A group of non-convicted individuals detained in Alameda County’s Santa Rita Jail filed a lawsuit against Aramark Correctional Services, LLC, Alameda County, and Sheriff Gregory J. Ahern. The plaintiffs claimed they were entitled to minimum wage and overtime pay under California’s Labor Code for work performed without pay for Aramark while detained. The defendants moved to dismiss these claims, arguing that the plaintiffs' compensation was governed by the California Penal Code, which allows counties to pay prisoners at rates below minimum wage.The United States District Court for the Northern District of California denied the defendants' motion to dismiss the minimum wage and overtime claims, holding that the California Penal Code did not preclude non-convicted detainees working for a private company from the protections of the Labor Code. The district court allowed the plaintiffs' claims to proceed, leading the defendants to file an interlocutory appeal.The United States Court of Appeals for the Ninth Circuit reviewed the case and certified a question to the California Supreme Court regarding whether non-convicted detainees working for a private company in county jails have a claim for minimum wages and overtime under the California Labor Code. The California Supreme Court responded that such detainees do not have a claim for minimum wages and overtime under Section 1194 of the California Labor Code. The court clarified that section 4019.3 of the California Penal Code applies broadly to all county inmates, including pretrial detainees, and does not depend on the identity of the employer.Based on the California Supreme Court's response, the Ninth Circuit reversed the district court's order denying the motion to dismiss the plaintiffs' minimum wage and overtime claims. The court held that the plaintiffs' claims failed under the current law and reversed the district court's decision. View "RUELAS V. COUNTY OF ALAMEDA" on Justia Law

In the early hours of August 21, 2017, the M/V ALNIC, a Liberian-flagged oil-and-chemical tanker, collided with the U.S.S. JOHN S. MCCAIN, a Navy destroyer, in the Singapore Strait. The collision resulted in the deaths of ten Navy sailors and injuries to dozens more. Both vessels sustained significant damage. Energetic Tank, Inc., the owner of ALNIC, sought exoneration from or limitation of liability for the collision. Forty-one Navy sailors or their representatives, along with the United States, filed claims for damages against Energetic. Energetic counterclaimed against the United States. The parties agreed on the monetary value of the damages to ALNIC and MCCAIN as $442,445 and $185 million, respectively.The United States District Court for the Southern District of New York concluded that Singapore law would govern the determination of liability and the calculation of damages. After a Phase 1 bench trial, the district court denied Energetic’s petition for exoneration or limitation of liability, allocating 80% of the fault to the United States and 20% to Energetic. The court indicated it would proceed to a Phase 2 trial to determine damages to the Sailor-Claimants. Energetic appealed, and while the appeal was pending, the district court dismissed Energetic’s claims for contribution or indemnity against the United States for any damages awarded to the Sailor-Claimants, citing sovereign immunity. Energetic also appealed this order. The district court retroactively certified its earlier opinion on the apportionment of liability as a final judgment as to the United States. Several Sailor-Claimants cross-appealed, challenging the application of Singapore law to the calculation of damages.The United States Court of Appeals for the Second Circuit found no error in the district court’s apportionment of liability under Singapore law or its sovereign immunity ruling, affirming the district court’s judgment and order on Energetic’s appeals. However, the court dismissed the Sailor-Claimants’ cross-appeals for lack of jurisdiction, as the choice-of-law ruling was a non-appealable collateral order. View "In the Matter of Energetic Tank, Inc." on Justia Law

The case involves Puerto Rico's attempt to enact Law 29, which aimed to relieve municipalities from contributing to the Commonwealth's reformed public pension funding scheme. The Financial Oversight and Management Board for Puerto Rico (the Board) challenged the law, and the Title III court overseeing Puerto Rico's debt restructuring declared Law 29 a nullity and of no effect. This decision was not appealed. La Liga de Ciudades de Puerto Rico (La Liga) argued that the Title III court's order did not authorize the Board to recover funds retained by municipalities under Law 29 before the order took effect.The United States District Court for the District of Puerto Rico, interpreting its own prior order, granted motions to dismiss filed by the Board and other defendants. The court dismissed some claims on the merits and others for lack of standing. The court held that the Title III court's order applied retroactively, nullifying Law 29 from its inception and allowing the Board to recover the funds.The United States Court of Appeals for the First Circuit reviewed the case. The court affirmed the district court's dismissal of La Liga's complaint. It held that the Title III court's order declaring Law 29 a nullity and of no effect applied retroactively, covering the period from the law's enactment. The court found that the Title III court had the authority under PROMESA to nullify Law 29 from its inception and that the Board's actions to recover the funds were justified. The court also addressed standing issues, affirming that La Liga had standing to sue the Board and CRIM but not the executive branch defendants. View "La Liga de Ciudades de P.R. v. Financial Oversight and Management Board" on Justia Law

