Justia Government & Administrative Law Opinion Summaries

An employee of the United States Postal Service (USPS) worked as an Operations Industrial Engineer beginning in 2013. He alleged that, shortly after starting, he was harassed by a mentor on the basis of his national origin, race, and religion, and that after he complained, his work environment became more hostile. He also claimed to have faced retaliation for whistleblowing about safety violations and wastefulness. Over time, he received a Letter of Warning, was placed on a Performance Improvement Plan, and issued a Letter of Concern, all of which he believed were retaliatory. The situation resulted in medical issues, leading him to take medical leave, request reasonable accommodation, and ultimately remain on leave for several months. During this time, he filed an Equal Employment Opportunity Commission (EEOC) complaint, and while it was pending, he resigned, attributing his departure to the intolerable environment and alleged retaliation.The EEOC eventually granted summary judgment in favor of USPS, finding no evidence of unlawful discrimination or that the employee suffered an adverse employment action. Nearly four years after resigning and shortly after the EEOC’s decision, he appealed to the Merit Systems Protection Board (the Board), asserting that his resignation was involuntary due to duress and coercion by USPS. The Board’s administrative judge found that he failed to non-frivolously allege that his resignation was coerced, misinformed, or otherwise involuntary, noting he could have continued to pursue remedies instead of resigning. The Board affirmed the dismissal for lack of jurisdiction.The United States Court of Appeals for the Federal Circuit reviewed the case to determine if the employee had made non-frivolous allegations of involuntary resignation that would entitle him to a hearing. The court held that he had not, emphasizing that the facts did not show the agency effectively imposed his resignation or deprived him of reasonable alternatives. The court affirmed the Board’s dismissal for lack of jurisdiction. View "TAVAKKOL v. MSPB " on Justia Law

A woman sued a North Carolina town, alleging that a police officer employed by the town had sexually assaulted her while on duty. She claimed that the officer coerced her into sexual acts during visits to her home, sometimes in exchange for leniency regarding traffic violations. The officer had previously passed a background check, though some concerns were raised about his temperament and integrity, and a domestic violence complaint had been filed against him but was dismissed. The police department had no specific written policy prohibiting sexual misconduct, but did have general rules regarding officer conduct. During the officer’s employment, he was disciplined for minor infractions, but no complaints of sexual misconduct were received. The plaintiff reported the alleged assault more than a year after the officer resigned.The United States District Court for the Eastern District of North Carolina granted summary judgment to the town. The court found there was insufficient evidence to show that the town’s police department was deliberately indifferent to the risk of sexual assault by its officers, or that any failure in its policies, training, or supervision caused the plaintiff’s injuries. The court also granted summary judgment on state law claims for negligent hiring, supervision, and retention, concluding there was no evidence that the town knew or should have known that the officer was unfit for employment.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s decision. The Fourth Circuit held that the plaintiff failed to establish municipal liability under 42 U.S.C. § 1983 because there was no evidence of a pattern of similar constitutional violations or deliberate indifference by policymakers. The court also affirmed the dismissal of state law claims, finding no evidence that the town was negligent in hiring, supervising, or retaining the officer. View "Mullen v. Town of Sunset Beach" on Justia Law

