Justia Government & Administrative Law Opinion Summaries

Healthy Blue, a vendor, submitted a proposal to operate Nebraska’s Medicaid managed care program but was not selected. After its bid protest and request for reconsideration were denied by the Nebraska Department of Health and Human Services (DHHS), Healthy Blue filed a lawsuit in the district court for Lancaster County against state officials and the winning bidders. Healthy Blue sought declaratory and injunctive relief under the Uniform Declaratory Judgments Act (UDJA), claiming DHHS acted unlawfully in awarding the contracts.The district court overruled the state officials' motion to dismiss, which argued that Healthy Blue lacked standing as a taxpayer and that the claim was barred by sovereign immunity. The court found that Healthy Blue adequately pled taxpayer standing and that the claim was not barred by sovereign immunity because it sought relief from an invalid act by public officers. The state officials then moved for summary judgment, reiterating their sovereign immunity argument. The district court denied this motion, maintaining that the claim was an official-capacity suit not barred by sovereign immunity.The Nebraska Supreme Court reviewed the case. The court held that the state officials' motion for summary judgment was not based on the assertion of sovereign immunity, as they did not appeal the district court's ruling that the claim was an official-capacity suit. The court emphasized that standing and sovereign immunity are distinct jurisdictional concepts and that the question of standing can be reviewed on appeal of a final order without being effectively lost. Consequently, the Nebraska Supreme Court dismissed the appeal for lack of jurisdiction. View "Community Care Health Plan of Nebraska, Inc. v. Jackson" on Justia Law

Vincent Bell, a pretrial detainee with an amputated right leg, alleged that deputies used excessive force during a cell extraction and transfer at the San Francisco Jail. Bell claimed that Sergeant Yvette Williams did not provide him with a wheelchair or other mobility device, forcing him to hop on one leg until he fell. Deputies then carried him by his arms and leg, causing him pain and minor injuries. Bell sued under the Fourteenth Amendment, the Americans with Disabilities Act (ADA), and the Rehabilitation Act.The United States District Court for the Northern District of California held a jury trial. The jury found in favor of Bell on his excessive force claim against Williams and his ADA and Rehabilitation Act claims against the City and County of San Francisco. However, the jury did not find that Williams caused Bell physical or emotional harm. The jury awarded Bell $504,000 in compensatory damages against the City but not against Williams. The district court denied the defendants' post-trial motion for judgment as a matter of law or a new trial.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court affirmed the jury's verdict on Bell's Fourteenth Amendment excessive force claim and his ADA and Rehabilitation Act claims, finding substantial evidence supported these claims. However, the court reversed the district court's decision on Bell's Monell theory of liability, concluding that Bell did not present substantial evidence showing that the City's training was the product of deliberate indifference to a known risk. The court also vacated the jury's compensatory damages award, deeming it grossly excessive, and remanded for a remittitur or a new trial on damages. View "BELL V. WILLIAMS" on Justia Law

The relator, Jumaane Scott, filed an action requesting a writ of mandamus to compel the Toledo Correctional Institution (TCI) to produce public records. Scott claimed that between April and July 2023, he made four separate requests for public records, including body-camera footage from three different correction officers and a vegetarian diet menu. He alleged that TCI staff denied his requests or failed to respond. Scott sought the production of these records, statutory damages, and court costs.The case was initially reviewed by the Supreme Court of Ohio. TCI filed a motion to dismiss, which was denied, leading to the issuance of an alternative writ. TCI conceded most of Scott’s factual allegations but argued that the requested body-camera footage did not exist. TCI’s evidence included an affidavit from Derek Burkhart, the warden’s assistant, stating that the footage was not saved and therefore did not exist. Scott did not provide contrary evidence to rebut this claim.The Supreme Court of Ohio denied Scott’s request for a writ of mandamus, finding that the body-camera footage did not exist and that TCI had no obligation to produce nonexistent records. The court also denied Scott’s request for the vegetarian diet menu because his petition did not explicitly seek relief for that request. Additionally, the court denied Scott’s requests for statutory damages and court costs, concluding that Scott failed to demonstrate that TCI did not meet its obligations under the Public Records Act or acted in bad faith.In summary, the Supreme Court of Ohio held that TCI had no duty to produce nonexistent records and that Scott was not entitled to statutory damages or court costs. The court denied the writ of mandamus and all associated requests for relief. View "State ex rel. Scott v. Toledo Corr. Inst." on Justia Law

