The case involves the Newport School Committee and the Cumberland School Committee (collectively, plaintiffs) and the Rhode Island Department of Education and the Rhode Island Council on Elementary and Secondary Education (collectively, defendants). The dispute arose when the plaintiffs refused to reimburse the Department of Children, Youth, and Families (DCYF) at the "per-pupil special-education" rate for the cost of educating children who were placed in residential treatment programs by DCYF but were not receiving special-education services. The Family Court had placed two children in the temporary custody of DCYF and designated Newport and Cumberland as the residences of the children's custodial parents for the purpose of determining the municipalities' financial responsibility for the children's education.The Commissioner of Elementary and Secondary Education agreed with DCYF's argument that the municipalities were required to pay the per-pupil special-education rate according to the unambiguous language of the relevant statutes. The Commissioner issued two decisions ordering Newport and Cumberland to reimburse DCYF for the cost of educational services provided to the children at the special-education rate. After the Council on Elementary and Secondary Education denied the municipalities' independent appeals of the Commissioner's decisions, the municipalities appealed to the Superior Court. The trial justice consolidated the two cases and issued a written decision, determining that the clear and unambiguous language of the statute required the designated city or town to pay its share of the cost of educational services to DCYF rather than the higher, per-pupil special-education rate.The Supreme Court of Rhode Island reviewed the case and found that there is nothing in the relevant statutes that expressly obligates a municipality to pay the per-pupil special-education rate when the child in question is not actually receiving special-education services. The court concluded that municipalities are not required to reimburse DCYF at the per-pupil special-education rate when there were no special education services rendered and thus, no special education costs incurred. The court directed the parties to file supplemental briefs to resolve the remaining question of what reimbursement, if any, DCYF should receive for the educational cost of non-special-education students placed in residential treatment programs that include the delivery of educational services. View "Newport School Committee v. Rhode Island Department of Education" on Justia Law

This case involves four individuals, Joao Neves, Keith Nunes, Pablo Ortega, and Mario Monteiro, who were convicted of various crimes in Rhode Island and were serving multiple sentences, including life sentences. The issue at hand is the interpretation of a Rhode Island statute, G.L. 1956 § 13-8-13(e), which was enacted in 2021 and provides that any person sentenced for any offense committed prior to their twenty-second birthday, other than a person serving life without parole, shall be eligible for parole review after serving no fewer than twenty years' imprisonment.The state argued that the statute applies only to individuals serving a single sentence and does not require the aggregation of multiple sentences for parole eligibility. The respondents, on the other hand, argued that the statute applies to "any offense," and thus requires the aggregation of multiple sentences, including consecutive sentences, for parole eligibility.The trial justice agreed with the respondents and ordered that each respondent be immediately released on parole. The state appealed, arguing that the trial justice's interpretation of the statute violated the separation-of-powers doctrine by modifying judicial sentences.The Supreme Court of Rhode Island held that the statute mandates the aggregation of a qualified offender’s sentences, including consecutive sentences, for parole eligibility. The court also concluded that the statute, as interpreted, does not violate the separation-of-powers doctrine. However, the court found that the trial justice erred in ordering each respondent to be immediately released on parole, as the statute only provides a qualified offender the opportunity to appear before the parole board, not the right to be paroled. The court affirmed in part and vacated in part the judgments of the lower court, and remanded the cases to the parole board for further proceedings. View "Neves v. State of Rhode Island" on Justia Law

The case involves an American citizen and her noncitizen husband who sued two U.S. Citizenship and Immigration Services (USCIS) officials, alleging that USCIS unreasonably delayed adjudicating a waiver application the husband submitted two years prior. The plaintiffs argued that the Administrative Procedure Act (APA) and the Mandamus Act granted subject-matter jurisdiction over their claims. The district court dismissed their claims, concluding that language in the Immigration and Nationality Act (INA) that denies courts jurisdiction over suits based on agency “decisions or actions” also bars suits over agency inaction.The United States Court of Appeals for the Fourth Circuit affirmed the district court's decision, but for different reasons. The appellate court found that the district court erred in interpreting the INA's jurisdictional bar to include agency inaction. However, the court concluded that no statute or regulation requires USCIS to adjudicate the husband’s waiver application, and therefore, the district court lacked jurisdiction over the plaintiffs' claims. The court noted that while the delay in adjudication was stressful for the plaintiffs, their complaint should be addressed to the political branches, as the court lacked jurisdiction to order the relief sought. View "Lovo v. Miller" on Justia Law

