The plaintiffs challenged the constitutionality of North Carolina’s sex offender registration statute, arguing that it violated the Ex Post Facto Clause of the Constitution by retroactively imposing new punishments for crimes committed in the past. The statute requires offenders to report personal information to law enforcement and restricts where they can live, work, and visit. The plaintiffs, including two nonprofit organizations and two individuals, sought to bar the retroactive application of certain amendments to the statute.The United States District Court for the Middle District of North Carolina held a bench trial and found that the statute was nonpunitive and thus did not violate the Ex Post Facto Clause. The court concluded that the legislature intended to create a civil, nonpunitive scheme and that the plaintiffs failed to show by the clearest proof that the statute’s effects were punitive.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court’s judgment. The appellate court agreed that the legislature intended to enact a civil, nonpunitive scheme aimed at protecting public safety. The court also found that the statute was rationally connected to this nonpunitive purpose and was not excessive in relation to its goal. Although the statute imposed significant burdens on registrants, the court concluded that these burdens did not amount to punishment. The court held that the plaintiffs did not provide the clearest proof that the statute’s effects were so punitive as to override the legislature’s intent.Therefore, the Fourth Circuit affirmed the district court’s judgment, upholding the constitutionality of North Carolina’s sex offender registration statute under the Ex Post Facto Clause. View "National Assoc. For Rational Sexual Offense Laws v. Stein" on Justia Law

In 2001, China and Nigeria signed a bilateral investment treaty to encourage investment between the two countries, agreeing to treat each other's investors fairly and protect their investments. Zhongshan Fucheng Industrial Investment, a Chinese company, invested in Nigeria by participating in a joint venture with Ogun State to develop a free-trade zone. After years of development and significant investment, Ogun State abruptly terminated its relationship with Zhongshan, and Nigerian federal authorities expelled the company's executives. Zhongshan initiated arbitration proceedings, and an arbitrator found that Nigeria had breached its obligations under the treaty, awarding Zhongshan over $55 million in damages.The United States District Court for the District of Columbia held that it had jurisdiction over the case, finding that the Foreign Sovereign Immunities Act’s (FSIA) arbitration exception applied because the award was governed by the New York Convention, an international arbitration treaty. Nigeria appealed, arguing that it was immune from suit under the FSIA.The United States Court of Appeals for the District of Columbia Circuit reviewed the case and affirmed the district court's decision. The appellate court held that the FSIA’s arbitration exception applied because the arbitration award arose from a legal relationship considered commercial, governed by the New York Convention. The court found that Nigeria had an arbitration agreement with Zhongshan, an arbitration award was issued, and the award was governed by the New York Convention. The court rejected Nigeria's argument that the New York Convention only applies to private acts, holding that the treaty covers arbitral awards arising from sovereign acts when a state consents to arbitration. Thus, the court affirmed the district court's jurisdiction and the enforceability of the arbitration award. View "Zhongshan Fucheng Industrial Investment Co. Ltd v. Federal Republic of Nigeria" on Justia Law

The plaintiffs, Medicare beneficiaries with chronic illnesses, rely on home health aides for essential care. They allege that Medicare-enrolled providers have either refused to provide in-home care or offered fewer services than entitled, attributing this to the policies of the Secretary of Health and Human Services. They sought systemwide reforms through a lawsuit.The United States District Court for the District of Columbia dismissed the plaintiffs' complaint for lack of Article III standing. The court found that the plaintiffs failed to plausibly allege that their requested relief would redress any harm. The court noted that the injuries were caused by private home health agencies (HHAs) not before the court and that it was speculative whether enjoining the Secretary would change the HHAs' behavior. The court also found the plaintiffs' requested relief too general, making it difficult to evaluate its potential impact.The United States Court of Appeals for the District of Columbia Circuit reviewed the case and affirmed the district court's dismissal. The appellate court held that the plaintiffs failed to demonstrate redressability, a key component of standing. The court noted that the plaintiffs' injuries stemmed from the independent choices of private HHAs, and it was speculative that the requested injunctions would prompt these agencies to change their behavior. The court emphasized that the plaintiffs did not provide sufficient evidence to show that the Secretary's enforcement policies were a substantial factor in the HHAs' decisions. Consequently, the plaintiffs lacked standing to bring the suit, and the dismissal for lack of jurisdiction was affirmed. View "Johnson v. Becerra" on Justia Law

