Justia Government & Administrative Law Opinion Summaries

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

A group of individuals traveling through Kansas were stopped by Kansas Highway Patrol (KHP) troopers while driving on interstate highways, primarily I-70. In each instance, the drivers and passengers were from out of state, often driving to or from Colorado, and were stopped for alleged traffic violations. After the initial traffic stop was concluded, troopers used a tactic known as the “Kansas Two-Step”—they would briefly disengage, then reinitiate conversation in an attempt to gain consent for further questioning or searches. These stops often led to extended detentions and searches, but no contraband was discovered. The troopers testified that they considered the drivers’ out-of-state status, travel to or from Colorado, and other factors in developing reasonable suspicion.The individuals sued under 42 U.S.C. § 1983 in the United States District Court for the District of Kansas, alleging violations of their Fourth Amendment rights against unreasonable searches and seizures and their constitutional right to travel. Some plaintiffs also brought damages claims, resulting in jury verdicts in their favor. For their claims for injunctive relief, the district court conducted a bench trial and found that KHP had a pattern and practice of targeting out-of-state drivers and using the Two-Step in a manner violating the Fourth Amendment. The court granted a permanent injunction, requiring changes in KHP’s training, documentation, consent procedures, and supervision.On appeal, the United States Court of Appeals for the Tenth Circuit reviewed whether the plaintiffs had standing for injunctive relief and whether the district court abused its discretion in issuing the injunction. The Tenth Circuit held that the plaintiffs had standing because there was a substantial risk they would be stopped again and that KHP had a pattern of unconstitutional conduct. However, the Tenth Circuit found that the injunction was overly broad regarding the use of a driver’s state of origin and the Two-Step tactic. The court affirmed the injunction in part, reversed it in part, and remanded for further proceedings. View "Shaw v. Smith" on Justia Law

A female custodian employed by a public university filed a Title IX complaint alleging physical assault and a pattern of sexual harassment by a male co-worker, both of whom were members of the same union. The university, which receives federal funding, initiated a Title IX grievance process compliant with 2020 federal Title IX Regulations. After an investigation and hearing in which both parties participated, university decision-makers found the accused violated university policy and determined there was just cause for his termination. The accused’s appeal within the Title IX process was unsuccessful, and he was terminated.The union representing the accused employee filed a grievance under its 2019 collective negotiation agreement (CNA) with the university, seeking arbitration to determine whether the termination was for just cause. The university denied the grievance, arguing that the federal Title IX Regulations preempted the CNA’s grievance procedure. The union sought arbitration through the New Jersey Public Employment Relations Commission (PERC), which denied the university’s request to restrain arbitration and held, applying state preemption law, that the Title IX Regulations did not preempt arbitration. The Superior Court, Appellate Division, affirmed, finding no conflict precluding the union’s grievance procedure.The Supreme Court of New Jersey reviewed the case and reversed the lower courts. The Court held that the CNA’s grievance procedure is preempted by the 2020 federal Title IX Regulations because those regulations require that any grievance or appeal process must apply equally to both complainant and respondent. The CNA’s arbitration process excluded the alleged victim from participation, granting rights only to the accused. The Court concluded that this inequality creates a direct conflict with federal law, which therefore preempts the CNA’s arbitration provision in this context. The decision is limited to this particular CNA and does not preempt all union grievance procedures. View "In the Matter of Rutgers, the State University of New Jersey v. AFSCME Local 888" on Justia Law

