Justia Government & Administrative Law Opinion Summaries

The case revolves around Alphonso Mobley Jr., who filed a writ of mandamus against Ohio Secretary of State Frank LaRose, seeking a certified copy of a document in response to a public-records request. Mobley also sought statutory damages and court costs under R.C. 149.43(C). The document in question was the "Certified Bond of Director of Ohio Department of Rehabilitations and Corrections for year 2021-2022." Mobley had initially received an uncertified copy of the bond, and upon his second request, he enclosed a check for $5 for a certified copy. However, he alleged that the secretary had not responded to his request for a certified copy, leading him to file this action.The secretary's office sent Mobley a certified copy of the bond six business days after he filed the action. The secretary denied liability under the Ohio Public Records Act, R.C. 149.43 et seq., and stated that he had provided the requested record. The Supreme Court of Ohio granted an alternative writ and set a schedule for the parties’ submission of evidence and merit briefs.The Supreme Court of Ohio ruled that the mandamus claim was moot as the secretary had provided Mobley with a certified copy of the record he had requested. Mobley argued that the record was incomplete, but the court found no merit in his argument. The court also denied Mobley's request for statutory damages, stating that the failure to provide a certified copy within a reasonable time is not a failure to comply with an obligation under R.C. 149.43(B). The court also denied Mobley's claim for court costs, as he had filed an affidavit of indigency and therefore had no obligation to pay costs. View "State ex rel. Mobley v. LaRose" on Justia Law

Emilio Puente, a police officer for the City of Iowa City, resigned from his position and later attempted to rescind his resignation. When the City rejected his attempt, Puente filed an action with the Civil Service Commission of Iowa City (Commission) for review of the City’s refusal to reinstate him. The Commission dismissed Puente's complaint, agreeing with the City that it was untimely. Puente then filed a petition for judicial review in the Johnson County District Court, which was dismissed for lack of jurisdiction. The court concluded that Puente’s “petition for judicial review” was not a “notice of appeal” as required by Iowa Code § 400.27.The Iowa Court of Appeals affirmed the district court's decision. The court of appeals relied on the differences between a chapter 17A proceeding and an appeal under section 400.27 to conclude that the petition for judicial review could not be deemed a notice of appeal. The court of appeals noted that the two are initiated differently, have different venue provisions and service requirements, and have different standards and scopes of review.The Supreme Court of Iowa reversed the lower courts' decisions. The Supreme Court found that Puente had substantially complied with the requirements for filing a notice of appeal from the Commission’s decision to the district court. The court noted that Puente's petition sought "judicial review" of the Commission’s decision, identifying the Commission as a “respondent” rather than a “defendant.” The court concluded that Puente's reference to the wrong Code provision for venue did not mean he failed to substantially comply with the correct Code provision. The court vacated the decision of the court of appeals, reversed the district court judgment dismissing Puente’s appeal from the Commission’s decision, and remanded for further proceedings. View "Puente v. Civil Service Commission of Iowa City" on Justia Law

The case revolves around Stuart Harrow, a Department of Defense employee who was furloughed for six days. Harrow challenged this decision before the Merit Systems Protection Board. After a five-year delay, the Board ruled against him. Harrow had the right to appeal this decision to the Court of Appeals for the Federal Circuit within 60 days of the Board's final order. However, Harrow did not learn about the Board's decision until after the 60-day period had elapsed, and he filed his appeal late. Harrow requested the Federal Circuit to overlook his untimeliness and equitably toll the filing deadline. The Federal Circuit, however, denied his request, believing that the deadline was an unalterable "jurisdictional requirement."The Supreme Court of the United States reviewed the case. The main issue was whether the 60-day filing deadline under Section 7703(b)(1) was jurisdictional, meaning it marked the bounds of a court's power and could not be waived or subject to exceptions. The Supreme Court held that the 60-day filing deadline was not jurisdictional. The Court reasoned that procedural rules, even when phrased in mandatory terms, are generally subject to exceptions like waiver, forfeiture, and equitable tolling. The Court found no language in Section 7703(b)(1) that suggested it was a jurisdictional requirement. The Court also rejected the Government's argument that the term "pursuant to" in a different statute, 28 U.S.C. §1295(a)(9), made the deadline jurisdictional.The Supreme Court vacated the judgment of the Federal Circuit and remanded the case for further proceedings consistent with its opinion. The Federal Circuit was directed to determine whether equitable tolling was available and, if so, whether Harrow was entitled to that relief given the facts of the case. View "Harrow v. Department of Defense" on Justia Law