An attorney whose license to practice law in Connecticut was suspended for one year sought reinstatement and, after delays in the consideration of her application, filed a complaint with the Commission on Human Rights and Opportunities. She alleged that the delay by the standing committee responsible for reviewing her reinstatement was racially discriminatory. When the standing committee sought guidance from the Superior Court regarding how to proceed given her discrimination complaints, the attorney filed a second complaint alleging retaliation. The Commission investigated this second complaint, found reasonable cause, and certified it for a public hearing.The Judicial Branch, named as a respondent in the administrative proceedings, moved to dismiss the retaliation complaint, arguing that the Commission lacked subject matter jurisdiction, particularly because the underlying conduct implicated the core judicial function of regulating attorney admission. The Human Rights Referee denied the motion to dismiss, and the Judicial Branch appealed to the Superior Court under the Uniform Administrative Procedure Act. The Superior Court concluded that the Commission’s assertion of jurisdiction over attorney reinstatement decisions violated the separation of powers doctrine, as such matters fall within the exclusive authority of the Judicial Branch, and ordered that the complaint be dismissed.On further appeal, the Supreme Court of Connecticut affirmed the Superior Court’s judgment. The Supreme Court held that the Superior Court had subject matter jurisdiction over the interlocutory appeal because the Judicial Branch had asserted a colorable claim of immunity from suit based on the separation of powers doctrine, which would be irretrievably lost absent immediate review. The Supreme Court further held that, under the circumstances, the Commission’s exercise of jurisdiction over complaints arising from attorney discipline or reinstatement proceedings would impermissibly interfere with the essential functions of the Judicial Branch, violating the separation of powers. The Court clarified, however, that its ruling does not shield the Judicial Branch from judicial review of discrimination claims arising from its regulation of the bar. View "State of Connecticut, Judicial Branch v. Commission on Human Rights & Opportunities" on Justia Law

Eighteen transgender women incarcerated in federal women’s prisons challenged a federal executive order that directed the Attorney General to ensure that “males”—defined by biological sex assigned at conception—are not detained in women’s facilities. These plaintiffs were a small group of transgender women whom the Bureau of Prisons had, after individualized assessments, placed in women’s facilities. Each had been diagnosed with gender dysphoria, received long-term hormone therapy, and some had undergone gender-affirming surgeries. The plaintiffs alleged that transferring them to men’s prisons would expose them to grave risks of violence, abuse, and psychological harm.The United States District Court for the District of Columbia granted the plaintiffs preliminary injunctive relief, blocking their transfers and requiring the government to maintain their housing in women’s facilities. The district court found that transgender women are at a significantly higher risk of harm in men’s facilities and that the government was aware of these risks. The court also rejected government arguments that judicial review was barred or that the plaintiffs had failed to exhaust administrative remedies, holding instead that no effective administrative remedy was available.On appeal, the United States Court of Appeals for the District of Columbia Circuit reviewed the case. The appellate court held that judicial review of constitutional claims was not barred by statute and that the government had not shown exhaustion of available administrative remedies. However, the court vacated the preliminary injunctions, finding that the district court’s broad, categorical reasoning was not defended by the plaintiffs on appeal, who instead advanced more individualized grounds. The record did not contain the necessary factual findings as to each plaintiff’s specific vulnerabilities. The case was remanded for further proceedings, and the expired injunctions were dismissed as moot. View "Doe v. Blanche" on Justia Law

Two individuals who are transgender women, one living in Montana and the other in Alaska, challenged recent Montana laws and administrative policies that restrict the ability to amend the sex designation on birth certificates and driver's licenses. These state actions, enacted in response to legislative changes, allow amendments to these documents only in limited circumstances such as clerical errors, not to reflect a person’s gender identity. The plaintiffs argued that these restrictions forced them to carry identification that does not match their gender identity, resulting in concrete harms such as disclosure of their transgender status during routine activities and difficulties in verifying their identity.The case was filed in the First Judicial District Court of Lewis and Clark County. The plaintiffs sought declaratory and injunctive relief, alleging violations of equal protection, right to privacy, and prohibition against compelled speech under the Montana Constitution, as well as violations of the Montana Administrative Procedure Act. The District Court found that the plaintiffs had standing, demonstrated concrete and particularized injuries, and satisfied all four factors required for a preliminary injunction. The court concluded that the policies likely violated Montana’s Equal Protection Clause by discriminating against transgender individuals on the basis of sex, and that the plaintiffs were likely to suffer irreparable harm without relief. The District Court preliminarily enjoined enforcement of the challenged state policies as applied to amending birth certificates and driver’s licenses.The Supreme Court of the State of Montana reviewed whether the plaintiffs had standing and whether the District Court manifestly abused its discretion in granting the preliminary injunction. The Supreme Court affirmed the District Court’s order. It held that the plaintiffs had standing and that the District Court did not abuse its discretion in concluding that the state policies likely constitute unconstitutional sex discrimination under Article II, Section 4 of the Montana Constitution, warranting preliminary injunctive relief. View "Kalarchik v. State" on Justia Law

