Justia Government & Administrative Law Opinion Summaries

The case involves an individual who pleaded guilty to residential burglary in 2013 and, approximately ten years later, pleaded guilty to second-degree murder in 2024. After being sentenced to 180 months’ imprisonment for second-degree murder, the Arkansas Division of Correction determined that he was ineligible for parole because of his prior violent felony conviction for residential burglary. He challenged this determination, arguing that his residential burglary conviction should not be classified as a “prior violent felony” under Arkansas Code Annotated section 16-93-609, claiming the offense was committed before 2015 and that his sentencing order for second-degree murder did not expressly designate it under the relevant statute.He sought relief in the Pulaski County Circuit Court, petitioning for declaratory judgment, injunction, and mandamus. The circuit court reviewed the statutory language and found that the exception to the violent-felony rule for residential burglaries committed before April 1, 2015, only applies when the sentence for which parole eligibility is sought was imposed before May 24, 2022. Since his second-degree murder sentence was imposed in 2024, the court concluded the exception did not apply. The court denied his petition, holding that the Arkansas Division of Correction did not exceed its legal authority in denying parole eligibility.The Supreme Court of Arkansas reviewed the circuit court’s dismissal for abuse of discretion and interpreted the statute de novo. The court held that the statute’s plain language precludes parole eligibility for sentences imposed after May 24, 2022, regardless of when the prior residential burglary was committed or the absence of express designation on the sentencing order. The court also declined to address an ex post facto claim that had not been raised below. The Supreme Court of Arkansas affirmed the circuit court’s decision. View "NANCE v. ARKANSAS POST-PRISON TRANSFER BOARD" on Justia Law

The dispute centers on the distribution of Kirkland Signature alcoholic beverages in Arkansas. Costco, a major retailer with a registered trademark for Kirkland Signature, began selling its branded alcoholic beverages in Arkansas through various manufacturers. These manufacturers registered different Kirkland Signature products, such as Chianti, Pinot Grigio, Sauvignon Blanc, and Strawberry Margarita, with the Arkansas Alcoholic Beverage Control (ABC) Division, each designating one of two different wholesalers: Moon Distributors or Arkansas Wine and Spirits (AWS). The ABC Division later determined that state law required all Kirkland Signature products, regardless of the manufacturer or variety, to be distributed by the same wholesaler.The Director of the ABC Division instructed manufacturers who had designated a different wholesaler from the first registered wholesaler (Moon Distributors) to submit change requests. Mach Flynt and Levecke, two manufacturers who had previously designated AWS, complied but expressed their preference for AWS. The Director held a hearing and granted the change requests, removing AWS as the wholesaler for those products. AWS appealed this administrative action to the ABC Board, which upheld the Director’s decision after its own hearing. AWS then sought review in the Pulaski County Circuit Court, which affirmed the Board’s decision. The Arkansas Court of Appeals certified the case to the Supreme Court of Arkansas.The Supreme Court of Arkansas held that under Arkansas Code Annotated section 3-2-403, “brand” refers to the trademark or distinctive name, meaning all Kirkland Signature alcoholic beverages constitute a single brand. Therefore, only one wholesaler may be designated for the brand, and subsequent manufacturers must use the same wholesaler as the first registrant. The court further concluded that the ABC Board’s decision was supported by substantial evidence and was not arbitrary, capricious, or an abuse of discretion. The decision was affirmed. View "ARKANSAS WINE AND SPIRITS WHOLESALE, LLC v. DEPARTMENT OF FINANCE AND ADMINISTRATION" on Justia Law

