This case involves a catastrophic wildfire that occurred in 2016 in the Great Smoky Mountains National Park in Eastern Tennessee. The fire spread into Gatlinburg and Sevier County, resulting in the destruction of over 2,500 structures and the death of 14 people. The appellant insurance companies paid claims to policy holders and then filed claims under the Federal Tort Claims Act (FTCA) against the National Park Service (NPS), alleging negligence for failure to follow multiple mandatory fire-management protocols and for the failure to issue mandatory warnings to the public.The government moved to dismiss the case for lack of subject-matter jurisdiction, arguing that it was immune from suit under the discretionary-function exception to the FTCA. The district court granted the motion on all three claims relating to fire-management protocols, but denied the motion on claims relating to the duty to warn. The insurance companies appealed, and the government cross-appealed.The United States Court of Appeals for the Sixth Circuit reversed the district court's order granting the government's motion to dismiss the insurance companies' incident-command claim. The court affirmed the district court's dismissal of the fire-monitoring claim and the Wildland Fire Decision Support System (WFDSS) claim as part of the discretionary fire-suppression decision-making process. The court also affirmed the district court's denial of the government's facial challenge to the insurance companies' duty-to-warn claims, and remanded these claims for further proceedings. View "American Reliable Insurance Co. v. United States" on Justia Law

The Supreme Court of the United States reviewed two cases involving challenges to a rule promulgated by the National Marine Fisheries Service under the Magnuson-Stevens Act. The rule required certain fishing vessels to carry observers onboard to collect data necessary for fishery conservation and management, with the cost of these observers to be borne by the vessel owners. The petitioners, various fishing businesses, argued that the Act did not authorize the Fisheries Service to impose these costs on them.In the lower courts, the District Court for the District of Columbia Circuit and the First Circuit Court of Appeals both upheld the rule. They applied the Chevron framework, a two-step process used to interpret statutes administered by federal agencies. Under this framework, if a statute is ambiguous, courts defer to the agency's interpretation as long as it is reasonable. Both courts found that the Magnuson-Stevens Act was ambiguous on the issue of observer costs and deferred to the Fisheries Service's interpretation.The Supreme Court, however, overruled the Chevron doctrine, holding that it was inconsistent with the Administrative Procedure Act (APA). The APA requires courts to exercise their independent judgment in deciding whether an agency has acted within its statutory authority. Courts may not defer to an agency interpretation of the law simply because a statute is ambiguous. The Court vacated the judgments of the lower courts and remanded the cases for further proceedings consistent with this opinion. The Court emphasized that while courts may seek guidance from the interpretations of those responsible for implementing particular statutes, they must not defer to these interpretations. Instead, they must independently interpret the statute and ensure that the agency has acted within its statutory authority. View "Loper Bright Enterprises v. Raimondo" on Justia Law

A group of residents and a church, collectively referred to as the "Neighbors," sued Ghassan Korban, the Executive Director of the Sewerage and Water Board of New Orleans (SWB), for damages caused to their properties during a drainage project. The Neighbors won a judgment for inverse condemnation, but the SWB did not pay. The Neighbors then filed a federal lawsuit, which was dismissed. They subsequently filed a state lawsuit seeking a writ of mandamus to compel payment of the judgment. The district court dismissed the case, but the appellate court reversed, finding that the payment of a judgment for inverse condemnation is a ministerial duty and can be enforced via a writ of mandamus.The Supreme Court of Louisiana affirmed the appellate court's decision. The court found that the federal lawsuit did not bar the state lawsuit under the doctrine of res judicata because the federal court would have declined to exercise jurisdiction over the state mandamus claim. The court also found that the Neighbors had stated a valid cause of action for a writ of mandamus. The court held that the payment of a judgment based on inverse condemnation under the Louisiana Constitution is a ministerial duty and can be enforced via a writ of mandamus. The court remanded the case to the district court to devise a plan for satisfying the judgment within a reasonable period of time. View "WATSON MEMORIAL SPIRITUAL TEMPLE OF CHRIST V. KORBAN" on Justia Law