Kevin Lewis, who is legally blind, was arrested in Georgia on an outstanding warrant and detained for less than 48 hours in the Chatham County jail and for about 16 days in the Fulton County jail. During both periods of incarceration, Lewis alleges he was denied assistance with reading documents, navigating the facilities, accessing the grievance process, and obtaining requested medications. He also reports that, despite his requests, he was not provided accommodations for using jail telephones and kiosks.After his release and the dismissal of criminal charges against him, Lewis filed suit in the United States District Court for the Northern District of Georgia against Sheriffs John Wilcher and Patrick Labat in their official capacities, seeking damages and injunctive relief under Title II of the Americans with Disabilities Act and § 504 of the Rehabilitation Act. The district court granted summary judgment in favor of the sheriffs. The court found that Lewis had not produced sufficient evidence to show he was denied benefits or discriminated against “by reason of” his disability, and had not shown that the sheriffs engaged in intentional discrimination. Regarding his claims for injunctive relief, the court determined they were moot because Lewis was no longer incarcerated.On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s decision. The appellate court held that Lewis failed to present evidence of intentional discrimination by the sheriffs, as required for damages under both statutes. It also held that his claims for injunctive relief were moot, as there was no reasonable expectation he would be subject to the challenged conditions again. The district court’s grant of summary judgment was thus affirmed. View "Lewis v. Sheriff, Fulton County Georgia" on Justia Law

In 2005, an individual was convicted of endangering the welfare of a child and placed on Parole Supervision for Life (PSL) in New Jersey. The State Parole Board imposed two special conditions: a ban on accessing social media and a ban on viewing or possessing pornography. In 2018, the individual was arrested on a parole warrant for allegedly violating both conditions. After a hearing, the Parole Board found violations, revoked PSL, and ordered twelve months of incarceration. The individual challenged the constitutionality of the conditions, arguing they violated First Amendment rights. While an appeal was pending, the Parole Board vacated the revocation in February 2020 and later discharged the conditions. On June 1, 2020, the Board issued a decision stating there was no clear and convincing evidence of violations.The complainant and spouse then filed suit under the New Jersey Civil Rights Act (CRA) and the Tort Claims Act (TCA) against the State and others, alleging substantive due process violations, gross negligence, deliberate indifference, and false arrest/imprisonment. The trial court dismissed all claims as time-barred, holding that the statute of limitations began to run at various points before June 2020. The Appellate Division affirmed, finding that the claims accrued earlier and that even under the favorable-termination rule from Heck v. Humphrey, the relevant accrual event was the Board's February 2020 vacatur of the revocation.The Supreme Court of New Jersey held that the favorable-termination rule from Heck v. Humphrey applies to claims under the CRA and the TCA, meaning that civil rights claims that necessarily challenge the validity of a criminal or quasi-criminal proceeding do not accrue until that proceeding is terminated in the plaintiff’s favor. The Court determined that substantive due process and related claims accrued on June 1, 2020, making them timely, but that any false arrest/imprisonment claim accrued earlier and was time-barred. The Court reversed the dismissal of the first three counts and affirmed the dismissal of the false arrest/imprisonment claim. View "C.A.L. v. State of New Jersey" on Justia Law

After the Texas Legislature passed the Election Protection and Integrity Act of 2021 (“S.B.1”), a sweeping law that amended numerous aspects of the state’s election procedures, multiple groups of plaintiffs—including civil rights and voter advocacy organizations—challenged thirty-eight provisions of the law. They alleged violations of various constitutional amendments, the Voting Rights Act (VRA), the Americans with Disabilities Act (ADA), and the Rehabilitation Act, naming state officials including the Texas Secretary of State and Attorney General as defendants.In the United States District Court for the Western District of Texas, the defendants moved to dismiss on grounds of sovereign immunity and lack of standing. The district court addressed the motions on a provision-by-provision basis, concluding that the Secretary and Attorney General were sufficiently connected to the enforcement of most challenged provisions to overcome sovereign immunity under Ex parte Young, and that plaintiffs had standing to sue. It denied the motions to dismiss for the majority of the claims, although it dismissed others as moot, for lack of standing, or for failure to state a claim. The defendants appealed the denials.The United States Court of Appeals for the Fifth Circuit held it had appellate jurisdiction over the interlocutory sovereign immunity appeals. On the merits, the Fifth Circuit affirmed in part and reversed in part. It held that the VRA claims were not barred by sovereign immunity. For the constitutional and other statutory claims brought under 42 U.S.C. § 1983, the court determined that the Secretary of State is a proper defendant only for those provisions she directly enforces—such as those involving the design of forms and sanctioning of registrars—and not for those enforced by other officials. Similarly, it held the Attorney General could be sued only for one provision authorizing civil penalties. The court affirmed standing for claims against provisions enforced by these officials. View "Un del Pueblo Entero v. Nelson" on Justia Law