The case involves a dispute between the City of Hastings and a group of appellants referred to as the "chief petitioners." The chief petitioners submitted a referendum petition to repeal a city council measure approving the demolition of a viaduct. The City of Hastings sought a declaratory judgment to determine whether it was required to hold a special referendum election, given that the viaduct was demolished during the pendency of the action.The District Court for Adams County initially denied the chief petitioners' request for a temporary injunction to prevent the demolition. Subsequently, the viaduct was demolished. The district court then ruled that the case was moot because the viaduct no longer existed, and any referendum would be ineffectual. However, the court also addressed other arguments and ultimately declared that no election or ballot submission should be made.The Nebraska Supreme Court reviewed the case and agreed with the district court's finding that the case was moot. The court noted that the demolition of the viaduct eradicated the parties' legal interests in the dispute, making any referendum on the issue meaningless. The court also considered whether the public interest exception to the mootness doctrine applied but concluded that the specific circumstances of the case did not warrant an authoritative adjudication for future guidance.The Nebraska Supreme Court affirmed the district court's decision in part, reversed it in part, and remanded the case with directions to dismiss the action due to mootness. View "City of Hastings v. Sheets" on Justia Law

WasteXperts, Inc. (WasteXperts) filed a complaint against Arakelian Enterprises, Inc. dba Athens Services (Athens) and the City of Los Angeles (City) in June 2022. WasteXperts alleged that Athens, which holds a waste collection franchise from the City, sent a cease and desist letter to WasteXperts, arguing that WasteXperts was not legally permitted to handle Athens’s bins. WasteXperts sought judicial declarations regarding the City’s authority and Athens’s franchise rights, and also asserted tort claims against Athens for interference with contract, interference with prospective economic advantage, unfair competition, and trade libel.The Superior Court of Los Angeles County granted Athens’s anti-SLAPP motion to strike the entire complaint, finding that the claims were based on Athens’s communications, which anticipated litigation and were therefore protected activity. The court also held that the commercial speech exemption did not apply and that WasteXperts had no probability of prevailing on the merits of its claims. WasteXperts’s request for limited discovery was denied.The California Court of Appeal, Second Appellate District, Division Four, reversed the trial court’s order. The appellate court concluded that the declaratory relief claim did not arise from protected activity, as it was based on an existing dispute over the right to move waste collection bins, not on the prelitigation communications. The court also found that the commercial speech exemption applied to Athens’s communications with WasteXperts’s clients, removing those communications from the protection of the anti-SLAPP statute. Consequently, the tort claims did not arise from protected activity. The appellate court did not address the probability of WasteXperts prevailing on the merits or the request for limited discovery. View "Wastexperts, Inc. v. Arakelian Enterprises, Inc." on Justia Law

The case involves Lion Elastomers, a synthetic rubber manufacturer, and the National Labor Relations Board (NLRB). Lion Elastomers had been found guilty of unfair labor practices by the NLRB for threatening, disciplining, and discharging an employee, Joseph Colone, for engaging in protected activities. The NLRB applied the Atlantic Steel standard to assess whether Colone's behavior lost its protected status. However, before the appeal of the Board’s decision had been briefed, the NLRB issued a new interpretation of the National Labor Relations Act (NLRA) in a case called General Motors, which overruled Atlantic Steel. The NLRB then sought a remand to apply this new interpretation to the Lion Elastomers case.The case was remanded to the NLRB by the Fifth Circuit Court of Appeals. However, instead of applying the new interpretation from General Motors as expected, the NLRB used the remand proceeding to overrule General Motors and return to the Atlantic Steel standard. Lion Elastomers argued that the NLRB exceeded the scope of the remand and violated its due-process rights during the remand proceeding.The Fifth Circuit Court of Appeals agreed with Lion Elastomers. The court found that the NLRB had exceeded the scope of the remand by not applying the General Motors standard as expected. The court also found that the NLRB had violated Lion Elastomers's due-process rights by not giving the company an opportunity to be heard before deciding to overturn General Motors. The court vacated the NLRB's decision and remanded the case back to the NLRB, instructing it to apply the General Motors standard to this case. View "Lion Elastomers v. National Labor Relations Board" on Justia Law

The case revolves around Benjamin Ramirez, who, on behalf of a putative class, sued the Director and the Treasurer of the Missouri Department of Revenue in their official capacities. Ramirez had resolved criminal charges against him by pleading guilty and paying court costs, including certain mandatory surcharges. These surcharges were then paid to various funds, as authorized by Missouri statute. Ramirez alleged that the Director and the Treasurer received payment of, collected, and deposited the surcharges in and otherwise managed these funds. He claimed a single count of unjust enrichment and asserted the statutes authorizing the surcharges violate a section of the Missouri Constitution.The Director and the Treasurer moved for summary judgment, asserting that Ramirez’s suit is barred by sovereign immunity and the statutes authorizing the surcharges do not violate the Missouri Constitution. The circuit court sustained the motion, concluding the statutes authorizing the surcharges do not violate the Missouri Constitution. Ramirez appealed this decision.The Supreme Court of Missouri affirmed the circuit court's judgment. The court held that sovereign immunity, a common law judicial doctrine barring suit against a government or public entity, applied to Ramirez's claim for unjust enrichment. The court noted that sovereign immunity is the default rule in all suits against the state and applies to non-tort claims. The court found that the state had not waived its sovereign immunity through express statutory consent or a recognized common law exception. Therefore, Ramirez's unjust enrichment suit against the Director and the Treasurer was barred by sovereign immunity. View "Ramirez vs. Missouri Prosecuting Attorneys' & Circuit Attorneys' Retirement System" on Justia Law

