Justia Government & Administrative Law Opinion Summaries

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Angelo Jackson was identified as a suspect in a double murder in Montgomery County, Maryland, based on information from law enforcement officers. Detective Michael Carin used this information to obtain an arrest warrant for Jackson. After Jackson's arrest, Carin continued the investigation and found exculpatory evidence, including DNA and cellphone records, which led to the charges being dropped and Jackson's release after 65 days of detention.Jackson filed a lawsuit against Carin, alleging that Carin's affidavit for the arrest warrant and his grand jury testimony were deliberately false or made with reckless disregard for the truth. Jackson claimed that if the commissioner and grand jury had been presented with truthful evidence, they would not have found probable cause for his arrest and indictment.The United States District Court for the District of Maryland granted summary judgment in favor of Carin, finding that even with disputed material removed, the affidavit still provided probable cause for Jackson's arrest. The court also found that Carin was protected by qualified immunity on Jackson's federal claims and dismissed Jackson's gross negligence claim under Maryland law.The United States Court of Appeals for the Fourth Circuit affirmed the district court's judgment. The court concluded that Carin did not violate legal standards in his investigation and was shielded by qualified immunity. The court also found that Carin's actions were reasonable and based on information he received from other officers, and that Jackson failed to meet the burden of proving that Carin's statements were false, made with reckless disregard for the truth, or material to the probable cause determination. View "Jackson v. Carin" on Justia Law

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Captain Gardenia Dorado-Ocasio, an Army officer, challenged a decision by the Army Board for Correction of Military Records (ABCMR) regarding an adverse performance evaluation she received. The evaluation was based on her failure to comply with her superior's orders and alleged retaliation against a subordinate. Dorado-Ocasio claimed the evaluation was biased and factually inaccurate. The ABCMR upheld the evaluation, finding no substantive errors or evidence of bias.The United States District Court for the Eastern District of Virginia reviewed the case and granted summary judgment in favor of the defendant, the Acting Secretary of the Army. The district court found that the ABCMR had adequately explained its decision and that the decision was not arbitrary or capricious.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court's decision. The Fourth Circuit held that the ABCMR's decision was supported by substantial evidence and that the Board had provided a discernible path for its determination. The court emphasized the special deference given to military judgments and found that the ABCMR had met the required standard of review. The court concluded that the ABCMR's decision was not arbitrary, capricious, or contrary to law. View "Dorado-Ocasio v. Averill" on Justia Law

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A medical institute and its co-director sought to provide patients with psilocybin, a schedule I controlled substance, for therapeutic use. They requested the Drug Enforcement Administration (DEA) to exempt the co-director from registration under the Controlled Substances Act (CSA) or to waive the registration requirement. The DEA declined both requests, leading the petitioners to seek judicial review.Previously, the petitioners had asked the DEA for guidance on accommodating the Right to Try Act (RTT Act) for psilocybin use. The DEA responded that the RTT Act did not waive CSA requirements, and the petitioners' initial judicial review was dismissed for lack of jurisdiction. The petitioners then made a concrete request to the DEA for exemption or waiver, which the DEA again denied, prompting the current appeal.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that it had jurisdiction under 21 U.S.C. § 877 to review the DEA's final decision. The court found that the DEA's denial was not arbitrary and capricious. The DEA provided a reasonable explanation, stating that the RTT Act did not exempt the CSA's requirements and that the proposed use of psilocybin was inconsistent with public health and safety. The DEA also noted that the petitioners did not provide sufficient details for the proposed regulation. The court denied the petition for review, affirming the DEA's decision. View "ADVANCED INTEGRATIVE MEDICAL SCIENCE INSTITUTE, PLLC V. UNITED STATES DRUG ENFORCEMENT ADMIN" on Justia Law

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A nonprofit organization, Prutehi Litekyan: Save Ritidian, challenged the U.S. Air Force's decision to engage in hazardous waste disposal at Tarague Beach, Guam, without conducting a National Environmental Policy Act (NEPA) review. The Air Force planned to dispose of unexploded ordnance through Open Burning/Open Detonation (OB/OD) operations. The nonprofit argued that the Air Force failed to take a "hard look" at the environmental impacts and did not engage the public as required by NEPA.The District Court of Guam dismissed the case, holding that Prutehi Litekyan lacked standing because its injury was not fairly traceable to the Air Force's actions. The court also found that there was no final agency action, making the case unripe for judicial review. Additionally, the court ruled that the Resource Conservation and Recovery Act (RCRA) permitting process made NEPA review redundant, thus Prutehi Litekyan failed to state a claim.The United States Court of Appeals for the Ninth Circuit reversed the district court's dismissal. The appellate court held that Prutehi Litekyan had standing because the Air Force's failure to conduct NEPA review could have influenced its decision on waste disposal methods, making the injury fairly traceable to the Air Force's actions. The court also determined that the Air Force's decision to apply for a RCRA permit and its detailed plans for OB/OD operations constituted final agency action, making the case ripe for judicial review.Furthermore, the Ninth Circuit held that NEPA applied to the Air Force's decision to conduct OB/OD operations at Tarague Beach. The court found that RCRA's permitting process did not displace NEPA's requirements, as the two statutes serve different purposes and are not redundant. The case was remanded for further proceedings consistent with the appellate court's opinion. View "LITEKYAN V. UNITED STATES DEPARTMENT OF THE AIR FORCE" on Justia Law

