Justia Government & Administrative Law Opinion Summaries

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The case involves Earl Johnson, a former inmate of the Maryland Correctional Training Center, who alleged that corrections officer Chad Zimmerman sexually harassed and abused him during strip searches, in violation of his Fourth and Eighth Amendment rights. Johnson also sued Zimmerman’s supervisor, Lt. Richard Robinette, alleging supervisory and bystander liability. The district court dismissed Johnson’s claims against Robinette due to failure to exhaust administrative remedies but held that Johnson’s claims against Zimmerman were exempt from this requirement. The court also granted summary judgment to Zimmerman and Robinette on the merits of Johnson’s claims.The United States Court of Appeals for the Fourth Circuit held that the district court erred in concluding that Johnson’s claims against Robinette were subject to exhaustion requirements. However, the court affirmed the district court’s decision to grant summary judgment to both defendants. The court found that the strip searches, including those involving momentary touchings of Johnson’s genitalia or buttocks, did not rise to the level of an unreasonable search under the Fourth Amendment. The court also found that Johnson failed to present sufficient evidence to prove that Zimmerman had the requisite malicious intent to sexually abuse him, sexually arouse him or himself, or otherwise gratify sexual desire. Furthermore, the court found that Johnson’s evidence fell short of establishing supervisory or bystander liability against Robinette. View "Johnson v. Robinette" on Justia Law

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A group of twenty states sued the U.S. Department of Education and other federal entities, challenging the Department's interpretation of Title IX to prohibit discrimination based on sexual orientation and gender identity in education programs receiving federal financial assistance. The states argued that the Department's interpretation, issued without undergoing the notice-and-comment process required for legislative rules under the Administrative Procedure Act (APA), was procedurally and substantively unlawful.The U.S. District Court for the Eastern District of Tennessee granted the states a preliminary injunction, halting the enforcement of the Department's interpretation. The Department appealed, arguing that the states lacked standing, the interpretation was unreviewable, and the district court abused its discretion in issuing the injunction.The U.S. Court of Appeals for the Sixth Circuit affirmed the district court's decision. The court found that the states had standing to sue, the Department's interpretation was reviewable, and the states were likely to succeed on their claim that the interpretation was a legislative rule that should have undergone the notice-and-comment process. The court also found that the states would likely suffer irreparable harm without the injunction, the balance of equities tipped in their favor, and the public interest favored the injunction. View "Tennessee v. Department of Education" on Justia Law

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The case revolves around the legality of bump stocks, accessories that allow semi-automatic rifles to fire at a rate similar to machine guns. The Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) had long held that semi-automatic rifles equipped with bump stocks were not machine guns under the statute. However, following a mass shooting in Las Vegas, Nevada, where the shooter used bump stocks, the ATF reversed its position and issued a rule classifying bump stocks as machine guns.The case was first heard in the District Court, where Michael Cargill, who had surrendered two bump stocks to the ATF under protest, challenged the rule. Cargill argued that the ATF lacked statutory authority to classify bump stocks as machine guns because they did not meet the definition of a machine gun under §5845(b). The District Court ruled in favor of the ATF, concluding that a bump stock fits the statutory definition of a machine gun.The case was then taken to the Court of Appeals, which initially affirmed the District Court's decision but later reversed it after rehearing en banc. The majority of the Court of Appeals agreed that §5845(b) was ambiguous as to whether a semi-automatic rifle equipped with a bump stock fits the statutory definition of a machine gun. They concluded that the rule of lenity required resolving that ambiguity in Cargill's favor.The Supreme Court of the United States affirmed the decision of the Court of Appeals. The Court held that a semi-automatic rifle equipped with a bump stock is not a machine gun because it cannot fire more than one shot by a single function of the trigger. Furthermore, even if it could, it would not do so automatically. Therefore, the ATF exceeded its statutory authority by issuing a rule that classifies bump stocks as machine guns. View "Garland v. Cargill" on Justia Law