This case arose from a conflict regarding the distribution of Kirkland Signature alcoholic beverages in Arkansas. Under Arkansas’s three-tier system for alcohol distribution, several manufacturers registered different Kirkland Signature products with the Arkansas Alcoholic Beverage Control (ABC) Division, designating different wholesalers. After realizing that multiple wholesalers were assigned to the same brand, the ABC Director directed all Kirkland Signature manufacturers to use the same wholesaler—Moon Distributors—because Moon was the first registered wholesaler for the brand. As a result, the Director granted change requests from two manufacturers (Mach Flynt and Levecke) that switched their designated wholesaler from Arkansas Wine and Spirits (AWS) to Moon Distributors, effectively removing AWS as a wholesaler for those Kirkland Signature products.After the Director’s decision, AWS appealed to the Arkansas Alcoholic Beverage Control Board (Board), which held a hearing and upheld the Director’s ruling. AWS then sought review in the Pulaski County Circuit Court, which affirmed the Board’s decision. AWS further appealed, and the Arkansas Court of Appeals certified the case to the Supreme Court of Arkansas, which accepted review.The Supreme Court of Arkansas held that, under Arkansas Code Annotated section 3-2-403, Kirkland Signature constitutes a single brand for distribution purposes, requiring all manufacturers of that brand to designate the same exclusive wholesaler. The court found the statute ambiguous but, after applying rules of statutory construction and reviewing relevant regulations, determined that the legislative intent was to grant wholesalers exclusivity for each brand. The court also held that the Board’s decision was supported by substantial evidence and was not arbitrary, capricious, or an abuse of discretion. Accordingly, the Supreme Court of Arkansas affirmed the Board’s decision. View "ARKANSAS WINE AND SPIRITS WHOLESALE, LLC v. ARKANSAS DEPARTMENT OF FINANCE AND ADMINISTRATION" on Justia Law

A patient at Coalinga State Hospital challenged a policy and regulation that permitted hospital staff to x-ray and open all incoming mail outside the presence of patients. He argued that this policy conflicted with certain provisions of the Welfare and Institutions Code and regulations, which he claimed guaranteed patients the right to receive unopened correspondence. The patient, who is civilly committed as a sexually violent predator (SVP), alleged his mail had been opened and contents withheld without his permission, and he sought a judicial declaration concerning his rights under state law.The Superior Court of Fresno County sustained a demurrer filed by the Department of State Hospitals Coalinga and its Hospital Police Chief. The court concluded that the statutory rights cited by the patient, specifically those in Welfare and Institutions Code section 5325, applied only to individuals committed under the Lanterman-Petris-Short (LPS) Act, not to SVPs. The court also found that the regulation authorizing inspection of mail for non-LPS patients did not conflict with the statute, as they applied to different populations. The patient's amended petition was dismissed without leave to amend.On appeal, the California Court of Appeal, Fifth Appellate District, affirmed the lower court’s judgment. The appellate court held that Welfare and Institutions Code section 5325 confers mail rights only to LPS patients and that sexually violent predators, as non-LPS patients, are governed by separate regulations under title 9, section 884, which specifically allows for the inspection of their mail. The court found no irreconcilable conflict between the statute and the regulation and concluded that the Department of State Hospitals has authority to adopt regulations necessary for institutional security. The judgment dismissing the patient’s amended petition was affirmed. View "Seeboth v. State Dept. of State Hospitals" on Justia Law

Federal agents executed a pre-dawn raid targeting a gang member in Atlanta, but mistakenly entered the plaintiffs’ residence, three houses away from the intended address and on a different street. The FBI SWAT team forcibly entered, detonated a flash-bang grenade, and detained the plaintiffs, including a minor, before realizing their error and departing. The raid’s leader, Agent Guerra, later attributed the mistake to his personal GPS device, which he discarded shortly after the incident. Plaintiffs disputed the adequacy of pre-raid preparations and alleged multiple torts and constitutional violations.The plaintiffs filed suit in the United States District Court for the Northern District of Georgia, asserting claims against the United States under the Federal Tort Claims Act (FTCA) for false arrest, assault and battery, trespass, emotional distress, and negligence, as well as a Bivens claim against Agent Guerra and others for Fourth Amendment violations. The district court granted summary judgment to the United States on most FTCA claims under the discretionary-function exception, and to Agent Guerra on the Bivens claim based on qualified immunity. After an intervening Eleventh Circuit decision, the district court granted judgment to the government on the remaining FTCA claims.On appeal, the United States Court of Appeals for the Eleventh Circuit was instructed by the Supreme Court (following Martin v. United States, 605 U.S. 395 (2025)) to re-examine whether the FTCA’s discretionary-function exception barred the plaintiffs’ claims. The Eleventh Circuit held that the discretionary-function exception shielded the United States from all FTCA claims arising from the raid and affirmed their dismissal. However, the court reversed the grant of qualified immunity to Agent Guerra, finding that, when viewing the evidence most favorably to the plaintiffs, his actions violated clearly established Fourth Amendment law. The case was remanded for further proceedings consistent with these holdings. View "Martin v. USA" on Justia Law

