The case involves the Environmental Protection Agency (EPA) and its denial of small refinery exemptions under the Renewable Fuel Standard (RFS) program. The RFS program mandates that refineries blend renewable fuels into fossil fuels or purchase credits to comply. Small refineries can petition for exemptions if compliance causes disproportionate economic hardship. In 2022, the EPA denied all pending exemption petitions, arguing that compliance costs are passed on to consumers, thus no refinery faces economic hardship due to the RFS program. The EPA also provided alternative compliance options for certain refineries whose exemptions were initially granted but later denied.Previously, the EPA had granted exemptions based on a Department of Energy (DOE) study and a scoring matrix that considered various economic factors. However, following a Tenth Circuit decision and the Supreme Court's ruling in HollyFrontier, the EPA revised its approach, focusing solely on compliance costs and the RIN cost passthrough theory. This led to the denial of all pending petitions, including those of Sinclair Wyoming Refining Company and Wynnewood Refining Company, which had initially received exemptions.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court found that the EPA's rationale for denying the exemptions was contrary to law and arbitrary and capricious. The court held that the EPA's interpretation of "disproportionate economic hardship" was too narrow and inconsistent with the Clean Air Act. The court also found that the EPA failed to adequately support its assumption that refineries could always purchase RINs ratably and pass the costs to consumers. Consequently, the court vacated the EPA's denial actions, except for two refineries deemed ineligible on other grounds, and dismissed Growth Energy's petition for lack of standing. The court denied Sinclair's petition challenging the alternative compliance action and dismissed Wynnewood's petition for not challenging a final agency action. View "Sinclair Wyoming Refining Company LLC v. Environmental Protection Agency" on Justia Law

Two non-domiciliary companies, S&H Independent Premium Brands East, LLC, and S&H Independent Premium Brands West, LLC, import and distribute European alcoholic beverages in the United States. They hold certificates of compliance under Massachusetts General Laws Chapter 138, Section 18B, allowing them to sell alcoholic beverages to licensed wholesalers in Massachusetts. In 2019, an Austrian malt beverage producer, Stiegl Getränke & Service GmbH & Co. KG, terminated its distribution agreement with S&H without prior notice and entered into a new agreement with another distributor, Win-It-Too, Inc.S&H filed a petition with the Alcoholic Beverages Control Commission (ABCC), alleging that Stiegl violated Massachusetts General Laws Chapter 138, Section 25E, which prohibits suppliers from refusing to sell to any licensed wholesaler without good cause. The ABCC dismissed the petition, stating that Section 25E protections apply only to wholesalers licensed under Section 18, not to certificate holders under Section 18B. S&H then sought judicial review in the Superior Court, which upheld the ABCC's decision, agreeing that Section 25E protections do not extend to Section 18B certificate holders.The Supreme Judicial Court of Massachusetts reviewed the case and affirmed the lower court's decision. The Court held that the term "any licensed wholesaler" in Section 25E refers only to wholesalers licensed under Section 18, not to certificate holders under Section 18B. The Court also concluded that this interpretation does not violate the dormant commerce clause of the United States Constitution, as Section 18B certificate holders and Section 18 licensed wholesalers serve different roles in the regulatory framework. Therefore, the ABCC's decision to dismiss S&H's petition was upheld. View "S&H Independent Premium Brands East, LLC v. Alcoholic Beverages Control Commission" on Justia Law

This case involves a dispute over the sale of surplus state property owned by the Idaho Transportation Department (ITD). The property, located at 3311 West State Street in Boise, was declared surplus after a flood rendered its largest building unusable. The Idaho Department of Administration (DOA) initiated a bidding process, and the petitioners, a group of business entities, submitted the highest bid. Despite negotiating a purchase and sale agreement, the DOA did not finalize the sale due to legislative actions that revoked its authority to dispose of the property and transferred control back to the ITD Board.The petitioners filed an original action in the Idaho Supreme Court seeking writs of prohibition and mandate. They argued that the legislative provisions revoking the DOA's authority were unconstitutional, violating the single-subject rule of the Idaho Constitution. They sought a declaratory judgment to invalidate these provisions and compel the DOA to complete the sale. The Idaho House of Representatives and its Speaker intervened, and the State Board of Examiners disclaimed further participation, having fulfilled its statutory duties.The Idaho Supreme Court held that the petitioners lacked standing to bring the action. The court found that while the petitioners demonstrated a distinct and palpable injury from the halted sale, they failed to show that a favorable decision would redress their injury. The court noted that the petitioners did not have a legally enforceable right to purchase the property, as the DOA had discretion in concluding the sale. Additionally, the court determined that the petitioners did not meet the criteria for relaxed standing, as other parties, such as the DOA and ITD, could potentially bring the constitutional claim. Consequently, the court dismissed the petition for writs of prohibition and mandate. View "Hawkins Companies, LLC v. State" on Justia Law