The case involves a series of public records requests made by People for the Ethical Treatment of Animals (PETA) to Louisiana State University (LSU) seeking records related to the use and treatment of wild songbirds in the labs of Dr. Christine Lattin, an associate professor at LSU. After LSU failed to produce the requested records, PETA filed a Petition for Writ of Mandamus, Declaratory Judgment, and Injunctive Relief Pursuant to the Louisiana Public Records Act. LSU denied PETA’s allegations and asserted four affirmative defenses. The district court ruled in favor of PETA, granting access to all the records requested. LSU appealed the decision.The court of appeal affirmed in part and reversed in part the district court's decision. It found that some of the records requested by PETA had been answered by LSU and were not subject to production. However, it also found that some video recordings were not exempt from production as they had been publicly released or published. The court of appeal concluded that the district court had erred in ordering LSU to produce the video recordings that were not utilized by Dr. Lattin for the article or for her presentations and, therefore, had not been publicly released or published.The Supreme Court of Louisiana affirmed the decision of the court of appeal. It held that the veterinary care records, video recordings, communications relating to Dr. Lattin’s plans to trap or experiment on birds and to amend the City of Baton Rouge’s wild bird ordinance, and records relating to Dr. Lattin’s hiring of private counsel were all public records subject to production under the Louisiana Public Records Law. The court rejected LSU's arguments that the records were not public records, were exempt from production, or were unduly burdensome to produce. View "PEOPLE FOR THE ETHICAL TREATMENT OF ANIMALS VS. BOARD OF SUPERVISORS OF LOUISIANA STATE UNIVERSITY" on Justia Law

The case revolves around Huazhi Han, who was convicted on charges of money laundering and related offenses. Han used his electronic goods business to launder drug proceeds for Mexican drug traffickers. The Drug Enforcement Administration (DEA) and Chicago Police Department (CPD) began investigating a money laundering organization in Chicago, in which Han played a key role. Han received cash proceeds from a drug trafficker, Rafiq Roman, on multiple occasions. After Roman's arrest, he cooperated with the authorities, leading to Han's arrest. The officers found a loaded firearm, approximately $200,000 in cash, and lookalike currency in Han's car. They also searched Han's home, where they found nearly $1.3 million in cash, a money counter, rubber bands, and firearms.Han was indicted on four charges, including conspiracy to commit money laundering and operating an unlicensed money transmitting business. Before trial, Han moved to suppress the evidence seized from his home, arguing that the officers searched his home without a warrant or consent. The district court denied the motion, finding that Han's wife had voluntarily consented to the search. The case proceeded to a jury trial, where Han was convicted on all counts.On appeal, Han argued that the district court erred in denying his motion to suppress, admitting threat evidence, and denying his motion for a mistrial based on the government’s closing argument. The United States Court of Appeals for the Seventh Circuit found no error and affirmed the district court's decision. The court held that Han's wife had voluntarily consented to the search of their home, the threat evidence was admissible as it was directly related to Han's crimes, and the prosecutor's remarks during closing arguments did not result in an unfair trial. View "United States v. Huazhi Han" on Justia Law

The case involves Dianne Hensley, a justice of the peace in Texas, who announced that due to her religious beliefs, she would not perform weddings for same-sex couples but would refer them to others who would. The State Commission on Judicial Conduct issued her a public warning for casting doubt on her capacity to act impartially due to the person's sexual orientation, in violation of Canon 4A(1) of the Texas Code of Judicial Conduct. Hensley did not appeal this warning to a Special Court of Review (SCR) but instead sued the Commission and its members and officers for violating the Texas Religious Freedom Restoration Act (TRFRA) and her right to freedom of speech under Article I, Section 8 of the Texas Constitution. The trial court dismissed her claims for lack of jurisdiction, and the court of appeals affirmed.The Supreme Court of Texas held that Hensley's suit was not barred by her decision not to appeal the Commission’s Public Warning or by sovereign immunity. The court affirmed the part of the court of appeals’ judgment dismissing one of Hensley's declaratory requests for lack of jurisdiction, reversed the remainder of the judgment, and remanded to the court of appeals to address the remaining issues on appeal. The court found that the SCR could not have finally decided whether Hensley is entitled to the relief sought in this case or awarded the relief TRFRA provides to successful claimants. View "HENSLEY v. STATE COMMISSION ON JUDICIAL CONDUCT" on Justia Law

The case involves Ammonite Oil & Gas Corporation (Ammonite) and the Railroad Commission of Texas and EOG Resources, Inc. (EOG). Ammonite leases mineral rights beneath a riverbed from the State of Texas. EOG leases the minerals on the land adjoining the river on both sides. All the minerals in the area lie in a common subsurface reservoir. EOG's wells, however, do not reach the minerals beneath the riverbed. Ammonite argued that without pooling, its minerals are left stranded. Ammonite applied to the Railroad Commission for forced pooling under the Texas Mineral Interest Pooling Act (MIPA).The Railroad Commission rejected Ammonite's applications to force-pool the minerals beneath the river—which are not being produced—with those beside it—which are. The lower courts affirmed the Commission’s order. The Supreme Court of Texas also affirmed the lower courts' decisions but for different reasons than the court of appeals gave.The Supreme Court of Texas held that the Commission’s conclusion that “Ammonite failed to make a fair and reasonable offer to voluntarily pool as required by [MIPA Section] 102.013” is reasonable. The court also held that Ammonite has failed to show that forced pooling of its acreage with EOG’s wells is necessary to prevent its minerals from ultimately being lost. The court concluded that Ammonite applied for a share of EOG’s revenue without contributing to it and that the Commission’s conclusion that forced pooling would not prevent waste or protect correlative rights is not unreasonable. View "AMMONITE OIL & GAS CORPORATION v. RAILROAD COMMISSION OF TEXAS" on Justia Law

