Justia Government & Administrative Law Opinion Summaries

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Ming Zheng, a drilling field engineer, suffered a work-related injury to her right ankle while attempting to disassemble a tool string. She reported the injury and received workers' compensation benefits. Approximately a year later, Zheng sought additional benefits for an injury to her left ankle and requested preauthorization for surgery on her right ankle. The Wyoming Department of Workforce Services, Workers' Compensation Division, denied these requests, finding the treatments were not related to her original work injury. The Division also discontinued her temporary total disability benefits after she received a 0% impairment rating.The Wyoming Medical Commission upheld the Division's denial of benefits and discontinuation of temporary total disability benefits after a contested case hearing. The Commission found that Zheng failed to prove the requested treatments for her left ankle were related to her compensable work injury and that the surgery on her right ankle was necessary. The district court affirmed the Medical Commission's decision.The Wyoming Supreme Court reviewed the case and affirmed the lower court's decision. The Court held that substantial evidence supported the Medical Commission's findings that Zheng's left ankle issues were not related to her work injury and that the requested surgery on her right ankle was not necessary. The Court also found that the Medical Commission did not act arbitrarily or capriciously in admitting an addendum to Dr. Orth's independent medical evaluation, as Zheng had the opportunity to cross-examine Dr. Orth and present rebuttal evidence. The Court concluded that the Medical Commission's decision was supported by substantial evidence and was not arbitrary or capricious. View "Zheng v. State of Wyoming, Ex Rel. Department of Workforce Services" on Justia Law

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Tenaska Clear Creek Wind, LLC ("Clear Creek") sought to generate wind energy for sale in parts of Missouri, southeast Iowa, and northeast Oklahoma. Clear Creek challenged the Federal Energy Regulatory Commission's (FERC) decision to allow Southwest Power Pool, Inc. (SPP) to assign over $100 million in upgrade costs to Clear Creek for its wind turbine project. Clear Creek argued that FERC's decision was arbitrary, capricious, and contrary to precedent.Initially, Clear Creek submitted an interconnection request to Associated Electric Cooperative, Inc. (AECI) and requested Network Resource Interconnection Service (NRIS). AECI identified SPP and Midcontinent Independent System Operator, Inc. (MISO) as potentially affected systems. SPP conducted several studies, initially estimating upgrade costs at $31.2 million, which later fluctuated significantly. Clear Creek began construction based on initial studies but faced a restudy by SPP, which increased the estimated costs to $763 million, later adjusted to $102 million. Clear Creek filed a complaint with FERC, which partially granted and partially denied the complaint, requiring SPP to restudy the project using updated models. The restudy resulted in $88 million in upgrade costs.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court upheld FERC's orders, finding that SPP's methodology for assigning upgrade costs was consistent with the "but for" cost allocation principle and not arbitrary or capricious. The court also found that Clear Creek's downgrade to Energy Resource Interconnection Service (ERIS) did not moot the case, as Clear Creek retained the right to re-open the matter if it prevailed. The court concluded that FERC's decision was based on reasoned decision-making and substantial evidence, denying Clear Creek's petitions for review. View "Tenaska Clear Creek Wind, LLC v. FERC" on Justia Law

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The Environmental Protection Agency (EPA) updated its regulations to ensure that the transportation fuel mix in the United States contains the required amounts of renewable fuel. The new regulations specifically address biogas-derived renewable fuel, implementing a more structured process to prevent fraud and error. The Coalition for Renewable Natural Gas, representing industry stakeholders, petitioned to overturn these changes, arguing that the new rules were too rigid and burdensome.The case was reviewed by the United States Court of Appeals for the District of Columbia Circuit. The Coalition argued that the EPA lacked authority to regulate biogas producers and that the new requirements were arbitrary and capricious. They also claimed procedural violations in the rulemaking process. The EPA defended its regulations, stating that they were necessary to ensure compliance with renewable fuel standards and to prevent fraud and double counting.The Court of Appeals found that the EPA acted within its authority under the Clean Air Act to regulate biogas producers and that the new rules were reasonable and supported by substantial evidence. The court also held that the EPA had followed proper procedures in adopting the rule. The court denied the Coalition's petition for review, upholding the EPA's updated regulations. The main holding was that the EPA's modifications to the biogas-derived renewable fuel regulations were reasonable and necessary to ensure compliance with renewable fuel standards and to prevent fraud. View "Coalition for Renewable Natural Gas v. EPA" on Justia Law

