The Supreme Court affirmed as modified the judgment of the district court denying Defendants' motion to dismiss Plaintiffs' claims of open records violations, holding that Iowa's Open Records Act, Iowa Code chapter 22, may permit Plaintiffs to pursue claims based on untimeliness and that the district court did not err in granting Defendants' motion to dismiss.In 2020 and 2021, Plaintiffs requested public records from Defendants. Plaintiffs brought this suit in December 2021, and in January 2022, Defendants provided responsive records. Defendants filed a motion to dismiss, arguing that the timeliness claims were moot. The district court denied the motion. The Supreme Court affirmed as modified, holding (1) most of the claims concerning production of already-produced records were moot; and (2) with some qualifications, Plaintiffs could pursue claims that Defendants violated chapter 22 through delays in responding to Plaintiffs' open records requests. View "Belin v. Reynolds" on Justia Law

The Supreme Court affirmed the rulings of the district court and court of appeals that the workers' compensation commissioner erred in granting Employer's motion for summary judgment and dismissing Employee's review-reopening petition, holding that Employee was permitted to pursue a claim for a permanent injury in a review-reopening proceeding despite an earlier adjudication that her injury was not permanent.Employee was injured during the course and work of her employment. Employee filed a petition seeking workers' compensation for a permanent disability, but the deputy commissioner refused to order additional benefits beyond those that Employer had already paid. Employee filed a petition for review-reopening with the workers' compensation commission. The commission determined that Employee's claim for permanent disability benefits was barred by principles of res judicata. The district court reversed, and the court of appeals affirmed. The Supreme Court affirmed, holding that the agency erred in dismissing Employer's review-reopening petition. View "Green v. North Central Iowa Regional Solid Waste Authority" on Justia Law

Plaintiff sought the services of the customized postage program to print copies of an adaptation of his drawing of Uncle Sam being strangled by a snake labeled “Citizens United” and configured as a dollar sign. However, acting through Zazzle, Inc., a third-party vendor, USPS rejected Plaintiff’s proposed design due to its partisan message, even as it accepted other customers’ postage designs with obvious political content. Plaintiff filed a complaint in the District Court against the Postal Service, contending that USPS’s customized postage program violated the prohibition against viewpoint discrimination under the First Amendment. In 2018, while Plaintiff’s case was pending in district court, the Postal Service amended the guidelines of its customized postage program to prohibit, inter alia, all “political” stamps. Plaintiff filed a Supplemental Complaint incorporating by reference every allegation from his First Amended Complaint and further alleging that the 2018 Guidelines were unconstitutional on its face. The district court granted summary judgment and declaratory relief to Plaintiff but declined to award injunctive relief.   The DC Circuit affirmed. The court first noted that Plaintiff has standing to seek injunctive and declaratory relief. The Postal Service rejected his customized stamp design due to its partisan message, even as USPS accepted other customers’ postage designs with obvious political content. As a result, Plaintiff suffered viewpoint discrimination, and his continuing inability to speak through custom stamps while others can is sufficient to support standing. However, the fact that Plaintiff has suffered injury sufficient to confer standing to seek injunctive relief does not necessarily make such relief appropriate on the merits. View "Anatol Zukerman v. USPS" on Justia Law

Under the Clean Air Act, Congress gave the Courts of Appeals jurisdiction to hear petitions for review of Environmental Protection Agency (EPA) actions. But it mandated that petitions for review of “nationally applicable” actions be heard in the Court of Appeals for the D.C. Circuit.Here, Petitioner challenges the EPA’s allocation of permits to consume hydrofluorocarbons—a type of chemical refrigerant—under the American Innovation and Manufacturing Act. Specifically, RMS argues that it received fewer permits than it was entitled to because the EPA improperly allocated some historic HFC usage to RMS’s competitors.Finding that the EPA’s action was nationally applicable, the Eleventh Circuit transferred the petition to the D.C. Circuit. The court reasoned that the Allocation Notice at issue allocated permits nationwide and was not restricted in geographic scope; therefore, it was nationally applicable. View "RMS of Georgia, LLC v. U.S. Environmental Protection Agency, et al." on Justia Law

