Justia Government & Administrative Law Opinion Summaries

During a prolonged standoff in Las Vegas, New Mexico, Alejandro Alirez shot Cristal Cervantes and her grandfather inside their home while livestreaming the incident on Facebook. Law enforcement officers from multiple agencies responded after being alerted that Alirez, believed to be armed and mentally ill, was acting erratically at the residence. Upon the deputies’ arrival and their attempt to make contact, gunshots were fired almost immediately, with Cristal and her grandfather ultimately killed during the ordeal. Law enforcement officers established a perimeter and called for tactical support, but Cristal was found unresponsive after Alirez surrendered hours later.The plaintiffs, including Cristal’s personal representative and her mother, brought suit against various law enforcement agencies and officials under 42 U.S.C. § 1983 and New Mexico state law, alleging failure to intervene and negligence. The United States District Court for the District of New Mexico granted summary judgment for all defendants, concluding that qualified immunity barred the § 1983 claims and that the plaintiffs could not prevail on their state-law claims, including negligent investigation, negligent training, and loss of consortium.On appeal, the United States Court of Appeals for the Tenth Circuit affirmed the district court’s judgment. The Tenth Circuit held that the law enforcement officers did not affirmatively act to create or increase the danger to Cristal, a necessary element for liability under the substantive due process “danger-creation” exception, and thus the officers were entitled to qualified immunity. Additionally, the court found that the officers’ inability to intervene was caused by the immediate deadly threat posed by Alirez, precluding liability under New Mexico law for negligent investigation or related torts. The disposition of the case was affirmed in favor of the defendants. View "Salcido v. City of Las Vegas" on Justia Law

An Indiana prisoner, while serving a 65-year sentence for murder, attacked a correctional officer at the Miami Correctional Facility in 2022. The attack caused serious injuries requiring outside medical treatment. Following an administrative hearing, the prisoner was found guilty of battering staff and was sanctioned by losing nearly 19 years of accumulated good time credits. The hearing officer based the sanction on the severity of the attack and the resulting injury and checked factors including the seriousness of the offense and the disruption to facility security.The prisoner filed a pro se habeas petition under 28 U.S.C. § 2254 in the United States District Court for the Southern District of Indiana, raising due process and Eighth Amendment claims. He alleged procedural errors, hearing officer bias, and that there was no evidence of serious injury. He also argued that the sanction was grossly disproportionate. After counsel was appointed, he submitted a brief that referenced, but did not fully restate, these claims. The district court denied relief, holding that the due process claims lacked merit and that the Eighth Amendment claim was waived due to insufficient argument in the brief.On appeal, the United States Court of Appeals for the Seventh Circuit held that the relevant constitutional claims were not waived, as the amended filing preserved the original petition’s arguments. The Seventh Circuit affirmed the district court’s judgment, holding that the hearing officer’s finding of serious bodily injury was supported by sufficient evidence under the “some evidence” standard. The court also concluded that the loss of good time credits was not grossly disproportionate in violation of the Eighth Amendment, given the circumstances of the offense, the petitioner’s disciplinary record, and the nature of his underlying conviction. The district court’s judgment was affirmed. View "Hawkins v. Sevier" on Justia Law

The plaintiff owned a building in Corpus Christi, Texas, with significant cultural and historical importance, particularly within the Black community. Over several years, the City’s Code Enforcement Division cited the property for structural deficiencies and ultimately recommended its demolition. Despite the plaintiff’s efforts to preserve the building for historic purposes, the Building Standards Board voted to recommend demolition at a hearing that the plaintiff and her counsel could not attend. After the City temporarily suspended the demolition order, it imposed conditions on the plaintiff to secure the property, which the City later deemed unmet. The City then gave the plaintiff 30 days to demolish the building or face further action.The plaintiff filed suit in Texas state court against the City and two City employees, alleging that selective enforcement of building codes violated her rights under the Equal Protection Clause, asserting a “class of one” theory under 42 U.S.C. § 1983. The case was removed to the United States District Court for the Southern District of Texas. The district court dismissed the complaint for failure to state a claim, finding that the plaintiff had not sufficiently pleaded a substantive constitutional violation and thus did not reach the question of municipal liability.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed only the claim against the City, as the plaintiff did not pursue claims against the individual defendants. The Fifth Circuit affirmed the dismissal. The court held that the plaintiff’s allegations did not establish a municipal policy, custom, or pattern of selective enforcement sufficient to state a claim for municipal liability under Monell v. Department of Social Services. The court found that a single cited instance of allegedly selective enforcement was insufficient to plead an official policy or custom. Accordingly, the Fifth Circuit affirmed the district court’s dismissal of the action. View "Cambric v. City of Corpus Christi" on Justia Law

