Justia Government & Administrative Law Opinion Summaries

The case involves Smith & Wesson Brands, Inc., Smith & Wesson Sales Company, and Smith & Wesson Inc. (collectively, “Smith & Wesson”) and the Attorney General of the State of New Jersey and the New Jersey Division of Consumer Affairs. The New Jersey Attorney General issued a subpoena to Smith & Wesson under the New Jersey Consumer Fraud Act, seeking documents related to the company's advertising practices. Smith & Wesson filed a federal lawsuit to enjoin enforcement of the subpoena, alleging it violated various constitutional provisions. The New Jersey Attorney General then filed a subpoena enforcement action in state court. The state court rejected Smith & Wesson’s objections and ordered the company to comply with the subpoena.The state court proceedings concluded before the federal case, with the state court ordering Smith & Wesson to comply with the subpoena. The federal court then dismissed Smith & Wesson’s civil rights action on claim preclusion grounds, giving preclusive effect to the state court’s order. The state appellate court later affirmed the state court judgment. Smith & Wesson appealed to the United States Court of Appeals for the Third Circuit, arguing that the District Court should not have given preclusive effect to the state court order.The United States Court of Appeals for the Third Circuit affirmed the District Court’s order. The court found that all elements of New Jersey’s claim preclusion test were satisfied. The court also rejected Smith & Wesson’s argument that it had reserved its right to litigate in federal court, finding that such reservation was unavailable in this case. The court emphasized that litigants get one opportunity to make their arguments, not two, and they cannot file a federal lawsuit to hedge against a potentially unfavorable state ruling. View "Smith & Wesson Brands Inc. v. Attorney General of the State of New Jersey" on Justia Law

The case involves a group of civil rights organizations, voters, and an election official who sought to challenge recent amendments to Texas's election code, alleging that these amendments violated the United States Constitution and several federal statutes. The defendant was the District Attorney for Harris County, sued in her official capacity. The district court denied the District Attorney's motion to dismiss, holding that she was not immune from the plaintiffs' constitutional claims and that the plaintiffs had standing to bring their claims against her.The United States Court of Appeals for the Fifth Circuit held that it had jurisdiction to hear the appeal and that the district court should have dismissed the plaintiffs' constitutional claims as barred by sovereign immunity. The court did not reach the issue of standing. The court reversed in part, vacated in part, and remanded the case for further proceedings.The court's decision was based on the principle of sovereign immunity, which generally protects state officials from being sued in their official capacities. However, there is an exception to this rule, known as the Ex parte Young exception, which allows federal courts to enjoin state officials from enforcing unconstitutional state statutes. The court found that the District Attorney did not have a sufficient connection to the enforcement of the challenged laws to fall within this exception. Therefore, the court concluded that the District Attorney was immune from the plaintiffs' constitutional claims. View "Mi Familia Vota v. Ogg" on Justia Law

The Washington State Attorney General filed a lawsuit against the city of Sunnyside and several of its officials, alleging that the city's crime-free rental housing program (CFRHP) was being used to evict tenants without due process and that these evictions disproportionately impacted Latinx renters, women-headed households, and families with minor children. The city argued that the Attorney General lacked the authority to bring this suit, as the scope of the Attorney General's authority under RCW 43.10.030(1) limits their ability to act to matters that impact more people than those affected by the CFRHP. The trial court granted summary judgment in favor of the defendants.On appeal, the Supreme Court of Washington reversed and remanded the case. The court held that the Attorney General did have the authority to bring the suit, as the case involved matters of public concern in which the state had an interest. The court also found that there were genuine disputes of material fact regarding whether the city's enforcement of the CFRHP had a disparate impact on protected classes, and whether the individual respondents were entitled to qualified immunity. However, the court affirmed the trial court's grant of summary judgment on the Attorney General's claims under the Residential Landlord-Tenant Act, finding that the respondents were not landlords and therefore the Act did not apply to them. View "State v. City of Sunnyside" on Justia Law

The case involves two casino operators, PNK (Baton Rouge) Partnership, PNK Development 8 LLC, PNK Development 9 LLC, and Centroplex Centre Convention Hotel, LLC, who incentivize their patrons with rewards, including complimentary hotel stays. The City of Baton Rouge/Parish of East Baton Rouge Department of Finance and Linda Hunt, its director, discovered through an audit that the operators had not remitted state and local taxes associated with these complimentary stays for several years. The City argued that the operators needed to pay these taxes, while the operators presented various arguments as to why they did not. The City filed a lawsuit in state court, which the operators removed to federal court on diversity jurisdiction grounds.The operators' removal of the case to federal court was challenged by the City, which argued that the tax abstention doctrine (TAD) warranted abstention in this case. The United States District Court for the Middle District of Louisiana agreed with the City, finding that all five TAD factors favored abstention: Louisiana's wide regulatory latitude over its taxation structure, the lack of heightened federal court scrutiny required by the operators' due process rights invocation, the potential for the operators to seek an improved competitive position in the federal court system, the greater familiarity of Louisiana courts with the state's tax regime and legislative intent, and the constraints on remedies available in federal court due to the Tax Injunction Act.The United States Court of Appeals for the Fifth Circuit affirmed the District Court's decision. The Appeals Court found that the District Court had correctly applied the TAD and had not abused its discretion in deciding to abstain. The Appeals Court agreed that all five TAD factors favored abstention and that any doubt about the propriety of removal should be resolved in favor of remand. View "City of Baton Rouge v. PNK" on Justia Law