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T.W., a Harvard Law School graduate with disabilities, sued the New York State Board of Law Examiners for denying her requested accommodations on the New York State bar exam in 2013 and 2014. She alleged violations of Title II of the Americans with Disabilities Act (ADA) and Section 504 of the Rehabilitation Act. T.W. claimed that the Board's actions caused her to fail the bar exam twice, resulting in professional and financial harm.The United States District Court for the Eastern District of New York initially denied the Board's motion to dismiss, finding that the Board had waived its sovereign immunity under the Rehabilitation Act. However, the United States Court of Appeals for the Second Circuit reversed this decision, holding that the Board was immune from suit under Section 504. On remand, the district court granted the Board's motion to dismiss T.W.'s Title II claim, ruling that the Board was an "arm of the state" and entitled to sovereign immunity. The court also held that Title II did not abrogate the Board's sovereign immunity for money damages and that T.W. could not seek declaratory and injunctive relief under Ex parte Young.The United States Court of Appeals for the Second Circuit affirmed the district court's decision. The court held that the Board is an arm of the state and thus entitled to sovereign immunity. It further concluded that Title II of the ADA does not validly abrogate sovereign immunity in the context of professional licensing. Additionally, the court found that the declaratory relief sought by T.W. was retrospective and therefore barred by the Eleventh Amendment. The court also ruled that the injunctive relief sought by T.W. was not sufficiently tied to an ongoing violation of federal law, making it unavailable under Ex parte Young. Consequently, the court affirmed the dismissal of T.W.'s claims for compensatory, declaratory, and injunctive relief. View "T.W. v. New York State Board of Law Examiners" on Justia Law

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A state trooper brought his patrol vehicle to a car dealership for service, accompanied by his canine, Diesel. During the visit, Diesel attacked and injured an employee, Cristina Berrier, without provocation. Berrier suffered serious injuries and subsequently sued the Minnesota State Patrol, alleging negligence and later indicating her intention to pursue a claim under Minnesota’s strict liability dog-bite statute, Minn. Stat. § 347.22.The district court denied the State Patrol’s motion to dismiss, concluding that Berrier’s complaint sufficiently pleaded her statutory claim and that the dog-bite statute waived sovereign immunity. The State Patrol appealed, and the Minnesota Court of Appeals reversed, holding that the State Patrol was immune from suit under the doctrine of sovereign immunity. The appellate court did not address whether Berrier adequately pleaded her statutory dog-bite claim.The Minnesota Supreme Court reviewed the case to determine if the dog-bite statute waived sovereign immunity. The court concluded that the language of Minn. Stat. § 347.22, which imposes liability on the "owner" of a dog, was sufficiently plain, clear, and unmistakable to waive sovereign immunity. The court emphasized that the statute’s broad application to any dog owner, including state entities, served the public policy interest of protecting individuals from dog attacks and ensuring their full recovery. Consequently, the court reversed the appellate court’s decision and remanded the case for further proceedings. View "Hennesy vs. Minnesota State Patrol" on Justia Law

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Healthy Blue, a vendor, submitted a proposal to operate Nebraska’s Medicaid managed care program but was not selected. After its bid protest and request for reconsideration were denied by the Nebraska Department of Health and Human Services (DHHS), Healthy Blue filed a lawsuit in the district court for Lancaster County against state officials and the winning bidders. Healthy Blue sought declaratory and injunctive relief under the Uniform Declaratory Judgments Act (UDJA), claiming DHHS acted unlawfully in awarding the contracts.The district court overruled the state officials' motion to dismiss, which argued that Healthy Blue lacked standing as a taxpayer and that the claim was barred by sovereign immunity. The court found that Healthy Blue adequately pled taxpayer standing and that the claim was not barred by sovereign immunity because it sought relief from an invalid act by public officers. The state officials then moved for summary judgment, reiterating their sovereign immunity argument. The district court denied this motion, maintaining that the claim was an official-capacity suit not barred by sovereign immunity.The Nebraska Supreme Court reviewed the case. The court held that the state officials' motion for summary judgment was not based on the assertion of sovereign immunity, as they did not appeal the district court's ruling that the claim was an official-capacity suit. The court emphasized that standing and sovereign immunity are distinct jurisdictional concepts and that the question of standing can be reviewed on appeal of a final order without being effectively lost. Consequently, the Nebraska Supreme Court dismissed the appeal for lack of jurisdiction. View "Community Care Health Plan of Nebraska, Inc. v. Jackson" on Justia Law

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A group of plaintiffs, including several states and corporations, challenged a Department of Labor rule that allowed ERISA fiduciaries to consider environmental, social, and governance (ESG) factors when making investment decisions if those factors equally serve the financial interests of the plan. This rule was issued following an executive order by President Biden, which counteracted a previous Trump-era rule that prohibited considering non-pecuniary factors in investment decisions.The United States District Court for the Northern District of Texas upheld the Department of Labor's rule, relying on the Chevron deference doctrine, which allows courts to defer to a federal agency's interpretation of ambiguous statutory language. The district court concluded that the rule was not "manifestly contrary to the statute" after affording the Department the deference due under Chevron.The United States Court of Appeals for the Fifth Circuit reviewed the case. During the appeal, the Supreme Court decided Loper Bright Enterprises v. Raimondo, which overruled Chevron, thus eliminating the deference previously given to agency interpretations. Given this significant change in the legal landscape, the Fifth Circuit vacated the district court's judgment and remanded the case for reconsideration in light of the new Supreme Court decision. The appellate court emphasized the importance of allowing the district court to reassess the merits without the Chevron framework, ensuring that the lower court's independent judgment is applied to the statutory interpretation of ERISA. View "State of Utah v. Su" on Justia Law

