Shamrock Building Materials, Inc. imported steel tubing from Mexico, which had a thin interior coating primarily composed of epoxy, melamine, and silicone additives. The United States Customs and Border Protection classified the tubing under heading 7306 of the Harmonized Tariff Schedule of the United States (HTSUS), which pertains to other tubes and pipes of iron or nonalloy steel. Shamrock contested this classification, arguing that the tubing should be classified under heading 8547 of the HTSUS, which covers electrical conduit tubing of base metal lined with insulating material. Customs rejected Shamrock's protests.The United States Court of International Trade reviewed the case and granted summary judgment in favor of the United States, upholding Customs' classification under heading 7306. The court found that the interior coating of the tubing did not provide significant electrical insulation, which is a requirement for classification under heading 8547. The court noted that the coating's primary function was to facilitate the installation of electrical wires by reducing friction, rather than providing electrical insulation.The United States Court of Appeals for the Federal Circuit reviewed the case and affirmed the decision of the Court of International Trade. The Federal Circuit agreed with the lower court's interpretation that heading 8547 requires a commercially significant level of electrical insulation. The court found that Shamrock did not provide sufficient evidence to prove that the interior coating of the tubing provided such insulation. Consequently, the court held that the tubing was correctly classified under heading 7306 of the HTSUS. View "SHAMROCK BUILDING MATERIALS, INC. v. US " on Justia Law

The plaintiffs, parents of minor children, challenged a public act that eliminated the religious exemption from vaccination requirements for school enrollment. They argued that the act violated their constitutional rights to free exercise of religion, equal protection, and a free public education, as well as their statutory rights under Connecticut law. The defendants, state and municipal officials, moved to dismiss the case on the grounds of sovereign immunity.The trial court denied the defendants' motions to dismiss, concluding that the plaintiffs' constitutional claims satisfied the substantial claim exception to sovereign immunity, and their statutory claim under Connecticut law satisfied the statutory waiver exception. The defendants appealed this decision.The Connecticut Supreme Court reviewed the case and determined that the trial court must assess the legal sufficiency of the plaintiffs' allegations to determine whether they have asserted a substantial claim of a constitutional violation. The court concluded that the plaintiffs' constitutional claims failed as a matter of law. The act was deemed a neutral law of general applicability, rationally related to the state's interest in protecting public health. The court also found that the act did not violate the plaintiffs' right to a free public education, as it imposed a reasonable vaccination requirement.However, the court agreed with the trial court that the plaintiffs' statutory free exercise claim under Connecticut law satisfied the statutory waiver exception to sovereign immunity. The court found that the scope of the waiver extended to free exercise challenges to the enforcement of legislation and that applying the statute to the public act did not violate any constitutional principles.The Connecticut Supreme Court reversed the trial court's decision in part, directing the dismissal of the constitutional claims, but affirmed the decision regarding the statutory claim, allowing it to proceed. View "Spillane v. Lamont" on Justia Law

The case involves the People of the State of California, represented by the San Diego City Attorney, who filed a complaint against Kaiser Foundation Health Plan, Inc. The complaint alleged that Kaiser violated the unfair competition law (UCL) and false advertising law (FAL) by failing to maintain and update accurate health plan provider directories (PDs) as required by California Health and Safety Code section 1367.27. The People claimed that Kaiser’s inaccuracies in PDs misled consumers and harmed competitors.The Superior Court of San Diego County granted Kaiser’s motion for summary judgment, exercising its discretion to abstain from adjudicating the action. The court reasoned that the legislative framework did not impose an accuracy requirement but rather outlined procedural steps for maintaining PDs. The court concluded that adjudicating the People’s claims would require it to assume regulatory functions and interfere with policy judgments already made by the Legislature and the Department of Managed Health Care (DMHC).The Court of Appeal, Fourth Appellate District, Division One, State of California, reviewed the case and concluded that the trial court abused its discretion by applying the doctrine of judicial abstention. The appellate court found that section 1367.27 sets forth clear mandates for PD accuracy, which the trial court could enforce through its ordinary judicial functions. The appellate court held that the People’s enforcement of these statutory requirements would not interfere with the DMHC’s regulatory functions and that the trial court’s abstention was based on a mistaken view of the law. Consequently, the appellate court reversed the judgment and remanded the matter with directions to deny Kaiser’s motion for summary judgment. View "P. ex rel. Elliott v. Kaiser Foundation Health Plan" on Justia Law