A woman called 911 to request a welfare check on her elderly neighbors’ home after noticing an unfamiliar vehicle and a young Black male there while the neighbors were out of town. When Officer Smith of the Childersburg Police Department arrived, he found a man watering flowers and asked if he lived at the house. The man, who identified himself as Pastor Jennings and said he lived across the street, explained he was watching the house for the neighbors. When asked for identification, Jennings became agitated and refused to provide any. Other officers arrived, and after Jennings repeatedly refused to further identify himself, he was arrested and charged with obstructing a governmental function.After the charge was dismissed, Jennings sued the officers and the City of Childersburg in the United States District Court for the Northern District of Alabama, alleging unlawful and retaliatory arrest under federal law and false arrest under state law. The district court granted summary judgment and dismissal in favor of the officers and the City, finding that Jennings violated Alabama’s stop-and-identify statute, Ala. Code § 15-5-30, by refusing to give his complete name. The United States Court of Appeals for the Eleventh Circuit reversed, relying on a prior interpretation of the statute that prohibited officers from demanding physical identification. On remand, the district court found the law’s interpretation uncertain and certified a question to the Supreme Court of Alabama.The Supreme Court of Alabama held that Ala. Code § 15-5-30 does not prohibit law enforcement officers, during a valid Terry stop, from requesting physical identification if a suspect gives an incomplete or unsatisfactory oral response regarding their name and address. The court clarified that suspects must provide sufficient identifying information and that failure to do so can constitute a violation of Alabama law. View "Jennings v. Smith" on Justia Law

While incarcerated in a Colorado state prison, the plaintiff, a practicing member of the Sac & Fox faith, brought suit seeking monetary and injunctive relief. He alleged that certain prison regulations and practices violated his rights under the First Amendment and the Religious Land Use and Institutionalized Persons Act. His claims focused on being denied possession of sacred items, spiritual cleansing of his cell, use of donated firewood for religious ceremonies, and access to faith grounds during and after the COVID-19 pandemic. The plaintiff named numerous officials and employees, including the Governor of Colorado, in both their official and individual capacities.The United States District Court for the District of Colorado denied the Governor’s motion to dismiss the official-capacity claims for injunctive relief, rejecting his assertion of Eleventh Amendment immunity. The Governor argued he lacked the required connection to the challenged regulations to qualify for the Ex Parte Young exception. During the appeal, the plaintiff was transferred to another facility within the Colorado Department of Corrections. The Governor raised the issue of mootness due to this transfer.The United States Court of Appeals for the Tenth Circuit considered whether the claims for injunctive relief against the Governor were moot because of the transfer and whether Eleventh Amendment immunity applied. The court held that the claims were neither constitutionally nor prudentially moot, as the plaintiff’s affidavit showed ongoing exposure to substantially similar conditions at the new facility. The court further held that, under Colorado law and the facts alleged, the Governor had sufficient authority and demonstrated involvement in the challenged practices to satisfy the Ex Parte Young exception. The court therefore affirmed the district court’s denial of Eleventh Amendment immunity and remanded for further proceedings. View "Eaves v. Polis" on Justia Law