The Attorney General of California drafted language for the ballot title, summary, and label for Proposition 5, a proposed amendment to the California Constitution that would allow certain local bonds to be approved by 55 percent of voters instead of the current two-thirds requirement. Jon Coupal and the Howard Jarvis Taxpayers Association challenged the ballot label, arguing it was misleading because it did not mention the existing two-thirds approval requirement. They claimed this omission failed to inform voters of the measure's true purpose.The Superior Court of Sacramento County agreed with the challengers, finding that the ballot label did not adequately inform voters of the measure's chief purpose. The court ordered the Attorney General to revise the ballot label to include the current two-thirds approval requirement. The Attorney General then filed a petition for writ of mandate in the Court of Appeal of the State of California, Third Appellate District, challenging the Superior Court's decision.The Court of Appeal concluded that the ballot label drafted by the Attorney General accurately and concisely described Proposition 5 and was not misleading. The court emphasized that the Attorney General is afforded considerable discretion in drafting ballot materials and that the label's language was factually accurate. The court found that the Superior Court failed to accord the proper discretion to the Attorney General and that there was no clear and convincing evidence that the ballot label was misleading. Consequently, the Court of Appeal issued a peremptory writ of mandate directing the Superior Court to deny the challengers' petition and allow the Attorney General's original ballot label to be used. View "Bonta v. Super. Ct." on Justia Law

In 2013, Ronald Fossat, a coal miner, filed a claim for benefits under the Black Lung Benefits Act (BLBA). Fossat had worked in coal mines for 24 years, with 10 years underground and 14 years above ground. He suffered from severe respiratory issues and was on oxygen therapy. After filing his claim, he underwent medical evaluations, including those by Dr. Gagon (OWCP-sponsored) and Drs. Farney and Rosenberg (requested by his employer, Sunnyside Coal Company). The evaluations produced mixed results regarding the cause and extent of his respiratory impairment.An Administrative Law Judge (ALJ) awarded Fossat benefits in 2021, concluding that he was totally disabled based on arterial blood gas studies and medical opinions. Sunnyside appealed to the U.S. Department of Labor Benefits Review Board, which affirmed the ALJ’s decision. Sunnyside then petitioned the United States Court of Appeals for the Tenth Circuit for review, arguing that the agency’s interpretation of the BLBA was erroneous and that the ALJ’s medical merits analysis was flawed.The Tenth Circuit reviewed the case and rejected Sunnyside’s arguments. The court held that Fossat’s employment qualified him for the rebuttable presumption under the BLBA, as he had worked for more than 15 years in an underground coal mine, including above-ground work at the same mine. The court also found that the ALJ correctly applied the burden of proof and that substantial evidence supported the ALJ’s conclusion that Fossat was totally disabled. The court further determined that any error in admitting a supplemental medical report was harmless, as the ALJ’s conclusions were supportable without it. Consequently, the Tenth Circuit denied Sunnyside’s petition for review. View "Sunnyside Coal Company v. Office of Workers' Compensation Programs" on Justia Law

Maria Pomares submitted three Freedom of Information Act (FOIA) requests to the Department of Veterans Affairs (VA) concerning potential misconduct within the VA. She suspected that Charmain Bogue, the director of the Education Service in the Veterans Benefit Administration, had improper ties to a political advocacy organization and that the VA might have leaked nonpublic information. After Pomares submitted her FOIA requests, the VA’s Office of Inspector General (OIG) found that Bogue had acted improperly.The United States District Court for the Southern District of California granted summary judgment in favor of the VA. The court concluded that the VA’s search for responsive emails was reasonable and that the VA properly justified its withholdings under FOIA Exemptions 4, 5, 6, and 7. The district court found that the Vaughn Indices provided by the VA were adequate and included sufficient detail to justify the withholdings.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court affirmed the district court’s judgment regarding the adequacy of the VA’s search for emails and the application of Exemption 4 to records obtained from Evocati. The court also affirmed the application of Exemption 6 to the redaction of names and contact information, except for the names (but not email addresses) of Veterans Education Success (VES) employees who lobbied Congress or the VA. However, the court reversed the district court’s judgment regarding the withholding of OIG interview transcripts under Exemption 7(E), as the VA did not adequately justify that the interview techniques and methods used by OIG fell within this exemption. The case was remanded for further proceedings consistent with the opinion. View "Pomares v. USDVA" on Justia Law

In August 2020, Joe Willie Cannon, an inmate at Anamosa State Penitentiary (ASP), injured his right wrist while playing basketball. He sought medical attention from ASP staff, including nurses and a doctor, but experienced delays and inadequate treatment. Cannon alleged that the medical staff's failure to promptly diagnose and treat his wrist injury, which was later found to be a displaced fracture, constituted deliberate indifference to his serious medical needs, violating his Eighth Amendment rights.The United States District Court for the Northern District of Iowa denied summary judgment to four defendants—Dr. Michael Dehner and Nurses Amy Shipley, Courtney Friedman, and Barbara Devaney—who claimed qualified immunity. The court found that a reasonable jury could conclude that the defendants acted with deliberate indifference to Cannon's medical needs. The defendants appealed this interlocutory order.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court concluded that the district court failed to properly apply the principle that each defendant's knowledge and conduct must be individually assessed. The appellate court found that the nurses' actions, including their assessments and treatment plans, did not amount to deliberate indifference. Similarly, Dr. Dehner's decisions, including ordering an X-ray and referring Cannon to an orthopedic specialist, were based on his medical judgment and did not constitute deliberate indifference.The Eighth Circuit held that each appellant was entitled to qualified immunity because Cannon failed to prove that any of them acted with deliberate indifference to his serious medical needs. The court reversed the district court's order and remanded the case for further proceedings consistent with its opinion. View "Cannon v. Dehner" on Justia Law

