In 2013, Ronald Fossat, a coal miner, filed a claim for benefits under the Black Lung Benefits Act (BLBA). Fossat had worked in coal mines for 24 years, with 10 years underground and 14 years above ground. He suffered from severe respiratory issues and was on oxygen therapy. After filing his claim, he underwent medical evaluations, including those by Dr. Gagon (OWCP-sponsored) and Drs. Farney and Rosenberg (requested by his employer, Sunnyside Coal Company). The evaluations produced mixed results regarding the cause and extent of his respiratory impairment.An Administrative Law Judge (ALJ) awarded Fossat benefits in 2021, concluding that he was totally disabled based on arterial blood gas studies and medical opinions. Sunnyside appealed to the U.S. Department of Labor Benefits Review Board, which affirmed the ALJ’s decision. Sunnyside then petitioned the United States Court of Appeals for the Tenth Circuit for review, arguing that the agency’s interpretation of the BLBA was erroneous and that the ALJ’s medical merits analysis was flawed.The Tenth Circuit reviewed the case and rejected Sunnyside’s arguments. The court held that Fossat’s employment qualified him for the rebuttable presumption under the BLBA, as he had worked for more than 15 years in an underground coal mine, including above-ground work at the same mine. The court also found that the ALJ correctly applied the burden of proof and that substantial evidence supported the ALJ’s conclusion that Fossat was totally disabled. The court further determined that any error in admitting a supplemental medical report was harmless, as the ALJ’s conclusions were supportable without it. Consequently, the Tenth Circuit denied Sunnyside’s petition for review. View "Sunnyside Coal Company v. Office of Workers' Compensation Programs" on Justia Law

Maria Pomares submitted three Freedom of Information Act (FOIA) requests to the Department of Veterans Affairs (VA) concerning potential misconduct within the VA. She suspected that Charmain Bogue, the director of the Education Service in the Veterans Benefit Administration, had improper ties to a political advocacy organization and that the VA might have leaked nonpublic information. After Pomares submitted her FOIA requests, the VA’s Office of Inspector General (OIG) found that Bogue had acted improperly.The United States District Court for the Southern District of California granted summary judgment in favor of the VA. The court concluded that the VA’s search for responsive emails was reasonable and that the VA properly justified its withholdings under FOIA Exemptions 4, 5, 6, and 7. The district court found that the Vaughn Indices provided by the VA were adequate and included sufficient detail to justify the withholdings.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court affirmed the district court’s judgment regarding the adequacy of the VA’s search for emails and the application of Exemption 4 to records obtained from Evocati. The court also affirmed the application of Exemption 6 to the redaction of names and contact information, except for the names (but not email addresses) of Veterans Education Success (VES) employees who lobbied Congress or the VA. However, the court reversed the district court’s judgment regarding the withholding of OIG interview transcripts under Exemption 7(E), as the VA did not adequately justify that the interview techniques and methods used by OIG fell within this exemption. The case was remanded for further proceedings consistent with the opinion. View "Pomares v. USDVA" on Justia Law

In August 2020, Joe Willie Cannon, an inmate at Anamosa State Penitentiary (ASP), injured his right wrist while playing basketball. He sought medical attention from ASP staff, including nurses and a doctor, but experienced delays and inadequate treatment. Cannon alleged that the medical staff's failure to promptly diagnose and treat his wrist injury, which was later found to be a displaced fracture, constituted deliberate indifference to his serious medical needs, violating his Eighth Amendment rights.The United States District Court for the Northern District of Iowa denied summary judgment to four defendants—Dr. Michael Dehner and Nurses Amy Shipley, Courtney Friedman, and Barbara Devaney—who claimed qualified immunity. The court found that a reasonable jury could conclude that the defendants acted with deliberate indifference to Cannon's medical needs. The defendants appealed this interlocutory order.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court concluded that the district court failed to properly apply the principle that each defendant's knowledge and conduct must be individually assessed. The appellate court found that the nurses' actions, including their assessments and treatment plans, did not amount to deliberate indifference. Similarly, Dr. Dehner's decisions, including ordering an X-ray and referring Cannon to an orthopedic specialist, were based on his medical judgment and did not constitute deliberate indifference.The Eighth Circuit held that each appellant was entitled to qualified immunity because Cannon failed to prove that any of them acted with deliberate indifference to his serious medical needs. The court reversed the district court's order and remanded the case for further proceedings consistent with its opinion. View "Cannon v. Dehner" on Justia Law

