Justia Government & Administrative Law Opinion Summaries

Several nonprofit organizations filed suit after President Trump issued an executive order and subsequent memorandum directing federal agencies to pause the disbursement of funds appropriated under the Infrastructure Investment and Jobs Act (IIJA) and the Inflation Reduction Act (IRA). The nonprofits, which had been awarded grants under these statutes, alleged that the “freeze” on funding had resulted in denial of financial assistance and disruption of their operations. The complaint named several federal agencies and officials, alleging violations of the Administrative Procedure Act (APA) and seeking declaratory and injunctive relief.The United States District Court for the District of Rhode Island found that the plaintiffs had Article III standing and rejected the government’s arguments regarding prior pending actions in other courts and the nature of the claims as contract disputes. The District Court determined that the challenged agency actions were not committed to agency discretion, likely constituted final agency actions, and were likely arbitrary and capricious under the APA. The court granted a preliminary injunction, ordering agencies to resume processing and payment of already-awarded funds and prohibiting further implementation of the funding freeze directives.The United States Court of Appeals for the First Circuit reviewed the case and affirmed much of the District Court’s order, finding that the nonprofits demonstrated standing and were likely to succeed on the merits of their APA claims. The Court held that the categorical funding freezes constituted final agency actions and that agencies failed to consider reliance interests, rendering their actions likely arbitrary and capricious. However, the Court vacated the portion of the order that directly compelled agencies to make monetary payments under contractual grants, finding it exceeded the District Court’s authority under the APA. The remainder of the injunctive relief was affirmed. View "Woonasquatucket River Watershed Council v. USDA" on Justia Law

The plaintiffs in this case are residents of Hillman Ridge Road in Brown County, Ohio. They experienced a cessation of direct mail delivery to their homes after 2017, following an incident involving a neighbor and a mail carrier. As a result, they were required to retrieve their mail from a distant location and travel to a nearby town for parcels. Other delivery services continued to serve their properties, and the Postal Service continued direct delivery on similar roads in the area. The plaintiffs argued that the Postal Service’s refusal to deliver directly to their homes constituted unconstitutional, unreasonable discrimination.The plaintiffs filed suit in the United States District Court for the Southern District of Ohio, naming the United States Postal Service and two officials as defendants. They asserted a “class of one” equal protection claim, alleging that the Postal Service’s actions violated their constitutional rights. The defendants moved to dismiss the complaint for lack of subject matter jurisdiction. The district court held that the plaintiffs’ dispute belonged exclusively before the Postal Regulatory Commission, not in federal district court, and granted the dismissal. Plaintiffs then appealed.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s decision de novo. It held that Congress intended for claims concerning unreasonable discrimination in mail service—such as those under 39 U.S.C. § 403(c)—to be addressed first by the Postal Regulatory Commission under the administrative procedures of the Postal Accountability and Enhancement Act. The court found that the statutory scheme precludes district court jurisdiction over such claims, even those framed as constitutional issues. The court affirmed the district court’s dismissal for lack of jurisdiction, holding that plaintiffs must pursue their claim through the Commission before seeking judicial review. View "Klein v. USPS" on Justia Law