The case involves the Animal Legal Defense Fund (ALDF) challenging the U.S. Department of Agriculture's (USDA) approval of Perdue's "Fresh Line" chicken and turkey product labels. ALDF claimed that the labels, which depicted birds roaming outside, were misleading because the birds were raised indoors. ALDF requested the USDA to disapprove these labels, arguing that they misled consumers. The USDA declined, leading ALDF to sue, alleging violations of the Poultry Products Inspection Act (PPIA) and the Administrative Procedure Act (APA).The United States District Court for the District of Columbia dismissed ALDF's complaint, concluding that ALDF lacked standing to challenge the USDA's actions. The court found that ALDF failed to establish both organizational and associational standing. Specifically, the court determined that ALDF's member, Marie Mastracco, did not suffer a sufficiently concrete injury to confer standing.The United States Court of Appeals for the District of Columbia Circuit reviewed the case de novo. The court agreed with the district court, finding that ALDF did not demonstrate that Mastracco faced an ongoing or imminent injury. The court noted that while Mastracco was misled by the labels in the past, she now knows the truth about the birds' living conditions, making any future reliance on the labels self-inflicted. Additionally, the court found that ALDF failed to show that other poultry-product labels with similar misleading graphics existed, which would be necessary to establish a substantial likelihood of future harm.The Court of Appeals affirmed the district court's dismissal of ALDF's complaint without prejudice, holding that ALDF lacked standing to pursue its claims. View "Animal Legal Defense Fund, Inc. v. Vilsack" on Justia Law

In 2017, Special Counsel Robert S. Mueller III began investigating Russian interference in the 2016 presidential election, during which Giorgi Rtskhiladze testified before a grand jury. When the Department of Justice (DOJ) released a redacted version of Mueller’s report, it included information that Rtskhiladze claimed was inaccurate and damaging to his reputation. Rtskhiladze sued for both equitable and monetary relief and sought a copy of his grand jury testimony transcript.The United States District Court for the District of Columbia ruled that Rtskhiladze lacked standing for his equitable claims, failed to state a claim for damages, and was not entitled to obtain a copy of the transcript. The court found that Rtskhiladze had abandoned his separate damages claim against DOJ and Mueller personally and forfeited arguments about this claim on appeal.The United States Court of Appeals for the District of Columbia Circuit held that Rtskhiladze has standing to bring all his claims and remanded the equitable claims for further consideration. The court agreed with the district court that Rtskhiladze failed to state a claim for damages under the Privacy Act, as he did not allege "intentional or willful" conduct by DOJ. The court also upheld the district court’s decision to deny Rtskhiladze’s request to obtain a copy of his grand jury testimony transcript, emphasizing the government’s interest in maintaining grand jury secrecy and preventing witness intimidation.In summary, the appellate court reversed the district court’s dismissal of Rtskhiladze’s equitable claims for lack of standing, affirmed the dismissal of his damages claim for failure to state a claim, and upheld the denial of his request to obtain a copy of his grand jury transcript. View "Rtskhiladze v. Mueller" on Justia Law

The Bureau of Alcohol, Tobacco, Firearms, and Explosives (ATF) issued a final rule reclassifying pistols equipped with stabilizing braces as short-barreled rifles under the National Firearms Act (NFA) and the Gun Control Act (GCA). This reclassification subjects these weapons to stringent regulations. The plaintiffs, including a stabilizing-brace manufacturer, a firearm manufacturer, a gun association, an individual owner, and twenty-five states, challenged the rule, arguing it exceeded the ATF’s statutory authority and was arbitrary and capricious. The district court denied the plaintiffs' motion for a preliminary injunction, leading to this appeal.The United States District Court for the District of North Dakota initially reviewed the case and denied the plaintiffs' request for a preliminary injunction. The court concluded that the plaintiffs did not demonstrate a substantial likelihood of success on the merits of their claims, which included arguments that the rule exceeded the ATF’s statutory authority and was arbitrary and capricious. The plaintiffs then appealed this decision.The United States Court of Appeals for the Eighth Circuit reviewed the case and found that the plaintiffs were likely to succeed on the merits of their arbitrary-and-capricious challenge. The court held that the ATF’s rule was arbitrary and capricious because it lacked clear metrics for determining when a stabilizing brace provides sufficient surface area to shoulder a weapon, and the multifactor test used by the ATF was internally inconsistent and inadequately explained. Additionally, the court found that the accompanying slideshows, which classified certain weapons as short-barreled rifles without explanation, further demonstrated the arbitrary nature of the rule. Consequently, the Eighth Circuit reversed the district court’s denial of the preliminary injunction and remanded the case for reconsideration consistent with its opinion. View "Firearms Regulatory Accountability Coalition, Inc. v. Garland" on Justia Law

The Board of Allied Mental Health Practitioners denied an application for a license to practice clinical mental-health counseling in Vermont, citing the applicant's failure to meet educational prerequisites. The applicant, who graduated from a non-accredited program, argued that her coursework met the requirements through a combination of two courses. She also claimed that the Board had previously accepted similar coursework from another candidate, J.L., and sought to present evidence to support this claim.The Office of Professional Regulation (OPR) upheld the Board's decision. The applicant appealed, arguing that the Board and OPR improperly limited her ability to demonstrate that she was treated differently from similarly situated candidates. She also contended that the Board failed to justify its allegedly inconsistent application of licensing regulations. The appellate officer denied her motion to present additional evidence, concluding that the Board's evidentiary ruling was a matter of record and that the applicant was not seeking to introduce evidence of procedural irregularities but rather the excluded evidence itself.The Vermont Supreme Court reviewed the case and affirmed the decisions of the Board and OPR. The Court held that comparator evidence might be relevant in some circumstances but found that the applicant failed to make a threshold showing that the Board had accepted credits from two courses in J.L.'s case. The Court also concluded that the Board did not abuse its discretion in excluding further evidence about J.L.'s coursework as cumulative and of dubious relevance. The appellate officer's denial of the motion to present additional evidence was also upheld, as the applicant did not demonstrate good cause for the motion. The Court affirmed the lower decisions, finding no basis to disturb them. View "In re McNamer" on Justia Law

