Justia Government & Administrative Law Opinion Summaries

A journalist submitted a public records request to the Delaware State Police (DSP) seeking seven categories of information about troopers, including names, ranks, salaries, employment history, résumés, lists of former officers, and demographic data. DSP denied the request in its entirety, asserting various statutory exemptions, the absence of certain records, and safety and privacy concerns. The journalist then petitioned the Chief Deputy Attorney General to review the denial, the required process for state agency FOIA disputes. The Chief Deputy found no FOIA violation, determining that disclosure of trooper identities and related information was exempt from public access due to safety risks and privacy interests.The journalist appealed to the Superior Court of Delaware. The Superior Court ordered DSP to disclose the names, ranks, and salaries of current troopers but upheld DSP’s refusal to produce employment histories, résumés, lists of former officers, and demographic data. The court also denied the journalist’s request for attorney fees and costs, reasoning that FOIA’s fee-shifting provision did not clearly apply to on-the-record appeals from administrative determinations.The Supreme Court of the State of Delaware reviewed the case. It held that DSP had not met its statutory burden to justify the denial of the employment history, former officer lists, résumés (with redaction of private information), or anonymized demographic information, finding that DSP’s affidavits and representations were insufficient. The Court ordered DSP, on remand, to produce available records or submit adequate sworn statements about their existence and to provide résumés and demographic data in redacted or anonymized form. The Court affirmed the Superior Court’s ruling that attorney fees and costs are not available for petitioners who prevail in FOIA on-the-record appeals, holding that the statute does not authorize such awards. The judgment was thus affirmed in part, reversed in part, and remanded for further proceedings. View "Vanella v. Duran" on Justia Law

A quadriplegic individual applied to become a foster parent in Michigan, relying on a network of full-time aides and informal caregivers to assist with physical tasks. Despite successfully completing initial steps of the application process, her physician’s medical statement indicated she was physically incapable of caring for a foster child. The private agency overseeing her application, after home visits and a review of her situation, recommended against granting her a foster license, citing several state regulatory provisions related to the physical and mental health required of foster parents. The state agency subsequently administratively closed her application, permitting her to reapply at any time or provide additional information.The United States District Court for the Eastern District of Michigan reviewed the case after the applicant sued the State of Michigan, individual officials, and the private agency, alleging violations of the Americans with Disabilities Act (ADA), the Rehabilitation Act, and the Equal Protection Clause. The parties filed cross-motions for summary judgment. The district court granted summary judgment in favor of the defendants on all claims, finding that the applicant’s proposed accommodation—her network of aides—was not a reasonable accommodation under the ADA or Rehabilitation Act, and that the defendants’ actions were rationally related to legitimate state interests.The United States Court of Appeals for the Sixth Circuit affirmed the district court’s grant of summary judgment. The court held that while the ADA and Rehabilitation Act require individualized assessments and reasonable accommodations, the applicant’s patchwork of formal and informal assistance did not reliably assure the physical care of foster children, making her accommodation request unreasonable. The court also found no facial disability discrimination in Michigan’s foster care regulations and concluded that the defendants’ actions did not violate Equal Protection, as they were rationally related to ensuring child safety. View "Metcalf v. Michigan" on Justia Law