F.C. Bloxom Company, a Seattle-based distributor of fresh produce, entered into an agreement with Seven Seas Fruit to deliver three loads of onions to Honduras. The onions required phytosanitary certificates from the U.S. Department of Agriculture to clear Honduran customs, but the parties did not explicitly discuss who would procure these certificates. Bloxom believed Seven Seas would handle it, based on past practices and vague assurances. However, the onions were shipped without the necessary certificates, leading to their rejection in Honduras and eventual spoilage upon return to the U.S.Seven Seas initiated administrative proceedings under the Perishable Agricultural Commodities Act (PACA) when Bloxom refused to pay for the onions. The Secretary of Agriculture ruled in favor of Seven Seas, finding no evidence that Seven Seas had agreed to procure the certificates. Bloxom appealed to the U.S. District Court for the Central District of Illinois, which granted summary judgment for Seven Seas. The court found that Bloxom had accepted the onions at the Port of Long Beach and did not revoke that acceptance, thus obligating Bloxom to pay for the onions.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's decision. The appellate court agreed that Bloxom had accepted the onions by shipping them to Honduras and did not revoke this acceptance even after learning the certificates were missing. The court also found no abuse of discretion in the district court's denial of Bloxom's request for additional discovery time, as further discovery would not have changed the outcome. The court concluded that Bloxom was liable for the payment under PACA. View "F.C. Bloxom Company v. Tom Lange Company International, Inc." on Justia Law

The case involves Business and Professions Code section 7451, enacted through Proposition 22, which classifies app-based drivers for companies like Uber, Lyft, and DoorDash as independent contractors rather than employees, provided certain conditions are met. This classification exempts these drivers from California workers’ compensation laws, which typically apply to employees. Plaintiffs, including several individuals and unions, argue that section 7451 conflicts with article XIV, section 4 of the California Constitution, which grants the Legislature plenary power to create and enforce a complete system of workers’ compensation.The Alameda County Superior Court found Proposition 22 unconstitutional, reasoning that it improperly limited the Legislature’s power to govern workers’ compensation, a power deemed "unlimited" by the state Constitution. The court held that the people must amend the Constitution through an initiative constitutional amendment, not an initiative statute, to impose such limitations. Consequently, the court invalidated Proposition 22 in its entirety.The California Court of Appeal reversed the lower court’s decision, holding that article XIV, section 4 does not preclude the electorate from using its initiative power to legislate on workers’ compensation matters. The court reasoned that the Legislature’s power under article XIV, section 4 is not exclusive and that Proposition 22 does not conflict with this constitutional provision. The court did, however, affirm the invalidation of certain severable provisions of Proposition 22 not at issue in this appeal.The California Supreme Court affirmed the Court of Appeal’s judgment, agreeing that section 7451 does not conflict with article XIV, section 4. The court held that the Legislature’s plenary power under article XIV, section 4 is not exclusive and does not preclude the electorate from enacting legislation through the initiative process. The court did not address whether other provisions of Proposition 22 improperly constrain the Legislature’s authority, as those issues were not presented in this case. View "Castellanos v. State of California" on Justia Law

Enright Seeding, Inc. is involved in a dispute with the International Union of Operating Engineers, Local 150, AFL-CIO, regarding the nature of their collective bargaining agreement. Enright Seeding, a construction industry subcontractor, signed a bargaining agreement with the union in 2007, which included language suggesting it was a § 9(a) agreement under the National Labor Relations Act, indicating majority employee support for the union. The company later claimed that its obligations ended when it repudiated the contract in 2016. The union, however, argued that the agreement was a § 9(a) agreement and that the company violated the Act by not providing requested information.An administrative law judge determined that the agreement was a § 9(a) agreement and that Enright Seeding violated Sections 8(a)(1) and (5) of the Act by failing to provide the requested information. The judge also concluded that even if the agreement was under § 8(f), the company did not clearly repudiate it. A three-member panel of the National Labor Relations Board (NLRB) affirmed this decision, focusing on the § 9(a) status and not addressing the repudiation issue.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court found that the NLRB's decision was not supported by substantial evidence, as there was no actual evidence of majority employee support for the union in 2007, only boilerplate contract language. The court emphasized that all evidence must be considered to determine the status of the relationship, and mere contract language is insufficient. The court also rejected the argument that Enright Seeding was barred from disputing the agreement's status due to the six-month limitation period in § 10(b) of the Act.The Eighth Circuit vacated the NLRB's order and remanded the case for further proceedings, without expressing a view on whether Enright Seeding had effectively repudiated the agreement or whether the union was entitled to the requested information under a § 8(f) agreement. View "NLRB v. Enright Seeding, Inc." on Justia Law

The City of Custer applied for a permit from the South Dakota Department of Agriculture and Natural Resources (DANR) to discharge treated wastewater into French Creek as part of an upgrade to its wastewater treatment facility. Preserve French Creek, Inc. (Preserve), a group of local citizens, opposed this discharge. Two years after the permit was issued, a Custer County ordinance was passed by citizen initiative, declaring the discharge of treated water into French Creek a nuisance. Preserve demanded the City cease construction based on the new ordinance, but the City did not comply. Preserve then sought mandamus relief to enforce the ordinance, which the circuit court denied.The Circuit Court of the Seventh Judicial Circuit in Custer County found that the ordinance conflicted with state law, specifically SDCL 21-10-2, which states that actions done under the express authority of a statute cannot be deemed a nuisance. The court concluded that the City’s actions, authorized by the DANR permit, could not be considered a nuisance. The court also rejected Preserve’s estoppel argument, stating that the City and County had no duty to enforce an ordinance that conflicted with state law.The Supreme Court of the State of South Dakota reviewed the case and affirmed the circuit court’s decision. The court held that the ordinance was preempted by state law because it attempted to declare a nuisance something that state law expressly authorized. The court also found that the City and County were not estopped from asserting the ordinance’s invalidity, as their actions in placing the ordinance on the ballot and canvassing the vote were statutorily required and did not constitute an inconsistent position. Therefore, the writ of mandamus was properly denied. View "Preserve French Creek V. Custer County" on Justia Law