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In September 2021, the San Diego Unified School District (District) proposed a "Vaccination Roadmap" requiring students to be vaccinated against COVID-19 to attend in-person classes and participate in extracurricular activities. Plaintiffs, including an organization and an individual parent, challenged the District's authority to impose this requirement, arguing that such decisions must be made at the state level. The trial court agreed, ruling that the Roadmap was preempted by state law, and judgment was entered in favor of the plaintiffs.The District appealed, and the Court of Appeal, Fourth Appellate District, affirmed the trial court's decision, holding that the local vaccination requirement conflicted with state law and that the state had fully occupied the field of school vaccination mandates. Following this decision, the plaintiffs sought attorney’s fees under California's private attorney general statute, Code of Civil Procedure section 1021.5. The trial court denied the motions, reasoning that the litigation did not enforce an important right affecting the public and that the District's actions were commendable and did not adversely affect the public interest.The Court of Appeal, Fourth Appellate District, reversed the trial court's denial of attorney’s fees. The appellate court held that the plaintiffs' lawsuit enforced an important public right by ensuring that the District complied with state law regarding school vaccination requirements. The court emphasized that the litigation conferred a significant benefit on the general public by upholding the state's comprehensive immunization policy. The court also rejected the trial court's rationale that the District's good intentions precluded an award of attorney’s fees, clarifying that the focus should be on the enforcement of public rights, not the subjective merits of the District's actions. The case was remanded to the trial court to determine the appropriate amount of attorney’s fees. View "Let Them Choose v. San Diego Unified School District" on Justia Law

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The case involves the Pennsylvania Department of Environmental Protection (DEP) developing a rulemaking package to join the Regional Greenhouse Gas Initiative (RGGI), aimed at reducing CO2 emissions from power plants. The RGGI Regulation faced opposition from the Pennsylvania Legislative Reference Bureau (LRB) and other state officials, leading to litigation. Three nonprofit environmental organizations (Nonprofits) sought to intervene in the litigation to defend the RGGI Regulation, citing environmental and health concerns.The Commonwealth Court initially denied the Nonprofits' application to intervene, ruling that their interests were adequately represented by DEP. The court also granted a preliminary injunction against the RGGI Regulation. Nonprofits appealed both the denial of intervention and the preliminary injunction.The Supreme Court of Pennsylvania reviewed the case. It found that the Nonprofits had established a substantial, direct, and immediate interest in the outcome of the litigation, based on the testimony of their members regarding the adverse health and environmental impacts of CO2 emissions. The court determined that DEP did not adequately represent the Nonprofits' interests, particularly because DEP had not invoked the Environmental Rights Amendment (ERA) in its defense of the RGGI Regulation.The Supreme Court of Pennsylvania reversed the Commonwealth Court's decision denying the Nonprofits' application to intervene, allowing them to participate as parties in the ongoing litigation. However, the appeal from the preliminary injunction was dismissed as moot because the Commonwealth Court had already issued a permanent injunction against the RGGI Regulation, superseding the preliminary injunction. View "Shirley v. PA Legislative Reference Bureau" on Justia Law

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Vincent Bell, a pretrial detainee with an amputated right leg, alleged that deputies used excessive force during a cell extraction and transfer at the San Francisco Jail. Bell claimed that Sergeant Yvette Williams did not provide him with a wheelchair or other mobility device, forcing him to hop on one leg until he fell. Deputies then carried him by his arms and leg, causing him pain and minor injuries. Bell sued under the Fourteenth Amendment, the Americans with Disabilities Act (ADA), and the Rehabilitation Act.The United States District Court for the Northern District of California held a jury trial. The jury found in favor of Bell on his excessive force claim against Williams and his ADA and Rehabilitation Act claims against the City and County of San Francisco. However, the jury did not find that Williams caused Bell physical or emotional harm. The jury awarded Bell $504,000 in compensatory damages against the City but not against Williams. The district court denied the defendants' post-trial motion for judgment as a matter of law or a new trial.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court affirmed the jury's verdict on Bell's Fourteenth Amendment excessive force claim and his ADA and Rehabilitation Act claims, finding substantial evidence supported these claims. However, the court reversed the district court's decision on Bell's Monell theory of liability, concluding that Bell did not present substantial evidence showing that the City's training was the product of deliberate indifference to a known risk. The court also vacated the jury's compensatory damages award, deeming it grossly excessive, and remanded for a remittitur or a new trial on damages. View "BELL V. WILLIAMS" on Justia Law