Justia Government & Administrative Law Opinion Summaries

The federal government initiated a project to replace the East Wing of the White House, completing demolition in December 2025 and beginning construction of a new wing, which included both a below-ground military installation and an above-ground ballroom. The National Trust for Historic Preservation challenged aspects of the ongoing construction and sought a preliminary injunction to halt the above-ground work due to concerns about its impact on aesthetic, cultural, and historical interests.The United States District Court for the District of Columbia granted the Trust’s motion for a preliminary injunction, allowing only construction strictly necessary for security purposes above ground but permitting below-ground work to continue. The government appealed, and the United States Court of Appeals for the District of Columbia Circuit initially stayed the injunction, then ultimately affirmed the district court’s order. With the injunction set to take effect, the government sought relief from the Supreme Court of the United States.The Supreme Court granted the requested stay of the district court's injunction pending the government’s petition for certiorari. The Court held that the government is likely to succeed in showing the Trust lacks Article III standing, as the Trust’s asserted injury—distress at viewing the new ballroom’s design—does not constitute a concrete and particularized injury. The Court also found that the government would likely suffer irreparable harm from halting construction, given national security concerns and operational needs, while the Trust’s claimed harm was outweighed by these factors. The stay will remain in effect until certiorari is denied or, if granted, until the judgment is issued. View "National Park Service v. National Trust for Historic Preservation in the United States" on Justia Law

The case involves a dispute between homeowners who own property within a common interest development (CID) in the City of Indian Wells and the City itself. The City, responding to complaints about the negative effects of short-term rentals (STRs), enacted ordinances that effectively banned STRs by imposing a 29-night minimum stay requirement. To accommodate homeowners in CIDs who wanted to operate STRs, the City adopted an ordinance (No. 732) allowing CIDs to opt out of the minimum stay requirement through a vote of their members. The plaintiffs, owners of property in a CID with governing documents allowing rentals of any duration, sought an STR permit after their CID certified an opt-out vote. The City denied the permit, leading the plaintiffs to file suit, arguing that the City’s opt-out provision conflicted with state law and unconstitutionally delegated legislative authority to private parties.The Superior Court of Riverside County ruled in favor of the plaintiffs, finding that the City’s opt-out ordinance conflicted with provisions of the Davis-Stirling Common Interest Development Act, particularly Civil Code section 4740, and with the Act’s voting requirements for amending CID governing documents. The court also found that the opt-out provision was an unconstitutional delegation of legislative authority. As a result, the court ordered the City to issue an unrestricted STR permit and awarded attorney fees to the plaintiffs.The California Court of Appeal, Fourth Appellate District, Division Two, reversed the trial court’s judgment. It held that the City’s opt-out provision is not preempted by Civil Code section 4740 because a CID’s vote to opt out does not amend its governing documents or conflict with the Act. The Court further held that the City did not unconstitutionally delegate legislative authority because it established a general policy and permissibly allowed CIDs to waive the restriction. The City’s enactment of the ordinance was not arbitrary or capricious. The judgment and attorney fee order were reversed. View "Parsons v. City of Indian Wells" on Justia Law

Bryan Smith requested court records from the Bonneville County District Court in April 2025, specifically seeking copies of judgments and certificates of service for 169 small claims cases. The Clerk’s Office charged him $352 for the records, relying on a 2017 Administrative Order that set fees for electronic records production. Smith paid the fee after the Clerk refused to reduce the charge, then filed suit against the Clerk in his official capacity, alleging he was overcharged and that Idaho Code section 74-102(10) should control the fee charged for electronic records. He sought declaratory relief and damages for the alleged overcharge.The Seventh Judicial District, Bonneville County, heard cross motions for summary judgment. The Clerk asserted quasi-judicial immunity based on following an administrative court order. The district court granted summary judgment for the Clerk, holding he had absolute quasi-judicial immunity and declining to address the merits of Smith’s claims, including whether the fee was excessive or inconsistent with Idaho law.The Supreme Court of the State of Idaho reviewed the appeal. Applying a de novo standard, the Court held that quasi-judicial immunity is only a defense to personal liability, not official capacity suits, and the district court erred in applying that defense. On the merits, the Court found the 2017 Administrative Order’s fee structure was inconsistent with Idaho Court Administrative Rule 32 and Idaho Code section 74-102(10), which require fees to reflect actual labor and material costs. Smith was overcharged by $330.67. The Supreme Court reversed the district court’s grant of summary judgment, vacated the amended judgment, and remanded with instructions to enter judgment in favor of Smith, directing the Clerk to refund $330.67 and awarding Smith costs on appeal. View "SMITH v. POULTER" on Justia Law