A company, A.D. Improvements, Inc. (ADI), leased property from the California Department of Transportation (Caltrans). Caltrans had initially acquired the property, which was undeveloped at the time, for a freeway project. ADI used the property commercially as a staging area for equipment and machinery. In 2021, Caltrans deemed the property "excess real property" as it was no longer needed for the freeway project. ADI sought to purchase the property under Streets and Highways Code section 118.1, which requires Caltrans to offer to sell excess commercial property to the current occupant. Caltrans denied the application, arguing the property was not commercial when acquired.The Superior Court of San Bernardino County agreed with Caltrans, interpreting the statute to mean that the property had to be commercial at the time of acquisition. The court denied ADI's petition for a writ of mandate to compel Caltrans to offer the property for sale.The Court of Appeal, Fourth Appellate District, Division One, State of California, reviewed the case. The appellate court found that the statute's plain language and legislative history indicated that the property only needed to be commercial at the time it was deemed excess, not when it was acquired. The court concluded that the trial court had erred in its interpretation of the statute.The appellate court reversed the trial court's decision and remanded the case with directions to issue a writ requiring Caltrans to offer the property for sale to ADI at fair market value. The court held that Caltrans must comply with its ministerial duty under section 118.1 to sell the excess commercial property to the current occupant. ADI was awarded its costs on appeal. View "A.D. Improvements v. Dept. of Transportation" on Justia Law

Jarrod Miller, a resident of Athens-Clarke County, filed a complaint against Deborah Gonzalez, the District Attorney for the Western Judicial Circuit, alleging violations of the Open Records Act (ORA). Miller claimed that Gonzalez, in her official capacity as district attorney and custodian of public records, failed to produce requested public records related to the district attorney’s office. Gonzalez argued that neither she nor her office is subject to the ORA because district attorneys are constitutional officers of the judicial branch. She also contended that Miller lacked standing to bring the enforcement action and that prosecutorial immunity barred the suit.The Superior Court of Clarke County denied Gonzalez’s motion to dismiss Miller’s complaint. The court rejected Gonzalez’s argument that district attorneys are judicial officers exempt from the ORA, concluding that district attorneys perform executive functions. The court also found that Miller had standing to bring the enforcement action and that prosecutorial immunity did not bar Miller’s claims. Gonzalez then sought an interlocutory appeal, which was granted.The Supreme Court of Georgia affirmed the trial court’s decision. The court held that the ORA applies to district attorneys’ offices, as they are considered “offices” under the statute. The court also determined that district attorneys exercise executive power, not judicial power, and thus are subject to the ORA. Additionally, the court found that Miller had standing to sue because he directed his attorney to make the records requests on his behalf. The court further held that prosecutorial immunity does not bar official-capacity claims under the ORA, as the statute waives sovereign immunity for such claims. The court did not address the merits of Miller’s individual-capacity claims against Gonzalez. View "GONZALEZ v. MILLER" on Justia Law

Richard Andrew Justice filed a claim against the Georgia Department of Public Safety (DPS) for breach of an employment contract, alleging that DPS failed to pay him for overtime hours as required under the Fair Labor Standards Act (FLSA). Justice argued that the FLSA provisions were incorporated into his employment contract. The central issue was whether Justice had demonstrated the existence of a written contract sufficient to overcome DPS’s motion to dismiss on sovereign immunity grounds.The trial court allowed limited discovery and reviewed documents submitted by Justice, including a written offer of employment and subsequent communications. The trial court ultimately granted DPS’s motion to dismiss, finding that the documents did not constitute a valid written contract and that there was no meeting of the minds regarding FLSA overtime compensation provisions. The Court of Appeals reversed this decision, concluding that the documents did form a written contract that included FLSA provisions, thereby waiving sovereign immunity.The Supreme Court of Georgia reviewed the case and determined that Justice had shown the existence of a written contract with DPS, which established a waiver of sovereign immunity under the ex contractu clause of the Georgia Constitution. The Court held that the question of whether the FLSA obligations were part of the written contract was a merits question, not a sovereign immunity question, and thus was not properly before the trial court on a motion to dismiss for lack of subject-matter jurisdiction. The Supreme Court affirmed the Court of Appeals' decision in part, vacated it in part, and remanded the case for further proceedings consistent with its opinion. View "GEORGIA DEPARTMENT OF PUBLIC SAFETY v. JUSTICE" on Justia Law

Petitioners, Bill Paschall and Arkansans for Patient Access (APA), sought a declaration from the court that the ballot title for the proposed "Medical Marijuana Amendment of 2024" was sufficient and requested that votes for the amendment be counted in the November 5, 2024, general election. The proposed amendment aimed to expand access to medical marijuana and included provisions for legalizing marijuana possession for all purposes if federal law changes. The Secretary of State, John Thurston, and intervenors, Jim Bell and Protect Arkansas Kids (PAK), opposed the petition, arguing that the proposal was insufficient due to misleading language and failure to meet signature requirements.The Secretary of State rejected APA's petition on the grounds that APA did not meet the 90,704 minimum-signature requirement, as affidavits were signed by individuals from Nationwide Ballot Initiative (NBA) rather than APA. PAK argued that the popular name and ballot title were misleading, as they did not inform voters about the amendment's broader implications, including the legalization of recreational marijuana and changes to the Arkansas Constitution unrelated to medical marijuana.The Supreme Court of Arkansas reviewed the case and found that the Secretary of State erred in rejecting the petition based on the signature requirement, as APA's delegation to NBA was permissible under Arkansas law. However, the court agreed with PAK that the popular name and ballot title were misleading. The court held that the proposed amendment's popular name suggested it was limited to medical marijuana, while it also sought to legalize recreational marijuana and amend unrelated constitutional provisions. The ballot title failed to adequately inform voters about these significant changes.The Supreme Court of Arkansas denied the petitioners' request, granted the intervenors' request for relief, and enjoined the Secretary of State from canvassing or certifying any ballots cast for the proposed amendment in the November 5, 2024, general election. View "PASCHALL V. THURSTON" on Justia Law

