect cost reimbursement for all NIH-funded research grants, effective almost immediately. Indirect costs, which include necessary administrative and facility expenses not attributable to a single research project, had previously been negotiated individually with grant recipients according to established regulations and memorialized in negotiated indirect cost rate agreements (NICRAs). The new policy would substantially reduce the reimbursement many recipients, such as universities and hospitals, could receive under existing and future grants.Shortly after the guidance was issued, a coalition of states, medical associations, and higher education organizations challenged the NIH’s action in the United States District Court for the District of Massachusetts. The district court first granted temporary restraining orders to prevent implementation of the guidance, then issued a nationwide preliminary injunction. After further proceedings, the district court converted this into a permanent injunction and vacated the Supplemental Guidance, concluding that the NIH’s action likely violated a congressional appropriations rider and HHS regulations, and finding the action arbitrary, capricious, and procedurally improper.On appeal, the United States Court of Appeals for the First Circuit affirmed the district court’s decision. The court held that the district court had jurisdiction because the plaintiffs challenged an agency-wide policy rather than seeking contract damages, which would fall under the exclusive jurisdiction of the Court of Federal Claims. The appellate court further held that the NIH’s Supplemental Guidance violated the statutory appropriations rider and HHS regulations governing indirect cost reimbursement, including the requirements for deviations from negotiated rates. The First Circuit affirmed the permanent injunction and vacatur of the Supplemental Guidance. View "Commonwealth of Massachusetts v. National Institutes of Health" on Justia Law

Several trusts and entities purchased properties in Nevada that were subject to deeds of trust held by Fannie Mae or Freddie Mac. After unsuccessful attempts in state court to extinguish the deeds of trust and quiet title, each property remained encumbered. Between 2022 and 2024, foreclosure proceedings were initiated on these properties, with Fannie Mae and Freddie Mac acting through their conservator, the Federal Housing Finance Agency (FHFA). In response, the plaintiffs brought suit against the FHFA and its Director, seeking to prevent foreclosure and challenging the constitutionality of the FHFA’s funding mechanism under the Appropriations Clause and the nondelegation doctrine.The United States District Court for the District of Nevada reviewed the case. The district court denied the plaintiffs’ motions for preliminary relief, then dismissed their amended complaint with prejudice, finding that the FHFA’s funding structure was constitutional. The court determined that the Recovery Act, which created the FHFA and provides for its funding via regulatory assessments rather than Congressional appropriations, met constitutional standards by specifying both a source and purpose for the funds. The court also found that the Recovery Act’s limitation to “reasonable costs” provided an intelligible principle, satisfying the nondelegation doctrine. Leave to amend was denied as futile.The United States Court of Appeals for the Ninth Circuit affirmed the district court’s judgment. The appellate court held that the plaintiffs had Article III standing, but rejected their arguments on the merits. It concluded that the FHFA’s funding mechanism, as established by the Recovery Act, does not violate the Appropriations Clause because it identifies a source and purpose for expenditures, consistent with the Supreme Court’s decision in Consumer Financial Protection Bureau v. Community Financial Services Association of America, Limited. It further held the mechanism does not violate the nondelegation doctrine, as the statute provides an intelligible principle. The judgment of dismissal was affirmed. View "DAISEY TRUST v. FEDERAL HOUSING FINANCE AGENCY" on Justia Law

