Justia Government & Administrative Law Opinion Summaries

In this case, the plaintiff brought a defamation claim against Donald J. Trump, based on statements he made in June 2019 during his first term as President. The suit was initially filed in New York state court. In September 2020, the Department of Justice, acting under the Westfall Act, certified that Trump was acting within the scope of his employment and removed the case to federal court, seeking to substitute the United States as the defendant. The District Court for the Southern District of New York denied substitution, finding Trump was not acting within the scope of his employment. Trump appealed, and the United States Court of Appeals for the Second Circuit reversed in part, vacated in part, and certified a question to the D.C. Court of Appeals regarding the scope of employment under D.C. law. The D.C. Court of Appeals clarified the law but did not resolve whether Trump’s conduct was within the scope of employment. The Second Circuit remanded for the District Court to apply the clarified law.On remand, the Department of Justice declined to certify that Trump was acting within the scope of his employment, and neither Trump nor the government sought substitution before trial. The case proceeded to trial, and a jury found in favor of the plaintiff, awarding substantial damages. Trump appealed. After the appeal was fully briefed, and after Trump began his second term as President, Trump and the government jointly moved in the Second Circuit to substitute the United States as a party under the Westfall Act.The United States Court of Appeals for the Second Circuit denied the motion to substitute. The court held that the motion was statutorily barred by the Westfall Act because it was not made before trial, that both Trump and the government had waived any right to seek substitution by failing to timely petition the District Court, and that equitable considerations also warranted denial of the belated motion. View "Carroll v. Trump" on Justia Law

A four-year-old child drowned after wandering unattended from the home where she had been placed under temporary custody by order of the Probate Court. The child’s parents had previously lost guardianship, and the court had vested temporary custody in maternal relatives. To determine whether to grant a full transfer of guardianship, the Probate Court ordered the Department of Children and Families (DCF) to investigate the home and report its findings. DCF submitted its report, recommending the placement, but before the court could hold a hearing on permanent guardianship, the child died. The child’s estate, through her father as administrator, alleged that DCF’s negligence in investigating the placement and in making recommendations to the Probate Court was a proximate cause of the child’s death, and also claimed DCF failed to fulfill independent duties to protect the child from abuse and neglect.After the estate received permission from the Claims Commissioner to sue the state, DCF moved to dismiss the action in the Superior Court, arguing that it was entitled to absolute quasi-judicial immunity for actions integral to the judicial process, such as conducting court-ordered investigations and making recommendations. The Superior Court agreed, holding that DCF was protected by absolute quasi-judicial immunity when acting as an arm of the Probate Court, and that the Claims Commissioner could not waive this immunity. The court dismissed the action, finding the complaint’s allegations insufficient to overcome DCF’s immunity.On appeal, the Connecticut Supreme Court held that the Claims Commissioner’s waiver of sovereign immunity under the relevant statute does not preclude the state from asserting absolute quasi-judicial immunity. However, the Court reversed in part, concluding that some of the estate’s allegations may fall outside the scope of quasi-judicial immunity, particularly those involving DCF’s independent statutory duties. The case was remanded for further proceedings to determine which claims, if any, are not barred by quasi-judicial immunity. View "Jamie G. v. Dept. of Children & Families" on Justia Law

The appellant, a Slovenian-born U.S. permanent resident, claimed to have discovered billions of dollars dispersed across Africa after the death of Muammar Gaddafi. He sought to repatriate these funds to the United States and enlisted the help of a Washington, D.C. lawyer. The appellant alleged that, during his efforts in Kenya and Côte d'Ivoire, he was unable to complete the repatriation due to issues with verifying the legitimacy of Treasury Department letters. He further claimed that, while detained in Côte d'Ivoire, the funds were stolen and replaced with counterfeit cash, and that he was later arrested for alleged money laundering and misrepresentation of U.S. documents. Upon returning to the United States, the lawyer withdrew representation due to the criminal allegations against the appellant.The United States District Court for the District of Columbia dismissed the appellant’s fraud claims in two parts. First, it found that the complaint failed to allege any actionable misrepresentation by the lawyer, noting that the lawyer had provided legal services as agreed. Second, for the claims against three federal employees, the court allowed the United States to substitute itself as defendant under the Westfall Act, as the employees were acting within the scope of their employment. The court then dismissed the claim against the United States on the basis of sovereign immunity.The United States Court of Appeals for the District of Columbia Circuit affirmed the district court’s decision. It held that the appellant’s complaint did not allege with particularity any fraudulent misrepresentation by the lawyer at the time of contract formation. Regarding the federal employees, the court found that the appellant failed to rebut the government’s certification that the employees acted within the scope of their employment, and thus sovereign immunity barred the claim. The court also denied the appellant’s request for leave to amend and for jurisdictional discovery. View "Plevnik v. Sullivan" on Justia Law

