The case involves the Western Coal Traffic League (the League), a coalition of coal shippers, petitioning for a writ of mandamus to compel the Surface Transportation Board (the Board) to take action on a proceeding related to the concept of "revenue adequacy" in freight rail shipping rates. The Board had opened an informational docket in April 2014 to gather public comments on how it calculates and applies revenue adequacy in rate cases. Over the next six years, the Board collected information through written comments and public hearings but had not issued a decision since February 2020. The League participated in the hearings and submitted comments advocating for changes to the Board's framework.The League filed a petition for a writ of mandamus in May 2023, arguing that the Board's delay in responding to the comments was unreasonable and requesting the court to compel the Board to publish a notice of proposed rulemaking or issue a final decision within 90 days. The League relied on the Administrative Procedure Act (APA) to argue that the Board's inaction was a clear violation of its duty to act promptly.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court noted that mandamus is an extraordinary remedy reserved for clear violations of a duty to act. The court found that it lacked jurisdiction to issue the writ because the Board's management of the Revenue Adequacy docket did not constitute a "final order" subject to judicial review under the Hobbs Act. The Board had convened the proceeding solely to gather public comments without any statutory duty or plans to undertake a rulemaking or specific regulatory action. Consequently, the court dismissed the League's petition for mandamus for lack of jurisdiction. View "In re: Western Coal Traffic League" on Justia Law

Andres Cabezas was arrested in an FBI sting operation in 2017 and later pled guilty to receipt of child pornography. While his appeal was pending, he submitted FOIA requests to the FBI for records related to his case. After six months without a response, Cabezas filed a lawsuit in the U.S. District Court for the District of Columbia, seeking the release of the requested records. The FBI eventually released some records but withheld others, citing various FOIA exemptions. The district court granted summary judgment to the FBI, finding that it had conducted a reasonable search and properly withheld documents under FOIA and the Privacy Act.Cabezas appealed the district court's decision, challenging the adequacy of the FBI's search and the justification for withholding records. He also contested the denial of his motions for limited discovery and in camera review. The U.S. Court of Appeals for the District of Columbia Circuit reviewed the case de novo and found that the FBI had made a good faith effort to conduct a reasonable search, using appropriate methods and search terms. The court also found that the FBI's affidavits provided a detailed account of the search process and the reasons for withholding certain records.The Court of Appeals affirmed the district court's judgment, agreeing that the FBI had conducted a reasonable search and properly invoked FOIA exemptions to withhold certain records. The court also upheld the denial of Cabezas's motions for limited discovery and in camera review, finding no abuse of discretion. The court concluded that Cabezas had not provided sufficient evidence to challenge the adequacy of the FBI's search or the validity of the exemptions claimed. View "Cabezas v. FBI" on Justia Law

In February 2021, a severe cold snap hit the central United States, causing widespread power outages and fatalities. This event highlighted the need for improved grid reliability. The Midcontinent Independent System Operator (MISO), which manages the electrical grid in the region, proposed changes to its capacity market to address these issues. MISO's new system includes seasonal capacity markets, a revised method for calculating generator capacity, and new rules for generator outages. The Federal Energy Regulatory Commission (FERC) approved these changes.Entergy Arkansas, LLC, along with other companies, petitioned for review of FERC's approval, arguing that FERC acted arbitrarily and capriciously. Entergy challenged three main aspects: the new method for calculating generator capacity, the requirement for generator owners to replace capacity if offline for more than 31 days in a season, and the 120-day notice requirement for planned outages. Entergy was supported by several intervenors, including public utilities commissions and the East Texas Electric Cooperative.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court found that FERC had adequately explained its approval of MISO's changes. FERC's reliance on a study showing the new methodology's accuracy was deemed reasonable. The court also upheld the 31-day capacity replacement rule and the 120-day notice requirement, finding that FERC had provided sufficient rationale for these rules. The court denied Entergy's petitions for review and did not address issues raised solely by the intervenors. The court concluded that FERC's decisions were not arbitrary or capricious and were supported by substantial evidence. View "Entergy Arkansas, LLC v. FERC" on Justia Law

Federal agents seized packages containing noncompliant plant and animal products shipped to Amazon fulfillment centers in the U.S. by overseas sellers. The Department of Agriculture concluded that Amazon, by providing its fulfillment services, had aided, abetted, caused, or induced the unlawful importation of these products and imposed a $1 million fine on Amazon.The case was initially reviewed by an administrative law judge (ALJ) who granted summary judgment in favor of the Department, finding that Amazon had unlawfully imported the products by aiding, abetting, causing, or inducing their importation. The ALJ rejected Amazon's argument that it was unaware of the sellers' noncompliance, stating that neither bad intent nor any mens rea was required for liability. The Judicial Officer of the Department affirmed the ALJ's decision, concluding that Amazon's conduct fell within the scope of the statutes and that Amazon had substantially assisted the importations with knowledge.The United States Court of Appeals for the District of Columbia Circuit reviewed the case and set aside the Department's order. The court held that civil aiding-and-abetting liability generally requires conscious and culpable participation in unlawful conduct. The Plant Protection Act and Animal Health Protection Act incorporate this understanding. The court found that Amazon's provision of a neutral fulfillment service did not amount to conscious and culpable participation in the sellers' wrongdoing. Therefore, the court granted Amazon's petition for review, vacated the Department's order, and remanded the case for further proceedings consistent with its opinion. View "Amazon Services LLC v. AGRI" on Justia Law

