Justia Government & Administrative Law Opinion Summaries

A county attorney in Montana advised local officials not to provide confidential criminal justice information (CCJI) to Immigration and Customs Enforcement (ICE) for civil purposes without a court order, citing Montana law. The Montana Attorney General disagreed, asserting that ICE is a “criminal justice agency” entitled to access such information and ordered the county attorney to change her policy. When the county attorney requested a formal opinion, the Attorney General refused, then formally asserted supervisory control, requiring the county attorney to issue a memo permitting full disclosure of CCJI to ICE. The county attorney complied under protest and filed a petition with the Supreme Court of Montana seeking a declaratory judgment on the matter.The Attorney General claimed the dispute was nonjusticiable, arguing it was a political question, that the county attorney lacked standing, and that any opinion would be advisory. The Supreme Court of Montana found these arguments unpersuasive. The Court determined that the county attorney had standing because she is an independently elected official with statutory duties, including advising county officials, and the Attorney General’s supervisory authority does not extend to this advisory function. The Court also concluded that the dispute did not present a political question or an advisory opinion and thus was justiciable.The Supreme Court of the State of Montana held that the county attorney’s petition is properly before the Court and that the Attorney General exceeded his authority by attempting to direct the county attorney’s legal advice to county officials. The Court declared the Attorney General’s order unenforceable. The Court did not decide whether ICE is a “criminal justice agency” under Montana law but ordered further briefing on that issue and whether such agencies are automatically entitled to CCJI solely by virtue of their status. View "Cromwell v. Knudsen" on Justia Law

A nonprofit organization planned to run several political advertisements critical of socialism and the Democratic Socialists of America ahead of the 2025 New York City Mayoral Election. New York’s independent expenditure disclosure law, which requires entities spending money on political elections to register and disclose information about their expenditures, was interpreted by state regulators to cover these advertisements, as the only citywide candidate affiliated with the DSA was running for mayor. The organization feared enforcement of the law against its ads and sought judicial relief.After filing its complaint in the United States District Court for the Southern District of New York, the organization moved for a preliminary injunction to prevent the State from enforcing the disclosure law against its advertisements before the upcoming election. The district court denied this emergency motion. The organization then appealed the denial to the United States Court of Appeals for the Second Circuit while the underlying challenge to the law was stayed in the district court at the organization’s request.The United States Court of Appeals for the Second Circuit dismissed the appeal as moot. The court explained that the motion for preliminary injunction sought relief only for an injury related to the 2025 mayoral election, which had already occurred, making it impossible for the appellate court to grant effectual relief. The court further held that the “capable of repetition, yet evading review” exception to mootness did not apply because the underlying action remained pending in the district court, and thus could still be litigated and reviewed in the future. The appeal was therefore dismissed for lack of a live controversy, with instructions that any future appeals concerning preliminary injunctions in this matter would be heard by the same panel. View "Am. Future Fund, Inc. v. N.Y. Bd. of Elections" on Justia Law

After a new audio and visual system was installed in a county courthouse, including microphones for security and meeting purposes, certain county board members discovered that audio feeds were accessible during closed meetings and private sessions. This led to concerns about privacy and prompted the board to hire a special attorney and deputy to investigate potential breaches of courthouse security and possible violations of law. A district court determined that a conflict of interest prevented the special attorney from conducting a related criminal investigation and instead appointed the Nebraska Attorney General’s office as a special prosecutor. The court ordered that investigative materials be sealed. After the special prosecutor declined to file charges, the special prosecutor’s appointment was terminated, and additional records summarizing the investigation were also sealed.Subsequently, the board’s own civil investigation led to discipline or discharge of several employees, including a former county attorney whose name had been reported for possible professional misconduct. This former county attorney later moved in the original miscellaneous court file to unseal the records related to the special prosecutor’s investigation, arguing that the documents could be relevant to ongoing litigation and reputational interests. The special prosecutor did not oppose unsealing, but the board, represented by the special attorney, objected, arguing lack of subject matter jurisdiction and insufficient grounds for unsealing. The District Court for Knox County found it had jurisdiction, determined good cause existed, and ordered the records unsealed.On appeal, the Nebraska Supreme Court reviewed whether it had appellate jurisdiction over the district court’s order. The court held that the order to unseal records in a special proceeding was not a final, appealable order because the board failed to demonstrate that any substantial right was affected by unsealing. Therefore, the Nebraska Supreme Court dismissed the appeal for lack of jurisdiction. View "In re Special Knox Cty. Atty. Begley" on Justia Law