Plaintiffs, including Mike Yoder and his company Drone Deer Recovery, LLC (DDR), along with hunter Jeremy Funke, challenged a Michigan law that bans the use of drones to hunt or collect downed game. DDR uses drones equipped with infrared cameras to locate downed game and provide hunters with GPS coordinates. Plaintiffs argued that the law prevents DDR from operating in Michigan, violating their First Amendment rights to create, disseminate, and receive information.The United States District Court for the Western District of Michigan dismissed the complaint, holding that Plaintiffs lacked standing and failed to state a claim. The court found that the law did not prohibit the dissemination of location information but only the use of drones to locate game, which it deemed non-speech conduct. The court also concluded that the alleged injury was not redressable because the law would still prohibit drone use even if the requested injunction was granted.The United States Court of Appeals for the Sixth Circuit reviewed the case and found that Plaintiffs had standing but failed to state a claim. The court determined that Plaintiffs' intended conduct of using drones to create and share location information was arguably affected with a constitutional interest and that there was a credible threat of enforcement under the Michigan law. However, the court applied intermediate scrutiny, finding the law content-neutral and justified by substantial governmental interests in conservation and fair-chase hunting principles. The court concluded that the law was narrowly tailored to achieve these interests and did not violate the First Amendment.The Sixth Circuit affirmed the district court's dismissal of the complaint, holding that Plaintiffs failed to state a claim on which relief could be granted. View "Yoder v. Bowen" on Justia Law

Plaintiffs-Appellants, owners of bonds issued by the Puerto Rico Sales Tax Financing Corporation (COFINA), sued the United States, alleging a taking of their property under the Fifth Amendment due to the enactment of the Puerto Rico Oversight, Management, and Economic Stability Act (PROMESA). They claimed that the restructuring of COFINA's debts under PROMESA resulted in a significant loss of the principal and interest value of their bonds and their security interest.The United States Court of Federal Claims determined it had subject matter jurisdiction over the case but dismissed it for failure to state a claim. The court found that the enactment of PROMESA by Congress did not constitute sufficient federal government action to support a takings claim. The court reasoned that the actions of the Puerto Rico Oversight Board, which was created by PROMESA and acted autonomously, could not be attributed to the United States as coercive or as an agency relationship.The United States Court of Appeals for the Federal Circuit reviewed the case and affirmed the decision of the Claims Court. The Federal Circuit held that PROMESA did not displace Tucker Act jurisdiction, as there was no clear congressional intent to withdraw the Tucker Act remedy. The court also agreed with the Claims Court that the United States did not exert coercive control over the Oversight Board's actions, which were necessary to establish a taking. The court concluded that the plaintiffs could not establish that the United States was liable for the alleged taking of their property. The court also found no abuse of discretion in the Claims Court's decision to deny the plaintiffs' request to amend their complaint. View "DINH v. US " on Justia Law

Kevin Rowe filed a lawsuit against his ex-wife, Dione Rowe, alleging tortious interference with a business relationship. Dione, with the help of her daughters, sent a letter to the Tribal Land Enterprise (TLE) making disparaging allegations against Kevin, who leased Tribal-owned land from the TLE. The letter requested the TLE to cancel Kevin’s leases and lease the land to her daughters instead. The TLE rescinded Kevin’s leases at their next board meeting, leading Kevin to file the lawsuit.The Circuit Court of the Sixth Judicial Circuit in Tripp County, South Dakota, denied Dione’s motion for summary judgment, which argued that her letter was an absolutely privileged communication under SDCL 20-11-5(2). The court concluded that the TLE meeting was a quasi-judicial proceeding but held that the privilege did not apply because the TLE did not follow its own procedures, including providing notice to Kevin.The Supreme Court of the State of South Dakota reviewed the case and reversed the circuit court’s decision. The Supreme Court held that the absolute privilege under SDCL 20-11-5(2) applies to claims of tortious interference with a business relationship. The court found that the TLE board meeting was an official proceeding authorized by law and that Dione’s letter had a logical relation to the TLE’s proceedings. The court also determined that the lack of notice to Kevin did not negate the privilege. Additionally, the court concluded that Dione did not waive the privilege by failing to plead it in her answer, as the issue was tried by implied consent during the summary judgment proceedings. The Supreme Court directed the lower court to enter summary judgment in favor of Dione. View "Rowe v. Rowe" on Justia Law

CPI Security Systems, Inc. filed a lawsuit against Vivint Smart Home, Inc., alleging that Vivint engaged in deceptive practices to lure away CPI’s customers. Vivint sales representatives falsely claimed that Vivint had acquired CPI, that CPI was going out of business, or that Vivint needed to upgrade CPI’s equipment. These tactics led many CPI customers to switch to Vivint, causing significant losses for CPI. A jury found Vivint liable for violating the Lanham Act, the North Carolina Unfair and Deceptive Trade Practices Act (UDTPA), and for committing the common-law torts of unfair competition and tortious interference with contracts. The jury awarded CPI $49.7 million in compensatory damages and $140 million in punitive damages.The United States District Court for the Western District of North Carolina upheld the jury’s verdict. Vivint appealed, raising several issues, including the requirement of CPI’s reliance on false statements for the UDTPA claim, the sufficiency of evidence supporting the damages award, the application of North Carolina’s cap on punitive damages, and the admission of prejudicial evidence.The United States Court of Appeals for the Fourth Circuit reviewed the case and found no reversible error. The court held that CPI was not required to prove its own reliance on Vivint’s false statements to establish a UDTPA claim, as the claim was based on unfair competition rather than fraud. The court also found that the evidence presented by CPI was sufficient to support the jury’s damages award. Additionally, the court ruled that the district court correctly applied North Carolina’s cap on punitive damages by considering the total compensatory damages awarded. The court further held that the district court did not abuse its discretion in denying Vivint’s motion to bifurcate the trial or in its evidentiary rulings. The reassignment of the trial judge post-trial did not warrant a new trial. Consequently, the Fourth Circuit affirmed the district court’s judgment. View "CPI Security Systems, Inc. v. Vivint Smart Home, Inc." on Justia Law