A municipal corporation operating a large regional commuter rail system in the Chicago area provided rail service on lines owned by a freight rail company. For decades, this service was conducted under a series of agreements, but in 2019, the freight rail company announced it would cease operating the commuter trains. Following litigation, the freight company obtained a declaratory judgment that it had no ongoing obligation to provide such service. While the commuter rail operator began transitioning to run the service itself, the parties failed to reach agreement on compensation for continued use of the lines. With no long-term agreement in place and negotiations at an impasse, the commuter rail operator applied to the federal Surface Transportation Board for terminal trackage rights, which would allow it to use the lines despite the lack of agreement.The Surface Transportation Board granted the application, finding the lines to be terminal facilities for a reasonable distance from the terminal, and that the use would be practicable, in the public interest, and not substantially impair the freight carrier’s operations. The Board did not set compensation or use conditions at that time but pledged to do so retroactively if the parties could not agree. The freight rail company sought review of this decision in the United States Court of Appeals for the Eighth Circuit.The Eighth Circuit held that the Board acted within its statutory authority in granting terminal trackage rights to the commuter operator, including over the full extent of the lines at issue, and properly concluded the public interest was served. However, the court found that the Board erred by granting immediate rights without first ensuring that compensation was paid or adequately secured, as required by statute. The court vacated the Board’s order and remanded for further proceedings, allowing time for the parties to address compensation. View "Union Pacific Railroad Company v. STB" on Justia Law

An individual asserted interests in six oil leases that were proposed for inclusion in an oil exploration and development unit on Alaska’s North Slope. The Alaska Division of Oil and Gas initially approved two of these leases for unit inclusion but later reversed its position and denied inclusion for all six. During the administrative appeal process, the leases expired because the lessees failed to pay the required rental payments, as mandated by a Department of Natural Resources (DNR) regulation. The individual did not pay the rent necessary to reinstate the leases, and the Division confirmed their termination.The individual appealed both the termination of the leases and the denial of their inclusion in the unit to the Commissioner of Natural Resources. The Commissioner affirmed the terminations and denied the inclusion request. Separate appeals were filed in the Alaska Superior Court: one challenging the lease terminations (raising the validity of the rent-during-appeal regulation) and one challenging the denial of unit inclusion (alleging agency overreach, unreasonableness, and due process violations). The Superior Court affirmed the termination of five leases and remanded the sixth for further proceedings regarding its production capabilities. It also affirmed the denial of unit inclusion, finding no violation of due process or agency overreach.The Supreme Court of the State of Alaska held that the DNR regulation requiring rental payments during the pendency of an appeal is constitutional and a reasonable exercise of DNR’s authority. Because the lessees failed to pay rent, the terminations of five leases were affirmed, rendering the unitization appeal for those leases moot. The dispute over the sixth lease was found to remain live, but the Commissioner’s denial of its inclusion in the unit was affirmed as neither arbitrary, unreasonable, nor a violation of due process. The award of attorney’s fees against the appellant was also affirmed. View "Donkel v. State of Alaska" on Justia Law