Jacquelyn N’Jai filed a lawsuit against the U.S. Department of Education, New York University (NYU), Long Island University (LIU), Immediate Credit Recovery, Inc. (ICR), and FMS Investment Corporation (FMS), alleging various violations of federal law. N’Jai claimed that she had repaid her student loans but was falsely certified for additional loans by a bank analyst, with NYU and LIU allegedly signing her name on fraudulent loan applications. She contended that the Department of Education and its debt collectors used unlawful practices to collect on these loans, including garnishing her tax refund and threatening to garnish her Social Security checks.The United States District Court for the District of Columbia dismissed N’Jai’s claims against LIU, NYU, ICR, and FMS for lack of personal jurisdiction, citing the government contacts exception. This exception prevents the assertion of personal jurisdiction based solely on a defendant’s contact with federal government agencies in the District of Columbia. The court dismissed the claims against the remaining defendants for other reasons.The United States Court of Appeals for the District of Columbia Circuit reviewed the case, focusing on whether the government contacts exception under D.C. law is limited to First Amendment activities. The court noted the ongoing uncertainty about the scope of this exception, referencing previous cases where the D.C. Court of Appeals had not definitively resolved whether the exception is confined to First Amendment activity. Due to this uncertainty, the appellate court certified two questions to the D.C. Court of Appeals: whether the government contacts exception is limited to First Amendment activity and, if so, whether the contacts alleged in this case fall under that exception. The appellate court did not make a final ruling on the personal jurisdiction issue, pending the D.C. Court of Appeals' response to the certified questions. View "N'Jai v. Department of Education" on Justia Law

A chemical manufacturer and two trade associations challenged an EPA rule regulating emissions from certain facilities, specifically disputing the EPA’s assessment of cancer risk from ethylene oxide emissions. The EPA had determined that emissions from these sources posed an unacceptable risk to public health and tightened emissions standards accordingly. The EPA’s assessment concluded that the maximum lifetime individual risk of cancer from exposure to ethylene oxide was significantly higher than what is generally considered acceptable.The petitioners initially raised their complaints during the EPA’s rulemaking process and sought reconsideration after the final rule was issued. The EPA granted reconsideration and solicited further public comment, ultimately affirming its decision to use its existing cancer-risk assessment and rejecting an alternative assessment proposed by the Texas Commission on Environmental Quality (TCEQ). The petitioners then sought review from the United States Court of Appeals for the District of Columbia Circuit.The United States Court of Appeals for the District of Columbia Circuit reviewed the case and found that the EPA had adequately explained its modeling approach and decisions. The court held that the EPA’s reliance on its 2016 cancer-risk assessment was not arbitrary or capricious and that the EPA had properly considered and rejected the TCEQ’s alternative assessment. The court also found that the EPA had provided sufficient opportunities for public comment and had not violated any procedural requirements. The court denied the petitions for review, upholding the EPA’s rule and its assessment of the cancer risk from ethylene oxide emissions. View "Huntsman Petrochemical LLC v. EPA" on Justia Law

A group of property owners sued Columbia County over stormwater drainage issues that caused damage to their property. The property, purchased in 1996, contained a metal pipe used in the County's stormwater system. Over the years, heavy rains caused the pipe to fail multiple times, leading to significant property damage. The property owners sent a notice to the County in October 2013, outlining their claims, but the County declined to make repairs. The property owners then filed a lawsuit in March 2014, seeking damages and an injunction to prevent further damage.The trial court found in favor of the property owners, ruling that the County maintained a nuisance that amounted to a taking without just compensation. The court awarded damages and issued a permanent injunction against the County. The County appealed to the Court of Appeals, which affirmed some parts of the trial court's decision and vacated others. The Court of Appeals vacated the damages award for harms incurred after the October 2013 notice and reversed the award of attorneys' fees. However, it upheld the injunction against the County.The Supreme Court of Georgia reviewed the case and vacated the Court of Appeals' decision to uphold the injunction, ruling that it exceeded the bounds of the Georgia Constitution's limited waiver of sovereign immunity. The Court directed the Court of Appeals to remand the case to the trial court to consider a new injunction within the constitutional limits. The Supreme Court also concluded that it should not have granted certiorari on the issue of damages for harms incurred after the October 2013 notice, as the Court of Appeals' ruling was specific to the facts of this case and did not establish a general rule of law. The petition for certiorari on this issue was therefore denied. View "Satcher v. Columbia County" on Justia Law