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The case revolves around Stephen Wynn, a casino owner and real estate developer, who was accused by the Department of Justice (DOJ) of acting as an unregistered foreign agent for the People's Republic of China in 2017. The DOJ alleged that Wynn lobbied then-President Trump and his administration on behalf of China to cancel a certain Chinese businessperson's visa or to otherwise remove that person from the United States. Wynn's lobbying efforts ceased in October 2017, and he never registered under the Foreign Agents Registration Act (FARA).The DOJ sued Wynn in 2022, seeking to compel him to register as a foreign agent under FARA. The United States District Court for the District of Columbia dismissed the complaint for failure to state a claim, holding that since Wynn's alleged agency relationship with the Chinese government ended in October 2017, FARA no longer required him to register.The DOJ appealed the decision to the United States Court of Appeals for the District of Columbia Circuit. The appellate court affirmed the district court's decision, holding that under the precedent set by United States v. McGoff, Wynn's obligation to register under FARA expired when he ceased acting as a foreign agent. The court rejected the DOJ's argument that the civil enforcement provision of FARA allowed for an injunction to compel compliance for past violations, stating that the provision only applies to ongoing or imminent violations. Therefore, the court concluded that there was no legal basis for the government to compel Wynn to register now. View "Attorney General v. Wynn" on Justia Law

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In this case, the defendant, Gerald Smith, was convicted of murder, kidnapping, and drug trafficking charges three decades ago. He was sentenced to multiple life sentences under the then-mandatory sentencing guidelines. In 2018, Congress passed the First Step Act, which allows courts to resentence defendants convicted for certain drug crimes that carry lighter sentences today than at the time of sentencing. In 2019, the Supreme Court held unconstitutionally vague one aspect of the “crime-of-violence” definition set forth in 18 U.S.C. § 924(c)(3). Smith sought vacatur of his crime-of-violence convictions and for First Step Act resentencing for other convictions. The district court denied both forms of relief.The United States Court of Appeals for the District of Columbia Circuit affirmed the district court's decision. The court found that Smith's convictions for Continuing Criminal Enterprise (CCE) murder involved the intentional use of force against others, qualifying them as crimes of violence under Section 924(c)’s elements clause. The court also affirmed the district court's denial of resentencing under the First Step Act, as Smith was not eligible for resentencing on most counts, and the district court reasonably explained its denial of resentencing on the eligible counts. The court remanded to the district court for the limited purpose of entering a revised judgment and conviction order that reflects this court’s prior vacatur of Smith’s felony-murder and attempted-armed-robbery convictions. View "United States v. Smith" on Justia Law

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The case involves a dispute over the Federal Energy Regulatory Commission's (FERC) approval of a project to expand a natural-gas pipeline from western Pennsylvania to the New York metropolitan area. The petitioner, Food & Water Watch, argued that FERC overlooked environmental issues in approving the project. Specifically, they claimed that FERC's Environmental Impact Statement failed to quantify greenhouse-gas emissions from upstream drilling for the extra gas, to quantify ozone emissions from its downstream burning, and to categorize emissions impacts as either significant or insignificant. Additionally, Food & Water Watch argued that FERC did not adequately consider New York State and New York City laws mandating reductions in carbon-dioxide emissions.The case was reviewed by the United States Court of Appeals for the District of Columbia Circuit. The lower courts had approved the project, with FERC issuing a certificate of public convenience and necessity for the East 300 Upgrade Project. FERC had prepared a full Environmental Impact Statement (EIS), which estimated the downstream carbon-dioxide emissions but declined to address upstream environmental effects. FERC also declined to characterize downstream emissions as significant or insignificant.The Court of Appeals for the District of Columbia Circuit rejected the petitioner's contentions and denied the petitions for review. The court found that FERC had reasonably concluded that there was too much uncertainty regarding the number and location of additional upstream wells. The court also held that FERC had reasonably explained its decision not to give a quantitative estimate of how much ozone would be produced as a result of the project. Finally, the court found that FERC had amply discussed the significance of GHG emissions and that it was not required to label the increased emissions and ensuing costs as either significant or insignificant. The court also found that FERC had reasonably explained why the New York State Climate Leadership and Community Protection Act did not undercut its finding of need for the project. View "Food & Water Watch v. Federal Energy Regulatory Commission" on Justia Law

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The case revolves around a program proposed by Harris County, Texas, known as "Uplift Harris." The program aimed to provide $500 monthly cash payments to 1,928 Harris County residents for 18 months, with recipients chosen by lottery from applicants with income below 200% of the federal poverty line living in certain zip codes. The State of Texas challenged the program, arguing that it violated the Texas Constitution’s prohibition on gratuitous payments to individuals.The State sued the County, seeking an injunction to block the implementation of the program. The district court denied the State's request for a temporary injunction, leading the State to appeal this decision and request a stay of payments under the Uplift Harris program while the appeal was ongoing. The court of appeals denied this request, prompting the State to seek mandamus relief in the Supreme Court of Texas.The Supreme Court of Texas granted the State's motion for temporary relief, prohibiting all payments under the Uplift Harris program pending further order of the court. The court found that the State had raised serious doubt about the constitutionality of the program, and that potential violation of the Texas Constitution could not be remedied if payments were to commence while the underlying appeal proceeded. The court also noted that once the funds were distributed to individuals, they could not feasibly be recouped if it was later determined they were paid in violation of the Texas Constitution. The court concluded that temporarily preventing the expenditure of these funds while the State's appeal proceeded ensured public funds were not irrecoverably spent in violation of the Texas Constitution. The State's appeal of the denial of a temporary injunction remains pending in the court of appeals. View "In re The State of Texas" on Justia Law

