Justia Government & Administrative Law Opinion Summaries

In 1991, the predecessor to the plaintiffs conveyed land to the United States in a land exchange but retained certain water rights that could only be accessed through the conveyed property, now managed by the U.S. Forest Service. The conveyance documents did not mention these water rights or provide any right of access. Over the years, the plaintiffs and their predecessors sought permits from the Forest Service to access and develop the water rights, but the agency repeatedly expressed concerns about environmental impacts and indicated it had the authority to deny access. In 2010, the Forest Service formally opposed the plaintiffs’ efforts to maintain the water rights in state court, asserting it would not grant the necessary land use authorization.The United States District Court for the District of Colorado dismissed the plaintiffs’ claims under the Quiet Title Act (QTA) and the Declaratory Judgment Act (DJA). The court found the QTA claim time-barred by the statute’s twelve-year limitations period, reasoning that the plaintiffs or their predecessors were on notice of the government’s adverse claim well before the suit was filed in 2022. The court also dismissed the DJA claim, holding it was essentially a quiet title claim subject to the same limitations period.The United States Court of Appeals for the Tenth Circuit affirmed the district court’s dismissal. The Tenth Circuit held that the QTA claim was untimely because, by 2006 at the latest, the Forest Service had asserted exclusive control sufficient to put the plaintiffs on notice of its adverse claim, causing the limitations period to expire before the suit was filed. The court also held that it lacked jurisdiction over two of the plaintiffs’ requests for declaratory relief and that the third, alleging a taking, was not ripe because the plaintiffs had not first sought compensation under the Tucker Act. View "Purgatory Recreation I v. United States" on Justia Law

A flight attendant employed by an airline and represented by a labor union was terminated after sending graphic anti-abortion images and messages to the union president and posting similar content on social media. The employee, a pro-life Christian and vocal opponent of the union, had previously resigned her union membership but remained subject to union fees. The union’s leadership had participated in the Women’s March, which the employee viewed as union-sponsored support for abortion, prompting her messages. The airline investigated and concluded that while some content was offensive, only certain images violated company policy. The employee was terminated for violating social media, bullying, and harassment policies.Following termination, the employee filed a grievance, which the union represented. The airline offered reinstatement contingent on a last-chance agreement, which the employee declined, leading to arbitration. The arbitrator found just cause for termination. The employee then sued both the airline and the union in the United States District Court for the Northern District of Texas, alleging violations of Title VII and the Railway Labor Act (RLA), among other claims. The district court dismissed some claims, allowed others to proceed, and after a jury trial, found in favor of the employee on several Title VII and RLA claims. The court awarded reinstatement, backpay, and issued a broad permanent injunction against the airline and union, later holding the airline in contempt for its compliance with the judgment.On appeal, the United States Court of Appeals for the Fifth Circuit reversed the judgment for the employee on her belief-based Title VII and RLA retaliation claims against the airline, remanding with instructions to enter judgment for the airline on those claims. The court affirmed the judgment against the airline on practice-based Title VII claims and affirmed all claims against the union. The court vacated the permanent injunction and contempt sanction, remanding for further proceedings, and granted the employee’s motion to remand appellate attorney’s fees to the district court. View "Carter v. Transport Workers Union of America Local 556" on Justia Law