Jacquelyn N’Jai filed a lawsuit against the U.S. Department of Education, New York University (NYU), Long Island University (LIU), Immediate Credit Recovery, Inc. (ICR), and FMS Investment Corporation (FMS), alleging various violations of federal law. N’Jai claimed that she had repaid her student loans but was falsely certified for additional loans by a bank analyst, with NYU and LIU allegedly signing her name on fraudulent loan applications. She contended that the Department of Education and its debt collectors used unlawful practices to collect on these loans, including garnishing her tax refund and threatening to garnish her Social Security checks.The United States District Court for the District of Columbia dismissed N’Jai’s claims against LIU, NYU, ICR, and FMS for lack of personal jurisdiction, citing the government contacts exception. This exception prevents the assertion of personal jurisdiction based solely on a defendant’s contact with federal government agencies in the District of Columbia. The court dismissed the claims against the remaining defendants for other reasons.The United States Court of Appeals for the District of Columbia Circuit reviewed the case, focusing on whether the government contacts exception under D.C. law is limited to First Amendment activities. The court noted the ongoing uncertainty about the scope of this exception, referencing previous cases where the D.C. Court of Appeals had not definitively resolved whether the exception is confined to First Amendment activity. Due to this uncertainty, the appellate court certified two questions to the D.C. Court of Appeals: whether the government contacts exception is limited to First Amendment activity and, if so, whether the contacts alleged in this case fall under that exception. The appellate court did not make a final ruling on the personal jurisdiction issue, pending the D.C. Court of Appeals' response to the certified questions. View "N'Jai v. Department of Education" on Justia Law

A chemical manufacturer and two trade associations challenged an EPA rule regulating emissions from certain facilities, specifically disputing the EPA’s assessment of cancer risk from ethylene oxide emissions. The EPA had determined that emissions from these sources posed an unacceptable risk to public health and tightened emissions standards accordingly. The EPA’s assessment concluded that the maximum lifetime individual risk of cancer from exposure to ethylene oxide was significantly higher than what is generally considered acceptable.The petitioners initially raised their complaints during the EPA’s rulemaking process and sought reconsideration after the final rule was issued. The EPA granted reconsideration and solicited further public comment, ultimately affirming its decision to use its existing cancer-risk assessment and rejecting an alternative assessment proposed by the Texas Commission on Environmental Quality (TCEQ). The petitioners then sought review from the United States Court of Appeals for the District of Columbia Circuit.The United States Court of Appeals for the District of Columbia Circuit reviewed the case and found that the EPA had adequately explained its modeling approach and decisions. The court held that the EPA’s reliance on its 2016 cancer-risk assessment was not arbitrary or capricious and that the EPA had properly considered and rejected the TCEQ’s alternative assessment. The court also found that the EPA had provided sufficient opportunities for public comment and had not violated any procedural requirements. The court denied the petitions for review, upholding the EPA’s rule and its assessment of the cancer risk from ethylene oxide emissions. View "Huntsman Petrochemical LLC v. EPA" on Justia Law

A group of property owners sued Columbia County over stormwater drainage issues that caused damage to their property. The property, purchased in 1996, contained a metal pipe used in the County's stormwater system. Over the years, heavy rains caused the pipe to fail multiple times, leading to significant property damage. The property owners sent a notice to the County in October 2013, outlining their claims, but the County declined to make repairs. The property owners then filed a lawsuit in March 2014, seeking damages and an injunction to prevent further damage.The trial court found in favor of the property owners, ruling that the County maintained a nuisance that amounted to a taking without just compensation. The court awarded damages and issued a permanent injunction against the County. The County appealed to the Court of Appeals, which affirmed some parts of the trial court's decision and vacated others. The Court of Appeals vacated the damages award for harms incurred after the October 2013 notice and reversed the award of attorneys' fees. However, it upheld the injunction against the County.The Supreme Court of Georgia reviewed the case and vacated the Court of Appeals' decision to uphold the injunction, ruling that it exceeded the bounds of the Georgia Constitution's limited waiver of sovereign immunity. The Court directed the Court of Appeals to remand the case to the trial court to consider a new injunction within the constitutional limits. The Supreme Court also concluded that it should not have granted certiorari on the issue of damages for harms incurred after the October 2013 notice, as the Court of Appeals' ruling was specific to the facts of this case and did not establish a general rule of law. The petition for certiorari on this issue was therefore denied. View "Satcher v. Columbia County" on Justia Law