Raunona Mays, an African American woman employed as a Sergeant with the Arkansas Highway Police, applied for four promotions between 2022 and 2023 but was denied each time. She alleges that less qualified Caucasian males or individuals with less experience and education received the positions. After filing an internal grievance regarding one promotion and receiving no relief, Mays filed an Equal Employment Opportunity Commission (EEOC) complaint alleging race and sex discrimination, as well as retaliation. The EEOC dismissed her charge and issued a right-to-sue letter, after which Mays brought suit seeking damages, a promotion, and injunctive relief.The Pulaski County Circuit Court denied the Arkansas Highway Police’s motion to dismiss, which was based on sovereign immunity. The agency argued that it could not be sued under the United States Constitution and federal statutes, as well as the Arkansas Civil Rights Act, because it is protected by sovereign immunity. The circuit court rejected this argument, allowing all claims to proceed.The Supreme Court of Arkansas reviewed the appeal and held that Mays’s claims under 42 U.S.C. § 1983, 42 U.S.C. § 1981, and the Arkansas Civil Rights Act could not proceed against the state agency because the agency is not considered a “person” under these statutes and is protected by sovereign immunity. The court reversed and remanded those claims for dismissal. However, the court determined that claims under Title VII of the Civil Rights Act of 1964 are not barred by sovereign immunity when brought against a state agency, and that Mays had pleaded sufficient facts to state a Title VII claim. The decision of the Pulaski County Circuit Court was affirmed as to the Title VII claim but reversed and remanded for dismissal of the other claims. View "ARKANSAS HIGHWAY POLICE v. MAYS" on Justia Law

A man whose only prior felony conviction had been expunged by a Missouri state court was arrested by a Missouri State Highway Patrol trooper for possessing a firearm as a convicted felon. The trooper had accessed his criminal history report, which still listed the expunged conviction with a notation indicating it was “Closed Pursuant to Chapter 610 RSMo.” However, the Missouri State Highway Patrol did not train officers to understand this notation meant the conviction was expunged and could not serve as a basis for arrest. The man informed the trooper of his expungement at the scene, but she stated she had to rely on the report’s information.Following his arrest, the plaintiff filed suit under 42 U.S.C. § 1983 in Missouri state court, asserting claims for damages and prospective relief against the Highway Patrol’s superintendent and others. The case was removed to the United States District Court for the Western District of Missouri. The superintendent moved to dismiss the official-capacity claim on sovereign immunity grounds and the individual-capacity failure-to-train claim on qualified immunity grounds. The district court denied both motions, prompting the defendants to file an interlocutory appeal.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s denial of immunity de novo. The appellate court held that the current superintendent was a proper Ex parte Young defendant for purposes of prospective relief, as he had sufficient connection to the dissemination practices that risked future constitutional violations. The court also held that the plaintiff had plausibly alleged a Fourth Amendment violation and deliberate indifference by the former superintendent regarding failure to train. Accordingly, the Eighth Circuit affirmed the district court’s denial of sovereign and qualified immunity. View "Cunningham v. Olson" on Justia Law

During the summer of 2025, protests erupted in Southern California in response to federal immigration raids. Protesters, legal observers, and journalists alleged that officers of the Department of Homeland Security (DHS), including agents from Immigration and Customs Enforcement, the Federal Protective Services, and Customs and Border Protection, used crowd control weapons indiscriminately against them. Multiple individuals, including members of the press and protesters, suffered significant physical injuries during these events, even when they were complying with police orders or were not near disruptive protest activity.Several individual journalists, legal observers, protesters, and two press organizations filed suit in the United States District Court for the Central District of California. They alleged violations of their First Amendment rights, specifically the right to be free from retaliation for engaging in protected activities and the right of public access to protests. The district court issued a preliminary injunction to protect the rights of protesters, journalists, and legal observers, finding that the defendants’ conduct chilled First Amendment activity. The government appealed, arguing that the injunction was overly broad and legally unsound.The United States Court of Appeals for the Ninth Circuit reviewed the district court’s decision. The Ninth Circuit held that the plaintiffs were likely to succeed on their First Amendment retaliation claims, that both individual and organizational plaintiffs had standing, and that the other requirements for a preliminary injunction were met. However, the court found that the scope of the injunction was overbroad because it extended relief to non-parties and included provisions not narrowly tailored to the specific harms alleged. The Ninth Circuit affirmed the district court’s decision to issue a preliminary injunction but vacated and remanded the case for the district court to craft a narrower injunction consistent with its opinion. View "LOS ANGELES PRESS CLUB V. NOEM" on Justia Law

