Justia Government & Administrative Law Opinion Summaries

Chris Kelly was pulled over in August 2020 for minor traffic infractions, leading to the suspension of his driver's license. Despite efforts by a prosecutor to correct the record, Kelly was pulled over again in January 2021 for driving on a suspended license. He continued to face issues with his suspended license, which he claimed caused him to lose a job opportunity and incur over $1,000 in expenses. Kelly alleged that despite acknowledging the error, the Bureau of Motor Vehicles (BMV) failed to correct his driving record.Kelly sued the BMV in January 2023 for negligently failing to correct his driving record, seeking costs, damages, and interest. The BMV moved to dismiss the claim, arguing that the statutes did not create a private right of action. The Marion Superior Court granted the BMV's motion and dismissed the complaint without prejudice. The Indiana Court of Appeals reversed, finding that Kelly had sufficiently alleged a common-law negligence claim and that the relevant statute conferred a private right of action. The BMV petitioned for transfer to the Indiana Supreme Court.The Indiana Supreme Court reviewed the case and affirmed the trial court's dismissal. The court held that the Legislature did not intend to create a private right of action under the relevant statutes, as the material error review process and the Administrative Orders and Procedures Act (AOPA) provided independent enforcement mechanisms. Additionally, the court found that the BMV's duty to maintain driving records primarily served public safety rather than individual drivers. The court also concluded that Kelly failed to establish a common-law duty for the BMV to maintain accurate records. View "Kelly v. Indiana Bureau of Motor Vehicles" on Justia Law

Lisa Sánchez, a member of the Boise City Council, moved her residence outside of the district she represented. She was informed by the mayor and city council that she had automatically vacated her seat due to this move. The mayor subsequently appointed a new council member to fill her seat. Sánchez sued the City of Boise, claiming improper removal and seeking reinstatement, along with damages for lost salary and benefits. The City moved for judgment on the pleadings, which the district court granted, dismissing her case with prejudice. Sánchez appealed, questioning whether a city council member automatically vacates their seat under Idaho Code section 59-901(1)(e) when they unintentionally move out of their district.The district court concluded that Idaho Code section 59-901(1)(e) applies to city council members and that Sánchez's intent to remain a resident of her district was irrelevant. The court held that the statute's plain language indicated an automatic vacancy upon moving out of the district, regardless of intent. The court also found that Sánchez received all due process required under the statute.The Supreme Court of Idaho affirmed the district court's decision. The court held that Idaho Code section 59-901(1)(e) applies to city council members and that the statute's plain language does not require an inquiry into the official's intent. The court also concluded that no additional due process was required because any potential property interest in Sánchez’s elected position was forfeited when she moved out of her district. Thus, the district court's judgment on the pleadings in favor of the City was affirmed. View "Sanchez v. City of Boise" on Justia Law

The Environmental Protection Agency (EPA) approved California regulations under the Clean Air Act that require automakers to produce more electric vehicles and fewer gasoline-powered vehicles to reduce emissions. Several fuel producers, including those of gasoline and ethanol, sued the EPA, arguing that the EPA lacked the authority to approve these regulations as they target global climate change rather than local air quality issues. The fuel producers claimed that the regulations would significantly reduce the demand for liquid fuels, causing them monetary injury.The United States Court of Appeals for the District of Columbia Circuit reviewed the case and held that the fuel producers lacked Article III standing. The court found that the fuel producers failed to demonstrate that automakers would likely respond to the invalidation of the regulations by producing fewer electric vehicles and more gasoline-powered vehicles, thus failing to establish redressability.The Supreme Court of the United States reviewed the case and held that the fuel producers have Article III standing to challenge the EPA’s approval of the California regulations. The Court found that the fuel producers demonstrated injury in fact, causation, and redressability. The Court reasoned that the regulations likely cause monetary injury to the fuel producers by reducing the demand for gasoline and other liquid fuels. The Court also found that invalidating the regulations would likely redress the injury by increasing the sales of gasoline-powered vehicles and, consequently, the demand for liquid fuels. The judgment of the Court of Appeals was reversed and the case was remanded for further proceedings. View "Diamond Alternative Energy, LLC v. Environmental Protection Agency" on Justia Law

