The Supreme Court reversed the summary judgment order of the district court requiring Memorial Hospital of Converse County (MHCC) to produce certain records requested under the Wyoming Public Records Act (WPRA) but also imposing a protective order on those documents, holding that the district court erred in finding that a certain document was not subject to disclosure under the WPRA.On appeal, Plaintiff challenged the denial of her motion for summary judgment related to the production of documents involving a settlement between MHCC and a patient (MB settlement), arguing that the MB settlement was subject to production under the WPRA. The Supreme Court reversed, holding (1) the district court erred should have ordered MHCC to produce the MB settlement; and (2) the district court's entry of a protective order was contrary to the WPRA and without evidentiary support. View "Gates v. "Memorial Hospital of Converse County - Advanced Medicine. Hometown Care", ex rel. Board of Trustees of the Memorial Hospital of Converse County" on Justia Law

The Affordable Care Act obligates large employers to provide their full-time employees with health insurance coverage meeting certain requirements. If an employer fails to provide coverage or provides noncomplying coverage, it is liable for an exaction under 26 U.S.C. Section 4980H. In 2019, the Internal Revenue Service sent two letters proposing exactions under Section 4980H to appellant Optimal Wireless, a wireless communications company. Optimal then filed an action against the IRS and the Department of Health and Human Services, claiming that the agencies had failed to satisfy certain procedural requirements before imposing the proposed exactions. Optimal sought a declaratory judgment and an injunction barring the IRS from collecting any money without complying with those procedures. The district court dismissed Optimal’s suit for lack of jurisdiction.   The DC Circuit affirmed. The court explained that the Anti-Injunction Act provides that, with certain exceptions, “no suit for the purpose of restraining the assessment or collection of any tax shall be maintained in any court by any person, whether or not such person is the person against whom such tax was assessed.” The court explained that because Congress repeatedly called the Section 4980H exaction a tax, Optimal’s suit is barred by the Anti-Injunction Act. The court further wrote that Congress’s use of the phrase “assessable payment” does not conflict with—or otherwise detract from the import of—its choice to label the Section 4980H exaction a “tax” in multiple provisions. The terms are not mutually exclusive. View "Optimal Wireless LLC v. IRS" on Justia Law

Two consolidated cases arise out of the Hungarian government’s confiscation of property owned by Jews during the Holocaust. The questions raised by these appeals bear on whether survivors of the Hungarian Holocaust may hale the Hungarian government and its instrumentalities into United States courts to answer for a subset of the wrongs they committed. The plaintiffs invoked the Foreign Sovereign Immunities Act’s expropriation exception as a means to pierce the Hungarian state’s sovereign immunity and assert jurisdiction in federal district court. Defendants object that the exception is inapplicable. The district court dismissed the claims of the plaintiffs asserting statelessness but concluded that most of the plaintiffs asserting Czechoslovakian nationality could proceed.   The DC Circuit largely affirmed. The court concluded that the plaintiffs claiming statelessness—have not made out a recognized claim within a Foreign Sovereign Immunities Act exception. Assuming without deciding that those plaintiffs were de facto stateless at the time of the alleged takings, as they claim, the plaintiffs have nevertheless failed to identify adequate affirmative support in sources of international law for their contention that a state’s taking of a stateless person’s property amounts to a taking “in violation of international law” within the meaning of the Foreign Sovereign Immunities Act.   The court affirmed the district court’s denial of Defendants’ motions to dismiss the claims of some of the plaintiffs asserting Czechoslovakian nationality, with a few exceptions. The district court correctly determined that four of those plaintiffs had plausibly alleged they were Czechoslovakian nationals at the time of the takings. The court concluded that as for the five Lebovics sisters, the district court should have dismissed their claims. View "Rosalie Simon v. Republic of Hungary" on Justia Law