A woman who immigrated to the United States as a child and later became a lawful permanent resident was convicted in North Carolina state court of two counts of common-law forgery and, in a separate proceeding, possession of marijuana. Years after serving her sentences, she was placed in removal proceedings when reentering the U.S. after a trip to Mexico. She conceded that her convictions made her inadmissible but sought a discretionary waiver that could allow her to remain in the country. While her removal case was pending, she successfully moved in state court to have her marijuana conviction vacated and the charge dismissed.The Immigration Judge denied her application for a waiver, concluding, among other things, that she could not show her marijuana offense involved 30 grams or less, did not prove extreme hardship, and was not entitled to relief as a matter of discretion. The judge did, however, grant her voluntary departure. On appeal, the Board of Immigration Appeals (BIA) independently determined that, under its established framework from Matter of Pickering, a conviction vacated for reasons other than substantive or procedural defect—such as to avoid immigration consequences—still counts for immigration purposes. The BIA found her vacated conviction still disqualified her from a waiver and denied her motion to remand for further proceedings.The United States Court of Appeals for the Fourth Circuit reviewed the BIA’s decision de novo. The court held that, under 8 U.S.C. § 1182(a)(2)(A)(i), a person whose state conviction has been vacated and the charge dismissed is not an “alien convicted of” that offense for immigration purposes. The court rejected the BIA’s Pickering framework as inconsistent with the statute. The petition for review was granted in part regarding the vacated conviction but denied as to the challenge to voluntary departure regulations, which the court found reasonable. View "Piedra v. Blanche" on Justia Law

A researcher and military veteran requested two volumes of a report created by the House Appropriations Committee (HAC) from the National Security Agency (NSA) under the Freedom of Information Act (FOIA). The HAC report, prepared in response to the 1967 attack on the U.S.S. Liberty, examined Department of Defense communications failures. The NSA had received a copy of this report from Congress in 1968. The report bore a prominent banner stating, “NOT FOR RELEASE UNLESS AND UNTIL AUTHORIZED BY COMMITTEE,” and was marked “TOP SECRET.” The NSA had never publicly released the report, though it was cited in a later declassified NSA report about the Liberty incident.The NSA denied the FOIA request, asserting that the report was not an agency record subject to FOIA because it was created by and remained under the control of the U.S. House of Representatives. The requester filed suit in the United States District Court for the Western District of Washington. The district court, referencing the D.C. Circuit’s standard for congressional documents, granted summary judgment in favor of the NSA, finding that Congress had manifested a clear intent to control the document, keeping it outside FOIA’s reach. After a voluntary remand for additional disclosures, the district court again granted summary judgment to the NSA.On appeal, the United States Court of Appeals for the Ninth Circuit affirmed the district court’s decision. The appellate court formally adopted the D.C. Circuit’s test: a document prepared by Congress and provided to an agency is not subject to FOIA if Congress has clearly manifested its intent to retain control. The court held that the HAC report’s prominent restriction banner demonstrated such intent, and thus, the report was not an agency record under FOIA. The judgment in favor of the NSA was affirmed. View "KINNUCAN V. NATIONAL SECURITY AGENCY" on Justia Law

A city council adopted a resolution to rename three historically significant streets—East Kings Canyon Road, East Ventura Avenue, and West California Avenue—in honor of Cesar Chavez, a prominent labor leader and civil rights activist. The plaintiff, an association of residents and business owners on or near these streets, opposed the renaming, arguing that it disrupted their personal and community identities, imposed financial and administrative burdens, and forced them to be associated with a political figure they found objectionable. The association also alleged that the renaming process was procedurally unfair and failed to provide adequate notice or opportunity for input from those affected.After the city proceeded with the renaming, the plaintiff filed suit in the Superior Court of Fresno County, raising claims that the city’s action constituted an invalid exercise of police power, violated due process, infringed on free speech and association rights, amounted to waste of public funds, and denied equal protection. The Superior Court sustained the city’s demurrer to the due process, free speech, and equal protection claims, and granted summary judgment to the city on the police power and waste claims, finding the city’s actions valid and within its discretion.On appeal, the California Court of Appeal, Fifth Appellate District, considered the case even though the city had reverted the street names after new information about Cesar Chavez emerged. Applying the public interest exception to mootness, the court affirmed the Superior Court’s judgment. The appellate court held that the renaming constituted government speech, which is generally not subject to free speech protections, and did not compel residents or business owners to espouse a particular message. The court further held that the city’s action was a valid exercise of its police power, reasonably related to a legitimate governmental objective, and that the use of public funds for the renaming was discretionary and not subject to challenge as waste. The court’s decision affirmed the judgment in favor of the city. View "1 Community Compact v. City of Fresno" on Justia Law