Nathan Gault was a party to a divorce action in the Medina County Court of Common Pleas. After the case concluded, the clerk charged him various fees, including a “Clerk Computer Operation” fee. Gault believed he had been overcharged, specifically challenging the additional dollar per page fee assessed for making a complete record of the proceedings. He filed a class-action complaint against the clerk, the county treasurer, and the county itself, alleging that the clerk charged him $125 in computer-operation fees, which was over $100 more than statutorily authorized.The Medina County Court of Common Pleas initially granted judgment on the pleadings for the defendants, finding Gault’s claim barred by res judicata. The Ninth District Court of Appeals reversed, holding that res judicata did not apply because the total amount owed and the methodology for determining the fees were not ascertainable from the final judgment in the divorce action, and the defendants were not parties to the prior proceedings. On remand, the trial court again ruled for the defendants, interpreting the statutes to permit the clerk to charge two dollars per page—one dollar under R.C. 2303.20(H) and an additional dollar under former R.C. 2303.201(B)(1). The Ninth District reversed, concluding that only one additional dollar total could be charged for the service, not one dollar per page.The Supreme Court of Ohio reviewed the case, consolidating a discretionary appeal and a certified conflict. The court held that, under the plain text of former R.C. 2303.201(B)(1), the clerk may charge only one additional dollar total for making a complete record under R.C. 2303.20(H), regardless of the number of pages. The Supreme Court of Ohio affirmed the judgment of the Ninth District Court of Appeals. View "State ex rel. Gault v. Medina Cty. Court of Common Pleas Clerk" on Justia Law

The case involved two related companies and three individuals who operated a business targeting immigrants detained by U.S. Immigration and Customs Enforcement (ICE) and eligible for release on immigration bonds. The companies marketed their services as an affordable way to secure release, but in reality, they charged high fees for services that were often misrepresented or not provided. The agreements were complex, mostly in English, and required significant upfront and recurring payments. Most consumers did not understand the terms and relied on the companies’ oral representations, which were deceptive. The business was not licensed as a bail bond agent or surety, and the defendants’ practices violated federal and state consumer protection laws.After the plaintiffs—the Consumer Financial Protection Bureau, Massachusetts, New York, and Virginia—filed suit in the United States District Court for the Western District of Virginia, the defendants repeatedly failed to comply with discovery obligations and court orders. They did not produce required documents, ignored deadlines, and failed to appear at hearings. The district court, after multiple warnings and opportunities to comply, imposed default judgment as a sanction for this misconduct. The court also excluded the defendants’ late-disclosed witnesses and exhibits from the remedies hearing, finding the nondisclosures unjustified and prejudicial.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court’s decisions. The Fourth Circuit held that the default judgment was an appropriate sanction for the defendants’ repeated and willful noncompliance. The exclusion of evidence and witnesses was also upheld, as was the issuance of a permanent injunction and the calculation of monetary relief, including restitution and civil penalties totaling approximately $366.5 million. The court found no abuse of discretion or legal error in the district court’s rulings and affirmed the final judgment in all respects. View "Consumer Financial Protection Bureau v. Nexus Services, Inc." on Justia Law

A group of Black farmers and their association, along with several individual members, sought to file claims with the U.S. Department of Agriculture (USDA) for financial assistance under a program created by the Inflation Reduction Act of 2022. They wished to submit applications on behalf of deceased relatives who had allegedly experienced discrimination in USDA farm lending programs. The USDA, however, had a policy that excluded applications reporting only discrimination against individuals who were deceased at the time of application, making such claims ineligible for the program.The plaintiffs filed suit in the United States District Court for the Western District of Tennessee, seeking an injunction to require the USDA to accept these “legacy claims.” The district court denied their motion for a preliminary injunction and granted the government’s motion to dismiss under Rule 12(b)(6), holding that the relevant statute only authorized financial assistance to living farmers. The plaintiffs appealed this decision to the United States Court of Appeals for the Sixth Circuit and also sought an emergency injunction pending appeal, which was denied.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s dismissal de novo. The appellate court held that the statutory language of § 22007(e) of the Inflation Reduction Act required the USDA to provide “assistance” to farmers who experienced discrimination, and that “assistance” was forward-looking and could not be provided to deceased individuals. The court found that the statute did not authorize compensation for past harm to deceased farmers, distinguishing “assistance” from “compensation.” The court affirmed the district court’s judgment and denied the motion for an injunction pending appeal as moot, holding that the USDA was required to reject applications filed on behalf of deceased farmers. View "Black Farmers & Agriculturalists Ass'n v. Rollins" on Justia Law