The plaintiff brought suit against a municipal defendant, raising several claims related to alleged procedural violations during a city council meeting, including purported breaches of Nebraska’s Open Meetings Act. The plaintiff sought to void actions taken at that meeting. The defendant responded by moving to dismiss the complaint for failure to state a claim. After a hearing, the District Court for Custer County dismissed most of the plaintiff’s claims but allowed five to proceed. Subsequently, the plaintiff withdrew two causes of action, and the court held a trial on the remaining three. The court determined it lacked jurisdiction over certain claims and found the plaintiff had not met the burden of proof, ultimately denying all requested relief.Following the district court’s entry of a judgment in April 2026, the plaintiff appealed. The Nebraska Court of Appeals summarily dismissed the appeal, concluding it lacked jurisdiction because, in its view, the district court had not rendered a judgment in compliance with Nebraska statutory requirements. The Court of Appeals relied on the absence of a “single written document” as prescribed by statute and cited the Nebraska Supreme Court’s prior decisions interpreting those requirements.The Nebraska Supreme Court reviewed the dismissal for plain error. It held that the district court had rendered judgment by signing a single written document that denied all relief and stated judgment was entered against the plaintiff and for the defendant as to each cause of action. The Supreme Court clarified that a judgment exists without explicit dismissal language, provided all relief is addressed in one signed document. The Court reversed the Court of Appeals’ dismissal and remanded the case for further proceedings, concluding the appellate court had jurisdiction over the appeal. View "Koch v. City of Sargent" on Justia Law

The dispute involved actions by city officials in Helena-West Helena, Arkansas, concerning two ordinances passed in December 2022 by outgoing city council members. These ordinances, among other things, increased the mayor’s salary from $48,000 to $70,000. The outgoing mayor attempted to veto these ordinances, but the newly elected mayor, Christopher Franklin, sought to rescind the veto. Greg Williams, a local resident, challenged the validity of the ordinances, arguing they had been properly vetoed and were therefore void.The Phillips County Circuit Court initially granted a temporary restraining order against implementation of the ordinances and, after a hearing, issued a declaratory judgment holding the two ordinances null and void. The court did not issue a permanent injunction. The City appealed, and the Supreme Court of Arkansas affirmed the Circuit Court’s declaratory judgment. Subsequently, Williams filed for contempt against Franklin, alleging he had violated the court’s order by accepting the increased salary. The Circuit Court found Franklin in civil contempt for willfully disobeying the declaratory judgment and ordered him to repay part of his salary or face jail.The Supreme Court of Arkansas reviewed the contempt order. The court held that a declaratory judgment, which only settles the rights and obligations of the parties without compelling or prohibiting specific actions, cannot be enforced by contempt; only injunctive orders may be enforced in this manner. Since the Circuit Court’s order was a declaratory judgment, and not an injunction, the contempt finding was improper. The Supreme Court of Arkansas reversed the Circuit Court’s contempt order and dismissed the contempt proceedings. View "FRANKLIN v. WILLIAMS" on Justia Law