Aly Abdellatif, an Egyptian citizen, suspected he was placed on government watchlists after experiencing unwarranted airport security screenings. He sought correction through the Transportation Security Administration's (TSA) redress program, which responded without confirming or denying his watchlist status. Abdellatif and his wife, Nina Araujo, petitioned for review, challenging the administration of the traveler redress program and their treatment during travel.The petitioners initially filed their case in the United States Court of Appeals for the District of Columbia Circuit. They named multiple federal agencies and officials as respondents, alleging that Abdellatif's inclusion on the Selectee List and TSA watchlists led to enhanced security screenings and secondary inspections. They argued that TSA's redress process failed to correct erroneous information, violating statutory obligations and due process rights. The court dismissed the petition against all respondents except TSA, citing jurisdictional limitations.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court dismissed the petition in part for lack of standing, as TSA cannot remove names from the Selectee List, which is maintained by the Terrorist Screening Center (TSC). The court found that petitioners' injuries related to the Selectee List were not redressable in this lawsuit. However, the court denied the remaining claims on the merits, concluding that TSA's redress process complies with statutory requirements and does not violate due process. The court also rejected the Fourth Amendment claims, finding that the enhanced security screenings and secondary inspections described were reasonable and did not constitute unreasonable searches or seizures. The petition was dismissed in part and otherwise denied. View "Abdellatif v. DHS" on Justia Law

The Federal Energy Regulatory Commission (FERC) is responsible for ensuring that rates charged by interstate oil pipelines are just and reasonable. Every five years, FERC reviews the methodology, known as the Index, used to set maximum annual rate increases. In 2020, FERC conducted its five-year review and set a new Index level, which was later modified on rehearing without adhering to notice-and-comment procedures.Initially, FERC invited comments on the proposed Index, receiving input from both pipeline operators (Carriers) and customers (Shippers). FERC issued an Initial Order in December 2020, establishing an Index level higher than proposed, effective July 1, 2021. Both Carriers and Shippers sought rehearing, with Carriers requesting minor changes and Shippers challenging the Index level. FERC issued a Rehearing Order in January 2022, adopting Shippers' suggestions and setting a new, lower Index effective March 1, 2022. Shippers sought clarification on the retroactive application of the Rehearing Order, which FERC denied.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. Carriers argued that FERC failed to comply with the Administrative Procedure Act (APA) by modifying the Index without notice-and-comment procedures. The court agreed, noting that once the Initial Order's Index became effective on July 1, 2021, any substantive changes required adherence to APA procedures. The court found that FERC's modification of the Index in the Rehearing Order without such procedures was improper.The court granted Carriers' petitions for review, vacated the Rehearing Order, and ordered FERC to reinstate the Initial Order. Shippers' petitions for review were dismissed as moot due to the vacatur of the Rehearing Order. View "Liquid Energy Pipeline Association v. FERC" on Justia Law

Hudson Transmission Partners, a merchant transmission facility, previously held firm rights to draw electricity from the PJM grid and was assessed costs for certain grid improvements. In 2017, Hudson relinquished its firm rights, leading to a dispute over whether it must continue paying for previously assessed costs for lower voltage facility upgrades and economic projects under the PJM Open Access Transmission Tariff.The Federal Energy Regulatory Commission (FERC) found that Hudson must continue to pay these costs. FERC determined that the PJM Tariff dictates that prior assessments for lower voltage facility upgrades are fixed and unaffected by a change in firm rights. Additionally, the costs of economic projects are validly allocated to entities like Hudson that benefit from the energy savings, regardless of their firm rights status.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court upheld FERC's decision, agreeing that Hudson remains responsible for the previously assessed costs. The court noted that the PJM Tariff includes a saving clause that fixes the cost responsibility for lower voltage facilities unless explicitly changed, which was not the case here. The court also found that Hudson continues to benefit from the economic projects, justifying the continued cost responsibility.The court concluded that FERC's interpretation of the PJM Tariff was consistent with its prior orders and the cost-causation principle, which assigns costs based on the burdens imposed or benefits received by a party. Therefore, the court denied the petitions for review, affirming that Hudson must continue to pay the previously assessed costs for the lower voltage facility upgrades and economic projects. View "New York Power Authority v. FERC" on Justia Law

