Justia Government & Administrative Law Opinion Summaries

A candidate who won the Republican Party nomination for state representative in Ohio’s 89th House District withdrew his candidacy after the primary election. Under Ohio law, a district committee composed of the chairpersons and secretaries of the Republican Party county central committees within the district was authorized to select a replacement candidate. The committee met privately, excluding the public and a board of elections member, and chose Caleb Stidham, who was himself a member and chair of the Erie County Republican Party, as the replacement. The committee certified Stidham’s nomination to the Erie County Board of Elections.When the board of elections considered certifying Stidham for the ballot, it split evenly. The two members against certification cited concerns about the closed committee meeting and Stidham’s participation in his own selection. The Secretary of State, as authorized by statute, broke the tie in favor of certifying Stidham. Shortly after, Carl Koebel, an elector in the district, filed a mandamus action in the Supreme Court of Ohio, seeking to prevent Stidham’s certification and requesting removal from the ballot, arguing that the committee violated Ohio’s Open Meetings Act.The Supreme Court of Ohio reviewed Koebel’s complaint, including arguments regarding the verification affidavit and standing. Ultimately, the court denied the writ on the grounds of laches, finding Koebel had unreasonably delayed for 25 days after the Secretary of State’s decision, thereby prejudicing the board and the Secretary due to statutory deadlines for ballot printing and absentee ballot distribution. The court did not reach the merits of Koebel’s Open Meetings Act claim, instead holding that the delay barred relief. The court also granted Koebel’s motion to submit a supplemental affidavit but denied his request for attorney fees. View "State ex rel. Koebel v. Erie Cty. Bd. of Elections" on Justia Law

A Medi-Cal recipient resided in a nursing care facility from 2010 until her death in 2015. During her enrollment, the Department of Health Care Services paid $261,957.40 in capitation payments to her managed care plan, while the plan paid $106,672.71 to health care providers for services she actually received. The Department sought estate recovery totaling $407,774.41, which included the full amount of capitation payments, Medicare Part B premiums, and accrued interest. Her trustee and beneficiaries challenged the Department’s claim, contending that only payments for health care services actually received should be recovered.The Superior Court of San Luis Obispo County certified a class of Medi-Cal recipients and estates subject to similar estate recovery claims. After hearings on stipulated issues, the trial court determined that seeking recovery for capitation payments exceeding the actual cost of health care services received violated Welfare and Institutions Code section 14009.5 and federal law. The trial court entered judgment for the Department for the portion attributable to services actually received, and issued a declaratory judgment and writ of mandate in favor of the beneficiaries and the class, requiring the Department to reform its estate recovery practices and reprocess certain claims.The California Court of Appeal, Second Appellate District, Division Six, reviewed the case de novo. It held that Welfare and Institutions Code section 14009.5 does not permit recovery of capitation payments in excess of the amounts paid for actual health care services received. The court also ruled that the Department’s regulation permitting recovery of excess capitation is void for conflict with the statute. The judgment by the trial court was affirmed. The Department cannot recover excess capitation from estates under section 14009.5. View "Phillip v. Baass" on Justia Law

A former Michigan Department of Corrections prisoner with asthma and an alleged allergy to dogs experienced allergic reactions while incarcerated at multiple facilities that housed dogs for training purposes. He reported symptoms such as asthma attacks and respiratory infections to prison officials, who provided prescribed treatments but did not confirm a specific dog allergy. After pursuing the prison’s grievance process, he was moved within the facility but still encountered dogs during required programming. Subsequently, he requested an ADA accommodation to be housed away from dogs, but this was denied due to lack of medical documentation. He later filed suit, alleging violations of the Eighth Amendment, the ADA, the Rehabilitation Act, and state laws.The United States District Court for the Western District of Michigan granted summary judgment in favor of the defendants. The court found that prison officials were not deliberately indifferent to his medical needs under the Eighth Amendment, as they consulted medical staff who did not recommend a transfer based on his condition. For the ADA and Rehabilitation Act claims, the court determined that inadequate medical treatment was not actionable under those statutes and that the plaintiff had not demonstrated denial of prison services or programs due to his disability. The court also declined to exercise supplemental jurisdiction over the state-law claims.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s decision de novo. The appellate court affirmed the grant of summary judgment, holding that the prison counselor was entitled to qualified immunity because no clearly established law required the transfer of prisoners with asthma to facilities without dog programs. The court also found that the plaintiff failed to provide sufficient medical documentation to support the necessity of the requested accommodation under the ADA and Rehabilitation Act and did not establish discriminatory animus. The district court’s refusal to exercise supplemental jurisdiction over state-law claims was also affirmed. View "Miles-El v. Michigan" on Justia Law