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In February 2024, Cailin Leann Gackle was arrested for driving under the influence of alcohol. At the police department, Officer Cullen Hall conducted two breath test sequences using the Intoxilyzer 8000. The first test sequence was invalidated due to a "Difference Too Great" between the two samples. Officer Hall began the second test sequence 18 minutes after the first test ended, instead of the required 20 minutes. Gackle's driving privileges were suspended for 365 days based on the results of the second test.Gackle requested an administrative hearing, arguing that the breath test was not fairly administered because Officer Hall did not comply with the 20-minute waiting period required by the approved method. The hearing officer overruled her objection, admitted the test records, and upheld the suspension. Gackle appealed to the District Court of Ward County, which affirmed the Department of Transportation's decision.The North Dakota Supreme Court reviewed the case and concluded that the Department failed to establish the fair administration of the breath test. The court determined that the approved method requires a 20-minute wait before beginning a new test sequence after an invalid test. Since Officer Hall only waited 18 minutes, the test was not administered in accordance with the approved method. The court held that without expert testimony to address the deviation, the test results could not be considered reliable. Consequently, the court reversed the lower court's decision and remanded the case to the Department for reinstatement of Gackle's driving privileges. View "Gackle v. NDDOT" on Justia Law

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The taxpayer, 480 McClellan LLC, leased property from the Massachusetts Port Authority (Massport) to construct and operate a cargo facility. The property, located in East Boston, was previously taxable before Massport acquired it in 1990. In 2017, the City of Boston began taxing the property, and the taxpayer sought abatements for the tax years 2017 through 2020, which were denied by the city's board of assessors.The taxpayer appealed to the Appellate Tax Board, arguing that section 53 of the 1993 supplemental appropriations bill exempted it from taxation because the property was used for "air transportation purposes." The board invited the parties to address whether section 53 had amended section 17 of the Massport enabling act, which governs the taxation of Massport lessees. The board concluded that section 53 was not enacted because the Senate did not finalize its reconsideration of the Governor's veto before the end of the 1993 legislative session. The board also determined that the property was leased for "business purposes" under section 17, making the taxpayer subject to taxation.The Supreme Judicial Court of Massachusetts reviewed the case and affirmed the board's decision. The court held that the Senate's initial vote to override the Governor's veto of section 53 was not final due to a timely motion to reconsider, which was not resolved before the legislative session ended. Therefore, section 53 did not amend section 17. The court also upheld the board's interpretation that "business purposes" under section 17 includes commercial, for-profit activities, and found that the taxpayer leased the property for such purposes. Consequently, the taxpayer was subject to taxation under section 17. View "480 McClellan LLC v. Board of Assessors of Boston" on Justia Law

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John Doe, an individual with a serious mental illness, sued James V. McDonald, M.D., New York’s Commissioner of Health, and other defendants, seeking declaratory and injunctive relief under the Americans with Disabilities Act, the Rehabilitation Act, the Fair Housing Act, and Article 78 of the New York Civil Practice Law and Rules. Doe alleged that New York State regulations discriminated against him by preventing his readmission to Oceanview Manor Home for Adults, a Transitional Adult Home (TAH) where he previously resided. After filing the suit, the State allowed Doe to return to Oceanview, amended the regulations to permit readmission of former TAH residents with serious mental illness, and removed Oceanview’s classification as a TAH.The United States District Court for the Northern District of New York denied the State’s motion for summary judgment, which argued that Doe lacked standing. The district court granted the State leave to file an interlocutory appeal. On appeal, the State contended that the district court erred in finding standing because Doe lacked a concrete plan to leave and seek readmission to Oceanview.The United States Court of Appeals for the Second Circuit reviewed the case and determined that the State’s jurisdictional challenge should be assessed as a question of mootness, not standing, because it addressed events occurring after Doe filed the suit. The court found that Doe’s suit was moot because the State had allowed Doe to return to Oceanview, amended the regulations, and removed Oceanview’s TAH classification. Consequently, there was no reasonable expectation that the alleged violation would recur.The Second Circuit dismissed the appeal, vacated the district court’s order, and remanded the case with instructions to dismiss for lack of subject matter jurisdiction. View "Doe v. McDonald" on Justia Law