Christopher Toland was sentenced in 1993 to a lengthy prison term for rape, kidnapping, and related offenses, making him eligible for parole in 2004. Between 2004 and 2020, the Pennsylvania Parole Board denied him parole fourteen times, often contrary to recommendations from the Department of Corrections. Toland filed a petition for review in the Commonwealth Court of Pennsylvania, seeking mandamus relief and alleging constitutional violations in the Board’s parole denials from 2017, 2018, and 2019. He claimed the Board relied on false information, acted arbitrarily, and applied parole standards retroactively in violation of ex post facto prohibitions.The Commonwealth Court overruled the Parole Board’s preliminary objections to Toland’s claims, allowing discovery to proceed. When Toland requested documents related to his parole eligibility, the Parole Board objected, citing its own regulation (37 Pa. Code § 61.2) that designates its records as “private, confidential and privileged.” The Commonwealth Court rejected the Board’s objections, finding that Toland, as the beneficiary of the privilege, could waive it. The Board then filed an interlocutory appeal.The Supreme Court of Pennsylvania reviewed the case and affirmed the Commonwealth Court’s order, but on a different basis. The Supreme Court held that the Parole Board does not have the authority to create an evidentiary privilege through its own regulation. Therefore, Section 61.2 does not establish a privilege that can be invoked to prevent disclosure of documents in discovery. The Court clarified that only privileges created by the legislature, the constitution, or the common law are recognized in Pennsylvania courts, and no such privilege exists under Section 61.2. The Supreme Court’s disposition was to affirm the lower court’s order. View "Toland v. PBPP" on Justia Law

Mark Howerton was convicted in 2010 of computer child pornography and three counts of internet stalking of a child, based on offenses committed in 2009. He received a total prison sentence of 24 years, with some sentences suspended. Howerton was paroled in 2017 but returned to prison in 2020 for a parole violation. He was denied parole in 2022 for two years and again in 2024 for another two years. Howerton filed a petition for declaratory judgment and writ of mandamus, alleging that the chairperson of the Arkansas Post-Prison Transfer Board, Lona McCastlain, acted without legal authority in denying his parole, arguing that the denial was based on statutes applied ex post facto and an unauthorized “detriment to the community” rationale.The Pulaski County Circuit Court, Sixth Division, granted McCastlain’s motion to dismiss Howerton’s petition. The court found that Howerton failed to state sufficient facts to support his claims, noting that Arkansas parole statutes and regulations do not create a protectable liberty interest in discretionary parole decisions, and that parole eligibility is determined by the law in effect at the time the crime was committed. The court also found that Howerton did not demonstrate that the incorrect statute was applied or that the Board’s regulations were violated.On appeal, the Supreme Court of Arkansas reviewed the dismissal for abuse of discretion and for the existence of a justiciable controversy. The court held that Howerton failed to present sufficient facts to establish that McCastlain acted outside her authority or violated applicable statutes or regulations. The court affirmed the circuit court’s dismissal, concluding that Howerton’s allegations were insufficient to warrant declaratory or mandamus relief. View "HOWERTON v. MCCASTLAIN" on Justia Law