A natural gas company operating in multiple states applied to the Federal Energy Regulatory Commission (FERC) for permission to build new pipeline facilities and abandon some existing ones, requesting that the costs of these improvements be included in future customer rates. The company’s customers, a group of retail natural gas distributors, challenged the application, arguing that less costly alternatives existed, that the improvements were not justified by customer needs, and that FERC should not pre-determine the rate treatment for the project. The core dispute arose when the customers requested access to specific pipeline flow data, designated as sensitive Critical Energy Infrastructure Information, which was withheld from the public docket. FERC eventually released the requested data, but the customers claimed that the delay impaired their ability to participate meaningfully in the proceedings.FERC granted the company’s application, issuing a Certificate of Public Convenience and Necessity and permitting facility abandonment. The Commission found that the evidence, including flow data, demonstrated the necessity of the project and justified the proposed rate treatment, noting that objections to rates could be addressed in future proceedings. The customers filed a rehearing request, alleging that FERC’s decision was premature and unsupported by substantial evidence due to delayed data access. FERC denied rehearing, later provided the requested data, and solicited comments, but the customers maintained that the timing was inadequate and refused to comment.The United States Court of Appeals for the District of Columbia Circuit reviewed the consolidated petitions. The court found the customers had standing, the case was not moot, and limited its review to arguments raised in the rehearing request. Applying the arbitrary and capricious standard, the court held that FERC’s procedures and consideration of the record, including flow data, were sufficient and did not violate due process. The petitions for review were denied. View "East Tennessee Group v. FERC" on Justia Law

The plaintiff, a former Senior Reimbursement Manager at a national pharmacy provider, alleged that her employer engaged in a scheme to overcharge government healthcare programs such as Medicare and Medicaid. She claimed the company exploited billing system discrepancies and other tactics to cause overpayments, including billing for deceased patients and miscoding pharmacy types for higher reimbursements. The company allegedly concealed these overpayments in its internal accounting and, after a period, transferred the unreturned funds into its own revenues. The plaintiff reported these practices to management and internal audit, but the issues persisted.After filing a complaint in the United States District Court for the Eastern District of New York, the plaintiff amended her allegations. The District Court dismissed all federal claims with prejudice, finding that the plaintiff did not meet the heightened pleading standards for fraud required under Federal Rule of Civil Procedure 9(b) for “direct” False Claims Act (FCA) claims (those based on submitting fraudulent invoices or statements to the government). The court also denied leave to further amend the complaint, and denied reconsideration.On appeal, the United States Court of Appeals for the Second Circuit reviewed the case de novo. The Second Circuit affirmed the District Court’s dismissal of the plaintiff’s direct FCA claims, holding that she did not identify any specific fraudulent submissions to the government, nor adequately allege that such information was solely within the defendants’ control. However, the Second Circuit vacated the dismissal of the “reverse” FCA claim, which is based on knowingly retaining government overpayments. The court found the plaintiff sufficiently alleged that the company had an obligation to return identified overpayments and knowingly concealed or improperly avoided that obligation. The case was remanded for further proceedings on the reverse FCA claim. View "United States v. Amerisource Bergen Corp." on Justia Law

A group of premium cigar manufacturers and trade associations challenged California’s Unflavored Tobacco List statute, which requires tobacco products to be approved and listed by the California Attorney General before they may be sold to consumers, retailers, or wholesalers in the state. To be listed, manufacturers must submit detailed applications and pay fees, certifying their products lack any characterizing flavor. The plaintiffs argued that the law would impose considerable compliance costs, particularly burdensome for the premium cigar industry where products are hand-made in smaller batches and change blends frequently. They asserted that their premium cigars, by federal definition, do not contain flavoring additives, and that the application and fee requirements would force them to reduce their product offerings in California.The plaintiffs sought a preliminary injunction against enforcement of the statute in the United States District Court for the Central District of California. They contended that the federal Family Smoking Prevention and Tobacco Control Act (TCA) expressly preempts California’s law as applied to premium cigars and that the statute’s presumption against flavoring based on manufacturers’ speech violates the First Amendment. The district court denied the motion, concluding the plaintiffs were unlikely to succeed on the merits of their claims.Upon review, the United States Court of Appeals for the Ninth Circuit affirmed the district court’s denial of a preliminary injunction. The appellate court held that the TCA’s Savings Clause exempts state requirements related to the sale of tobacco products from preemption, and the challenged statute falls within this exemption as it is directly tied to retail sales. The court also found that, based on the Attorney General’s representations, the statute imposes only a minimal burden on commercial speech and does not restrict speech more than necessary. Thus, the Ninth Circuit affirmed the denial of injunctive relief. View "ROCKY PATEL PREMIUM CIGARS, INC. V. BONTA" on Justia Law