The plaintiff, a magistrate in the domestic-relations division of a county court, declared her candidacy for a judicial seat alongside a fellow magistrate, who was also a court administrator. During her campaign, the plaintiff distributed literature that criticized her opponent’s work schedule and duties, suggesting that the opponent performed trivial administrative tasks and questioning her competence based on personal circumstances. These campaign materials were perceived by the administrative judge as undermining the integrity of the court and casting both the court and its staff in an unfavorable light. After the plaintiff lost the primary election, the administrative judge terminated her employment as a magistrate.Prior to this appeal, the United States District Court for the Southern District of Ohio dismissed the plaintiff’s suit brought under 42 U.S.C. § 1983, which alleged a violation of her First Amendment free-speech rights. The district court ruled that the court itself was not a legally cognizable entity subject to suit, that sovereign immunity barred claims for money damages against the administrative judge in her official capacity, and that the plaintiff failed to state a plausible free-speech claim against the administrative judge. The plaintiff appealed only the dismissal of her free-speech claim.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s dismissal de novo. It held that, because the plaintiff occupied a confidential or policymaking position and her campaign speech addressed matters related to court policy and politics in a manner that undermined the loyalty and efficient functioning required by her employer, her termination did not violate the First Amendment. The court affirmed the district court’s judgment, finding that the balancing test usually applied to public employee speech was unnecessary under these circumstances. The court also rejected the plaintiff’s arguments regarding insubordination, the scope of judicial candidate speech protections, and the applicability of strict scrutiny. View "Gaines v. Cross" on Justia Law

A group of activists and the Chinook Center, a nonprofit organization, participated in a housing-rights march in Colorado Springs. After the march, the Colorado Springs Police Department (CSPD) launched an investigation targeting some participants. CSPD obtained three search warrants: two related to Jacqueline Armendariz, a protester accused of obstructing an officer by dropping her bike, and one targeting the Chinook Center’s Facebook account. The first Armendariz warrant authorized a search of her home and seizure of her electronic devices. The second allowed a search of data on those devices, including a broad keyword search. The third warrant authorized obtaining all posts, messages, and events from the Chinook Center’s Facebook account for a seven-day period.Armendariz and the Chinook Center filed suit in the United States District Court for the District of Colorado against the City, individual CSPD officers, the FBI, and others, alleging that the warrants were overbroad in violation of the Fourth Amendment’s particularity requirement. They also brought state-law claims, and the Chinook Center alleged a violation of the Stored Communications Act. The district court granted motions to dismiss all claims, concluding that the officers were protected by qualified immunity, the plaintiffs failed to allege plausible constitutional violations, and that municipal liability was unsupported.On appeal, the United States Court of Appeals for the Tenth Circuit reviewed the case. It affirmed the district court’s ruling that the officers were entitled to qualified immunity regarding the warrant to seize Armendariz’s electronic devices. However, the court reversed the grant of qualified immunity to the officers for the second warrant (searching data on Armendariz’s devices) and the Facebook warrant, holding that the plaintiffs had plausibly alleged these warrants were overbroad in violation of their clearly established Fourth Amendment rights. The court also reversed the dismissal of related claims against the City and remanded for further proceedings. The dismissals of Armendariz's claims against the FBI and the United States were affirmed. View "Armendariz v. City of Colorado Springs" on Justia Law

Three individuals living with well-managed HIV, whose infections are controlled by daily medication and who have undetectable viral loads, sought to join or rejoin the U.S. Army. They were denied enlistment based on Department of Defense and Army policies that list HIV infection as a disqualifying medical condition, alongside numerous other chronic or communicable diseases. A nonprofit organization, Minority Veterans of America, also supported their challenge. The plaintiffs argued that these policies violate their equal protection rights under the Fifth Amendment and are arbitrary and capricious in violation of the Administrative Procedure Act.The United States District Court for the Eastern District of Virginia granted summary judgment to the plaintiffs. The court issued a permanent injunction barring the Military from denying accession to asymptomatic HIV-positive individuals with undetectable viral loads, prohibiting enforcement of HIV-specific policy provisions, and ordering reevaluation of prior decisions made under these policies. The district court concluded that the Military’s justifications—based on medical, cost, and diplomatic concerns—were irrational, arbitrary, and capricious.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the judgment. Applying rational basis review with heightened deference to military judgments, the Fourth Circuit found that the Military’s policies were rationally related to legitimate military purposes, including maintaining deployable, medically fit servicemembers, minimizing complications from chronic conditions, controlling costs, and addressing diplomatic issues with foreign host nations. The court distinguished this case from Roe v. Department of Defense, which concerned policies for current servicemembers rather than initial entry. The Fourth Circuit held that the Military’s HIV accession policy did not violate the Fifth Amendment or the APA and reversed the district court’s judgment, remanding with instructions to enter judgment for the Military. View "Wilkins v. Hegseth" on Justia Law