Ryan Milliron submitted an Open Records Act request to Manos Antonakakis, a professor at Georgia Tech, seeking records related to Antonakakis’s services to Georgia Tech as a private contractor. Milliron also sent a similar request to Georgia Tech. Antonakakis did not respond individually, but Georgia Tech provided some documents. Unsatisfied, Milliron sued Antonakakis, alleging he held additional public records in his capacity as a private contractor. Milliron claimed Antonakakis’s companies, formed to receive DARPA funding for Georgia Tech, maintained relevant records.The trial court dismissed Milliron’s complaint, ruling that only agencies, not individual employees or private contractors, are obligated to produce public records under the Open Records Act. The court also found that Milliron’s request to Antonakakis was improper because Georgia Tech had a designated open records officer. The Court of Appeals affirmed the trial court’s decision, agreeing that Milliron’s request was not properly submitted to the designated officer.The Supreme Court of Georgia reviewed the case and concluded that the Open Records Act applies to records held by private contractors performing services for public agencies. The Court held that requests for such records can be made directly to the custodian of the records, including private contractors, even if the agency has a designated open records officer. The Court reversed the Court of Appeals’ decision and remanded the case for further proceedings to determine what records Antonakakis may hold and whether they are public records under the Act. View "Milliron v. Antonakakis" on Justia Law

Noncitizen laborers were brought into the United States to work for construction subcontractor defendants. The plaintiffs alleged that the defendants fraudulently applied for B-1 employment visas, which cost less than the petition-based visas they should have applied for, thereby violating the False Claims Act (FCA). Additionally, one plaintiff claimed that the defendants violated the Trafficking Victims Prevention Reauthorization Act (TVPRA) by threatening prosecution and suing him to coerce other workers to continue working.The United States District Court for the Northern District of California dismissed the plaintiffs' claims. The court held that the defendants did not have an "established duty" to pay for the more expensive visas because they never applied for them, thus no legal obligation existed under the FCA. The court also dismissed the TVPRA claim, finding that the plaintiff did not allege that the defendants' actions coerced him to provide any labor.The United States Court of Appeals for the Ninth Circuit affirmed the district court's dismissal. The appellate court agreed that the defendants had no "established duty" to pay for the more expensive visas since they did not apply for them, and thus did not violate the FCA. The court also upheld the dismissal of the TVPRA claim, concluding that the plaintiff did not state a claim because the defendants' actions did not coerce him to provide any labor. The court's main holding was that potential liability for applying for the wrong visas does not constitute an "established duty" to pay under the FCA, and that the TVPRA claim failed because the plaintiff was not coerced into providing labor. The decision was affirmed. View "LESNIK V. ISM VUZEM D.O.O." on Justia Law

A charter school was accused of manipulating attendance records to receive excess state aid. The Minnesota Department of Education (the Department) audited the school based on these allegations and found significant discrepancies, leading to a retroactive reduction in aid by over $1.3 million. The school appealed the audit results administratively, but the Department upheld its decision.The school then appealed to the Minnesota Court of Appeals, arguing that the Department should have investigated the allegations under a statute dealing with violations of law (Minn. Stat. § 127A.42) rather than the statute used for auditing aid distributions (Minn. Stat. § 127A.41). The Court of Appeals affirmed the Department's decision, stating that the Department had the authority to conduct the audit under the statute it used.The Minnesota Supreme Court reviewed the case to determine whether the Department was required to investigate under the statute related to violations of law. The court held that the Department had the statutory authority to audit the school under Minn. Stat. § 127A.41 and was not required to investigate under Minn. Stat. § 127A.42, even though the allegations involved potentially illegal activity. The court affirmed the decision of the Court of Appeals, concluding that the Department's actions were within its legal authority. View "Minnesota Internship Center vs. Minnesota Department of Education" on Justia Law

The case involves several states suing the President of the United States, the Secretary of Education, and the U.S. Department of Education to prevent the implementation of a plan to forgive approximately $475 billion in federal student loan debt. The plan, known as SAVE, significantly alters the existing income-contingent repayment (ICR) plan by lowering payment amounts, often to $0 per month, and forgiving principal balances much sooner than previous plans.The United States District Court for the Eastern District of Missouri granted a preliminary injunction in part, finding that Missouri had standing through its state instrumentality, MOHELA, which faced certain irreparable harm. The court concluded that the states had a fair chance of success on the merits, particularly that loan forgiveness under SAVE was not statutorily authorized and violated the separation of powers under the major-questions doctrine. However, the court only enjoined the ultimate forgiveness of loans, not the payment-threshold provisions or the nonaccrual of interest.The United States Court of Appeals for the Eighth Circuit reviewed the case and agreed with the district court that Missouri had standing. The court found that the states demonstrated a fair chance of success on the merits, noting that the SAVE plan's scope was even larger than a previously contested loan-cancellation program. The court also found that the Government's actions had rendered the district court's injunction largely ineffective. Balancing the equities, the court decided to grant in part and deny in part the states' motion for an injunction pending appeal, prohibiting the use of the hybrid rule to circumvent the district court's injunction. The injunction will remain in effect until further order of the court or the Supreme Court of the United States. View "State of Missouri v. Biden" on Justia Law