A public benefit corporation, Lawyers for Fair Reciprocal Admissions (LFRA), challenged local rules of federal district courts in the Ninth Circuit. These rules require attorneys seeking general admission to be members in good standing of the bar of the state where the district court is located. LFRA argued that these rules prevent its members, who are barred in states outside the Ninth Circuit and do not wish to join another state bar, from seeking general admission to these federal district courts.The United States District Court for the District of Arizona dismissed LFRA’s amended complaint with prejudice. The court found that LFRA had standing to bring claims on behalf of its members, except for the Sixth Amendment claim, which lacked standing. The court dismissed the remaining claims for failure to state a claim, concluding that the Admission Rules did not violate constitutional, statutory, or procedural grounds as alleged by LFRA.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court’s dismissal with prejudice. The Ninth Circuit held that the Admission Rules are constitutional and do not violate separation of powers, federalism principles, the Privileges and Immunities Clauses, the Equal Protection Clause, the First Amendment, the Full Faith and Credit Act, the Rules Enabling Act, or procedural due process. The court also found that Rules 1 and 83 of the Federal Rules of Civil Procedure do not create a private right of action. The Ninth Circuit concluded that the district court did not abuse its discretion in dismissing the amended complaint without leave to amend, as the complaint could not be saved by amendment. The court also upheld the denial of LFRA’s motion for judgment on the pleadings as procedurally premature. View "Lawyers for Fair Reciprocal Admissions v. United States" on Justia Law

Delanor L. Macksyn, an inmate at the Richland Correctional Institution, filed an original action against Department of Rehabilitation and Correction employees Kenneth Spencer, LeAnn Walker-Williams, and Kelly Rose. Macksyn sought a writ of mandamus to compel the production of records in response to multiple public-records requests and an award of statutory damages. His requests included emails, kites, grievances, and video footage.The lower court proceedings involved Spencer assuming responsibility for answering public-records requests and responding to Macksyn’s various requests. Spencer provided some of the requested records, including kites and grievances, and allowed Macksyn to view the requested video footage. However, there was a dispute over whether all requested records, particularly emails, had been produced.The Supreme Court of Ohio reviewed the case and found that while Spencer had provided some records, there was insufficient evidence to confirm that all requested emails had been produced. The court issued a limited writ of mandamus ordering the respondents to, within 21 days, either produce the requested emails and certify the date of production or certify that no responsive emails exist. The court deferred ruling on Macksyn’s request for statutory damages until the respondents complied with the limited writ. The court also denied several motions filed by Macksyn, including motions to strike respondents’ brief and for judicial notice. View "State ex rel. Macksyn v. Spencer" on Justia Law

The case involves Pavan V. Parikh, the Hamilton County clerk of courts, who implemented a policy in May 2022 that eliminated remote online access to court records in residential-eviction cases older than three years from the date of judgment satisfaction. Parikh argued that this policy was to prevent misuse of court documents by the public, such as employers and landlords. The judges of the Hamilton County Municipal Court objected to this policy and issued Administrative Order No. 23-45 in October 2023, directing Parikh to rescind the policy and restore online access to the records. Parikh did not comply, leading to the judges threatening contempt proceedings.Parikh filed a complaint for a writ of prohibition in the First District Court of Appeals to prevent the judges from enforcing the administrative order and holding him in contempt. The judges counterclaimed, requesting a writ of mandamus to compel Parikh to comply with their order. The court of appeals, with visiting judges from the Twelfth District, ruled in favor of the judges, granting their motion for judgment on the pleadings on the prohibition claim and issuing a writ of mandamus ordering Parikh to rescind his policy and comply with the administrative order.The Supreme Court of Ohio reviewed the case and affirmed the court of appeals' judgment. The court held that Parikh had a clear legal duty under R.C. 1901.31(E) to comply with the judges' administrative order. The court also determined that Parikh had an adequate remedy through appeal if held in contempt, and the judges did not patently and unambiguously lack jurisdiction to hold him in contempt for noncompliance. Therefore, the court affirmed the denial of Parikh's request for a writ of prohibition and the granting of the judges' request for a writ of mandamus. View "State ex rel. Parikh v. Berkowitz" on Justia Law

Ronald Ayers, an inmate at the Lake Erie Correctional Institution, petitioned for a writ of mandamus to compel Laura Sackett, the prison's records custodian, to produce public records. Ayers requested a copy of the Department of Administrative Services’ general retention schedule and video footage from a security search of his cell on August 31, 2023. Sackett denied the requests, claiming the retention schedule was not specific to the Department of Rehabilitation and Correction and that the video footage was not preserved as it did not document a "qualifying event."The Supreme Court of Ohio reviewed the case after Ayers filed his petition. The court found that Ayers did not need to exhaust administrative remedies before filing for mandamus. The court determined that the requested video footage did not exist at the time of Ayers' request, as it had been recorded over, and thus Sackett correctly denied this request. However, the court found that the general retention schedule was a public record received and used by the prison, and Sackett's denial of this request was not justified.The Supreme Court of Ohio granted Ayers' writ of mandamus in part, ordering Sackett to produce the retention schedule. The court awarded Ayers $1,000 in statutory damages for the improper denial of the retention schedule but denied his request for court costs due to his affidavit of indigency. The court denied Ayers' motions for discovery as moot. View "State ex rel. Ayers v. Sackett" on Justia Law