In March 2021, the Camden County Commission voted to ban Plaintiff from county property for one year because he allegedly disrupted and harassed county officials and employees. Plaintiff sued Camden County, the Camden County Commission, and Commissioner (collectively, “Defendants”), claiming that Defendants retaliated against him for exercising his rights under the First Amendment.Defendant sought a preliminary injunction against Defendants and a damages claim against the Commissioner. The District Court granted the preliminary injunction over the Commissioner’s qualified immunity defense, finding that Plaintiff adequately alleged a violation of clearly established rights. However, the court determined Defendants’ appeal of the injunction was moot because it would have expired in March 2022. View "Nathan Rinne v. Camden County" on Justia Law

The Supreme Court affirmed the order of the circuit court denying Petitioner's petition for writ of mandamus or other supervisory writ, granting a motion for judgment on the pleadings filed by the Arkansas Game and Fish Commission and its director (collectively, AGFC) and dismissing Petitioner's complaint for declaratory judgment and injunctive relief, holding that there was no error.Petitioner brought this complaint seeking a declaration that holders of an Enhanced Concealed Carry License (ECCL) may carry concealed firearms in AGFC buildings and facilities, a declaration that AGFC illegally refused to permit his entrance, and an injunction prohibiting AGFC from denying ECCL holders entrance into AGFC buildings with firearms. The circuit court denied relief. The Supreme Court affirmed, holding that the circuit court properly denied Petitioner's motion for summary judgment and granted AGFC's motion for judgment on the pleadings. View "Corbitt v. Ark. Game & Fish Comm'n" on Justia Law

Workforce Safety and Insurance (“WSI”) and John Sandberg appealed a district court judgment affirming in part and reversing in part an Administrative Law Judge’s (“ALJ”) decision on remand, entered after the North Dakota Supreme Court's decision in State by & through Workforce Safety and Insurance v. Sandberg (“Sandberg II”), 956 N.W.2d 342. On appeal, the North Dakota Supreme Court determined the ALJ had made conflicting and insufficient findings to support the finding that Sandberg’s claim was compensable and it was “unable to reconcile the ALJ’s decision with the statutory requirements for medical evidence supported by objective medical findings for a compensable injury in N.D.C.C. § 65-01-02(10).” On remand, the ALJ made additional findings and again held Sandberg met his burden of proving by a preponderance of the evidence that he had sustained a compensable injury. WSI appealed to the district court and the court affirmed the ALJ’s order. On the second appeal, the Supreme Court affirmed the “judgment affirming the ALJ’s revised order to the extent the order found Sandberg sustained a compensable injury; however, the Court remand[ed] the case to WSI for further proceedings on whether benefits must be awarded on an aggravation basis under N.D.C.C. § 65-05-15.” On remand, WSI reversed its decision and accepted Sandberg’s claim on an aggravation basis and denied Sandberg disability benefits. Sandberg appealed to the district court, which affirmed WSI’s determination to award benefits on an aggravation basis and reversed the ALJ’s affirmance of WSI’s denial of disability benefits concluding WSI exceeded the scope of remand provided in Sandberg II. The Supreme Court concluded the district court erred in finding WSI exceeded the scope of the remand and in reversing the ALJ's order affirming WSI's denial of disability benefits. The Court affirmed the district court affirmance of the ALJ’s order awarding benefits on an aggravation basis under N.D.C.C. § 65-05-15. The Court reinstated the ALJ’s order affirming WSI’s denial of disability benefits. View "Sandberg v. WSI, et al." on Justia Law