A nonprofit healthcare organization based in the Bering Strait region owns a seven-unit apartment building in Nome, Alaska, located near its hospital. The building’s primary use is to house doctors, nurses, and newly hired hospital employees, most of whom are recruited from outside the region. The organization provides this housing to ensure that medical staff are available to quickly respond to emergencies, especially given the acute shortage of short-term housing in Nome. While the majority of occupants are hospital staff, a small percentage of the units are temporarily used by new hires, who receive free rent for the first 30 days and are then charged a nominal amount.The City of Nome denied a property tax exemption for the apartment building, reasoning that it was not used exclusively for hospital purposes. The matter was reviewed by the City of Nome Board of Equalization, which upheld the denial. The Board found that although the building housed hospital staff, it was also used for private residential purposes and that such use was not “vitally necessary” to the provision of medical care. The Board also rejected arguments based on federal preemption. On appeal, the Superior Court of Alaska reversed the Board’s decision, holding that the apartment building qualified for a hospital purposes exemption.The Supreme Court of the State of Alaska reviewed the case and affirmed the superior court’s judgment. The court held that while the apartment building is not used exclusively for hospital purposes because it also serves private residential needs, it is exempt from taxation because its use is directly incidental to and vitally necessary for hospital operations. The court found that, given the lack of local housing and the requirement for on-call staff, the apartment building meets the requirements for exempt use. The court also concluded that nominal rent charged to some tenants did not disqualify the property from exemption, as the issue was not properly raised or developed in the lower proceedings. View "City of Nome Equalization Board v. Norton Sound Health Corp." on Justia Law

A town administrator in Grand Chute, Wisconsin, was terminated by a newly elected faction on the town’s Board of Supervisors. The administrator, who had served since 2008, claimed his firing was retaliation for cooperating with a state Department of Justice investigation into alleged corruption by a newly elected supervisor. That supervisor had previously been involved in litigation against the town and was later indicted, though ultimately acquitted, on unrelated corruption charges. The administrator’s relationship with the new board members deteriorated, and he was perceived as politically aligned with their rivals and critical of their policies.The administrator sued the Town and individual supervisors in the United States District Court for the Eastern District of Wisconsin under 42 U.S.C. § 1983, asserting First Amendment retaliation. The supervisor also filed a counterclaim alleging the administrator had set him up for prosecution. The district court granted summary judgment for the defendants in both actions, finding the administrator’s termination did not violate the First Amendment and that qualified immunity applied due to unclear precedent regarding the firing of policymaking officials for political speech. The court also rejected the supervisor’s counterclaim, finding no evidence of state action or differential treatment required for an equal protection class-of-one claim.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s rulings de novo. The Seventh Circuit affirmed, holding that the individual defendants were entitled to qualified immunity because existing precedent did not clearly establish that firing a policymaking official under these circumstances violated the First Amendment. The court also affirmed dismissal of the counterclaim, finding neither a viable First Amendment retaliation nor an equal protection claim. View "March v. Wolff" on Justia Law

President Trump, without congressional approval or proper consultation, demolished the White House East Wing over three days in October 2025 to build a privately funded 90,000 square-foot ballroom. The National Park Service’s environmental assessment acknowledged that the project would cause permanent and adverse impacts on President’s Park’s historical landscape, disrupting architectural integrity and historical continuity. The National Trust for Historic Preservation, a congressionally chartered organization with longstanding ties to President’s Park, challenged the construction, citing irreparable harm to the historic, aesthetic, and cultural interests of its members.The United States District Court for the District of Columbia first denied a temporary restraining order, relying on government assurances about the timing and separability of underground and above-ground work. Later, after the National Trust amended its complaint and renewed its request, the district court issued a preliminary injunction against above-ground ballroom construction, but exempted below-ground work and measures necessary for safety and security. The court found both statutory (APA) and ultra vires claims likely to succeed, concluding that neither the President nor the National Park Service had congressional authority for such dramatic alterations.The United States Court of Appeals for the District of Columbia Circuit affirmed the district court’s modified preliminary injunction. The court held that Congress exercises exclusive control over federal property, including the White House, under the Property and District Clauses. Statutory language and appropriations history did not authorize unilateral demolition and replacement of the East Wing with a privately funded ballroom. The court ruled that the National Trust had associational standing, that the Trust was likely to succeed on the merits, and that the balance of equities and public interest favored the injunction. The court vacated its prior administrative stay and stayed its ruling for fourteen days to permit further review. View "National Trust for Historic Preservation in the United States v. NPS" on Justia Law

