In 2022, the Department of Energy (DOE) repealed regulations, known as the 2020 Rules, that had created new classes of dishwashers and laundry machines with shorter cycle times, arguing the 2020 rules were illegal. Several states, led by Louisiana, petitioned for the review of the repeal. The United States Court of Appeals for the Fifth Circuit ruled in favor of the states, finding that the DOE's repeal was arbitrary and capricious for failing to consider the performance characteristics of the appliances, the substitution effects, and the evidence showing that the Department’s conservation standards were leading Americans to use more energy and water. The court also noted that the DOE failed to consider other remedies short of repealing the 2020 rules entirely. The court did not reach a conclusion on whether the DOE had the statutory authority to regulate water use in dishwashers and clothes washers. The court granted the petition and remanded the case back to the DOE for further proceedings consistent with its opinion. View "Louisiana v. DOE" on Justia Law

The United States Court of Appeals for the Fifth Circuit reversed and vacated parts of a judgment against EOX Holdings, L.L.C., and Andrew Gizienski ("Defendants") in a case initiated by the Commodity Futures Trading Commission ("CFTC"). The CFTC had accused the defendants of violating a rule that prevents commodities traders from "taking the other side of orders" without clients' consent. The court ruled that the defendants lacked fair notice of the CFTC's interpretation of this rule. The case revolved around Gizienski's actions while working as a broker for EOX, where he had discretion to make specific trades on behalf of one of his clients, Jason Vaccaro. The CFTC argued that Gizienski's actions violated the rule because he was making decisions to trade opposite the orders of other clients without their knowledge or consent. The court, however, ruled that the CFTC's interpretation of the rule was overly broad, as it did not provide sufficient notice that such conduct would be considered taking the other side of an order. The court reversed the penalty judgment against the defendants, vacated part of the injunction against them, and remanded the case for further proceedings. View "Commodity Futures v. EOX Holdings" on Justia Law

In the case before the United States Court of Appeals for the Sixth Circuit, the defendant, Thomas O’Lear, was convicted of healthcare fraud, making a false statement in connection with healthcare services, and aggravated identity theft. O’Lear ran a company that provided mobile x-ray services to residents in nursing homes. However, he used the company to defraud Medicare and Medicaid programs by billing for fictitious x-rays using the identities of nursing-home residents. When an audit revealed the fraud, O’Lear attempted to conceal it by forging staff names and duplicating x-rays in the patient files.On appeal, O’Lear raised several questions. Firstly, he questioned whether his Sixth Amendment right to an impartial jury was violated by excluding individuals who had not been vaccinated against COVID-19 from the jury pool. The court ruled that the unvaccinated do not qualify as a “distinctive group” that can trigger Sixth Amendment concerns. Secondly, O’Lear questioned whether the nursing-home residents were “victims” of his fraud under a “vulnerable victims” sentencing enhancement, even though the monetary losses were suffered by Medicare and Medicaid. The court ruled that the residents were indeed victims, as O’Lear had used their identities and health records without their permission, which constituted taking advantage of them.O’Lear also challenged his two aggravated-identity-theft convictions and objected to his 180-month sentence on various grounds, but these arguments were also dismissed by the court. Ultimately, the court affirmed O’Lear's conviction and sentence. View "United States v. O'Lear" on Justia Law

In this case, the defendant, Patrick Thompson, was convicted of making false statements about his loans to financial institutions. Thompson took out three loans from a bank totaling $219,000. After the bank failed, its receiver, the Federal Deposit Insurance Corporation (FDIC), and a loan servicer, Planet Home, attempted to recoup the money owed by Thompson. However, Thompson disputed the loan balance, insisting that he had only borrowed $110,000. He was subsequently charged with and convicted of making false statements to influence the FDIC and a mortgage lending business, in violation of 18 U.S.C. § 1014.On appeal, Thompson argued that his statements were not “false” under § 1014 because they were literally true, and that the jury lacked sufficient evidence to convict him. He also claimed that the government constructively amended the indictment and that the district court lacked the authority to order him to pay restitution to the FDIC.The U.S. Court of Appeals for the Seventh Circuit rejected Thompson's arguments and affirmed the lower court's judgment. The court held that under its precedent, § 1014 criminalizes misleading representations, and Thompson's statements were misleading. The court also found that there was sufficient evidence to support Thompson's conviction and that the indictment was not constructively amended. Finally, the court held that the district court properly awarded restitution to the FDIC, as the FDIC had suffered a financial loss as a direct and proximate result of Thompson's false statements. View "USA v. Thompson" on Justia Law