A group of local United Methodist churches, through their trustees, sought to disaffiliate from the United Methodist Church while retaining ownership of their church property. This dispute arose amid a broader doctrinal disagreement within the denomination, particularly regarding the ordination of homosexual clergy and performance of same-sex weddings. The Conference, representing the denomination’s regional authority, asserted that church property was held in trust for the benefit of the entire denomination and could not be retained by a local church upon disaffiliation except as authorized by church law. The local churches alleged that the Conference engaged in fraudulent and collusive conduct, including misrepresentations about the procedures and timing for lawful disaffiliation, which caused them to miss the window for disaffiliation with property under denominational rules.The Circuit Court of Mercer County initially dismissed the complaint, holding that it lacked subject matter jurisdiction under the ecclesiastical abstention doctrine since the dispute required interpretation of church doctrine and governance—a matter reserved for the church’s highest tribunals. The court found that the allegations of fraud and collusion did not pertain to the procurement of a final ecclesiastical adjudication. However, following a Rule 59(e) motion by the local churches, a different judge vacated the prior dismissal, determining that the allegations of fraud and collusion raised factual questions for a jury and reopened the case.The Supreme Court of Appeals of West Virginia reviewed the matter on a petition for a writ of prohibition. The court held that constitutional limitations under the First Amendment and the West Virginia Constitution prevented civil courts from adjudicating disputes involving church doctrine, discipline, or governance. The court further clarified that the fraud or collusion exception only applies if such conduct procured a final ecclesiastical adjudication, which was not alleged here. The writ of prohibition was granted, barring enforcement of the order reopening the case, and reaffirming the circuit court’s lack of jurisdiction. View "State ex rel. Trustees of the West Virginia Conference of the United Methodist Church v. Wills" on Justia Law

A wrongful death action was brought by the administratrix of a decedent’s estate against an employee of Adult Protective Services (APS) and the West Virginia Department of Human Services (DHS). The decedent, a vulnerable adult, lived with family members and required assistance with daily activities. A referral alleging abuse and neglect was made to APS, prompting multiple visits and interviews by the APS worker, who documented improvements made to the residence and ultimately closed the referral without removing the decedent from the home or contacting law enforcement. The complaint alleged that the APS worker’s decisions, including closing the referral and failing to remove the decedent or report to authorities, proximately caused the decedent’s death.The Circuit Court of Logan County denied motions to dismiss filed by the APS employee and DHS, concluding that whether the acts were ministerial, violated statutory duties, or constituted willful, wanton, or intentional misconduct presented questions of fact for a jury. The circuit court declined to apply the qualified immunity doctrine at the motion to dismiss stage, asserting issues regarding statutory violations and the nature of the conduct required jury determination.The Supreme Court of Appeals of West Virginia reviewed the appeal, applying a de novo standard. The court held that the APS worker’s actions were discretionary and thus subject to qualified immunity, absent allegations of violation of a clearly established statutory or constitutional right, or conduct that was fraudulent, malicious, or oppressive. The court found that the complaint failed to plead sufficient facts to overcome qualified immunity and did not establish a causal link between the APS worker’s actions and the decedent’s death. Accordingly, the court reversed the circuit court’s denial of the motions to dismiss and remanded with instructions to grant the motions to dismiss. View "Secrist v. Watkins" on Justia Law

A company sought a lease from the Wyoming Board of Land Commissioners to develop a wind energy project on state land in Converse County. This project was designed to power a green hydrogen facility, with grid connection being possible but not necessary. The applicant engaged stakeholders and amended its proposal in response to feedback, including reducing the project’s footprint and number of turbines. Public comments were received, most expressing opposition. After a public meeting and legal consultation, the Board approved the lease.Stephens Land and Livestock, LLC, which owns property adjacent to the leased state land, challenged the Board’s approval in the District Court of Converse County. Stephens argued that the lease approval was not in accordance with law, exceeded statutory authority, and violated Board rules, including a requirement that wind energy leases involve connection to the transmission grid. The district court found that Stephens had standing, concluded the Board’s rules required grid connection for wind energy leases, and reversed the lease approval.On appeal, the Supreme Court of Wyoming reviewed the Board’s decision as if it came directly from the agency. The Court held that Stephens had standing due to immediate, substantial, and pecuniary interests affected by the project. Interpreting the Board’s rules, the Court found the term “including” to be expansive, meaning grid connection is one example of a permissible use, not a requirement. The Court concluded the lease approval was in accordance with law and did not conflict with the Board’s definition of “Wind Energy Leasing.”The Court further addressed and rejected Stephens’s additional legal arguments, finding the Board complied with its statutory duties, did not violate relevant executive orders or rules, and provided adequate financial assurances. The Supreme Court of Wyoming affirmed the Board’s approval of the wind energy lease. View "Pronghorn H2, LLC v. Stephens Land and Livestock, LLC" on Justia Law