Several federally licensed firearms dealers (FFLs), including both brick-and-mortar and home-based businesses, gun rights organizations, and private citizens challenged a California statute, Section 26806, which requires all FFLs to maintain a digital video and audio recording system on their business premises. The statute mandates 24/7 surveillance of specific areas, such as points of sale and firearm display areas, and limits when and how recordings may be released or accessed, including requirements for posting notification signs and annual certification of system functionality. Plaintiffs argued that this law infringed their rights under the First, Fourth, and Fifth Amendments by imposing surveillance burdens, chilling speech, violating privacy, and effecting a taking of property.The United States District Court for the Central District of California dismissed the complaint for failure to state a claim. The district court found that Plaintiffs had not sufficiently alleged a likelihood of success on the merits of any claims, denied injunctive relief, and granted leave to amend. Plaintiffs eventually chose not to further amend and requested final judgment, which the district court entered, leading to this appeal.The United States Court of Appeals for the Ninth Circuit affirmed the district court’s dismissal. The court held that Plaintiffs failed to allege a cognizable Fourth Amendment claim because there was no physical government intrusion or access to recordings, nor did mere compliance with the statute transform FFLs into state actors. The court also found no Fifth Amendment violation, as the statute did not result in a physical or regulatory taking; FFLs retained ownership and control over their recording systems, and the economic impact did not rise to a taking. Finally, the court ruled that the First Amendment theories advanced by Plaintiffs—overbreadth, violations of the right to anonymity and association, and chilling of speech—were unsupported because the statute did not regulate or compel speech or disclosure, nor did it plausibly chill protected expression. The Ninth Circuit therefore affirmed the district court’s judgment. View "RICHARDS V. NEWSOM" on Justia Law

A fourteen-year-old student, JPZ, was suspended from school following an altercation. The school principal, Melissa Arendts, notified JPZ's mother and requested JPZ be picked up. Upon arrival, JPZ's grandmother found him isolated and awaiting questioning by Scott Labish, a sheriff’s deputy serving as a school resource officer. Labish, in uniform, questioned JPZ, allegedly in a threatening manner, and told him about a “Three Strike” policy that would result in criminal prosecution and expulsion after another infraction. JPZ became distressed, left school, and subsequently died by suicide at home several hours later. JPZ's father, Brian Zimmermann, as administrator of JPZ’s estate, sued Arendts, Labish, the school district, and Macomb County, alleging federal due process violations and state law claims.The United States District Court for the Eastern District of Michigan dismissed the wrongful death claim but allowed four other claims to proceed: deprivation of substantive due process, conspiracy, intentional infliction of emotional distress, and Monell liability. Defendants moved to dismiss the remaining claims based on qualified and state governmental immunity and deficiencies in the Monell claim. The district court denied these motions in part, leading to an interlocutory appeal by the defendants.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s denial de novo. The Sixth Circuit held that the facts did not support a substantive due process claim under the state-created danger doctrine, as the defendants neither increased JPZ’s risk of harm from a third party nor acted with deliberate indifference. The conspiracy and Monell claims failed because no underlying constitutional violation was adequately alleged. The court also found the defendants entitled to state governmental immunity for the intentional infliction of emotional distress claim, as the conduct alleged did not indicate malice. The Sixth Circuit reversed the district court’s denial of the motions to dismiss and remanded the case. View "Zimmermann v. Labish" on Justia Law