A group of staffing companies in Texas challenged a memorandum issued by the former General Counsel of the National Labor Relations Board (NLRB), Jennifer Abruzzo. The memorandum outlined a plan to urge the NLRB to reverse its holding in a previous case, Babcock, which allowed employers to compel employees to attend meetings where they were urged to reject union representation. The staffing companies argued that the memorandum violated their First Amendment rights by restricting their speech about unionization and sought an injunction and declaratory judgment against its enforcement.The United States District Court for the Eastern District of Texas dismissed the case for lack of jurisdiction, stating that the plaintiffs were challenging unreviewable prosecutorial decisions by the NLRB General Counsel, that the NLRA's scheme precluded jurisdiction, and that the plaintiffs lacked standing. The staffing companies appealed, arguing that the district court erred in its dismissal and that they had standing because the memorandum applied to them and was a final agency action reviewable under the Administrative Procedure Act (APA).The United States Court of Appeals for the Fifth Circuit reviewed the case and found that the staffing companies lacked standing. The court noted that the plaintiffs had not provided evidence of a credible threat of enforcement of the memorandum causing them direct injury. The court also found that the plaintiffs did not demonstrate an intent to engage in conduct regulated by the memorandum, as there was no known unionization attempt at their businesses. The court concluded that the plaintiffs failed to establish a credible threat of enforcement or a substantial risk of future injury.The Fifth Circuit affirmed the district court's dismissal of the case for lack of standing. View "Burnett Specialists v. Cowen" on Justia Law

A group called Idahoans United for Women and Families filed a petition seeking writs of certiorari and mandamus against the Idaho Division of Financial Management (DFM), the Idaho Attorney General, and the Idaho Secretary of State. The petition concerns the fiscal impact statement (FIS) and ballot titles for a citizen initiative titled the “Reproductive Freedom and Privacy Act.” Idahoans United argued that the FIS and ballot titles did not comply with Idaho law and requested the court to either certify their proposed versions or order the respondents to prepare new compliant versions.The Idaho Supreme Court reviewed the case. The court dismissed the petition against the Secretary of State, finding that Idahoans United failed to properly invoke the court's original jurisdiction against him. However, the court partially granted the writ of mandamus against DFM, concluding that the FIS did not substantially comply with Idaho Code section 34-1812 due to a lack of a reasonable basis for its estimated fiscal impacts, unclear and conflicting statements, and unnecessary legal terms. The court also partially granted the writ of mandamus against the Attorney General, finding that the short ballot title did not substantially comply with Idaho Code section 34-1809 because it failed to capture all distinctive features of the initiative. However, the court found that the long ballot title substantially complied with the statutory requirements.The Idaho Supreme Court retained jurisdiction and ordered DFM to provide a new FIS and the Attorney General to provide a new short ballot title by June 23, 2025. The court denied the request for attorney fees, noting that both parties prevailed in part. View "Idahoans United for Women and Families v. Labrador" on Justia Law

Verizon Wireless sought permits from the City of Milwaukee to install small cells and matching utility poles in a downtown plaza next to a major arena. The City denied most of the permits, initially citing aesthetic concerns and proximity to existing poles. Later, it claimed it lacked authority to grant the permits because the plaza was leased to Deer District LLC. Verizon sued the City, arguing the denials violated the Telecommunications Act (TCA) and Wisconsin state law. The district court ruled in favor of Verizon, finding the City's justifications insufficient and ordered the City to issue the permits. Verizon installed the poles, and the City accepted the ruling.The district court found that the City's initial reasons for denial were not supported by substantial evidence and violated the TCA. It also found the City's later rationale, based on the lease with Deer District, untimely and unconvincing. The court held that the City violated Wisconsin state law as well, and ordered the City to issue the permits. The City complied and did not appeal the decision. Deer District, an intervening defendant, appealed, challenging the district court's interpretation of the lease and state law, but not the TCA holding.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court dismissed Deer District's appeal for lack of Article III standing, as Deer District could not demonstrate that its injury would be redressed by a favorable decision. The court noted that the City did not join the appeal and that the injunction ran exclusively against the City. Therefore, even if the court ruled in Deer District's favor, it would not change the City's obligations under the district court's order. The appeal was dismissed for want of jurisdiction. View "Cellco Partnership v Deer District LLC" on Justia Law