A city council in Ohio advanced a proposed ordinance to the voters for approval at the November 2026 general election. The measure, known as Issue 16, sought to increase the city’s income tax rate from 1.5% to 1.9% for six years, with the additional revenue earmarked for infrastructure improvements and equipment purchases. The proposed ordinance would maintain the existing cap on the credit residents could claim for taxes paid to other municipalities, meaning residents working elsewhere would not receive a credit for the 0.4% increase. The city council approved the ballot language, which was then reviewed and approved by the county board of elections and the Ohio Secretary of State.Individuals and organizations opposing the tax increase challenged the ballot language, arguing it was misleading for failing to inform voters about the unchanged credit provision. They sought a writ of mandamus to invalidate Issue 16 and impound the election results. The relators also attempted to bring the action as a statutory taxpayer suit and requested attorney fees.Before the Supreme Court of Ohio, the respondents argued that the claims lacked standing, were barred by laches due to delay, and that the ballot language complied with applicable law. The court dismissed the claims of one organization for lack of standing, finding it was not composed of local electors. The court also found the relators had not properly commenced a statutory taxpayer action and denied their motion for costs and attorney fees.The Supreme Court of Ohio held that the board of elections and Secretary of State did not abuse their discretion or disregard the law, as the ballot language complied with the specific statutory requirements for municipal-income-tax issues under R.C. 718.04(C)(2). The court denied the writ of mandamus and the request for attorney fees, and dismissed the claims of the non-elector organization for lack of standing. View "State ex rel. Avon Lake Commt. for the Citizens and Electors Rights to Vote on City Income Tax Increases v. Gracia" on Justia Law

In 2023, the Tennessee General Assembly enacted a statute imposing a cap of twenty voting members on metropolitan councils, affecting the Metropolitan Government of Nashville and Davidson County, which had a forty-member council. Metro Nashville and several individual plaintiffs challenged the statute, arguing it violated the Local Legislation Clause and the Exemption Clause of the Tennessee Constitution. They sought declaratory and injunctive relief to prevent implementation of the law.The Chancery Court for Davidson County, sitting as a three-judge panel, held that the cap violated both constitutional provisions and issued a permanent injunction against enforcement. The panel found some claims moot due to expired compliance deadlines but concluded that the main cap provision remained justiciable. The Court of Appeals reversed, holding that the cap did not violate either clause and that the claims were not moot, except as to certain implementation provisions.After granting permission to appeal, the Supreme Court of Tennessee reviewed the case. During the proceedings, the General Assembly amended the statute, removing the implementation provisions and the language linking the cap to those provisions. The Supreme Court determined that these amendments rendered the Local Legislation Clause claim moot, as the alleged defect no longer existed. The Court vacated the Court of Appeals’ judgment on this issue and instructed the trial court to dismiss the claim.The Court further held that the Exemption Clause claim remained justiciable but, on the merits, concluded that the Exemption Clause only exempts consolidated governments from constitutional requirements regarding legislative bodies, not from statutory requirements imposed by the legislature. Therefore, the twenty-member cap does not violate the Exemption Clause. The Supreme Court of Tennessee affirmed the Court of Appeals’ judgment on this issue and remanded the case for further proceedings consistent with its opinion. View "Metropolitan Government of Nashville and Davidson County v. Lee" on Justia Law