A.B., a 42-year-old individual with a longstanding diagnosis of schizoaffective disorder, had been receiving mental health services in San Francisco since 2008, including numerous psychiatric hospitalizations and crisis interventions. He was previously under conservatorship, which ensured compliance with medication, but historically disengaged from treatment and decompensated when conservatorship ended. In October 2023, following a psychiatric incident at home involving paranoia and disruptive behavior, A.B. was hospitalized. His mother, who provided housing, testified to his history of aggression and repeated decompensation when not medicated, stating she would not allow him to live with her absent a conservatorship and mandatory medication order.The San Francisco County Superior Court initially appointed the public conservator and imposed an involuntary medication order. After a mistrial in April 2023, the parties resolved the matter by conservatorship without a medication order, but following further decompensation, the conservator sought renewal with an involuntary medication order. At the 2025 court trial, testimony from A.B.’s mother and treating psychiatrist indicated that A.B. lacked insight into his illness, would not reliably take medication without a legal mandate, and was unable to maintain shelter independently. Although A.B. testified that he now recognized his diagnosis and would comply with medication, the court credited the testimony of his mother and psychiatrist over his own.The California Court of Appeal, First Appellate District, Division Two, held that substantial evidence supported the trial court’s findings that A.B. was presently gravely disabled due to his mental disorder and unable to provide for his own shelter without medication, which he would not take absent a court order. The appellate court also affirmed the finding that A.B. was incompetent to give or withhold informed consent for psychotropic medication. The orders renewing the conservatorship and involuntary medication were affirmed. View "Conservatorship of A.B." on Justia Law

Several residents of Estherville, Iowa, sued a former police officer, the police chief, the City of Estherville, and its insurance company, alleging that the officer repeatedly accessed and disseminated their confidential criminal history and intelligence data for improper purposes between 2015 and his resignation on May 3, 2019. The officer used this data for personal gain, including assisting with vehicle repossessions and harassing certain plaintiffs. Complaints about his conduct were made to the police chief, who ultimately placed the officer on administrative leave and accepted his resignation. Criminal charges were later brought against the officer in 2022 for his actions.After learning of the wrongful data access between 2021 and 2022, the plaintiffs filed suit on July 7, 2023, in the Iowa District Court for Emmet County, asserting statutory and common law claims, including invasion of privacy and conspiracy, and seeking damages under Iowa Code section 692.6. The defendants moved to dismiss, arguing the two-year statute of limitations under the Iowa Municipal Tort Claims Act (IMTCA) barred the claims, since all alleged misconduct ended by May 3, 2019. The district court denied dismissal, holding that the statutory claim under section 692.6 was subject to a five-year limitation with a discovery rule, and that the remaining claims accrued when plaintiffs discovered the wrongdoing.On appeal, the Iowa Court of Appeals reversed the district court and ordered dismissal, concluding that all claims were governed by the IMTCA’s two-year statute of limitations and that the date of injury was when the data was accessed or disseminated, not when plaintiffs learned of it. The Iowa Supreme Court affirmed the appellate court, holding that the IMTCA’s statute of limitations applied to all claims and began at the time of the wrongful acts, regardless of later discovery or emotional harm. The case was remanded for dismissal. View "Abrahamson v. Scheevel" on Justia Law