Several nonprofit organizations and associations that receive federal funding challenged a memorandum issued by the Office of Management and Budget (OMB) shortly after President Trump’s return to office in 2025. The memorandum, M-25-13, directed federal agencies to temporarily pause the obligation and disbursement of all federal financial assistance to analyze compliance with recent executive orders. Plaintiffs argued that the memorandum called for a sweeping freeze on virtually all federal funding, which they alleged would have catastrophic consequences for federally funded programs.The United States District Court for the District of Columbia initially responded to plaintiffs’ request for emergency relief by issuing a temporary restraining order, and later a preliminary injunction, barring OMB from implementing the memorandum. The district court found that the memorandum was likely to be arbitrary and capricious and possibly beyond OMB’s statutory authority. The court rejected the government’s argument that the case was moot after OMB rescinded the memorandum, relying in part on statements from the White House Press Secretary and ongoing funding disruptions.The United States Court of Appeals for the District of Columbia Circuit reviewed the preliminary injunction. It did not address the merits of the plaintiffs’ legal arguments or the district court’s interpretation of the memorandum. Instead, it concluded that the plaintiffs’ challenge was likely moot because OMB had rescinded the memorandum before the government knew of the lawsuit and had clarified, in guidance issued the day after the memorandum, that a global funding freeze was not intended. The court found that there was no reasonable expectation the government would reissue the challenged action. As a result, the court vacated the preliminary injunction. View "National Council of Nonprofits v. OMB" on Justia Law

The plaintiffs in this case, the State of California and the Giffords Law Center to Prevent Gun Violence, challenged a federal regulation issued by the Bureau of Alcohol, Tobacco, Firearms, and Explosives (ATF). The regulation expanded the scope of the Gun Control Act to cover certain partially complete, disassembled, or nonfunctional firearm frames and receivers, but explicitly stated that some unfinished components—such as those not sold with instructions or tools for completion—were not subject to the Act. California claimed that, as a result of the regulation’s limitations, it was forced to increase financial and training expenditures related to state law enforcement and the regulation of “ghost guns.” Giffords Law Center asserted that its core mission was frustrated by the regulation, requiring it to divert resources to address increased ghost gun proliferation.In the United States District Court for the Northern District of California, the plaintiffs and defendants filed cross-motions for summary judgment. The district court concluded that both California and the Giffords Law Center had standing to bring suit. On the merits, the district court granted summary judgment for ATF on one count, but for the plaintiffs on another, holding that the regulation was arbitrary and capricious. The district court declared the challenged portion of the regulation unlawful, vacated it, and remanded the matter to ATF.On appeal, the United States Court of Appeals for the Ninth Circuit reviewed the district court’s decision de novo. Focusing on Article III standing, the Ninth Circuit found that the plaintiffs failed to establish a causal connection between the challenged regulatory example and their alleged injuries. The court held that the plaintiffs’ asserted harms were too speculative and not fairly traceable to the regulation. As a result, the Ninth Circuit vacated the district court’s order and remanded the case with instructions to dismiss it without prejudice for lack of standing. View "STATE OF CALIFORNIA V. UNITED STATES BUREAU OF ALCOHOL TOBACCO FIREARMS AND EXPLOSIVES" on Justia Law