A group of utility customers in Texas and California paid interest on bonds issued by their utility companies, which were intended to finance recovery after winter storms and wildfires. These bonds, known as recovery bonds, were subject to approval by state public utility commissions in Texas and California. Plaintiffs alleged that Bloomberg, L.P. and Bloomberg Index Services, Ltd. unlawfully reclassified these bonds from corporate bonds to asset-backed securities, resulting in higher interest rates that were ultimately paid by the utility customers.After the utilities submitted applications and detailed bond terms, including interest rates, to the state public utility commissions, the commissions retained authority to approve or reject the bonds. The commissions received notice of Bloomberg’s reclassification and the associated interest rates, but permitted the issuance of the bonds. Plaintiffs filed a class action in the United States District Court for the Southern District of New York, claiming that Bloomberg’s actions led to inflated rates. The district court dismissed the case, finding that the filed rate doctrine barred the claims, since the challenged rates were filed with and approved by the relevant state regulators.On appeal, the United States Court of Appeals for the Second Circuit reviewed the district court’s dismissal de novo. The appellate court held that the filed rate doctrine barred the plaintiffs’ claims. It explained that the regulatory process provided sufficient safeguards, as the state commissions had notice of the reclassification and still allowed the bonds to be issued. The court found that plaintiffs had forfeited any argument that the federal filed rate doctrine could not bar state-law claims and further concluded that, under controlling circuit precedent, the doctrine applied. The Second Circuit affirmed the district court’s dismissal of the action with prejudice. View "Skolarus v. Bloomberg, L.P." on Justia Law

Two consumers challenged two rules issued by the U.S. Department of Energy (DOE) that imposed new water-use standards for residential dishwashers and clothes washers. Their argument was that the DOE exceeded its statutory authority under the Energy Policy and Conservation Act (EPCA), which, they claimed, only authorized DOE to regulate four specific appliances (showerheads, faucets, water closets, and urinals). The DOE had issued direct final rules (DFRs) in 2024 that further reduced water-use limits and changed measurement schemes for dishwashers and clothes washers. The plaintiffs sought declaratory and injunctive relief in federal district court, asking it to invalidate the DOE’s rules and restore the standards set by Congress.The United States District Court for the Northern District of Texas dismissed the case for lack of subject matter jurisdiction. The district court found that EPCA’s statutory-review mechanism, specifically 42 U.S.C. § 6306(b), vested exclusive jurisdiction for challenges to rules prescribed under § 6295 in the circuit courts, not the district courts. The court rejected plaintiffs’ arguments for concurrent jurisdiction and their reliance on the EPCA’s “savings clause” in § 6306(b)(4), holding that neither provided a jurisdictional basis for their claims. The district court also denied a motion to alter or amend the judgment.On appeal, the United States Court of Appeals for the Fifth Circuit first determined that the plaintiffs had standing, as their alleged reduction in market choices constituted an injury in fact traceable to the challenged DOE rules. The Fifth Circuit then affirmed the district court’s dismissal, holding that the circuit courts have exclusive jurisdiction over challenges to DOE rules under EPCA and that the district court was properly stripped of jurisdiction. The judgment of the district court was affirmed. View "Word v. Department of Energy" on Justia Law