In March 2020, Sherwood and Doyle lost their jobs because of the COVID-19 pandemic and applied for unemployment benefits. They never received those benefits, however, and still have not received notice of the denial of their claims or an opportunity for a hearing. Sherwood and Doyle filed a putative class action lawsuit against the Director of the Illinois Department of Employment Security (IDES), asserting equal protection and procedural due process claims.The Seventh Circuit affirmed the dismissal of the suit. Under the “Young doctrine,” which provides an exception to Eleventh Amendment immunity, private parties may sue individual state officials for prospective relief to enjoin ongoing violations of federal law. Even if these plaintiffs had standing to bring the equal protection claims, sovereign immunity bars them; the Young exception does not apply when federal law has been violated only at one time or over a period of time in the past. The plaintiffs alleged a sufficient injury to pursue their procedural due process claims and can invoke the Young exception to sovereign immunity but mandamus provides an adequate state-law remedy in this case. View "Sherwood v. Marchiori" on Justia Law

The First Circuit denied Petitioner's petition for review of the decision of the Board of Immigration Appeals (BIA) denying his motion to reopen proceedings under 8 U.S.C. 1229a(c)(7), holding that the BIA neither committed a material error of law nor acted arbitrarily, capriciously, or irrationally.Petitioner, a native and citizen of Guatemala, was charged as removable for being present in the United States without having been admitted. Petitioner conceded the charge and sought asylum. An immigration judge (IJ) denied the asylum application because Petitioner failed to establish that he was targeted based on a protected ground. The BIA affirmed. Petitioner subsequently filed an untimely motion to reopen, asserting that the applicable time limit should be equitably tolled due to ineffective assistance of counsel. The BIA denied the motion. The First Circuit denied Petitioner's petition for review, holding that the BIA did not abuse its discretion in denying Petitioner's untimely motion to reopen and declining to equitably toll the deadline. View "Yoc Esteban v. Garland" on Justia Law

Fisheries Reform Group alleges that shrimp trawlers operating in North Carolina’s Pamlico Sound are violating the Clean Water Act by engaging in two types of unpermitted activity: throwing bycatch overboard and disturbing sediment with their trawl nets.   The Fourth circuit affirmed the district court’s dismissal of Fisheries’ complaint. The court explained that though the Clean Water Act’s includes the term “biological materials” in its definition of “pollutant,” that is not clear authorization for the EPA to regulate bycatch under the Act. So Fisheries Reform Group’s first claim— that shrimpers are violating the Clean Water Act by discarding bycatch overboard without a Section 1342 permit—was properly dismissed. The court further explained that Fisheries’ second claim—that shrimpers are violating the Act by using trawl nets without a permit—fares no better. The shrimpers are not “dredging” the Pamlico Sound with their nets, so they cannot be discharging “dredged spoil.” And the dirt and sand that their nets kick up is not “added”—and thus not “discharged”—into the Sound. View "North Carolina Coastal Fisheries Reform Group v. Capt. Gaston LLC" on Justia Law

The Supreme Court held that an action taken by the Minnesota Pollution Control Agency (MPCA) in issuing a National Pollutant Discharge Elimination System/State Disposal System permit was arbitrary and capricious and that the permit did not comply with a Minnesota rule addressing wastewater discharges to groundwater, Minn. R. 7060.0600, subp. 2.At issue was the MPCA's issuance of the permit for a Poly Met Mining, Inc. project. The court of appeals reversed in part, concluding that the MPCA failed properly to consider whether the federal Clean Water Act (CWA) applied to future discharges from Poly Met's facility to groundwater. The Supreme Court remanded the cause, holding (1) remand was required because there were suggestions that the MPCA did not properly consider whether the permit complies with the CWA and that the MPCA did not genuinely engage in reasoned decision-making; (2) remand was required for consideration of whether a variance was available to allow the planned discharge to the unsaturated zone within the containment system; and (3) the prohibition on injecting polluted water directly to the groundwater saturated zone for long-term storage did not apply in this case. View "In the Matter of the Denial of Contested Case Hearing Requests & Issuance of National Pollutant Discharge Elimination System" on Justia Law