The case revolves around Thomas E. Hennig, Jr., who was discharged from his job at Money Metals Exchange, L.L.C. after making a controversial comment on the company's instant messaging system. Hennig referred to himself as his employer’s “good little Nazi” in a joke about enforcing the company’s time clock rules. After his termination, Hennig applied for unemployment benefits, but his application was denied by the Idaho Department of Labor (IDOL) on the grounds that he was discharged for misconduct connected with his employment. Hennig appealed this decision to the Idaho Industrial Commission, which upheld the IDOL's decision.Hennig then appealed to the Supreme Court of the State of Idaho, arguing that the Commission’s decision was unsupported by competent and substantial evidence. He contended that his use of the term "Nazi" was not objectively unprofessional and that the company had tolerated racist remarks from another employee. The Supreme Court of Idaho reversed the Commission’s decision and remanded the case for further proceedings. The court found that the Commission had failed to properly analyze whether the company's expectations of Hennig's behavior were objectively reasonable, given evidence that it had tolerated racist comments from another co-worker and then promoted him to a supervisory position. The court also found that the Commission had failed to consider Hennig's claim that the company had encouraged his unorthodox humor. View "Hennig v. Money Metals Exchange" on Justia Law

Domingo Musquiz, a former rail industry employee, petitioned for review of a decision by the U.S. Railroad Retirement Board (RRB). The RRB had adopted a hearing officer's finding that Musquiz was at fault for an overpayment of his reduced-age annuity under the Railroad Retirement Act (RRA) and denied his request for a waiver or reduction of repayment of the overpayment and penalty. Musquiz had failed to report his re-employment and additional income to the RRB, leading to the overpayment.The RRB's decision was based on the fact that Musquiz had received a booklet of regulations, including reporting requirements, when he applied for his annuity. The RRB concluded that Musquiz should have known about his reporting duties and was at fault when he did not report his change in employment and additional outside income.The United States Court of Appeals for the Ninth Circuit agreed with the RRB that Musquiz was at fault for the overpayment that occurred from August 2012 to June 2, 2013. However, the court concluded that Musquiz was without fault for the RRB’s overpayment of his annuity from June 3, 2013, onward. The court reasoned that by then, the RRB had informed Musquiz that they had taken his outside earnings into account and adjusted his annuity payments.The court granted Musquiz's petition, vacated the RRB's decision, and remanded the case to the RRB for further proceedings. The court instructed the RRB to develop a factual record and determine whether recovery of the overpayment from June 3, 2013, onward would be contrary to the purpose of the RRA, against equity, or against good conscience. View "Musquiz V. United States Railroad Retirement Board" on Justia Law

In April 2018, Benjamin Evans was shot and killed by Police Deputy Brian Krook in Lake Elmo, Minnesota, after Evans knelt in a crosswalk with a loaded gun pointed at his own head. Following a criminal trial, Krook was acquitted of a second-degree manslaughter charge. Subsequently, Evans' father, William O. Evans, Jr., filed a civil lawsuit against Krook under 42 U.S.C. § 1983, alleging excessive force in violation of the Fourth Amendment. Krook sought summary judgment based on qualified immunity, a defense unavailable when an officer uses deadly force against someone who does not pose an immediate threat of serious physical harm to another.The District Court for the District of Minnesota denied Krook's motion for summary judgment, citing genuine factual disputes over whether Evans' gun was ever pointed at the officers and whether Evans posed an immediate threat to them. Krook appealed this decision, challenging the denial of qualified immunity.The United States Court of Appeals for the Eighth Circuit, in reviewing the case, first addressed the question of jurisdiction. The court noted that it did not have jurisdiction to review the district court's determination regarding evidence sufficiency, i.e., what facts a party may or may not be able to prove at trial. The court's jurisdiction was limited to the purely legal question of whether the conduct that the district court found was adequately supported in the record violated a clearly established federal right.The court found that the availability of qualified immunity in this case hinged on whether Krook acted reasonably under the circumstances by shooting Evans because Evans either pointed his gun at another or otherwise wielded his gun in a menacing fashion. The court concluded that the inconclusive nighttime videos of Evans' actions did not clearly contradict the district court's factual determinations. Therefore, resolving the underlying factual dispute was beyond the court's limited review. As such, the court dismissed the appeal, stating it lacked the jurisdiction to resolve it. View "Evans v. Krook" on Justia Law

The case revolves around Larry Sapp, an Army veteran with a history of felony drug convictions, who was elected to the Sauk Village Board of Trustees in Illinois. However, his felony convictions came to the attention of the Cook County State’s Attorney’s Office, which used two Illinois statutes to remove him from his position. These statutes bar certain felons from holding public office. Sapp challenged the constitutionality of these statutes, arguing that they violated the Eighth Amendment's clauses on Cruel and Unusual Punishment and Excessive Fines by barring him from public service and depriving him of the income a career in public service would generate.The Cook County Circuit Court rejected Sapp's arguments, ruling that the statutes' enforcement did not violate the Eighth Amendment. The court held that Sapp was ineligible to serve as a Board Trustee and removed him from his position. Sapp then filed a federal lawsuit against Illinois Governor J.B. Pritzker and State’s Attorney Kimberly Foxx, seeking to bar the Cook County State’s Attorney from enforcing either statute against him in future elections. He reiterated his Eighth Amendment arguments and added a new one, claiming that enforcing the statutes against him would violate the Cruel and Unusual Punishment Clause.The United States Court of Appeals for the Seventh Circuit affirmed the dismissal of Sapp’s complaint. The court did not reach the merits of Sapp's constitutional arguments, instead ruling that they were foreclosed by Illinois principles of collateral estoppel and res judicata. The court held that Sapp's federal lawsuit arose from the same group of operative facts as the State’s Attorney’s quo warranto action in Cook County Court, and thus constituted the same "cause of action" under Illinois law. As a result, Sapp was barred from raising arguments in the federal suit that were available to him in the quo warranto action. View "Sapp v. Foxx" on Justia Law