The dispute centers on the extension of a grading and grubbing permit issued by the Director of the Department of Public Works, County of Maui, to Maui Lani Partners for excavation work at a residential development site containing ancestral Hawaiian burial sites. In March 2018, an unincorporated association and its members challenged the validity of the permit extension, alleging violations of state and county laws requiring consultation with the State Historic Preservation Division and arguing that the Director exceeded his authority in granting the extension without good cause.The Circuit Court of the Second Circuit granted motions to dismiss the complaint on all counts without prejudice, finding no regulatory or statutory authority requiring consultation with the State Historic Preservation Division for permit extensions and that the Director acted within his discretionary authority. The court denied the plaintiffs’ motion for summary judgment and later denied their HRCP Rule 60(b)(6) motion for reconsideration, concluding that the plaintiffs had not presented new law or argument. The plaintiffs appealed to the Intermediate Court of Appeals (ICA), which affirmed the circuit court’s denial of costs and the motion for reconsideration but held that the notice of appeal was untimely because the Rule 60(b) motion was not filed within ten days of judgment and thus did not toll the appeal deadline.The Supreme Court of Hawaiʻi reviewed the case and held that a motion for reconsideration filed under HRCP Rule 60(b) is a “tolling motion” under HRAP Rule 4(a)(3) if filed within a reasonable time and before the appeal deadline, thereby extending the time to file a notice of appeal. The court also held that the ICA did not err in affirming the circuit court’s denial of the Rule 60(b)(6) motion for reconsideration. The Supreme Court vacated the ICA’s judgment in part and remanded for further proceedings. View "Kakanilua v. Director of the Department of Public Works" on Justia Law

A nonprofit organization sought access to confidential court records from child protective and adoption proceedings involving a young girl who died after being placed in foster care and later adopted. The girl was reported missing in 2021, and her death was confirmed in 2023. The records also contained information about her siblings. The siblings, through their counsel, did not object to disclosure as long as their identities were protected through redactions. The Department of Human Services and the adoptive father opposed disclosure, arguing that the records were confidential and that redactions would not sufficiently protect privacy.The Family Court of the First Circuit denied the request, reasoning that releasing redacted records would be misleading and would not serve the public interest in understanding the response of agencies and the court to child abuse and neglect. The court concluded that the records should remain sealed, citing concerns about the completeness and potential for misunderstanding of the redacted information.The Supreme Court of the State of Hawaiʻi reviewed the case and held that, under Hawaiʻi Revised Statutes §§ 587A-40 and 578-15, public access to confidential child protective and adoption records is permitted when a foster child is missing, has suffered a near fatality, been critically injured, or has died, provided that information about living siblings is redacted to protect their privacy. The court overruled prior precedent to the extent it limited disclosure to only those purposes that further the best interests of the child, clarifying that a “legitimate purpose” for disclosure can exist independently. The court ordered the release of the redacted records and provided guidance for future requests, affirming the family court’s authority to require agencies to prepare redacted versions for public access. View "Public First Law Center v. Viola" on Justia Law

A woman who immigrated from China to the United States and later became a U.S. citizen founded an educational institution that participated in a Department of Defense tuition program. In 2010, the FBI began investigating her for statements made on immigration forms, conducting interviews, searches, and seizing personal and business materials. Although the U.S. Attorney’s Office ultimately declined to file charges, Fox News later published reports about her, including confidential materials from the FBI investigation. These reports cited anonymous sources and included documents and photographs seized during the FBI’s search. Following the reports, the Department of Defense terminated her institution’s participation in the tuition program, resulting in significant financial losses.She filed a lawsuit in the United States District Court for the District of Columbia against the FBI and other federal agencies, alleging violations of the Privacy Act due to the unauthorized disclosure of her records. During discovery, she was unable to identify the source of the leak despite extensive efforts. She then subpoenaed a Fox News journalist, who authored the reports, to reveal her confidential source. The journalist invoked a qualified First Amendment reporter’s privilege. The district court found that the plaintiff had met the requirements to overcome this privilege—demonstrating both the centrality of the information to her case and exhaustion of alternative sources—and ordered the journalist to testify. When the journalist refused, the court held her in civil contempt.On appeal, the United States Court of Appeals for the District of Columbia Circuit affirmed the district court’s orders. The appellate court held that, under its precedents, a qualified First Amendment reporter’s privilege may be overcome in civil cases if the information sought is crucial to the case and all reasonable alternative sources have been exhausted. The court also declined to recognize a broader federal common law reporter’s privilege. View "Chen v. FBI" on Justia Law