The case involves a wrongful-death lawsuit filed by the executors and an independent administrator of the estates of deceased residents of a nursing home, Geneva Nursing and Rehabilitation Center, LLC, doing business as Bria Health Services of Geneva. The plaintiffs allege that Bria negligently and willfully failed to control the spread of COVID-19, leading to the deaths of the decedents between March and May 2020. The complaints assert that Bria's failure to quarantine symptomatic staff and residents and to implement effective hygiene and equipment procedures caused the decedents to contract COVID-19 and die from related complications.The Kane County Circuit Court denied Bria's motions to dismiss the negligence claims but allowed Bria to file a motion to certify a question for interlocutory appeal. The certified question was whether Executive Order 2020-19 provided blanket immunity for ordinary negligence to healthcare facilities that rendered assistance to the State during the COVID-19 pandemic. The appellate court modified the question to clarify that the immunity in question derived from section 21(c) of the Illinois Emergency Management Agency Act and answered the modified question affirmatively, stating that Bria would have immunity from negligence claims if it could show it was rendering assistance to the State during the pandemic.The Supreme Court of Illinois reviewed the case and agreed with the appellate court's modification of the certified question. The court held that Executive Order 2020-19, which triggered the immunity provided in section 21(c) of the Act, grants immunity for ordinary negligence claims to healthcare facilities that rendered assistance to the State during the COVID-19 pandemic. The court affirmed the appellate court's judgment and remanded the case to the circuit court to determine whether Bria was indeed rendering such assistance. View "James v. Geneva Nursing & Rehabilitation Center, LLC" on Justia Law

A property developer settled claims with the U.S. Department of Justice for alleged violations of the Fair Housing Act (FHA) and sought to assert a state-law claim for contribution against other companies involved in developing the properties. The developer, Epcon Communities Franchising, L.L.C., alleged that the franchisees, including Wilcox Development Group, L.L.C., failed to comply with the FHA in their construction and design of certain properties.The trial court dismissed the case, not on the grounds argued by Wilcox, but on the theory that if a state-law cause of action for contribution existed, it was preempted by federal law. The Tenth District Court of Appeals affirmed this decision, and Epcon appealed the preemption issue to the Supreme Court of Ohio.The Supreme Court of Ohio reviewed the case and determined that the trial court erred in deciding the case on the basis of federal preemption. The court emphasized principles of judicial restraint, noting that no party had argued for federal preemption and that courts should avoid deciding constitutional questions unless necessary. The court also highlighted that the preemption issue was hypothetical and should not have been addressed without first determining whether a state-law contribution claim was available.The Supreme Court of Ohio reversed the judgments of the lower courts and remanded the case to the trial court to consider whether the facts alleged present a claim for relief under Ohio law. The court did not address the preemption issue, as it was not properly presented by the parties and was unnecessary to resolve at this stage. View "Epcon Communities Franchising, L.L.C. v. Wilcox Dev. Group, L.L.C." on Justia Law

L.C. Slaughter and Isiac Jackson were removed from their positions as commissioners of the Canton Municipal Utilities Commission by the City of Canton Board of Aldermen. They appealed their removal to the Madison County Circuit Court, arguing that their removal was illegal and violated their due process rights. The circuit court agreed, finding the removal void as a matter of law, and reinstated them to their positions. The Board appealed this decision.The Mississippi Supreme Court affirmed the circuit court's decision, holding that the Board's removal of Slaughter and Jackson without notice and an opportunity to be heard was improper. The Court issued its mandate on April 6, 2023, affirming their reinstatement. Subsequently, on April 27, 2023, Slaughter and Jackson filed a petition for back pay in the same circuit court case, seeking compensation for the period they were removed.The circuit court denied the petition for back pay, citing lack of jurisdiction, as the issue of back pay was not raised before the mandate was issued. Slaughter and Jackson appealed this denial. The Mississippi Supreme Court reviewed the case de novo and held that the circuit court lost jurisdiction once the appeal was filed and did not regain it after the Supreme Court's mandate, which did not remand any issues for further consideration. Consequently, the circuit court's denial of the petition for back pay was affirmed. View "Slaughter v. City of Canton, Mississippi" on Justia Law