The North Dakota Department of Health and Human Services1 appealed a district court judgment reversing the Department’s order affirming the denial of Joseph Jahner’s application to enroll as a Medicaid provider. n December 2020, Jahner applied with the Department to be an enrolled provider with North Dakota Medicaid as a peer support specialist. In June 2021, the Department denied Jahner’s application. The Department stated its Medicare Provider Enrollment Screening Policy (“1915(i) Policy”) prohibited Jahner “from enrolling as a provider with ND Medicaid” because of his criminal history. Between 2002 and 2017, Jahner was convicted of 13 crimes, including negligent homicide, reckless endangerment, aggravated assault, assault, and menacing. After the hearing, the ALJ recommended reversing the Department’s decision, concluding the Department should have done a thorough review of Jahner’s criminal history to determine if any offenses had a direct bearing on the position of peer support specialist. The Department did not adopt the ALJ’s recommended decision, and affirmed its decision denying Jahner’s application. The Department concluded peer support specialists serve a vulnerable population, Jahner’s criminal offenses have a direct bearing on the position of peer support specialist, and he was not sufficiently rehabilitated. The Department’s decision prevented Jahner from becoming a Medicaid provider but did not affect his ability to work as a peer support specialist. The district court reversed the Department's decision, holding the Department’s decision was not in accordance with the law. The North Dakota Supreme Court concluded the Department’s findings of fact were supported by a preponderance of the evidence, and its conclusions of law were supported by its findings of fact. It therefore reversed the district court’s judgment and reinstated the Department’s order. View "Jahner v. NDDHS" on Justia Law

The Supreme Court denied Relator's petition in this original action seeking a writ of mandamus to compel the city of Sheffield Lake and its mayor (collectively, the city) to produce documents in response to a public records request sent by Relator, holding that Relator failed to establish that he was entitled to the requested relief.Relator, a city police officer and the city's only black officer at the time, submitted a public records request for records relating to an incident in which Anthony Campo, the city's former police chief, resigned after placing a "KKK" sign across the back of Relator's coat to cover the word "POLICE," donned a paper KKK hat and told Relator he should wear one on his next police call. The city provided only partial responses to the request. Relator then brought this mandamus action. The Supreme Court denied relief, holding (1) the evidence showed that the city made reasonable efforts to locate the documents; and (2) Relator's requests for awards of statutory damages, attorney fees, and court costs are also denied. View "State ex rel. Pool v. Sheffield Lake" on Justia Law

The Food and Drug Administration (“FDA”) approved mifepristone to be marketed with the brand name Mifeprex under Subpart H (the “2000 Approval”). In January 2023, FDA approved a modified REMS for mifepristone, lifting the in-person dispensing requirement.  Plaintiffs (physicians and physician organizations) filed a suit against FDA, HHS, and a several agency heads in the official capacities. Plaintiffs challenged FDA’s 2000 Approval of the drug and also requested multiple grounds of alternative relief for FDA’s subsequent actions. Plaintiffs moved for a preliminary injunction ordering FDA to withdraw or suspend (1) FDA’s 2000 Approval and 2019 Generic Approval, (2) FDA’s 2016 Major REMS Changes, and (3) FDA’s 2021 Mail-Order Decision and its 2021 Petition Denial of the 2019 Citizen Petition. The district court entered an order staying the effective date of the 2000 Approval and each of the subsequent challenged actions.   The Fifth Circuit granted Defendants’ motions for a stay pending appeal. The court wrote that at this preliminary stage, and based on the court’s necessarily abbreviated review, it appears that the statute of limitations bars Plaintiffs’ challenges to the Food and Drug Administration’s approval of mifepristone in 2000. However, Plaintiffs brought a series of alternative arguments regarding FDA’s actions in 2016 and subsequent years. And the district court emphasized that its order separately applied to prohibit FDA’s actions in and after 2016 in accordance with Plaintiffs’ alternative arguments. As to those alternative arguments, Plaintiffs’ claims are timely. Defendants have not shown that Plaintiffs are unlikely to succeed on the merits of their timely challenges. For that reason, Defendants’ motions for a stay pending appeal are denied in part. View "Alliance Hippocratic Medicine v. FDA" on Justia Law