A veteran who served in the Marine Corps, including a tour in Vietnam, began experiencing fatigue and underwent a medical evaluation at a Veterans Affairs Medical Center in 2010. His blood tests showed elevated lymphocyte counts. However, VA physicians in Florida diagnosed him with monoclonal B-cell lymphocytosis (MBL), not chronic lymphocytic leukemia (CLL), and did not inform him of a CLL diagnosis. Years later, after his condition worsened and he relocated to Tennessee, a VA oncologist diagnosed him with CLL and retroactively opined that his medical records met the diagnostic criteria for CLL since 2010. The veteran then applied for VA disability compensation. The VA assigned a 100% disability rating with an effective date of January 29, 2016, the date his claim was filed.The veteran appealed, arguing for an earlier effective date due to the alleged misdiagnosis and failure to inform him about his CLL. The Board of Veterans’ Appeals partially granted his request, assigning an effective date of January 29, 2015, but declined to go earlier, finding that the law did not allow equitable considerations to affect the effective date under 38 U.S.C. § 5110. The veteran then appealed to the United States Court of Appeals for Veterans Claims, raising arguments that the VA should be equitably estopped from enforcing § 5110’s effective date restrictions, and that those restrictions were unconstitutional as applied to him. The Veterans Court affirmed the Board’s decision.On further appeal, the United States Court of Appeals for the Federal Circuit affirmed the Veterans Court. The Federal Circuit held that equitable estoppel cannot override the effective date limitations of 38 U.S.C. § 5110, and that § 7331 does not create a statutory precondition to enforcement of § 5110. It also held that the statute’s effective date limitations were not unconstitutional as applied to the veteran’s circumstances. View "LEY v. COLLINS " on Justia Law

Daryl Moore was employed by the Coahoma County School District Board as an at-will assistant coach for the high school boys’ basketball team during the 2019-2020 and 2020-2021 school years. He was paid $1,500 per year for his assistant coaching duties. Moore claimed that, at the request of the athletic director, he also performed the duties of the head coach for the junior-high boys’ basketball team but was never compensated for those additional responsibilities. He asserted that he was entitled to $5,000 for serving as the junior-high head coach over two years and brought suit against the Board for unjust enrichment and underpayment.The County Court of Coahoma County reviewed Moore’s claims after he filed suit for unpaid compensation. The Board moved for summary judgment, relying on Mississippi’s “minutes rule,” which requires that any binding contract with a public board be reflected in the board’s official minutes. The court denied summary judgment, finding that factual disputes remained regarding Moore’s coaching roles and compensation, and granted Moore additional time for discovery. The Board appealed, and the Supreme Court of Mississippi granted interlocutory review under Mississippi Rule of Appellate Procedure 5.The Supreme Court of Mississippi held that Moore’s claims were barred by the minutes rule because there was no evidence in the Board’s minutes of any agreement to pay Moore as head coach or to increase his compensation. The Court found that, since the Board’s minutes did not reflect approval of additional pay for head-coaching duties, Moore could not recover under theories of quantum meruit or unjust enrichment. The Supreme Court reversed the county court’s decision and rendered summary judgment in favor of the Board. View "Coahoma County School District Board of Education v. Moore" on Justia Law

The case concerns Robert Boyd, who had a history of sexual offenses involving minors. After serving prison time for downloading child sexual abuse material, post-incarceration civil commitment proceedings were initiated against him under the Adam Walsh Child Protection and Safety Act. Boyd was designated a “sexually dangerous person” and committed to the custody of the Attorney General. Eight years later, Boyd was conditionally discharged after the district court concluded he no longer posed a threat if released under a strict treatment regimen. Conditions included supervision, participation in treatment, restrictions on internet usage, and prohibitions on possessing pornography.About a year after his conditional discharge, the Government sought to revoke Boyd’s release, alleging he violated his treatment regimen by possessing an SD card with images deemed pornographic and engaging in risk-related behaviors, such as interactions with underage individuals and unauthorized internet use. The United States District Court for the Eastern District of North Carolina found Boyd in violation, determined he remained sexually dangerous, and revoked his conditional discharge, returning him to federal custody.The United States Court of Appeals for the Fourth Circuit reviewed the district court’s factual findings for clear error and legal conclusions de novo. The court held that revocation of conditional discharge under the Adam Walsh Act requires the Government to prove by a preponderance of the evidence that the individual failed to comply with their prescribed regimen, suffers from a serious mental disorder, and would have serious difficulty refraining from sexually violent conduct if released. The Fourth Circuit affirmed the district court’s findings, concluding there was sufficient evidence Boyd violated his regimen and posed a risk if allowed to remain in the community. The judgment revoking Boyd’s conditional discharge was affirmed. View "US v. Boyd" on Justia Law