The case involves challenges to a 2024 order issued by the Federal Communications Commission (FCC) regulating communications services provided to incarcerated individuals, following statutory amendments in 2022. The FCC's order imposed rate caps for intrastate, interstate, and international prison communications, regulated the reimbursement of facility costs, excluded site commission payments from rate calculations, prohibited service providers from paying site commissions, preempted state and local laws requiring such payments, allowed alternate pricing plans, and required clearer consumer disclosures. These actions prompted petitions for review from nonprofit organizations, service providers, and state governments, consolidated by the United States Multidistrict Judicial Panel on Litigation and transferred to the United States Court of Appeals for the First Circuit.In the lower proceedings, the FCC's imposition of rate caps and prohibition of site commissions were challenged, and the parties disputed whether the First Circuit was the proper venue. The FCC then issued a new order in late 2025, modifying certain aspects of the 2024 order, notably by increasing rate caps to include more safety and security costs. This led to supplemental briefing on mootness. Service providers requested voluntary dismissal of their petitions, state governments argued portions of their petitions were moot, and nonprofit organizations maintained some challenges remained live.The United States Court of Appeals for the First Circuit granted the voluntary dismissal of service providers' petitions, dismissed portions of state governments' petitions as moot or for lack of jurisdiction (including constitutional challenges not raised before the FCC), and denied other state challenges to the FCC's authority and rulemaking. The court denied most nonprofit organizations’ challenges except for those related to the FCC’s treatment of certain costs in rate caps, which it held in abeyance pending review of the 2025 order. The court’s disposition was to dismiss, deny, or hold in abeyance the various petitions as appropriate. View "Direct Action for Rights and Equality v. FCC" on Justia Law

A licensed psychologist faced disciplinary action after being convicted in 2018 of insurance fraud related to a workers’ compensation claim. The Board of Psychology issued an accusation in 2019 based on the conviction and also alleged dishonesty in her 2007 license application for failing to disclose a 1984 conviction. Following a two-day evidentiary hearing in 2020, the Board found cause to discipline her solely for the insurance fraud conviction, dismissed the charge related to the 1984 conviction, and placed her on probation for five years with various conditions, holding the probation in abeyance during periods when she was not practicing in California.After moving out of state and returning, the psychologist petitioned the Board in 2023 for early termination of her probation. The Board held an evidentiary hearing in 2024, found she failed to provide clear and convincing evidence of rehabilitation—citing her lack of insight and responsibility for the insurance fraud conviction—and denied the petition. The Board noted her probation had been tolled due to her absence and non-practice. She then sought judicial review of both the 2021 probation decision and the 2024 denial of early termination in the Superior Court of Sacramento County.The Superior Court denied her petition, finding the challenge to the 2021 decision untimely and concluding the 2024 denial was supported by substantial evidence. On appeal, the California Court of Appeal, Third Appellate District, affirmed the trial court’s judgment. The Court held that the trial court properly applied the substantial evidence test to review the Board’s denial of early termination, as this was analogous to review of an agency’s decision on reinstatement rather than discipline. The Court found the Board did not abuse its discretion and rejected arguments regarding procedural unfairness and relevance of the 1984 conviction. The judgment was affirmed. View "Bombardini v. Board of Psychology" on Justia Law

A juvenile dropped a sandbag from an overpass bridge undergoing reconstruction in Toledo, Ohio, resulting in the death of Marquise Shawndell Byrd, a vehicle passenger traveling on Interstate 75. At the time of the incident, the bridge's north side was closed for reconstruction, including removal of the existing vandal-protective fencing, while the south side remained open to pedestrian traffic with its fencing intact. The Ohio Department of Transportation (ODOT) managed the reconstruction, and the project contractor used sandbags to secure traffic barricades and signage. Prior to the incident, there had been no reported vandalism or safety concerns at the site.The estate of Byrd, represented by Patricia Wilkes, brought a wrongful death action against ODOT in the Ohio Court of Claims, alleging negligence in failing to mitigate dangerous conditions by allowing sandbags to remain accessible and not erecting temporary protective fencing. The Court of Claims denied ODOT’s motion for summary judgment on immunity grounds but ultimately found that the estate had not proven ODOT’s liability after trial. On appeal, the Tenth District Court of Appeals reversed, holding that ODOT was not immune and liable for Byrd’s death, remanding for a determination of damages.The Supreme Court of Ohio reviewed the case and held that ODOT’s decision not to install temporary vandal-protective fencing on the bridge’s north side during reconstruction was a basic policy decision involving a high degree of discretion, granting ODOT discretionary immunity from the negligence suit under R.C. 2743.02. The Supreme Court of Ohio reversed the appellate court’s judgment and remanded the case to the Court of Claims with instructions to dismiss the action. View "Wilkes v. Ohio Dept. of Transp." on Justia Law