A group of non-convicted individuals detained in Alameda County’s Santa Rita Jail filed a lawsuit against Aramark Correctional Services, LLC, Alameda County, and Sheriff Gregory J. Ahern. The plaintiffs claimed they were entitled to minimum wage and overtime pay under California’s Labor Code for work performed without pay for Aramark while detained. The defendants moved to dismiss these claims, arguing that the plaintiffs' compensation was governed by the California Penal Code, which allows counties to pay prisoners at rates below minimum wage.The United States District Court for the Northern District of California denied the defendants' motion to dismiss the minimum wage and overtime claims, holding that the California Penal Code did not preclude non-convicted detainees working for a private company from the protections of the Labor Code. The district court allowed the plaintiffs' claims to proceed, leading the defendants to file an interlocutory appeal.The United States Court of Appeals for the Ninth Circuit reviewed the case and certified a question to the California Supreme Court regarding whether non-convicted detainees working for a private company in county jails have a claim for minimum wages and overtime under the California Labor Code. The California Supreme Court responded that such detainees do not have a claim for minimum wages and overtime under Section 1194 of the California Labor Code. The court clarified that section 4019.3 of the California Penal Code applies broadly to all county inmates, including pretrial detainees, and does not depend on the identity of the employer.Based on the California Supreme Court's response, the Ninth Circuit reversed the district court's order denying the motion to dismiss the plaintiffs' minimum wage and overtime claims. The court held that the plaintiffs' claims failed under the current law and reversed the district court's decision. View "RUELAS V. COUNTY OF ALAMEDA" on Justia Law

In the early hours of August 21, 2017, the M/V ALNIC, a Liberian-flagged oil-and-chemical tanker, collided with the U.S.S. JOHN S. MCCAIN, a Navy destroyer, in the Singapore Strait. The collision resulted in the deaths of ten Navy sailors and injuries to dozens more. Both vessels sustained significant damage. Energetic Tank, Inc., the owner of ALNIC, sought exoneration from or limitation of liability for the collision. Forty-one Navy sailors or their representatives, along with the United States, filed claims for damages against Energetic. Energetic counterclaimed against the United States. The parties agreed on the monetary value of the damages to ALNIC and MCCAIN as $442,445 and $185 million, respectively.The United States District Court for the Southern District of New York concluded that Singapore law would govern the determination of liability and the calculation of damages. After a Phase 1 bench trial, the district court denied Energetic’s petition for exoneration or limitation of liability, allocating 80% of the fault to the United States and 20% to Energetic. The court indicated it would proceed to a Phase 2 trial to determine damages to the Sailor-Claimants. Energetic appealed, and while the appeal was pending, the district court dismissed Energetic’s claims for contribution or indemnity against the United States for any damages awarded to the Sailor-Claimants, citing sovereign immunity. Energetic also appealed this order. The district court retroactively certified its earlier opinion on the apportionment of liability as a final judgment as to the United States. Several Sailor-Claimants cross-appealed, challenging the application of Singapore law to the calculation of damages.The United States Court of Appeals for the Second Circuit found no error in the district court’s apportionment of liability under Singapore law or its sovereign immunity ruling, affirming the district court’s judgment and order on Energetic’s appeals. However, the court dismissed the Sailor-Claimants’ cross-appeals for lack of jurisdiction, as the choice-of-law ruling was a non-appealable collateral order. View "In the Matter of Energetic Tank, Inc." on Justia Law

The case involves Puerto Rico's attempt to enact Law 29, which aimed to relieve municipalities from contributing to the Commonwealth's reformed public pension funding scheme. The Financial Oversight and Management Board for Puerto Rico (the Board) challenged the law, and the Title III court overseeing Puerto Rico's debt restructuring declared Law 29 a nullity and of no effect. This decision was not appealed. La Liga de Ciudades de Puerto Rico (La Liga) argued that the Title III court's order did not authorize the Board to recover funds retained by municipalities under Law 29 before the order took effect.The United States District Court for the District of Puerto Rico, interpreting its own prior order, granted motions to dismiss filed by the Board and other defendants. The court dismissed some claims on the merits and others for lack of standing. The court held that the Title III court's order applied retroactively, nullifying Law 29 from its inception and allowing the Board to recover the funds.The United States Court of Appeals for the First Circuit reviewed the case. The court affirmed the district court's dismissal of La Liga's complaint. It held that the Title III court's order declaring Law 29 a nullity and of no effect applied retroactively, covering the period from the law's enactment. The court found that the Title III court had the authority under PROMESA to nullify Law 29 from its inception and that the Board's actions to recover the funds were justified. The court also addressed standing issues, affirming that La Liga had standing to sue the Board and CRIM but not the executive branch defendants. View "La Liga de Ciudades de P.R. v. Financial Oversight and Management Board" on Justia Law