Justia Government & Administrative Law Opinion Summaries

J.O. has been under a conservatorship since 2016, with the San Joaquin County Public Conservator serving as his conservator and represented by County Counsel. In December 2023, Judge Guy Castillo began presiding over most mental health cases in the San Joaquin County Superior Court. Starting in May 2024, County Counsel adopted a practice of filing “blanket” motions under Code of Civil Procedure section 170.6 to disqualify Judge Guy Castillo from all cases involving the Public Conservator. On July 10, 2024, County Counsel filed both a petition to extend J.O.’s conservatorship and a section 170.6 motion; the motion was initially denied as premature. J.O. subsequently sought to have the Public Conservator removed and his sister appointed. County Counsel filed another section 170.6 motion, which was granted, removing Judge Guy Castillo from J.O.’s case. J.O. objected, arguing the blanket challenges were improper and aimed at forcing Judge Guy Castillo’s reassignment following her admonishment of County Counsel’s attorney; Judge Guy Castillo was later reassigned.The San Joaquin County Superior Court overruled J.O.’s objection, relying on Solberg v. Superior Court, which permitted blanket section 170.6 challenges. The California Court of Appeal denied writ relief. The Supreme Court of California granted review, overruling Solberg in part, and held that blanket abuses of section 170.6 could unconstitutionally interfere with core judicial functions and are subject to as-applied separation-of-powers challenges. The Supreme Court established a burden-shifting procedure to evaluate whether such challenges are made in bad faith and remanded the matter to the Court of Appeal for further proceedings.The Court of Appeal of the State of California, Third Appellate District, determined the case was not moot and issued a writ directing the Superior Court to vacate its order granting County Counsel’s section 170.6 motion. The court ordered a hearing consistent with the Supreme Court’s procedure to determine whether County Counsel’s motion was made in bad faith. View "J.O. v. Super. Ct." on Justia Law

The Secretary of Homeland Security invoked Section 102 of the Illegal Immigration Reform and Immigrant Responsibility Act of 1996 to initiate a border construction project in the Big Bend Sector along the U.S.–Mexico border. Determining this area to be one of high illegal entry, the Secretary exercised statutory authority to waive several environmental and conservation laws to expedite construction. Subsequently, an individual river guide, an environmental nonprofit, and a historic church preservation organization filed suit, challenging the Secretary’s waiver determinations. Their claim focused on the argument that the Secretary violated the major questions doctrine under Article I, Section 1 of the Constitution, contending that the waivers exceeded statutory authority.The United States District Court for the Western District of Texas issued a preliminary injunction, halting the Secretary’s waivers and associated border construction. The court acknowledged its jurisdiction was limited to constitutional claims but concluded that the major questions doctrine constituted a constitutional clear statement rule, grounded in separation of powers, thus qualifying as a constitutional claim. The court additionally found that the respondents’ major questions doctrine claim was likely to succeed, reasoning that the Secretary lacked clear congressional authorization to issue the waivers.The Supreme Court of the United States reviewed an application for stay of the District Court’s injunction. The Court granted the stay, holding that the District Court lacked jurisdiction to adjudicate the respondents’ major questions doctrine claim, as the claim did not allege a violation of the Constitution but instead challenged the Secretary’s statutory authority. The Court emphasized that claims asserting the Executive exceeded statutory authority are not constitutional claims, and that the major questions doctrine is a canon of statutory interpretation, not a constitutional cause of action. The Supreme Court also found that the balance of equities favored the Government, given Congress’s clear preference for expeditious border construction. The injunction was stayed pending further proceedings. View "Mullin v. Friends of the Ruidosa Church" on Justia Law

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