The case involves the Union Leader Corporation (Union Leader) and the New Hampshire Department of Safety (Department). Union Leader sought to compel the Department to disclose records under the Right-to-Know Law, specifically records related to the response by New Hampshire State Police to the Sununu Youth Services Center (SYSC) on October 7 and 8, 2022. The Department refused to disclose the records, arguing that they were confidential law enforcement investigative records pertaining to juvenile delinquency.The Superior Court dismissed Union Leader's suit, siding with the Department. The court found that the requested records contained facts that underlie the basis for juvenile delinquency proceedings. Therefore, based on a previous decision in Petition of State of New Hampshire (Disclosure of Juvenile Records), the court concluded that the release of the records Union Leader requested was prohibited.The Supreme Court of New Hampshire reversed the lower court's decision and remanded the case. The Supreme Court found that the term "court records" in RSA 169-B:35 should not be read so expansively as to shield a broad category of otherwise public records from a request made pursuant to the Right to Know Law, even if that record is related to alleged unlawful conduct by unidentified minors. The court concluded that it is conceivable that information in the Department’s possession could answer Union Leader's questions without interfering with the rehabilitation of the minors against whom juvenile petitions were filed. It is also conceivable that responsive records could be redacted so as to ensure that their disclosure neither conflicts with nor compromises the rehabilitative purpose of RSA chapter 169-B. The case was remanded for the lower court to make those determinations. View "Union Leader Corp. v. N.H. Dep't of Safety" on Justia Law

The case revolves around a dispute between H. Cliff Page and the Portsmouth Redevelopment and Housing Authority (PRHA). Page owned a building in Portsmouth that shared a common wall with a building owned by PRHA. In 2014, PRHA demolished its building after the City of Portsmouth declared it an unlawful nuisance. Page claimed that the demolition was negligently performed and damaged his building. PRHA responded with a plea in bar, raising the defense of sovereign immunity.The circuit court held a hearing on the plea in bar and ruled in favor of PRHA, holding that sovereign immunity barred Page’s claim. The court found that the demolition of the property was implemented under the City of Portsmouth’s plan to address blight in the Downtown Portsmouth Historic District. The Court of Appeals affirmed the circuit court’s ruling, stating that PRHA’s immunity should be the same as that of the City of Portsmouth.However, the Supreme Court of Virginia disagreed with the lower courts' decisions. The court held that sovereign immunity does not shield PRHA from tort liability under the circumstances of this case. The court found that PRHA was acting in its proprietary capacity, similar to a private landowner, when it demolished the building. The court concluded that PRHA's obedience to the City’s Notice of Emergency Demolition was not an exercise of governmental discretion but a ministerial legal duty to perform a proprietary function. Therefore, the court reversed the decision of the Court of Appeals and remanded the case to the circuit court for further proceedings. View "Page v. Portsmouth Redevelopment & Housing Authority" on Justia Law

The case revolves around the Metropolitan Washington Airports Authority (the Authority), an entity jointly created by Virginia and the District of Columbia to manage the area's two airports. The Authority disputed the Virginia Department of Labor and Industry's (the Department) power to enforce its workplace safety laws against the Authority. The Department had levied a monetary penalty against the Authority following an accident that resulted in an employee's injury. The Authority contested the Department's power to enforce these penalties, arguing that it was not subject to Virginia workplace safety regulations due to its status as an interstate compact entity.The Department's adjudicator found that the Authority was subject to Virginia workplace safety regulations, a decision adopted by the Department's Commissioner. The Authority then sued the Commissioner in federal court seeking injunctive and declaratory relief. The district court ruled in favor of the Authority, reasoning that Virginia had surrendered its ability to exercise unilateral regulatory authority over the Authority's facilities when it created the Authority.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court's decision. The court agreed with the Authority that by jointly creating the Authority with the District, Virginia relinquished its control over the Authority except as otherwise provided in the Compact. The court rejected the Department's argument that the Compact expressly reserves its power to enforce Virginia’s workplace safety regulations against the Authority. The court also dismissed the Department's contention that it can enforce its workplace safety laws against the Authority because nothing in the Compact preempts Virginia law. View "Metropolitan Washington Airports Authority v. Pan" on Justia Law