A group of unhoused veterans with severe disabilities and mental illnesses sued the United States Department of Veterans Affairs (VA) and the Department of Housing and Urban Development (HUD), seeking to restore the West Los Angeles VA Grounds for its intended use: housing disabled veterans. The VA had leased portions of this land to third parties—including the Regents of the University of California, Brentwood School, and Bridgeland Resources LLC—for uses that did not principally benefit veterans. Plaintiffs argued that the lack of supportive housing denied meaningful access to VA healthcare, violated the Rehabilitation Act, and placed them at serious risk of institutionalization. They also challenged VA policies that counted disability benefits as income, restricting access to supportive housing, and claimed that certain land-use agreements violated the Administrative Procedures Act (APA). Additionally, they asserted that the original 1888 Deed created a charitable trust that the VA had breached.The United States District Court for the Central District of California held a four-week bench trial, finding that the VA’s land-use leases with UCLA, Brentwood School, and Bridgeland Resources LLC were unlawful, voided these leases, and enjoined the VA from renegotiating them. The court certified a plaintiff class, ordered the VA to build supportive housing, found the VA and HUD violated the Rehabilitation Act in several respects, and determined that the VA had breached fiduciary duties under a charitable trust theory, invalidating certain leases on that basis as well.On review, the United States Court of Appeals for the Ninth Circuit affirmed in part, reversed in part, vacated in part, and remanded. The Ninth Circuit held that federal courts retained jurisdiction over plaintiffs’ Rehabilitation Act claims, upheld class certification, and affirmed findings of meaningful access, Olmstead, and facial discrimination under the Rehabilitation Act against the VA. The court reversed judgment against HUD, and also reversed the charitable trust claim, finding no judicially enforceable fiduciary duties under the Leasing Act. The court vacated related injunctive relief and judgments based on the charitable trust theory, including those against UCLA, Brentwood, and Bridgeland. The injunctions were modified, allowing the VA to renegotiate leases if compliant with statutory requirements. View "Powers v. McDonough" on Justia Law

HRT Enterprises owned an 11.8-acre parcel adjacent to Detroit’s Coleman A. Young International Airport, with about 20 percent of the property falling within a regulated runway “visibility zone” that restricted development. Over time, the City of Detroit acquired other properties in a nearby area for airport compliance but did not purchase HRT’s. By late 2008, HRT’s property had become vacant and vandalized, and HRT alleged it could no longer use, lease, or sell the property due to City actions and regulatory restrictions.HRT first sued the City in Michigan state court in 2002, alleging inverse condemnation, but the jury found for the City; the Michigan Court of Appeals affirmed, and the Michigan Supreme Court denied leave to appeal. In 2008, HRT sued in federal court, but the United States District Court for the Eastern District of Michigan dismissed the action without prejudice because HRT had not exhausted state remedies. HRT then filed a second state suit in 2009, which was dismissed on res judicata grounds; the Michigan Court of Appeals affirmed. HRT did not seek further review.In 2012, HRT filed the present action in federal court, alleging a de facto taking under 42 U.S.C. § 1983. The district court denied the City’s preclusion arguments, granted summary judgment to HRT on liability, and held that a taking had occurred, leaving the date for the jury. A first jury found the taking occurred in 2009 and awarded $4.25 million; the court ordered remittitur to $2 million, then a second jury, after a new trial, awarded $1.97 million.The United States Court of Appeals for the Sixth Circuit affirmed the district court’s rulings, holding that HRT’s claim was ripe, not barred by claim or issue preclusion, that the district court properly granted summary judgment on liability, and that its remittitur decision was not an abuse of discretion. View "HRT Enterprises v. City of Detroit" on Justia Law