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The case revolves around the Public Utility Commission of Texas (PUC) and two market participants, RWE Renewables Americas, LLC and TX Hereford Wind, LLC. Following Winter Storm Uri, the Legislature amended the Public Utility Regulatory Act (PURA) to require that protocols adopted by the Electric Reliability Council of Texas (ERCOT) must be approved by the PUC before they take effect. ERCOT then adopted a revision to its protocols, which was approved by the PUC, setting the price of electricity at the regulatory maximum under Energy Emergency Alert Level 3 conditions. RWE challenged the PUC's approval order in the Third Court of Appeals, arguing that the order was both substantively and procedurally invalid.The Third Court of Appeals held that the PUC's order was both substantively invalid—because the PUC exceeded its statutory authority by setting the price of electricity—and procedurally invalid—because the PUC failed to comply with the Administrative Procedure Act’s rulemaking procedures in issuing the order.The Supreme Court of Texas reviewed the case and held that the PUC’s approval order is not a “competition rule[] adopted by the commission” subject to the judicial-review process for PUC rules. The court found that PURA envisions a separate process for ERCOT-adopted protocols, and the statutory requirement that the PUC approve those adopted protocols does not transform PUC approval orders into PUC rules eligible for direct review by a court of appeals. Therefore, the Third Court of Appeals lacked jurisdiction over this proceeding. The Supreme Court of Texas vacated the court of appeals’ judgment and dismissed the case for lack of jurisdiction. View "Public Utility Commission v. RWE Renewables Americas, LLC" on Justia Law

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The case revolves around the actions of the Public Utility Commission of Texas (Commission) during Winter Storm Uri, when the Texas electric grid was on the brink of collapse. The Commission issued two orders that effectively raised the market price of electricity to the regulatory ceiling of $9,000/MWh to incentivize generators to add supply and large industrial users to reduce their demand. This led to some market participants going bankrupt and subsequent litigation.The court of appeals held that the Commission’s orders exceeded its authority under Chapter 39 of the Public Utility Regulatory Act (PURA) because the statute prohibits price-setting. The court of appeals did not address whether the Commission complied with the Administrative Procedure Act’s (APA) procedural rulemaking requirements.The Supreme Court of Texas disagreed with the court of appeals' decision. It held that the Commission’s orders did not exceed its authority under PURA. The court also found that the Commission substantially complied with the APA’s procedural rulemaking requirements, an issue the court of appeals did not address. The Supreme Court of Texas reversed the judgment of the court of appeals and rendered judgment affirming the orders. View "Public Utility Commission v. Luminant Energy Co. LLC" on Justia Law

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The case revolves around Pureza “Didit” Martinez, who was terminated from her position at the Texas Tech University Health Sciences Center at the age of 72. She filed a lawsuit alleging age discrimination against the Health Sciences Center, the Texas Tech University System, and the Texas Tech University System’s Board of Regents. The Texas Tech University System and the Board of Regents argued that they were not Martinez's employer and thus retained sovereign immunity.Previously, the trial court denied the plea to the jurisdiction filed by the Texas Tech University System and the Board of Regents, and the court of appeals affirmed this decision. The defendants argued that Martinez failed to plead allegations that could make them liable for age discrimination under the Labor Code, essentially denying being Martinez’s employer.The Supreme Court of Texas disagreed with the lower courts' decisions. The court found that Martinez's petition did not allege facts demonstrating that the Texas Tech University System or the Board of Regents employed Martinez directly or that either one controlled access to and interfered with her employment. Therefore, the court concluded that Martinez failed to allege a waiver of sovereign immunity, and the plea to the jurisdiction of the Texas Tech University System and the Board of Regents should have been granted. However, the court remanded the case to the trial court to give Martinez an opportunity to replead, as her petition did not foreclose a valid claim against those defendants. View "Texas Tech University System v. Martinez" on Justia Law