The case involves a dispute between the Florida Division of Emergency Management (the Division) and a private company, Essential Diagnostics, LLC, over a contract for the purchase of COVID-19 test kits. The Division contracted with Essential Diagnostics to buy 200,000 COVID-19 test kits for $2.2 million. However, Essential claimed that the Division ordered 600,000 tests but only paid for 200,000. The Division, on the other hand, insisted that it only ever agreed to buy 200,000 tests and that it paid for them in full. Essential assigned its rights under the contract to Global Integrated Concepts, which sued the Division in Florida state court. However, the state court dismissed the complaint. Subsequently, Global and two other parties involved in the transaction sued the Division in federal district court in North Carolina, seeking to recover the same $4.4 million Global sought as damages in its state court suit.The Division moved to dismiss the suit on the grounds of sovereign immunity. The district court denied the motion to dismiss, concluding that the Division waived its sovereign immunity by contracting with the plaintiffs. The Division appealed this decision.The United States Court of Appeals for the Fourth Circuit vacated the district court’s order and remanded the case for further proceedings. The appellate court found that the district court erred in concluding that the Division waived its sovereign immunity by contracting with the plaintiffs. The court clarified that the rules governing waiver of federal-law sovereign immunity in federal court come from federal law, not state law. The court concluded that the district court failed to distinguish between the defenses and immunities a State might enjoy under state law and the constitutionally protected sovereign immunity that States enjoy from suit in federal court. The court also rejected the plaintiffs' argument that the court lacked jurisdiction over the appeal. View "Global Innovative Concepts, LLC v. State of Florida, Division of Emergency Management" on Justia Law

In 2007, Jon Oberg filed a lawsuit under the False Claims Act against various student-loan companies, including Nelnet, Inc., Nelnet Education Loan Funding, Inc., Brazos Higher Education Services Corporation, and Brazos Higher Education Authority, Inc. Oberg alleged that the companies submitted false claims to the Department of Education to inflate their loan portfolios eligible for interest subsidies. The parties agreed to a protective order for discovery, and the companies filed a joint motion for leave to file confidential summary judgment materials under seal. The magistrate judge granted in part the motion to file under seal. The parties eventually settled, and the magistrate judge dismissed the actions against the companies with prejudice.On March 31, 2023, Michael Camoin—a documentary filmmaker who covers the student-loan industry—filed a pro se letter in the district court requesting access to the materials that Oberg filed under seal in connection to his opposition to summary judgment. Nelnet and Brazos eventually filed a joint brief opposing Camoin’s request. On July 3, 2023, the magistrate judge denied Camoin’s motion. The judge found that Camoin has “no common law or First Amendment right to access the sought documents and portions of documents” because “a document must play a relevant and useful part in the adjudication process for either the First Amendment or common law rights of public access to attach.”On appeal, the United States Court of Appeals for the Fourth Circuit reversed the magistrate judge’s order and remanded for consideration of whether maintaining the seal on the requested documents is “necessitated by a compelling government interest[] and . . . narrowly tailored to serve that interest.” The court held that Camoin has a presumptive First Amendment right to access Oberg’s summary judgment motion and the documents attached to that motion. The court found that the public has an interest in ensuring basic fairness and deterring official misconduct not only in the outcome of certain proceedings, but also in the very proceedings themselves. The court concluded that irrespective of whether a district court ever resolves a summary judgment motion, the public has a presumptive First Amendment right to access documents submitted in connection with it. View "Camoin v. Nelnet, Inc." on Justia Law