The case involves Transcontinental Gas Pipe Line Company, LLC (Transco), a natural gas company that sought to abandon and expand its pipeline facilities in Pennsylvania and New Jersey. To do so, Transco needed a Certificate of Public Convenience and Necessity from the Federal Energy Regulatory Commission (FERC), which it obtained. However, the certificate was subject to conditions, including that Transco receive three additional permits from the Pennsylvania Department of Environmental Protection (PADEP). After receiving these permits, Transco began its pipeline project. However, three environmental advocates filed an administrative appeal with the Environmental Hearing Board (EHB) challenging PADEP's issuance of the permits. In response, Transco initiated a lawsuit in the District Court seeking to enjoin the administrative appeal, arguing that the Natural Gas Act preempts the state law allowing the appeal.The District Court rejected Transco's preemption arguments and denied its motion for a preliminary injunction. Transco appealed this decision to the United States Court of Appeals for the Third Circuit. The Court of Appeals affirmed the District Court's decision, finding that none of the theories of preemption advanced by Transco or the state agency applied in this case. The Court held that the Natural Gas Act does not expressly preempt administrative appeals to the EHB, nor does it field preempt such appeals. The Court also found that the possibility of multiple challenges in different fora to PADEP permitting decisions under the Clean Water Act for interstate natural gas pipelines does not impose an obstacle to the purposes of the Natural Gas Act. Therefore, the Court concluded that Transco's motion for a preliminary injunction was correctly denied. View "Transcontinental Gas Pipe Line Co LLC v. Pennsylvania Environmental Hearing Board" on Justia Law

The case revolves around Evergreen Shipping Agency (America) Corp. and its affiliates, who were charged by the Federal Maritime Commission (FMC) for imposing "unjust and unreasonable" detention charges on TCW, Inc., a trucking company. The charges were for the late return of a shipping container. The FMC argued that the charges were unreasonable as they were levied for days when the port was closed and could not have accepted a returned container. Evergreen contested this decision, arguing that the FMC's application of the interpretive rule was arbitrary and capricious, in violation of the Administrative Procedure Act.The FMC had previously ruled in favor of TCW, Inc. in a small claims program. The Commission then reviewed the decision, focusing on the application of the interpretive rule on demurrage and detention. The FMC upheld the initial decision, stating that no amount of detention can incentivize the return of a container when the terminal cannot accept the container. The Commission dismissed Evergreen's arguments that failing to impose detention charges during the port closure would have disincentivized the return of the container before the closure.The United States Court of Appeals for the District of Columbia Circuit reviewed the case and found the FMC's decision to be arbitrary and capricious. The court noted that the FMC failed to consider relevant factors and did not provide a reasoned explanation for several aspects of its decision. The court also found that the FMC's application of the incentive principle was illogical. The court concluded that a detention charge does not necessarily lack any incentivizing effect because it is levied for a day on which a container cannot be returned to a marine terminal. The court granted the petition for review, vacated the Commission’s order, and remanded the matter to the agency for further proceedings. View "Evergreen Shipping Agency (America) Corp. v. Federal Maritime Commission" on Justia Law

The case involves the Sandpiper Residents Association and other residents of Sandpiper Cove, a privately owned apartment complex in Texas, subsidized by the U.S. Department of Housing and Urban Development (HUD) under its Section 8 project-based rental assistance program. The residents sued HUD, alleging that the agency failed to ensure that Sandpiper Cove was maintained in a habitable condition. They sought to compel HUD to issue Tenant Protection Vouchers, which would allow them to receive rental payment assistance for use at other properties.The District Court dismissed the residents' claims for lack of subject-matter jurisdiction, reasoning that their claims had been mooted by the sale of Sandpiper Cove to a new owner who had not received a Notice of Default. The residents appealed this decision.The United States Court of Appeals for the District of Columbia Circuit held that the District Court erred in dismissing the residents' claims as moot. The court found that the question of whether the residents were legally entitled to relief after the sale of Sandpiper Cove went to the merits of their case, not mootness. However, the court affirmed the District Court’s dismissal of the residents' complaint because they failed to state a claim upon which relief could be granted. The court held that the residents had not shown that the new owner of Sandpiper Cove had received a Notice of Default, a condition necessary for the issuance of Tenant Protection Vouchers under the relevant statute. View "Sandpiper Residents Association v. Housing and Urban Development" on Justia Law