In June 2021, a deputy of the Maricopa County Sheriff rear-ended the plaintiffs while driving a vehicle owned by Maricopa County. The plaintiffs filed a notice of claim with the clerk of the Maricopa County Board of Supervisors and subsequently sued the County, arguing it was vicariously liable for the deputy’s negligence under the doctrine of respondeat superior. The County moved to dismiss the complaint, asserting it lacked the requisite control over the deputy to be held vicariously liable. The Superior Court in Maricopa County agreed and granted the County’s motion to dismiss.The plaintiffs appealed to the Arizona Court of Appeals, Division One, arguing that the deputy is an employee of the County and thus the County should be liable for his negligence. The Court of Appeals held that the County was not vicariously liable because it lacked the necessary control over deputy county sheriffs. The court also noted that county sheriffs qualify as public entities for notice of claim purposes under Arizona law.The Arizona Supreme Court reviewed the case to determine whether a county can be held vicariously liable for a deputy county sheriff’s negligence and whether the county is the proper public entity for notice of claim purposes. The Court held that a county does not control a deputy county sheriff when carrying out law enforcement duties and therefore cannot be vicariously liable for a deputy’s negligence. The Court further held that a sheriff in his official capacity is vicariously liable for any negligence or misconduct committed by a deputy engaged in law enforcement duties. Additionally, the Court clarified that a claimant may satisfy the notice of claim requirements by filing with the county sheriff’s office, which is responsible for the sheriff’s administrative functions. The Arizona Supreme Court affirmed the Superior Court’s dismissal of the case and vacated the opinion of the Court of Appeals. View "Sanchez v. Maricopa County" on Justia Law

Jordan Watkins, while in federal custody, underwent hernia repair surgery and subsequently experienced severe pain and swelling in his groin. Medical staff at the correctional facility dismissed his symptoms as routine side effects and refused to schedule a follow-up appointment before his transfer to another facility. Watkins filed Bivens claims against the medical and correctional staff for deliberate indifference to his serious medical needs and a Federal Tort Claims Act (FTCA) claim against the United States for negligent medical treatment.The United States District Court for the Northern District of Illinois dismissed all of Watkins' claims under Rule 12(b)(6). The court held that the Supreme Court's framework for evaluating Bivens claims barred Watkins' claims and that his FTCA claim was filed too late.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court held that Watkins' Bivens claims could proceed under the precedent set by Carlson v. Green, which allows federal prisoners to sue for damages resulting from deliberate indifference to their serious medical needs. The court found that Watkins' claims fit within the context recognized by Carlson and were not meaningfully different. The court also held that the district court's dismissal of Watkins' FTCA claim was premature. Watkins may be able to establish the requirements for equitable tolling due to extraordinary circumstances, such as disruptions caused by COVID-19, which prevented him from filing his suit on time. The Seventh Circuit reversed the district court's dismissal and remanded the case for further proceedings. View "Watkins v. Mohan" on Justia Law

In this case, the families of Michael Jackson, Carl Wiley, Jr., and Rashad Henderson, who were killed during high-speed police chases in Houston, Texas, sued the City of Houston. They alleged that the Houston Police Department (HPD) has a policy of racial profiling that leads to more high-speed chases in predominantly black neighborhoods, resulting in the deaths of their loved ones. The plaintiffs brought several federal municipal liability claims, including violations of equal protection, Title VI, 42 U.S.C. § 1982, and substantive due process, as well as state tort claims.The United States District Court for the Southern District of Texas granted in part and denied in part Houston's motions to dismiss for lack of subject matter jurisdiction and for judgment on the pleadings. The court dismissed all claims except the equal protection claims and Jackson’s state law claims. Houston then filed an interlocutory appeal, raising issues regarding standing, failure to state federal claims, capacity to sue, and governmental immunity for Jackson’s state law claims.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court determined that it lacked jurisdiction to review non-final district court orders except under 28 U.S.C. § 1292(b). The court found that it could only review whether the plaintiffs had standing to assert their equal protection claims. The court held that the plaintiffs lacked standing because their injuries did not stem from unequal treatment based on race. Consequently, the court reversed the district court’s order regarding standing for the equal protection claims and vacated the district court’s decision on governmental immunity for Jackson’s negligence claim, remanding the case for further proceedings. View "Jackson v. City of Houston" on Justia Law