A vacancy was created on the Orono City Council in November 2024 when a councilmember resigned with more than two years remaining in his term. At the time, the City of Orono did not have a special-election ordinance. The mayor appointed a replacement to fill the seat. Subsequently, in February 2025, the city council enacted a special-election ordinance and adopted a resolution to hold a special election to fill the remainder of the term.Dennis Walsh, who had appointed the replacement, petitioned the Hennepin County District Court under Minnesota Statutes section 204B.44 to quash the special election. He argued the relevant statute required the appointed councilmember to serve the remainder of the term because no special-election ordinance was in place at the time of the vacancy, and that holding a special election would improperly remove the appointee in violation of the Minnesota Constitution. The City of Orono and its city clerk opposed the petition, asserting statutory authority for their actions.The Hennepin County District Court denied Walsh’s petition, finding that the city was authorized to hold a special election and that passage of the ordinance after the vacancy did not violate the statute or constitution. Walsh sought accelerated review.The Minnesota Supreme Court affirmed the district court’s decision. It held that claims challenging the special election were properly raised under section 204B.44. Substantively, the court determined Minnesota Statutes section 412.02, subdivision 2a, permits a statutory city to enact and apply a special-election ordinance after a vacancy is filled by appointment, so long as more than two years remain in the term. Further, holding a special election in these circumstances does not constitute an unconstitutional removal of an inferior officer under article VIII, section 5, of the Minnesota Constitution. View "Walsh vs. City of Orono" on Justia Law

After the Texas Legislature passed the Election Protection and Integrity Act of 2021 (“S.B.1”), a sweeping law that amended numerous aspects of the state’s election procedures, multiple groups of plaintiffs—including civil rights and voter advocacy organizations—challenged thirty-eight provisions of the law. They alleged violations of various constitutional amendments, the Voting Rights Act (VRA), the Americans with Disabilities Act (ADA), and the Rehabilitation Act, naming state officials including the Texas Secretary of State and Attorney General as defendants.In the United States District Court for the Western District of Texas, the defendants moved to dismiss on grounds of sovereign immunity and lack of standing. The district court addressed the motions on a provision-by-provision basis, concluding that the Secretary and Attorney General were sufficiently connected to the enforcement of most challenged provisions to overcome sovereign immunity under Ex parte Young, and that plaintiffs had standing to sue. It denied the motions to dismiss for the majority of the claims, although it dismissed others as moot, for lack of standing, or for failure to state a claim. The defendants appealed the denials.The United States Court of Appeals for the Fifth Circuit held it had appellate jurisdiction over the interlocutory sovereign immunity appeals. On the merits, the Fifth Circuit affirmed in part and reversed in part. It held that the VRA claims were not barred by sovereign immunity. For the constitutional and other statutory claims brought under 42 U.S.C. § 1983, the court determined that the Secretary of State is a proper defendant only for those provisions she directly enforces—such as those involving the design of forms and sanctioning of registrars—and not for those enforced by other officials. Similarly, it held the Attorney General could be sued only for one provision authorizing civil penalties. The court affirmed standing for claims against provisions enforced by these officials. View "Un del Pueblo Entero v. Nelson" on Justia Law

A group of cities holding junior ground water rights in the Eastern Snake Plain Aquifer sought judicial review of a final order issued by the Director of the Idaho Department of Water Resources. This order updated the methodology used to assess whether pumping by junior ground water users caused material injury to senior surface water rights holders who divert water from the Snake River. The Director’s Fifth Amended Final Order revised technical aspects of the model and data, and after a hearing on objections by the cities, the Director affirmed the methodology with modifications and issued a Sixth Methodology Order, which expressly superseded all prior methodology orders.The cities filed a petition for judicial review in the Snake River Basin Adjudication district court, challenging the Director’s Post-Hearing Order regarding the Fifth Methodology Order. The district court affirmed the Director’s findings and conclusions, upholding the methodology and the application of the clear and convincing evidence standard, and found that the Director did not prejudice the cities’ substantial rights. The district court’s judgment specifically affirmed the Post-Hearing Order but did not address the operative Sixth Methodology Order.On appeal, the Supreme Court of the State of Idaho reviewed whether the cities had properly invoked its jurisdiction. The Court held that the cities failed to challenge the currently operative Sixth Methodology Order in district court, and therefore, under Idaho law, the Court lacked jurisdiction to consider the appeal or award the requested relief. As a result, the appeal was dismissed for lack of jurisdiction. The Court awarded attorney fees and costs to the Idaho Department of Water Resources but denied attorney fees to the intervening Surface Water Coalition, granting them costs only. View "City of Idaho Falls v. IDWR" on Justia Law