The case involves the owners and operators of several coal-fired power plants who challenged the Environmental Protection Agency's (EPA) actions regarding the disposal of coal combustion residuals. The petitioners argued that the EPA's actions amended existing legislative rules governing such disposal and that the EPA was required to promulgate those amendments according to the notice-and-comment procedures of the Administrative Procedure Act.The lower courts had previously reviewed the case, and the petitioners had sought extensions of the April 2021 closure deadline for their coal residual disposal sites. The EPA had proposed denials of these extension applications, concluding that the facilities failed to demonstrate compliance with other requirements of the coal residuals regulations.The United States Court of Appeals for the District of Columbia Circuit dismissed the petitions for lack of jurisdiction. The court found that the challenged documents straightforwardly applied existing regulations and did not amount to the kind of agency action “promulgating a[] regulation, or requirement” that the court had jurisdiction to review under the Resource Conservation and Recovery Act. The court also found that the EPA's actions did not amend the existing regulations but simply explained, interpreted, and applied them. View "Electric Energy, Inc. v. EPA" on Justia Law

This case involves five ballot initiative petitions related to the classification of "app-based drivers" (drivers) as employees of delivery network companies or transportation network companies (collectively, companies). The petitions aim to ensure that drivers are not classified as employees, thereby excluding them from the rights, privileges, and protections that Massachusetts General and Special Laws confer on employees. Three of the five petitions couple this deprivation with "minimum compensation, healthcare stipends, earned paid sick time, and occupational accident insurance." The other two do not.The plaintiffs, a group of registered voters, challenged the Attorney General's certification of the petitions and the fairness and conciseness of the summaries prepared by the Attorney General. They argued that the petitions do not meet the related subjects requirement of the Massachusetts Constitution, that one of the petitions inappropriately asks voters for an exemption from the entirety of Massachusetts law, and that the three long-form versions contain prohibited "sweeteners" that are misleadingly described. They also argued that the petitions are designed to confuse by using dense and technical language.The Supreme Judicial Court for the county of Suffolk found that all five petitions share a common purpose of defining and governing the relationship between drivers and companies, and thus meet the related subjects requirement. The court also found that the Attorney General's summaries of the petitions were fair and concise, as required by the Massachusetts Constitution. The court remanded the case to the county court for entry of a declaration that the Attorney General's certifications and summaries comply with the requirements of the Massachusetts Constitution. However, the court retained jurisdiction to revisit its rulings and conclusions if the proponents seek to place more than one petition on the November ballot. View "El Koussa v. Attorney General" on Justia Law

The case revolves around the certification of Initiative Petition 23-35, "An Act Giving Transportation Network Drivers the Option to Form a Union and Bargain Collectively" by the Attorney General. The plaintiffs argued that the petition should not have been certified as it does not meet the requirement of containing only related subjects. They contended that the provisions allowing transportation network drivers to organize and collectively bargain with transportation network companies are unrelated to its provisions subjecting the results of any collective bargaining to supervision, review, and approval by the Commonwealth's Secretary of Labor.The case was brought before the Supreme Judicial Court for Suffolk County, where the plaintiffs sought a declaration that the petition does not satisfy the related subjects requirement of art. 48, and an order enjoining the Secretary of the Commonwealth from placing the petition on the Statewide election ballot. The plaintiffs argued that the Secretary of Labor's role in the collective bargaining process is not part of the integrated scheme proposed by the petition.The Supreme Judicial Court of Massachusetts disagreed with the plaintiffs' argument. The court concluded that the petition seeks to establish a multistep collective bargaining scheme in which the Secretary of Labor's role is an integrated component. Therefore, the subjects of the petition are related for purposes of art. 48. The court affirmed the Attorney General's certification of the petition. The court also noted that the Secretary of Labor's supervisory role is designed to anticipate and address a potential consequence of the collective bargaining process the petition seeks to create, specifically a legal challenge that the collective bargaining process would be preempted by Federal antitrust law. View "Craney v. Attorney General" on Justia Law