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Vietnamese refugees and residents of San Diego County, Anh Thai and Don Doan, alleged that two law enforcement officers, Dulce Sanchez and William Villasenor, violated their constitutional rights by forcibly entering their homes and interrogating them about their disability benefits. Sanchez and Villasenor were Los Angeles District Attorney’s Office investigators assigned full-time to a joint federal-state task force, the Cooperative Disability Investigations (CDI) Unit, which investigates fraud in Social Security disability benefits applications. The plaintiffs claimed that the officers displayed guns and state badges, did not seek consent for the search, and failed to have an interpreter present during the investigations.The United States District Court for the Southern District of California granted summary judgment in favor of Sanchez and Villasenor, concluding that the officers were acting under color of federal law, not state law, and therefore could not be held liable under 42 U.S.C. § 1983. The district court found that the CDI Unit was implemented under federal authority, and the officers’ day-to-day work was supervised by a federal officer, Special Agent Glenn Roberts.The United States Court of Appeals for the Ninth Circuit affirmed the district court’s decision. The Ninth Circuit held that because the CDI Unit was created under federal authority and supervised by a federal officer, Sanchez and Villasenor were acting under color of federal law. The court noted that the officers’ paychecks were reimbursed by the Social Security Administration, and their investigations took place outside of Los Angeles County, further indicating their federal role. Consequently, the officers were not subject to suit under § 1983, which applies to actions under color of state law. The court affirmed the district court’s summary judgment in favor of the defendants. View "Thai v. County of Los Angeles" on Justia Law

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Isak Aden's ex-girlfriend called 911 on July 2, 2019, reporting that Aden had pointed a gun at her and ordered her to drive. She escaped, and Aden fled into a wooded area. Officers found Aden holding a gun to his head and began negotiating with him. Despite multiple attempts to get him to surrender, Aden refused and moved closer to his gun. Officers devised a tactical plan involving flashbangs and foam bullets to disorient Aden and arrest him. When the plan was executed, Aden reached for his gun, and officers fired lethal rounds, resulting in his death.The United States District Court for the District of Minnesota partially denied the defendants' motion for summary judgment, finding that the officers were not entitled to qualified or official immunity and that the City of Eagan could be liable under Monell. The court dismissed some claims but allowed others to proceed, leading to the current appeal.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court found that the officers' actions were reasonable under the circumstances and that they did not violate Aden's constitutional rights. The court held that the officers were entitled to qualified immunity because their use of force was not excessive. The court also found that the City of Eagan was not subject to Monell liability because there was no constitutional violation by the officers. Additionally, the court held that the officers were entitled to official immunity under Minnesota law, and thus, the City of Eagan was also entitled to vicarious official immunity.The Eighth Circuit reversed the district court's partial denial of summary judgment and remanded the case for entry of summary judgment based on qualified and official immunity. View "Aden v. City of Eagan" on Justia Law

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Donald Hunter, a former coal miner, applied for benefits under the Black Lung Benefits Act (BLBA) in 2019, claiming that he was totally disabled due to chronic obstructive pulmonary disease (COPD) caused by his coal mine employment. Southern Ohio Coal Company, his former employer, contested his claim, arguing that Hunter's COPD was caused by his significant history of smoking cigarettes rather than coal mine dust exposure.An Administrative Law Judge (ALJ) reviewed the case and awarded benefits to Hunter, finding that his COPD constituted legal pneumoconiosis and that it was a substantially contributing cause of his total disability. Southern Ohio Coal appealed to the Benefits Review Board (BRB), arguing that the ALJ erred in discrediting its evidence and in crediting Hunter's evidence. The BRB affirmed the ALJ's decision, holding that the ALJ had properly considered and weighed the evidence.The United States Court of Appeals for the Sixth Circuit reviewed the case. Southern Ohio Coal argued that the ALJ erred by relying on a pulmonary function test (PFT) that did not comply with regulatory quality standards and by relieving Hunter of his burden to establish entitlement to benefits. The court found that the ALJ acted within his discretion in determining that the PFT was compliant and supported Hunter's entitlement to benefits. The court also held that the ALJ did not improperly rely on regulatory guidance or flip the burden of proof to Southern Ohio Coal. The ALJ's decision was supported by substantial evidence, including expert opinions and Hunter's testimony.The Sixth Circuit denied the petition for review, affirming the ALJ's decision to award benefits to Hunter. The court held that the ALJ correctly applied the law and that his decision was supported by substantial evidence. View "Southern Ohio Coal Co. v. Office of Workers' Compensation Programs" on Justia Law