The Supreme Court of New Jersey affirmed the judgment of the Appellate Division in a case concerning the New Jersey State Health Benefits Program Act. The case was brought by James Meyers, a retired state police officer, who challenged the State Health Benefits Commission's (SHBC) decision that he was not exempt from health benefits premium-sharing obligations imposed by the Act. The Act requires public employees to contribute towards the cost of their healthcare benefits upon retirement, with an exemption for employees who had 20 or more years of creditable service in a state or locally administered retirement system as of June 28, 2011. Meyers had 17 years and 9 months of creditable service at that time. Upon his retirement in 2015, he was erroneously offered retiree health benefits at no premium cost. This mistake was discovered in 2017, and the state began deducting premium-sharing contributions from his pension payments.The Court held that Meyers was not eligible for the exemption under the Act, and correcting the erroneous exemption was proper. The court found that neither Meyers' subsequent service nor his purchase of four years of military service credit could change the fact that he did not meet the Act's requirement as of June 28, 2011. The court also agreed with the Appellate Division's determination that it was not necessary to reach the issue of equitable estoppel. The court noted that a governmental entity cannot be estopped from refusing to take an action that it was never authorized to take under the law, even if it had mistakenly agreed to that action. In this case, the SHBC was never authorized to offer Meyers free healthcare benefits, an act beyond the jurisdiction of the SHBC and therefore ultra vires in the primary sense. Thus, the doctrine of equitable estoppel did not apply. View "Meyers v. State Health Benefits Commission" on Justia Law

In this case, the United States Court of Appeals for the Eighth Circuit affirmed the district court's decision to grant summary judgment in favor of Officer Andrei Nikolov, who had been sued for excessive force under 42 U.S.C. § 1983. The case arose from an incident in which the officer shot Jennifer Morgan-Tyra multiple times after responding to a domestic-disturbance call. Upon arrival at the scene, the officer encountered an angry Morgan-Tyra holding a gun and shouting expletives at someone out of his view. When she did not comply with a command to drop the gun, Officer Nikolov fired at least nine shots, several of which struck Morgan-Tyra and caused severe and lasting injuries.In affirming the district court's judgment, the appeals court found that, even if Officer Nikolov's decision to shoot without warning was objectively unreasonable under the circumstances, he did not violate a clearly established right. The court noted that officers may use deadly force when there is probable cause to believe that a suspect poses a threat of serious physical harm, either to the officer or to others, and that a warning is less likely to be feasible in a high-pressure situation that requires a split-second judgment. The court also found that a reasonable officer in Nikolov's position would not have known whether Morgan-Tyra was the initial aggressor or a victim who had fought back, and that it was not clearly unreasonable to shoot her under the circumstances. Even considering Morgan-Tyra's version of facts, the court held that she was wielding the gun in a menacing fashion and appeared ready to shoot. Thus, the court concluded that Officer Nikolov is entitled to qualified immunity. View "Jennifer Morgan-Tyra v. Andrei Nikolov" on Justia Law

In this case, several residents of the town of Norwell, Massachusetts filed a lawsuit to compel the town's select board to transfer municipal land to the town's conservation commission. The select board had previously designated the land for the development of affordable housing. The main issue on appeal was whether the land was "held by a city or town . . . for a specific purpose" under Massachusetts General Laws Chapter 40, Section 15A. The Supreme Judicial Court of Massachusetts affirmed the Land Court's grant of summary judgment in favor of the select board. The Supreme Judicial Court held that town-owned land is held for a specific municipal purpose under Massachusetts General Laws Chapter 40, Section 15A, where the totality of the circumstances indicates a clear and unequivocal intent by the town to hold the land for such purpose. Applying this totality of the circumstances test, the court found no material dispute of fact regarding the town's intent to dedicate the municipal land at issue for the purpose of affordable housing. Therefore, the court concluded that the allowance of summary judgment for the select board was correct. View "Carroll v. Select Board of Norwell" on Justia Law