A man named Austen May died by suicide while incarcerated at a Missouri Department of Corrections (MODOC) facility in July 2021, following a prior suicide attempt and ongoing mental health treatment. Correctional officers and a supervising sergeant failed to perform required periodic checks of May’s cell for nearly three hours, during which May obscured the cell window. When officers eventually entered, May was found deceased. Kristine Williams, May’s mother, filed suit against MODOC and several employees, alleging state law wrongful death and federal constitutional claims, including deliberate indifference to a suicide risk.The United States District Court for the Eastern District of Missouri denied motions to dismiss brought by MODOC, Loflin, Yount, and Noisworthy. The court held that MODOC was not entitled to sovereign immunity because Williams plausibly alleged a dangerous condition exception under Missouri law. It also found that the correctional officers and sergeant were not entitled to qualified immunity on the constitutional claim, reasoning that Williams sufficiently alleged they knew of May’s suicide risk and were deliberately indifferent. Additionally, the court denied official immunity for the state wrongful death claim, concluding that the required checks were ministerial duties and thus not protected, and found the public duty doctrine did not bar the claim.Reviewing the case, the United States Court of Appeals for the Eighth Circuit reversed the district court’s rulings. The appellate court held that Williams’s allegations did not plausibly establish a dangerous condition under Missouri law, so MODOC was entitled to sovereign immunity. It also found Williams failed to allege that the officers had actual knowledge of May’s suicide risk, entitling them to qualified immunity. Lastly, the court determined the duties in question were discretionary, not ministerial, so official immunity applied. The case was remanded for further proceedings. View "Williams v. MO Department of Corrections" on Justia Law

A commercial property owner that operates a large shopping mall in Nassau County, New York, was fined approximately $4.8 million by county officials for failing to provide financial information as required under the county’s Annual Statement of Income and Expenses (ASIE) Law. This law mandates commercial property owners to report financial data to county assessors or face a fine calculated as a percentage of the property’s market value. The property owner did not submit the required statements for two consecutive years and was subsequently notified of the fine.After receiving notice of the penalty, the property owner filed suit in the United States District Court for the Eastern District of New York, rather than pursuing remedies under state law or contesting the fine through state administrative proceedings. The owner argued that the ASIE Law and the resulting penalty violated the Eighth Amendment’s Excessive Fines Clause, the Fourteenth Amendment’s Due Process Clause, and several state laws. The district court granted summary judgment in favor of Nassau County and its officials, finding that the fine was not excessive, that adequate procedural due process was available through an Article 78 state court proceeding, and that the ASIE Law did not violate substantive due process. The district court also denied the owner’s motion for sanctions against the county, finding no evidence of bad faith or egregious conduct.On appeal, the United States Court of Appeals for the Second Circuit affirmed the district court’s judgment. The Second Circuit held that the Excessive Fines Clause applies to business entities, including trusts, and that the fine imposed was not grossly disproportional to the offense. The court further found that the available procedures satisfied due process requirements and that the ASIE Law was rationally related to a legitimate government interest. The denial of sanctions was also upheld. View "The Retail Property Trust v. Nassau Cnty. Dep't of Assessment" on Justia Law