The case involves a dispute over a proposed project to significantly alter the California State Capitol complex. The plaintiff, Save the Capitol, Save the Trees (Save the Capitol), appealed against an order discharging a peremptory writ of mandate issued by the trial court. The writ was issued following a previous court decision that found an environmental impact report (EIR) for the project, prepared by the defendant Department of General Services and the Joint Committee on Rules of the California State Senate and Assembly (collectively DGS), failed to comply with the California Environmental Quality Act (CEQA). The writ directed DGS to vacate in part its certification of the EIR and all associated project approvals, and to file a final return to the writ “upon certification of a revised EIR.”The trial court had previously denied two petitions for writ of mandate, one sought by Save the Capitol and the other by an organization named Save Our Capitol!. The Court of Appeal reversed in part and affirmed in part the trial court’s denial. On remand, the trial court issued a peremptory writ of mandate directing DGS to vacate in part its certification of the EIR and all associated project approvals. After DGS partially vacated its certification of the EIR and all associated project approvals, it revised, recirculated, and certified the revised final EIR. DGS then partially reapproved the project without one of the project components, the visitor center. DGS thereafter filed its final return and the trial court discharged the writ, over plaintiff’s objection, without determining whether the revised final EIR remedied the CEQA violations the Court of Appeal had identified in its opinion.In the Court of Appeal of the State of California Third Appellate District, Save the Capitol argued that the discharge of the writ was premature because the writ not only required DGS to revise and recirculate the defective portions of the EIR, but also to certify a revised EIR consistent with the previous court decision before the writ could be discharged. The court agreed with Save the Capitol, concluding that the trial court must determine that the revised EIR is consistent with the previous court decision before discharging the writ. The court reversed the judgment and remanded the case for further proceedings. View "Save the Capitol, Save the Trees v. Dept. of General Services" on Justia Law

The case revolves around Jay Anthony Dobyns, a former agent with the United States Bureau of Alcohol, Tobacco, Firearms, and Explosives (ATF), who sued the United States for failing to adequately protect him and his family from threats related to his undercover work. The government counterclaimed, alleging that Dobyns violated his employment contract and several federal regulations by publishing a book based on his experience as an agent and by contracting his story to create a motion picture. The Court of Federal Claims found that the government had not breached the settlement agreement but had breached the covenant of good faith and fair dealing, awarding Dobyns emotional distress damages. The court also found that the government was not entitled to relief on its counterclaim.The government appealed the Claims Court’s judgment to the United States Court of Appeals for the Federal Circuit, which reversed the finding that the government breached the implied duty of good faith and fair dealing. Dobyns, having prevailed on the government’s counterclaim, sought attorneys’ fees and costs. However, the Claims Court denied his application for attorneys’ fees under the Equal Access to Justice Act (EAJA) as untimely. Dobyns appealed this decision.The United States Court of Appeals for the Federal Circuit found that the Claims Court had abused its discretion and applied the incorrect legal standard. The Appeals Court held that the filing deadline for fee applications under EAJA is subject to equitable tolling. It found that Dobyns had justifiably relied on the government's representations about the procedure for Claims Court judgments, and thus his motion for attorneys’ fees under EAJA should be accepted as timely. The court reversed the Claims Court's decision and remanded the case for further proceedings. View "Dobyns v. United States" on Justia Law

The case revolves around the dispute over whether the main roads within the Deerfield Estates subdivision in Newton County, Mississippi, are private or public. In 2001, the Newton County Board of Supervisors voted to accept the two main roads of the subdivision into the county road system. However, the roads were never added to the official county road registry. In 2020, the subdivision filed a complaint seeking a declaratory judgment that the roads are public and an injunction mandating the county to add them to the registry and perform repairs.The Newton County Chancery Court held that the roads had become public roads via express common law dedication and ordered that the roads be added to the county map and road register. The county appealed this decision, arguing that the subdivision's claims were barred by the doctrine of laches or the general three-year statute of limitations.The Supreme Court of Mississippi affirmed the lower court's decision. It held that the county's 2001 acceptance of the roads was effective and that the roads served public interest or convenience. The court also found that the county's failure to add the roads to the registry and the map in a timely manner did not negate the county's explicit acceptance of the dedication. Furthermore, the court ruled that the county could not invoke the doctrine of laches or the general three-year statute of limitations to bar the subdivision's request for a declaratory judgment that the roads are public roads. View "Newton County, Mississippi v. Deerfield Estates Subdivision Property Owners Association, LLC" on Justia Law