Robert William Doelz was convicted of possession of methamphetamine with intent to distribute. In 2019, the Kansas Supreme Court reversed his conviction, finding that his Fourth Amendment rights were violated due to a warrantless search, and the evidence obtained should have been suppressed. On remand, the State dropped the charge and did not pursue a retrial. Subsequently, Doelz sought compensation for his wrongful conviction under K.S.A. 2020 Supp. 60-5004, which requires proving actual innocence among other criteria.The Shawnee District Court denied both parties' motions for summary judgment, interpreting K.S.A. 2023 Supp. 60-5004(c)(1)(C) to require a claimant to prove that their innocence resulted in the reversal of their conviction, dismissal of charges, or a not guilty verdict upon retrial. The court found that Doelz's conviction was reversed due to a Fourth Amendment violation, not because he did not commit the crime. Since there was no evidence explaining why the charges were dismissed, a material fact remained unresolved. At a bench trial, Doelz testified to his innocence, but the court granted the State's motion for judgment as a matter of law, finding that Doelz failed to prove the charges were dismissed due to his innocence.The Kansas Supreme Court affirmed the district court's decision. The court held that K.S.A. 2023 Supp. 60-5004(c)(1)(C) requires a claimant to prove actual innocence and that this innocence led to the reversal, dismissal, or acquittal. The court found that the legislative intent behind the statute was to compensate only those who are factually innocent. Since Doelz did not provide evidence that the charges were dismissed because of his innocence, he did not meet the statutory requirements for compensation. View "In the Matter of the Wrongful Conviction of Doelz" on Justia Law

Nevada Health CO-OP, a health insurance provider, received two loans from the Centers for Medicare & Medicaid Services (CMS) under the Affordable Care Act’s CO-OP program. These loans included a start-up loan and a solvency loan. In 2015, Nevada Health faced financial difficulties and was placed into receivership by the Nevada Commissioner of Insurance. CMS subsequently terminated the loan agreement and began offsetting payments owed to Nevada Health against the start-up loan debt.The United States Court of Federal Claims reviewed the case and granted summary judgment in favor of the Nevada Commissioner of Insurance, acting as the receiver for Nevada Health. The court found that the government improperly withheld statutory payments owed to Nevada Health under the ACA. The court also held that the government could not invoke 31 U.S.C. § 3728 to withhold these payments in the future.The United States Court of Appeals for the Federal Circuit reviewed the case. The court affirmed the lower court’s judgment that the government improperly withheld payments owed to Nevada Health. The court held that the loan agreement subordinated the government’s claim to those of policyholders and basic operating expenses, thus precluding the government from asserting offset rights to jump ahead of these senior creditors. However, the appellate court vacated the portion of the lower court’s order that addressed the government’s ability to invoke 31 U.S.C. § 3728, ruling that the lower court exceeded its jurisdiction by addressing this issue, which was not raised by the parties. View "Richardson v. United States" on Justia Law

An inmate in the custody of the Nebraska Department of Correctional Services (DCS) filed a negligence action against the State of Nebraska under the State Tort Claims Act (STCA). The inmate alleged that DCS failed to investigate his complaint that other inmates had stolen his property while he was in segregated confinement. He claimed that this failure to investigate resulted in the loss of his property, valued at $496.05, and caused him mental and emotional distress.The District Court for Lancaster County dismissed the case, finding that it lacked subject matter jurisdiction. The court concluded that the inmate failed to plead a cognizable claim under the STCA because he did not show that the State owed him a legal duty under the relevant regulations. The court determined that the regulations cited by the inmate did not create a legal duty owed to him by the State.The Nebraska Supreme Court reviewed the case de novo and affirmed the district court's decision. The Supreme Court held that the inmate disciplinary procedure statutes and regulations did not give rise to a tort duty of the State to investigate the alleged theft of the inmate's property. The court found that these regulations were designed to prescribe disciplinary procedures for inmates who allegedly engaged in misconduct, not to protect an inmate seeking an investigation into other inmates' alleged misconduct. As a result, the inmate failed to state a claim of negligence under the STCA, and the State's sovereign immunity was not waived. Therefore, the district court correctly dismissed the case for lack of subject matter jurisdiction. View "Ryan v. State" on Justia Law