In 2015, Brian McNeal was found guilty of possessing cocaine and drug paraphernalia in Louisiana. He was given a five-year suspended sentence with five years of probation. In 2017, McNeal was arrested for violating probation and subsequently sentenced to serve 90 days at an in-patient substance abuse program. The Louisiana Department of Public Safety and Corrections (DPSC) determined McNeal's release date was to be November 1, 2017. However, McNeal was not released until December 12, 2017, 41 days after his proper release date. In 2018, McNeal sued James LeBlanc, the DPSC Secretary, in his individual capacity for wrongfully detaining him after his sentence expired. LeBlanc filed a motion to dismiss on the grounds of qualified immunity, which the district court denied. LeBlanc then appealed this decision to the United States Court of Appeals for the Fifth Circuit.The Court of Appeals affirmed the district court's decision, finding that McNeal's claims were not barred by Heck v. Humphrey, 512 U.S. 477 (1994), a case that limits certain legal claims if they would imply the invalidity of a conviction or sentence. The court reasoned that McNeal did not challenge his conviction or attendant sentence, but rather the 41 days he was imprisoned beyond his release date. Therefore, Heck did not apply.The court also rejected LeBlanc's argument that he was entitled to qualified immunity, a legal doctrine that shields government officials from liability for civil damages insofar as their conduct does not violate clearly established statutory or constitutional rights. The court determined that McNeal had sufficiently alleged that LeBlanc was deliberately indifferent to a pattern of overdetention in the DPSC. Furthermore, the court found that the right to a timely release from prison was clearly established at the time of McNeal's overdetention. Consequently, the court concluded that LeBlanc was not entitled to qualified immunity in this case. View "McNeal v. LeBlanc" on Justia Law

In the case of Planning and Conservation League et al., v. Department of Water Resources heard in the California Court of Appeal, Third Appellate District, the court considered whether the Department of Water Resources’ (department) approval of amendments to long-term contracts with local government agencies that receive water through the State Water Project violated various laws. The amendments extended the contracts to 2085 and expanded the facilities listed as eligible for revenue bond financing. Several conservation groups and public agencies challenged the amendments, arguing they violated the California Environmental Quality Act (CEQA), the Sacramento-San Joaquin Delta Reform Act (Delta Reform Act), and the public trust doctrine. However, the court held that the department did not violate CEQA, the Delta Reform Act, or the public trust doctrine, and therefore affirmed the trial court's judgment in favor of the department. The court found that the department used the correct baseline for its environmental impact report (EIR), properly segmented the amendments from related projects, and adequately considered the direct, indirect, and cumulative impacts of the amendments. The court also held that the department adequately described the project and considered a reasonable range of alternatives, and that recirculation of the EIR was not required. The court rejected arguments that the amendments violated the Delta Reform Act or the public trust doctrine, finding that they did not impact "water that is imbued with the public trust." The court concluded that the department acted within its authority in approving and executing the amendments. View "Planning and Conservation League v. Dept. of Water Resources" on Justia Law

In this case, plaintiffs Kewon English and Earl Powell were arrested for sexual assault and burglary and detained for over a year before their cases were nolle prossed and they were released. They sued Senior Investigator Joseph Clarke of the Richland County Sheriff’s Department, alleging that he had coerced them into signing false confessions. They also sued Sheriff Leon Lott and the Richland County Sheriff's Department for damages under § 1983, claiming their constitutional rights under the First, Fourth, Fifth, Sixth, and Fourteenth Amendments were violated. The United States Court of Appeals for the Fourth Circuit affirmed the grant of summary judgment on English’s claims and dismissed Clarke’s cross-appeal. The court determined that there was probable cause to arrest English based on the victim’s identifications. Regarding English's malicious prosecution claim, the court held that even assuming probable cause was negated, Clarke cannot be held responsible for English’s continued detention. The court found no evidence that the Richland County Sheriff's Department had any unconstitutional policy or custom, and that Clarke could not be held liable for the continued detention of English. Furthermore, the court dismissed Clarke's cross-appeal, ruling that the appeal turned on a question of fact and was therefore not suitable for interlocutory treatment. View "English v. Clarke" on Justia Law