The case involves a dispute between Missoula County and the Montana Department of Corrections (DOC) over the reimbursement rate for housing DOC inmates in county detention centers. The County and the DOC had entered into a contract in 2015, setting a reimbursement rate of $88.73 per day for each inmate. However, in 2015, the Montana Legislature capped the reimbursement rate at $69 per day. The County filed a lawsuit in 2020, alleging breach of contract, breach of the implied covenant of good faith and fair dealing, and unjust enrichment.The District Court granted summary judgment to the DOC, concluding that the County's contract claims were time-barred by a one-year statute of limitations. It also found that the County's tort claim for breach of the covenant of good faith was not supported by a special relationship and that the County could not recover under a theory of unjust enrichment.The Supreme Court of Montana affirmed the District Court's decision. It held that the one-year statute of limitations applied to the County's contract claims, rejecting the County's argument that an eight-year limitation period should apply. The court also agreed with the lower court that the County's tort claim for breach of the covenant of good faith was not supported by a special relationship. Finally, the court concluded that the County could not recover under a theory of unjust enrichment, as the County had not demonstrated that the DOC had reaped an inequitable gain. View "Missoula County v. Department of Corrections" on Justia Law

Dr. Jennifer Seed, a former employee of the Environmental Protection Agency (EPA), filed a lawsuit against the EPA and the United States, alleging age discrimination. Seed claimed that she was involuntarily demoted to a junior position as older managers were replaced with younger employees. The district court granted summary judgment in favor of the EPA, concluding that Seed had not provided sufficient evidence to support her claim of age discrimination.The district court's decision was based on its finding that Seed had not provided direct evidence of discriminatory intent that would entitle her to a trial, nor had she provided indirect evidence that would give rise to an inference of discrimination. The court also found that Seed had not shown that she was treated less favorably than younger employees after her reassignment or that her treatment was based on her age.On appeal, the United States Court of Appeals for the District of Columbia Circuit dismissed Seed's appeal, ruling that the court lacked jurisdiction to address the merits of her reassignment claims because she lacked standing under Article III of the United States Constitution. The court found that Seed had not demonstrated that a favorable court decision would likely redress her claimed injuries. The court therefore remanded the case to the district court with instructions to vacate the grant of summary judgment and to dismiss the reassignment claim for lack of standing. View "Seed v. EPA" on Justia Law

The City of Valdez in Alaska appealed two orders by the Regulatory Commission of Alaska (RCA) related to the transfer of the Trans-Alaska Pipeline System (TAPS) from BP Pipelines (Alaska) Inc. (BPPA) to Harvest Alaska, LLC. The first order (Order 6) approved confidential treatment of certain financial statements submitted by the oil company and its affiliates. The second order (Order 17) approved the transfer of a required certificate and the authority to operate the pipeline. The Superior Court dismissed Valdez’s appeals, concluding that Valdez lacked standing, failed to exhaust available administrative remedies, and the case was moot. The court also ordered Valdez to pay a portion of the attorney’s fees of the oil company and other companies involved in the proceedings.The Supreme Court of the State of Alaska reversed the dismissal of the appeal of Order 6, affirmed the dismissal of the appeal of Order 17, and vacated the award of attorney’s fees. The court found that Valdez had standing to appeal both orders, the appeals were not moot, and Valdez had exhausted administrative remedies with respect to Order 6 but not Order 17. The court remanded the case for further proceedings. View "City of Valdez v. Regulatory Commission of Alaska" on Justia Law

The case involves two plaintiffs, Michael Grim and Jim Maynard, who were employees of the Denton Municipal Electric (DME), a local electric utility owned by the City of Denton. The plaintiffs supported the construction of a controversial new power plant, the Denton Energy Center (DEC). Keely Briggs, a member of the Denton city council, opposed the new plant and leaked internal city documents about the project to a local newspaper. The plaintiffs reported Briggs's leak of confidential vendor information, alleging it violated the Public Information Act and the Open Meetings Act. They claimed that this report triggered the protections of the Whistleblower Act. The plaintiffs were later fired, which they alleged was retaliation for their report about Briggs.The case was initially heard in the district court, where the city argued that the Whistleblower Act did not apply because the plaintiffs did not report a violation of law "by the employing governmental entity or another public employee." The court was not convinced, and the case proceeded to a jury trial, which resulted in a $4 million judgment for the plaintiffs. The city appealed, raising several issues, including the legal question of whether the Whistleblower Act applied in this case. The court of appeals affirmed the district court's decision.The Supreme Court of Texas reversed the judgment of the court of appeals. The court held that the Whistleblower Act did not protect the plaintiffs because they reported a violation of law by a lone city council member, not by the employing governmental entity or another public employee. The court found that the lone city council member lacked any authority to act on behalf of the city, and her actions could not be imputed to the city. Therefore, her violation of law was not a "violation of law by the employing governmental entity." The court concluded that the plaintiffs did not allege a viable claim under the Whistleblower Act, and rendered judgment for the city. View "CITY OF DENTON v. GRIM" on Justia Law