A mortgage issuer, Reverse Mortgage Funding, LLC (RMF), participated in a federal program allowing it to securitize reverse mortgages. When RMF entered bankruptcy, Texas Capital Bank provided debtor-in-possession financing, secured by RMF’s interests in certain collateral, specifically incremental balances on the mortgages known as “tails.” After RMF defaulted on its agreement, the Government National Mortgage Association (Ginnie Mae), under its statutory and contractual authority, extinguished RMF’s interests in the underlying mortgages and assumed ownership of the loans, also extinguishing Texas Capital’s lien interest in the mortgage tails. Texas Capital argued that Ginnie Mae’s actions violated federal law and Texas tort law.The United States District Court for the Northern District of Texas initially allowed Texas Capital’s claims for statutory authority under the Administrative Procedure Act (APA) and tortious interference to proceed, but dismissed the promissory estoppel claim due to sovereign immunity. Later, the district court granted summary judgment to Ginnie Mae, finding it acted within its statutory authority and concluding that the extinguishment of RMF’s interests necessarily eliminated Texas Capital’s derivative interest in the mortgage tails. The court also dismissed Texas Capital’s tortious interference claim, citing sovereign immunity and a lack of legal basis, and refused to consider Texas Capital’s arbitrary-and-capricious APA theory because it was not sufficiently pled.The United States Court of Appeals for the Fifth Circuit reviewed the case de novo. It held that Ginnie Mae acted within its statutory and contractual authority under 12 U.S.C. § 1721(g)(1) in extinguishing both RMF’s and Texas Capital’s interests in the mortgages. The court affirmed the district court’s summary judgment, finding Texas Capital’s tortious interference claim barred by sovereign immunity and ruling that Texas Capital’s failure to plead an arbitrary-and-capricious APA theory justified the district court’s refusal to consider it. The judgment of the district court was affirmed. View "Texas Captl Bank v. Govt Natl Mtge" on Justia Law

Two attorneys, licensed in New Jersey and Michigan, sought admission to the Florida Bar and challenged a Florida rule requiring applicants admitted to another bar for more than twelve months to pay a higher application fee. They argued that this "experienced-applicant" rule violated the dormant Commerce Clause by burdening out-of-state applicants both on its face and in practical effect. One attorney paid the fee and then sued, seeking a refund and an injunction; the other attorney did not pay and joined the suit to seek prospective relief.The United States District Court for the Northern District of Florida initially dismissed most claims for lack of standing or based on Eleventh Amendment immunity, but allowed a limited practical-effect claim against the executive director of the Florida Board of Bar Examiners. After further amendments and discovery, the district court denied summary judgment to the plaintiffs and granted summary judgment to the executive director, finding that the rule did not discriminate against out-of-state applicants in practice.The United States Court of Appeals for the Eleventh Circuit reviewed the case. It held that the Board of Bar Examiners is an arm of the state and therefore immune from suit under the Eleventh Amendment. As to the claim against the executive director, the court found that the experienced-applicant rule did not facially discriminate against out-of-state applicants, as it was based solely on years of admission, not geographic origin. The court further concluded that undisputed evidence showed the rule imposed similar burdens on both in-state and out-of-state applicants and was adopted for legitimate, non-protectionist reasons. The Eleventh Circuit affirmed the district court’s dismissal and summary judgment, holding that neither facial nor practical-effect dormant Commerce Clause claims could succeed. View "Hernandez v. Florida Board of Bar Examiners" on Justia Law