The case involves a public-records request submitted by David Armiak and the Center for Media and Democracy to the Ohio Attorney General. The request sought documents related to the Republican Attorneys General Association (RAGA) and the Rule of Law Defense Fund (RLDF). The Attorney General refused to produce the documents, arguing they were not public records as defined by Ohio law. Armiak then filed a mandamus action to compel the production of the documents.The Tenth District Court of Appeals handled the initial proceedings. During discovery, the court allowed Armiak to conduct broad discovery to test the Attorney General's claim that the documents were not public records. This included deposing the Attorney General and obtaining extensive documents and interrogatories. The Attorney General sought a protective order to limit this discovery, arguing it was overly burdensome and interfered with his constitutional duties. The Tenth District denied the protective order and allowed the broad discovery to proceed.The Supreme Court of Ohio reviewed the case to determine whether the discovery order was appealable. The court found that the order met the criteria for a provisional remedy under R.C. 2505.02(B)(4), as it determined the action regarding the discovery dispute and prevented a judgment in favor of the Attorney General. The court also found that the Attorney General would not be able to obtain effective relief through an appeal following final judgment, as the discovery process itself would cause irreparable harm. Consequently, the Supreme Court of Ohio denied Armiak's motion to dismiss the appeal and set the matter for oral argument. View "State ex rel. Ctr. for Media & Democracy v. Yost" on Justia Law

The case involves a coalition of states led by Washington suing the FDA over its 2023 REMS, which eliminated in-person dispensing requirements for the abortion drug mifepristone. Washington argues that the FDA should have further reduced restrictions on the drug, claiming that the remaining requirements impose unnecessary hurdles. Idaho, leading another coalition of states, sought to intervene, arguing that the elimination of the in-person dispensing requirement would harm its interests by making the drug easier to obtain and harder to police, potentially increasing Medicaid costs and endangering maternal health and fetal life.The United States District Court for the Eastern District of Washington denied Idaho's motion to intervene. The court found that Idaho did not have a significantly protectable interest that would be impaired by the litigation, as its complaint concerned different aspects of the 2023 REMS. The court also denied permissive intervention, concluding that Idaho's claims did not share common questions of law or fact with Washington's claims.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court's denial of Idaho's motion to intervene as of right. The Ninth Circuit held that Idaho must independently satisfy the requirements of Article III standing because it sought different relief from Washington. The court concluded that Idaho's complaint did not establish a cognizable injury-in-fact that was fairly traceable to the FDA's revised safe-use restrictions. Idaho's alleged economic injuries, law enforcement burdens, and quasi-sovereign interests were deemed too speculative or indirect to confer standing. The court dismissed for lack of jurisdiction the portion of the appeal concerning the denial of permissive intervention. View "STATE OF WASHINGTON V. FDA" on Justia Law

The case involves individual falconers and the American Falconry Conservancy challenging state and federal regulations that require them to consent to unannounced, warrantless inspections as a condition for obtaining a falconry license. The plaintiffs argue that these regulations impose unconstitutional conditions on their right to obtain a license and violate the Fourth Amendment and the Administrative Procedures Act (APA).The United States District Court for the Eastern District of California dismissed the plaintiffs' claims for lack of standing. The court concluded that the plaintiffs failed to demonstrate injury in fact because they had not been subjected to a warrantless inspection under the challenged regulations and had not shown that future inspections were imminent. The district court also found that the American Falconry Conservancy lacked associational standing because it did not allege that its members faced immediate or threatened injury from unannounced inspections.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court reversed the district court’s dismissal of the plaintiffs' unconstitutional-conditions claim against the California Department of Fish and Wildlife (CDFW), holding that the plaintiffs had standing because they were forced to choose between retaining their Fourth Amendment rights and obtaining a falconry license. The court affirmed the dismissal of the remaining claims against CDFW and the U.S. Fish and Wildlife Service (FWS), finding that the plaintiffs' claims against FWS were unripe and that the plaintiffs failed to demonstrate a sufficient likelihood of future injury to support their Fourth Amendment claims. The court also concluded that the American Falconry Conservancy had standing for its unconstitutional-conditions claim but not for its unannounced-inspection claim.The Ninth Circuit's main holding was that the plaintiffs had standing to challenge the unconstitutional conditions imposed by CDFW but lacked standing for their other claims. The case was affirmed in part, reversed in part, and remanded for further proceedings. View "PETER STAVRIANOUDAKIS V. USFWS" on Justia Law