The case involves the Michigan Attorney General's attempt to shut down Enbridge’s Line 5 Pipeline, which runs underwater across the Straits of Mackinac between Michigan’s Lower and Upper Peninsulas. The Attorney General filed the case in Michigan state court in 2019, alleging violations of three state laws. Enbridge responded by moving for summary disposition, arguing that the complaint failed to state a claim on which relief could be granted. The state court held oral argument on those dispositive motions, focusing on preemption issues, including whether the Attorney General’s claims were preempted by either the Pipeline Safety Act or the federal Submerged Lands Act.In 2020, Michigan Governor Gretchen Whitmer issued a notice of revocation of the 1953 easement, calling for Line 5 to be shut down by May 2021, and simultaneously filed a complaint in state court to enforce the notice. Enbridge timely removed the Governor’s case to the United States District Court for the Western District of Michigan. The district court denied the Governor’s motion to remand, holding that it had federal-question jurisdiction. The Governor subsequently voluntarily dismissed her case.Enbridge removed the Attorney General’s case to federal court in December 2021, citing the district court’s order denying the motion to remand in the Governor’s case. The Attorney General moved to remand this case to state court on grounds of untimely removal and lack of subject-matter jurisdiction. The district court denied the motion on both grounds, excusing Enbridge’s untimely removal based on equitable principles and estopping the Attorney General from challenging subject-matter jurisdiction.The United States Court of Appeals for the Sixth Circuit reversed the district court's decision, holding that Enbridge failed to timely remove the case to federal court under 28 U.S.C. § 1446(b), and there are no equitable exceptions to the statute’s deadlines for removal. The case was remanded to Michigan state court. View "Nessel v. Enbridge Energy, LP" on Justia Law

The case involves a dispute over water rights associated with the Green Mountain Reservoir in Colorado. The City of Golden (Golden) opposed the implementation of an administrative protocol (the Protocol) developed by the United States and other parties, arguing that it would injure its rights upstream of the reservoir. The water court granted the United States' motion for summary judgment, ruling that the Protocol is consistent with the Blue River Decree, a series of decrees and stipulations governing water rights in the area. Golden appealed this decision.Previously, the water court had ruled that an assessment of injury was not required in this case, as the United States was merely requesting confirmation that the Protocol was consistent with the existing Blue River Decree. The court also rejected Golden's claims that the Protocol contradicted language in the Blue River Decree requiring the "fair" and "equitable" treatment of all parties with interests in the Colorado-Big Thompson Project (CBT), a complex water diversion project.The Supreme Court of the State of Colorado affirmed the water court's ruling. It held that the Protocol is consistent with the Blue River Decree and does not violate the prior appropriation doctrine, a principle of water law that gives priority to those who first used the water. The court also rejected Golden's procedural arguments regarding the water court's denial of its motion for reconsideration. View "City of Golden v. City of Aurora" on Justia Law

The case involves a dispute over the eligibility of a married individual, Costa Tingos, for Medicaid long-term care benefits. Costa and his wife, Mary, had been married for over 50 years, but had kept their finances largely separate due to Costa's history of gambling and financial mismanagement. When Costa moved into a nursing home, he applied for Medicaid benefits. However, Mary refused to provide information about her income and assets, which was necessary to determine Costa's eligibility. Costa argued that Mary's refusal to cooperate should not affect his eligibility.The case was initially heard by the Massachusetts Medicaid program, MassHealth, which denied Costa's application. Costa appealed to the MassHealth board of hearings, which also denied his appeal. Costa then sought judicial review in the Superior Court, which vacated the board's decision and remanded the case back to the board. After two more rounds of hearings and appeals, the Superior Court affirmed the board's decision to deny Costa's application.The Supreme Judicial Court of Massachusetts affirmed the decision of the Superior Court. The court held that the board's interpretation of the phrase "refuses to cooperate" in the relevant regulation was reasonable. The court found that Mary's refusal to disclose her financial information did not constitute a refusal to cooperate within the meaning of the regulation, given the couple's long history of cooperation in other aspects of their marriage. The court also rejected Costa's argument that the board's decision was arbitrary and capricious. View "Freiner v. Secretary of the Executive Office of Health and Human Services" on Justia Law

Felissa Jones, the mother of an elementary school student, reported to the Mississippi Department of Child Protection Services (MDCPS) that her son had suffered abuse and neglect by staff at his school. MDCPS responded that it does not investigate reports of abuse at school. Jones then sued MDCPS, seeking declaratory and injunctive relief related to MDCPS’s policy that the agency does not investigate allegations of abuse in out-of-home settings such as schools.The Hinds County Chancery Court denied Jones's motion for a judgment in her favor on the pleadings and granted MDCPS's motion for a judgment on the pleadings, dismissing Jones's complaint. The court ruled that Jones's request for declaratory relief related to MDCPS’s former intake policy was moot because the policy was no longer in effect. It also ruled that the current intake policy does not violate the relevant statutes, but instead conforms to the statutory mandate to refer allegations of child abuse in out-of-home settings to local law enforcement.In the Supreme Court of Mississippi, Jones appealed the lower court's decisions. The court affirmed the lower court's rulings, stating that MDCPS does not have a duty to investigate reports of abuse in out-of-home settings, such as schools, because children who are mistreated by school staff do not fall under the youth court’s limited jurisdiction. The court also found that Jones's claim for declaratory relief from the amended policy had no merit because the policy tracks the relevant statutes. View "Jones v. Department of Child Protection Services" on Justia Law