Needy children in Texas receive orthodontic care through Medicaid, which is administered by the Texas Health and Human Services Commission (HHSC). HHSC contracted with Conduent State Healthcare, LLC (formerly known as Xerox Corporation and ACS State Healthcare, LLC) to review and approve prior-authorization requests for these services. After Conduent allegedly approved requests without adequately assessing medical necessity, legal disputes arose. The State of Texas pursued civil penalties against Conduent for violating Medicaid policy, resulting in a settlement. Separately, dentists, including Diana Malone, DDS; Scott Malone, DDS; and M&M Orthodontics, PA, settled Medicaid-fraud claims by paying $2 million. Subsequently, these dentists sued Conduent and the State, alleging tortious conduct by Conduent in approving requests without proper review.In Travis County District Court, the State’s plea to the jurisdiction based on sovereign immunity was granted, dismissing it from the case. Conduent’s plea to the jurisdiction, which invoked derivative sovereign immunity and the election-of-remedies provision in the Texas Tort Claims Act, was denied. Conduent appealed this interlocutory order. The Court of Appeals for the Third District of Texas affirmed the district court’s denial of Conduent’s plea, addressing Conduent’s immunity arguments on the merits. A dissenting justice argued that the appeal should have been dismissed for lack of appellate jurisdiction.The Supreme Court of Texas reviewed whether the court of appeals had jurisdiction to hear Conduent’s interlocutory appeal. It held that Conduent, as a private contractor, is not a “governmental unit” under the relevant statutory definitions, and thus cannot utilize Section 51.014(a)(8) or Section 51.014(a)(5) to appeal the denial of its jurisdictional plea. The Supreme Court vacated the court of appeals’ opinion and judgment and remanded the case to the district court. View "CONDUENT STATE HEALTHCARE, LLC v. M&M ORTHODONTICS, PA" on Justia Law

A man with a history of sexual offenses, including a 2017 conviction for sexual abuse in the third degree, was later incarcerated for violating the terms of a special sentence imposed due to that conviction. While serving time for this parole revocation, the State petitioned to civilly commit him as a sexually violent predator (SVP) under Iowa Code chapter 229A. The petition was filed shortly before his anticipated discharge from prison. The man had a long criminal record and numerous behavioral violations in prison, several involving sexual misconduct.The Iowa District Court for Polk County conducted a trial, during which the respondent moved to dismiss the petition. He argued that because he was only confined for a nonsexual violation of his special sentence at the time of the petition, he was not “presently confined” as required by statute, and that due process required the State to prove a recent overt act indicating a risk of future violence. The district court denied the motion, found that the State had proven the statutory elements beyond a reasonable doubt—including that the respondent was an SVP and was presently confined as defined in the statute—and ordered his commitment. The respondent appealed, reasserting his statutory and constitutional arguments.The Supreme Court of Iowa reviewed the appeal. The court held that the statutory definition of “presently confined” includes incarceration resulting from a special sentence for a sexually violent offense, and that the State was not required to prove a recent overt act under these circumstances. The court further concluded that this statutory scheme did not violate federal or state due process, as long as the respondent was presently confined due to a sexually violent offense and found to be an SVP under the statute. The judgment of the district court was affirmed. View "In Re Detention Of Harlow" on Justia Law

A Mississippi-based furniture company and its principal operated an online “drop shipping” business, selling to customers nationwide. They fulfilled over a thousand orders for Michigan residents, accepting payments and arranging deliveries to Michigan addresses, but beginning in 2020, they kept payments for furniture they never delivered. After numerous complaints, the Michigan Attorney General sued them for violations of Michigan’s consumer protection laws and statutory conversion involving ten Michigan consumers. The defendants did not appear in the Michigan court, asserting that their website’s terms limited legal disputes to Mississippi and that Michigan lacked personal jurisdiction. Default judgments were entered against both defendants, awarding damages, civil fines, and attorneys’ fees.Following the Michigan judgment, the Attorney General enrolled it in the Lowndes County Circuit Court in Mississippi under the Uniform Enforcement of Foreign Judgments Act. The defendants objected, arguing that the Michigan court lacked jurisdiction due to their choice-of-law provision and that the forum-selection clause in their terms of service precluded jurisdiction. The circuit court held that the forum-selection clause was irrelevant to the statutory action and that Michigan law governed its validity, overruling the objections and directing enrollment of the judgment.The Supreme Court of Mississippi reviewed the appeal de novo. It held that the Michigan court had personal jurisdiction over the defendants because they knowingly and repeatedly contracted with Michigan residents, took their money, and arranged deliveries into Michigan, thus purposefully availing themselves of Michigan’s market. The choice-of-law provision in the website’s terms did not negate purposeful availment. The court found that Michigan’s long-arm statutes and due process requirements were satisfied. It also held that the size of the judgment was irrelevant to full faith and credit. The Supreme Court of Mississippi affirmed the circuit court’s order enrolling the Michigan judgment. View "AF, LLC v. Nessel" on Justia Law