The case centers on whether John A. Sarcone III lawfully served as Acting U.S. Attorney for the Northern District of New York. After the departure of the Senate-confirmed U.S. Attorney, Sarcone was appointed as Interim U.S. Attorney for 120 days under 28 U.S.C. § 546. When his term expired, the district court did not appoint a permanent replacement, leaving the office vacant. The Department of Justice then reassigned the prior First Assistant to another role and designated Sarcone as the new First Assistant (FAUSA), claiming this made him Acting U.S. Attorney under the Federal Vacancies Reform Act of 1998 (FVRA). Sarcone subsequently issued two grand jury subpoenas to the New York State Attorney General’s Office regarding investigations into the National Rifle Association and Donald J. Trump.The United States District Court for the Northern District of New York granted the New York Attorney General’s motion to quash the subpoenas, holding that Sarcone had not lawfully become Acting U.S. Attorney under the FVRA since he was not the First Assistant at the time the vacancy arose. The court also found that the Attorney General’s general delegation of all U.S. Attorney duties to Sarcone was an impermissible circumvention of the FVRA. The court disqualified Sarcone from further involvement in the investigations.The United States Court of Appeals for the Second Circuit affirmed the district court’s decision. The court held that the FVRA only permits automatic succession by a First Assistant who is already in office when the vacancy arises. It further held that a general delegation of all duties is not a lawful means to install an acting official, as it would undermine the FVRA’s exclusivity provision. Because the government did not substantively contest Sarcone’s disqualification on appeal, the court treated that issue as forfeited and affirmed the district court’s order. View "In re Grand Jury Subpoenas to the Office of the New York State Attorney General" on Justia Law

A veteran who served in the U.S. Army from 1969 to 1972 and deployed to Vietnam sought disability benefits for post-traumatic stress disorder (PTSD) through four claims. His first claim in 1987 was denied due to his failure to attend a required examination. He filed a second claim in 1990, providing additional details, but it was denied for lack of evidence of a stressor or diagnosis. A third claim in 2000 was also denied for similar reasons. In 2007, he filed a fourth claim to reopen, providing further information about his service. During the appeal of the 2007 denial, he obtained and submitted new service department records in 2008 that supported his PTSD claim. Ultimately, the Department of Veterans Affairs (VA) awarded him benefits with an effective date corresponding to his 2007 claim to reopen.The Board of Veterans’ Appeals concluded in 2022 that reconsideration of his claim was warranted based on the new records and granted an effective date of 1990, finding he had provided sufficient information in his 1990 claim but not in his 1987 claim. The United States Court of Appeals for Veterans Claims affirmed, holding that the version of 38 C.F.R. § 3.156(c) in effect when the new records were associated with the file (the 2006 amended version) applied, rather than the prior version.The United States Court of Appeals for the Federal Circuit reviewed whether applying the 2006 regulation to the veteran’s claims was impermissibly retroactive. The court held that the regulation’s application is triggered by the VA’s receipt or association of new and relevant service department records, and since this occurred after the 2006 amendment, applying the new regulation was proper. The court affirmed the Veterans Court’s decision. View "MILLER v. COLLINS " on Justia Law

After the death of Grady L. Floyd, Sr. in Escambia County, Alabama, his family members alleged that the local medical examiner, Dr. J. Daniel Raulerson, mishandled Grady’s remains. According to the family, Dr. Raulerson failed to properly store the body, resulting in advanced decomposition, which prevented an autopsy and required cremation rather than a traditional funeral. The plaintiffs attributed this mishandling to inadequate storage and refrigeration at the county morgue, which was located at the local hospital.The plaintiffs initially sued the Escambia County Commission, individual county commissioners in both their official and personal capacities, the hospital, and later the Alabama Department of Forensic Sciences (ADFS). Their main allegations against the county defendants were based on a theory of vicarious liability for Dr. Raulerson’s actions, rather than any independent wrongdoing by the county or its commissioners. The Escambia Circuit Court denied the county defendants’ motion to dismiss the claims on immunity grounds, but granted ADFS’s motion to dismiss, finding it immune from suit.On mandamus review, the Supreme Court of Alabama considered whether the county defendants were immune from the plaintiffs’ claims. The court held that Dr. Raulerson, as medical examiner, was expressly granted immunity from civil liability for acts performed in his official capacity by § 45-27-60.11, Ala. Code 1975. Because the plaintiffs’ claims against the county defendants were entirely derivative of Dr. Raulerson’s acts, and he was immune, the county defendants could not be held vicariously liable. The Supreme Court of Alabama therefore granted the petition for writ of mandamus and directed the trial court to dismiss all claims against the county defendants. View "Ex parte Escambia County Commission" on Justia Law