A class of inmates at the Louisiana State Penitentiary alleged that the prison’s medical care was constitutionally inadequate and that the facility failed to comply with the Americans with Disabilities Act and the Rehabilitation Act. The lawsuit began in 2015, and evidence was introduced at trial in 2018. In 2021, the United States District Court for the Middle District of Louisiana issued a lengthy opinion finding systemic Eighth Amendment violations and ADA/RA noncompliance. While prison officials began making improvements ahead of a scheduled remedial trial, the district court later issued a Remedial Opinion and Order, prescribing detailed institutional changes and appointing special masters to oversee compliance.The district court’s Remedial Order required the state to bear the costs of three special masters, directed broad institutional reforms, and did not expressly adhere to the limitations imposed by the Prison Litigation Reform Act (PLRA). The court entered final judgment in favor of the plaintiffs, retaining jurisdiction only for compliance procedures. After entry of judgment, the defendants appealed. During the appeal, a panel of the United States Court of Appeals for the Fifth Circuit stayed the Remedial Order. The Fifth Circuit, sitting en banc, subsequently reviewed whether it had appellate jurisdiction and the validity of the district court’s orders.The United States Court of Appeals for the Fifth Circuit held that it had appellate jurisdiction under 28 U.S.C. § 1291 or, alternatively, § 1292(a)(1). The Fifth Circuit found that the district court’s Remedial Order violated the PLRA by failing to apply the statutory needs-narrowness-intrusiveness standard, improperly appointing multiple special masters, and requiring the state to pay their fees. The Fifth Circuit also concluded that the district court erred by disregarding ongoing improvements to prison medical care and by misapplying the standards for injunctive relief under the Eighth Amendment and the ADA/RA. The court vacated the district court’s judgment and remanded for further proceedings. View "Parker v. Hooper" on Justia Law

An inmate in an Arkansas maximum-security unit, who is Muslim, challenged a change in prison policy regarding meals served during Ramadan. Previously, fasting Muslims received a “double-portion” dinner after sunset and a standard breakfast before dawn. In 2023, the prison discontinued the double-portion dinner, providing only standard portions for both meals, but continued to serve them at the appropriate times for religious observance. The meals together provided at least 2,000 calories per day. The inmate often skipped the provided breakfast during Ramadan, preferring to eat commissary food instead, which he could easily obtain.The United States District Court for the Eastern District of Arkansas, Central Division, granted summary judgment to the prison officials, concluding that the new meal policy did not violate the inmate’s rights under the Eighth Amendment or the Religious Land Use and Institutionalized Persons Act (RLUIPA). The court found that the inmate’s allegations of hunger and physical symptoms were not corroborated by medical evidence, and that the inmate’s ability to supplement with commissary food meant he was not denied adequate nutrition.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that the prison’s policy did not impose a substantial burden on the inmate’s religious exercise under RLUIPA. The court emphasized that the inmate’s claimed need for 3,000 calories was not rooted in religious belief, but rather based on the institution’s general meal plan. The record showed that the meals provided were nutritionally adequate and that the inmate voluntarily skipped breakfast, supplementing from the commissary. Because the inmate failed to show a genuine dispute of material fact regarding a substantial burden on his religious exercise, the Eighth Circuit affirmed the district court’s judgment. View "Holt v. Payne" on Justia Law