The case involves an individual who pleaded guilty to residential burglary in 2013 and, approximately ten years later, pleaded guilty to second-degree murder in 2024. After being sentenced to 180 months’ imprisonment for second-degree murder, the Arkansas Division of Correction determined that he was ineligible for parole because of his prior violent felony conviction for residential burglary. He challenged this determination, arguing that his residential burglary conviction should not be classified as a “prior violent felony” under Arkansas Code Annotated section 16-93-609, claiming the offense was committed before 2015 and that his sentencing order for second-degree murder did not expressly designate it under the relevant statute.He sought relief in the Pulaski County Circuit Court, petitioning for declaratory judgment, injunction, and mandamus. The circuit court reviewed the statutory language and found that the exception to the violent-felony rule for residential burglaries committed before April 1, 2015, only applies when the sentence for which parole eligibility is sought was imposed before May 24, 2022. Since his second-degree murder sentence was imposed in 2024, the court concluded the exception did not apply. The court denied his petition, holding that the Arkansas Division of Correction did not exceed its legal authority in denying parole eligibility.The Supreme Court of Arkansas reviewed the circuit court’s dismissal for abuse of discretion and interpreted the statute de novo. The court held that the statute’s plain language precludes parole eligibility for sentences imposed after May 24, 2022, regardless of when the prior residential burglary was committed or the absence of express designation on the sentencing order. The court also declined to address an ex post facto claim that had not been raised below. The Supreme Court of Arkansas affirmed the circuit court’s decision. View "NANCE v. ARKANSAS POST-PRISON TRANSFER BOARD" on Justia Law

The dispute centers on the distribution of Kirkland Signature alcoholic beverages in Arkansas. Costco, a major retailer with a registered trademark for Kirkland Signature, began selling its branded alcoholic beverages in Arkansas through various manufacturers. These manufacturers registered different Kirkland Signature products, such as Chianti, Pinot Grigio, Sauvignon Blanc, and Strawberry Margarita, with the Arkansas Alcoholic Beverage Control (ABC) Division, each designating one of two different wholesalers: Moon Distributors or Arkansas Wine and Spirits (AWS). The ABC Division later determined that state law required all Kirkland Signature products, regardless of the manufacturer or variety, to be distributed by the same wholesaler.The Director of the ABC Division instructed manufacturers who had designated a different wholesaler from the first registered wholesaler (Moon Distributors) to submit change requests. Mach Flynt and Levecke, two manufacturers who had previously designated AWS, complied but expressed their preference for AWS. The Director held a hearing and granted the change requests, removing AWS as the wholesaler for those products. AWS appealed this administrative action to the ABC Board, which upheld the Director’s decision after its own hearing. AWS then sought review in the Pulaski County Circuit Court, which affirmed the Board’s decision. The Arkansas Court of Appeals certified the case to the Supreme Court of Arkansas.The Supreme Court of Arkansas held that under Arkansas Code Annotated section 3-2-403, “brand” refers to the trademark or distinctive name, meaning all Kirkland Signature alcoholic beverages constitute a single brand. Therefore, only one wholesaler may be designated for the brand, and subsequent manufacturers must use the same wholesaler as the first registrant. The court further concluded that the ABC Board’s decision was supported by substantial evidence and was not arbitrary, capricious, or an abuse of discretion. The decision was affirmed. View "ARKANSAS WINE AND SPIRITS WHOLESALE, LLC v. DEPARTMENT OF FINANCE AND ADMINISTRATION" on Justia Law