Plaintiff brought suit in federal district court against the Corporation of the President of the Church of Jesus Christ of Latter-Day Saints, alleging fraud under California law. Plaintiff is a former member of the Church of Jesus Christ of Latter-Day Saints. (The Corporation is the legal entity behind the Church of Jesus Christ of Latter-Day Saints. We refer to both the Corporation and the Church as “the Church.”) Plaintiff alleged that, from 1993 until 2015, he contributed substantial amounts of cash and corporate shares to the Church as tithes. He alleged that during at least some of that time, he relied on false and misleading statements by the Church about its use of tithing money. The district court granted the Church’s motion for summary judgment. It held that no reasonable juror could find that the Church had fraudulently misrepresented how tithing funds were used.   The Ninth Circuit reversed in part, affirmed in part, and remanded. The court held that there is evidence in the record from which a reasonable juror could conclude that the Church knowingly misrepresented that no tithing funds were being or would be used to finance the development of the shopping mall and that Huntsman reasonably relied on the Church’s misrepresentations. The panel rejected the Church’s argument that Plaintiff’s fraud claims are barred by the First Amendment. The panel held that the ecclesiastical abstention doctrine did not apply because the questions regarding the fraud claims were secular and did not implicate religious beliefs about tithing itself. Nor was the panel required to examine Plaintiff’s religious beliefs about the appropriate use of church money. View "JAMES HUNTSMAN V. CORPORATION OF THE PRESIDENT, ET AL" on Justia Law

Three conservation groups challenged the U.S. Bureau of Land Management’s approval of Jonah Energy’s development project on state and federal land in Wyoming. The project was designed to drill exploratory wells on land for which Jonah possessed development rights. The conservation groups argued the district court erred in upholding the BLM’s approval under the National Environmental Protection Act and the Federal Land Polocy and Management Act. Specifically, they contended the BLM inadequately considered the impact of the project on the sage-grouse and pronghorn antelope migration and grazing patterns. The Tenth Circuit concluded the BLM adequately collected and considered information on the sage-grouse and pronghorn, and selected a development plan that met statutory requirements. View "Western Watersheds Project, et al. v. United States Bureau of Land Management, et al." on Justia Law

In Hawaii, it is a misdemeanor knowingly to manufacture, sell, transfer, transport, or possess a butterfly knife—no exceptions. Plaintiffs sued Hawaii’s Attorney General and Sheriff Division Administrator (“Hawaii”). Plaintiffs sought declaratory relief to establish that section 134-53(a) violates the Second Amendment and injunctive relief against its enforcement. Plaintiffs alleged that, “but for Hawaii law,” they would purchase butterfly knives. On cross-motions for summary judgment, the district court concluded that section 134-53(a) does not violate the Second Amendment, granted Hawaii’s motion, and entered judgment in its favor.   The Ninth Circuit reversed district court’s summary judgment in favor of Hawaii officials. The court held that because the possession of butterfly knives is conduct protected by the plain text of the Second Amendment, and because Hawaii has not demonstrated that its ban on butterfly knives is consistent with this Nation’s historical tradition of regulating arms, the court concluded that section 134-53(a) violates Plaintiffs’ Second Amendment rights. The panel determined that Plaintiffs had standing to challenge Section 134-53(a) because they alleged that the Second Amendment provides them with a legally protected interest to purchase butterfly knives, and for section 134-53(a), they would do so within Hawaii. Plaintiffs further articulated a concrete plan to violate the law, and Hawaii’s history of prosecution under its butterfly ban was good evidence of a credible threat of enforcement. The panel held that possession of butterfly knives is conduct covered by the plain text of the Second Amendment. The panel held that Hawaii failed to prove that section 134-53(a) was consistent with this Nation’s historical tradition of regulating weapons. View "ANDREW TETER, ET AL V. ANNE E. LOPEZ, ET AL" on Justia Law